Lichfield Rd, Curdworth

Viewpoint - 18/03/2025

The Promised Land: Planning Policy & Land

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The new Government has brought important changes to the planning system which will have an impact on the logistics sector. Alex Roberts, Head of Economics & Planning Policy at LSH, sat down with Matt Dugdale at Richborough Commercial to discuss the land market, policy changes, and their potential impact.

Download the Industrial & Logistics Market Report 2025 in full here →

In December 2024, the Government introduced significant revisions to the National Planning Policy Framework (NPPF), emphasising logistics’ critical role in the economy. As a whole, the changes to the NPPF were brought in to streamline planning and support economic growth.

The NPPF now recognises logistics as a key sector, encourages the development of infrastructure essential for the efficient handling of goods, and requires the needs of the sector to be considered in plan-making. The changes to the NPPF were preceded by the Government’s Industrial Strategy Green Paper in October, which was criticised for its omission of the logistics sector. With the final version expected in Spring this year, there is time for important changes to be made.

We’re discussing all things planning and logistics with Matt Dugdale of Richborough Commercial.

Richborough Commercial is the commercial development arm of the UK’s leading strategic land promoter Richborough. Partnering with landowners and land agents who want to sell land for development, they masterplan and secure outline planning permission, then sell the site on the open market to a suitable development partner. With more than two decades’ experience, they are currently promoting over 1,500 acres of quality commercial land across industrial and logistics, roadside uses, retail parks, data centres, and mixed-use developments, equivalent to around 15m sq ft of floorspace.

Matt Dugdale is Planning Director for Richborough Commercial, and oversees planning strategies, applications, and appeals. With experience in local authorities, commercial developers, and consultancy, Matt has advised on a range of schemes across his career. His knowledge of the planning landscape is fundamental to the growth and expansion of the Commercial division.Matt is a chartered member of the Royal Town Planning Institute (MRTPI), and in 2024 was Chair of the North West Region, and subsequently elected to the RTPI General Assembly for 2025/26. He also represents Richborough Commercial on the British Property Federation’s (BPF) Industrial Committee.

With the NPPF just a few months old, what are your thoughts on it?

Overall, we’re pleased; it’s an excellent first step by the new Government. They have reversed the damage inflicted by previous decision-makers and have ambitions to go much further. That said, the changes made to date have been heavily focused on housing. It could have gone much further to focus on boosting economic growth, but we understand there are more changes afoot and we’re encouraged to hear that they’re engaging with the sector to shape future policy.

The introduction of the Grey Belt is a shrewd move. If it succeeds in changing the perception of Green Belt and enables more constructive conversations about where development should take place, then ‘Grey Belt’ could be one of the most significant planning changes in recent times. It could unlock suitable sites for development, without necessarily having to promote land through lengthy and unpredictable stages of local plan preparation. It could also remove the need for speculative ‘very special circumstances’ Green Belt cases, which often come at great cost and risk to the applicant.

Is there anything in particular that is a concern at the moment?

Well, we hope the differences between a ‘sustainable location’ for commercial and other developments to a ‘sustainable location’ for housing will be recognised. For example, the locational requirements for a strategic logistics scheme or a last-mile distribution facility will be quite different from housing, where proximity to schools and doctors etc is important. Nevertheless, we were pleasantly surprised that the so-called ‘golden rules’ only apply to housing; although that’s certainly not an invitation to impose more onerous requirements – our sector needs all the support it can get!

Lichfield Road

Richborough Commercial's strategic site at M42 J9, near Curdworth in the West Midlands Green Belt. An outline planning application for 750,000 sq ft of B2/B8 floorspace is currently pending with North Warwickshire Borough Council. LSH provided specialist input including preparation of an Employment Land Assessment to demonstrate an immediate need for the development in line with Policy LP6.

What do you think of the support given to the expansion of Heathrow and support in re-opening regional airport at Doncaster? Do you think this may impact demand for logistics and warehousing space?

Any support for the expansion of strategic transport infrastructure is positive for the whole freight and logistics sector, be that airports, ports or rail freight terminals. Aviation in particular plays an important role in global supply chains and ‘just in time’ deliveries. Such investments are bound to increase the demand for logistics and warehousing space to support an uptick in air freight movements in well-connected and proximate locations.

The investment in more regional airports is encouraging as it recognises that different types and scales of facilities are required in different locations. We and other land promoters are primed to open up such opportunities for further development. Developers of logistics space will always seek out sites such as these with the right planning consent.

Turning to the National Infrastructure Plan and the policy support and push for AI, do you think Government’s policy position, as a whole, is supportive to the logistics sector?

