Comment

The NPPF and town centres: small steps towards modernisation but not far enough

As high streets continue to evolve policy must be equally adaptive. The draft National Planning Policy Framework (NPPF) is an opportunity to shape town centre policy for the future, but the document, published for consultation in December, largely seeks to maintain the status quo. We submitted our consultation responses earlier this month, below we summarise our views and some of our submitted responses on town centre policy.

The draft document in its current form raises important questions about clarity, practicality, and alignment with market realities. There is a need to refine certain elements to ensure the new framework genuinely supports the long-term vitality and viability of town centres.

Recognising the need for contraction and redefinition

Draft Policy TC1 acknowledges the need for flexibility but stops short of recognising the need for contraction and redefinition of town centres. The retail landscape has evolved dramatically; many centres no longer need to accommodate increased floorspace but instead require consolidation. Actively planning for contraction, especially in secondary or tertiary areas, can strengthen core commercial locations, reduce long-term vacancies, and support sustainable investment.

Recognising contraction as a strategic tool, rather than a sign of failure, is crucial. The draft NPPF should explicitly guide LPAs to consider whether their town centres need expansion, maintenance, or purposeful rationalisation in response to market and societal trends.

The uncertain role of the Primary Shopping Area

The treatment of the Primary Shopping Area (PSA) is ambiguous. While the PSA still appears in the glossary as a ‘defined area’, it is noticeably absent from Policy TC1. Without clear policy reference, this inconsistency creates the risk of dispute between local planning authorities (LPAs) and applicants trying to understand the locational context of proposals.

The role of Article 4 Directions and Class E: protecting flexibility

Paragraph 2 references the use of Article 4 Directions to remove permitted development (PD) rights. PD rights, particularly within Class E, play a crucial role in encouraging the reuse of vacant units, providing operators with agility and supporting the delivery of residential in our town centres.

In the same vein, LPAs frequently restrict Class E uses in practice, specifying what they deem to be acceptable subcategories of Class E in town centres. This approach runs counter to the aspirations for Class E.

The policy should be explicit that Article 4 Directions and restrictions on Class E should only be applied in exceptional circumstances, supported by robust evidence, to avoid undermining the very flexibility that has proven beneficial in revitalising high streets.

Disaggregation in the sequential test 

The proposed reference in paragraph 3 to whether developments could be split across multiple sites raises practical concerns. Disaggregation has long been recognised as unrealistic and inconsistent with real-world development needs. Retaining this reference would add unnecessary complexity to the sequential test and impose unreasonable expectations on applicants. There is a need to acknowledge that many developments have location specific operational requirements.

Similarly, paragraph 4’s suggestion of a blanket refusal where the sequential test is not met is inappropriate. Planning decisions must balance a range of considerations, including economic benefits such as job creation and local investment. Rigid adherence to a single test risks overlooking broader public value.

Impact assessment thresholds: a need for certainty

Clear thresholds for impact assessments are essential for predictability. Where development plan policies do not set local thresholds, the national default should apply definitively—not as a guideline but as a firm rule. This approach would prevent LPAs from requiring unnecessary assessments contrary to the intention of national policy, providing much-needed certainty for developers while focusing resources on genuinely impactful proposals.

Conclusion

The draft NPPF takes some small steps to modernise planning policy for town centres, but stops short of making fundamental changes. Its effectiveness will depend on the clarity of its definitions, the realism of its sequential and impact test requirements, and its commitment to preserving the flexibility that Class E was designed to offer. Strengthening the framework in these areas would better equip town centres to adapt, consolidate where needed, and ultimately thrive as lynch pins of our communities and urban areas.

For more information on what the proposed NPPF changes could mean for town centres please contact Cat White, Andrea Arnall and Chris Pickup. 

25 March 2026