National Planning Policy Framework - impact on theatres in England

Theatres Trust is concerned by proposed changes to the National Planning Policy Framework and urges theatres to respond to the government’s consultation.

What is the NPPF and why does it matter to theatres?

It is the National Planning Policy Framework – the government’s planning policies for England that guide planning decisions.

As part of the government’s ambition to build more homes, Ministry for Housing, Communities and Local Government (MHCLG) has drafted a new version of the NPPF and is running a consultation on the proposed changes.

Theatres Trust understands that the planning system probably isn’t what you want to be thinking about when you’ve got one hundred other things to worry about while running a theatre building. And ordinarily, you wouldn’t need to pay much attention to the planning system. Theatres Trust, as the statutory consultee for theatres, is the go-to organisation to consult before making a planning application involving a theatre, so you don’t need to the know the ins and outs of the policy framework.

However, there are key proposed amendments to the NPPF that would significantly weaken the protection for theatres in the planning system. Considered alongside the proposal to remove Theatres Trust as a statutory consultee, there could be serious consequences for cultural infrastructure in England if these amendments are adopted. We think it is important that you are aware of the potential issues – and take action.

Theatres Trust is talking to government officials about our concerns, and we will be submitting a robust response to the consultation. But it is important that ours isn’t the only voice.

A large volume of responses will help the government to understand what needs to change and why this is vital, not just to our sector, but to communities across England.

The extension of the Creative Foundations Fund shows that the Department of Culture, Media and Sport (DCMS) has understood what the sector needs to continue to make its vital contribution to communities up and down the country. Now we need to make that case to another government department.

What are the issues?

The section on “Retention of key community facilities and public service infrastructure” (HC6) is now weaker than many local plans and the existing NPPF – and crucially does not include cultural buildings in the list of uses to which the policy explicitly applies.

This omission could be an oversight, but just as troubling is that the protection policy only applies where a building is the last of its type in its local area. So, if there is another theatre in your area, your building would not be protected. It wouldn’t matter that you operate at different scales, have a completely different programme or serve different audiences.

Organisations with unlisted theatre buildings that you do not own should be particularly concerned by these proposed changes because your landlord could decide to sell your building and it would no longer be protected from conversion to housing. This may be a worst-case scenario, but it is a genuine risk.

However, it isn’t just those theatres who should act - the whole theatre sector should respond to the consultation with its concerns as these policy changes could negatively impact the whole theatre ecosystem.

A positive change – ‘Agent of Change’

There are some positive proposed changes on heritage, healthy communities and most importantly for theatres, on ‘Agent of Change’. The new draft policy strengthens the ‘Agent of Change’ principle – which makes new developments responsible for mitigating measures for noise, vibration and other issues arising from residential developments next to venues. The draft policy will mean that these issues need to be resolved before developments are given planning permission.

With other changes in the NPPF giving a bias towards approving developments, it is essential that this strengthened principle does make it to the final version of the NPPF. So that is another reason to respond to the consultation – to welcome this positive change.

What you need to do now

There are two simple things you can do:

One: Respond to the relevant questions in government consultation by the deadline on 10 March.

You don’t need to respond to every part of the consultation– just the parts that will impact theatres and other cultural organisations. A copy of our NPPF consultation response to help guide your answers is available here.

Two: Spread the word about the consultation and the issues amongst your networks. We need the theatre sector’s concerns to be heard, but these changes will also impact music venues, arts centres, galleries, museums and other community facilities, so there will no doubt be other people who will care about this too. We’ve posted about the NPPF on LinkedIn and Facebook so please share our posts.