In our view, there is a lack of joined-up thinking across Government departments, so Labour needs to crystallise its policy support for the logistics sector across the board. For example, Richborough Commercial is a member of the BPF which expressed disappointment that the Government’s Industrial Strategy Green Paper (“Invest 2035”) did not reference the industrial and logistics property sector, despite the vital role it plays in the UK economy. And yet, the new NPPF now emphasises meeting the needs “for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics” whilst data centres have been given ‘Critical National Infrastructure’ status.

Data centres are an interesting one because, despite their phenomenal demand and values, they are competing in the same market for land as logistics. This is because data centres typically fall within Use Class B8 (Storage and Distribution).

Do you think this could cause any problems going forward, perhaps some unforeseen circumstances?

There is the possibility they take away land allocated or consented that would otherwise be available for logistics. The Government needs to recognise this and ensure that local authorities do not count data centre completions towards their employment land supply figures at the expense of not meeting their requirements for logistics. Authorities need to allocate and approve enough land for both logistics and data centres.

So perhaps some clearer guidance to avoid that problem, it could be something that becomes an issue at an appeal or Local Plan examination. So were there aspects of the NPPF you would have liked to see change, but were not?

We need to remember we’re starting from a very low base. Currently, there are only five NPPF paragraphs dedicated to economic growth and two of these relate to the rural economy; it would be difficult for the Government to say any less than is currently written! Our message to the Government would be to put commercial development on an even footing with housing.

We suggested some ideas in our response to the NPPF consultation and acknowledge some might take longer than others to implement, so we’re hopeful that Labour follow through with the changes.

  1. Strategic planning – pushing forward with devolution and the universal reinstatement of strategic planning. This is important to ensure that employment needs are met in full across functional economic market areas.
  2. Employment requirements – a consistent approach to calculating land requirements across the country. This doesn’t need to be a mandatory figure but a standardised approach which insists on these needs being met.
  3. Employment supply – where we have a five-year housing land supply and a housing delivery test, we need equivalent mechanisms to measure the performance of delivery and to ensure a healthy future supply of sites.
Have these changes to Government policy led to you to consider other types of development?

Our primary goal is to achieve the best possible returns for our landowners by supplying consented land to the market, balancing risk versus reward. As an agile land promoter, we can adapt our strategy to suit different locations, opportunities and constraints, and changing circumstances, including the demand for different uses and planning considerations. Typically, we will seek a flexible outline consent for industrial and logistics or even roadside uses, but we always keep an eye out for other opportunities as they emerge. Data centres are an interesting proposition because of their strong credentials, yet because they typically fall within Use Class B8 (Storage and Distribution Uses), we will already have factored this in; the key thing will be ensuring power connections.

So putting the new NPPF to one side, what has been keeping you busy?

The last year has been incredibly busy for Richborough Commercial, landowners across the board have welcomed our land promotion model as the best choice to offer a speedier, more transparent route to achieve the highest value for their land. We’ve subsequently seen a record number of promotion proposals being submitted to landowners with this then being reflected in the growing number of sites being promoted within our portfolio. Two applications keeping us busy include our strategic I&L site for 750,000 sq ft at M42 J9, North Warwickshire and a 314,000 sq ft scheme near Bardon Hill, North West Leicestershire.

So is that a deliberate focus on the Midlands and around the ‘Golden Triangle’ or are you active elsewhere at the moment?

We operate nationwide with live projects on the M1 and M6 in the North, several projects in the South and South West, and even more around the M40, M42, M45, and M69. Currently, we have over 1m sq ft in the planning system in the East and West Midlands. The work to date has been assisted by external specialists such as LSH.

On one previous scheme, we secured outline consent at Viking Way, Congleton for a mixed-use development comprising residential and commercial uses that was successfully sold to Clowes Developments. This is now on-site with over 250,000 sq ft of logistics floorspace in addition to an Aldi, Starbucks, KFC, and Greggs alongside Bloor Homes.

Similarly, a mixed-use scheme in Market Weighton, Yorkshire, was sold through a competitive process to Danum Developments, following an outline consent for a new discount foodstore alongside 69,000 sq ft of commercial floorspace and 120 homes.

We’re also working with external specialists such as yourself and the team at LSH to identify further opportunities. One of the areas we’re looking to target next is the South East, but we’ll consider any well-located site with strong demand for different commercial uses across the UK.

Is your strategy likely to change in the coming years how are you responding to demand?

Richborough Commercial will continue to seek to meet market demand for both I&L and other commercial uses. The team is already expanding across all skill sets to ensure we have the capacity to deliver the best service to the landowners and the development market. This includes bolstering our site-finding capabilities.

Viking Way

Richborough sold a 55 acre mixed-use site at Viking Way, Congleton to Clowes Development in 2021 following outline consent from Cheshire East Council. The scheme is now under construction with over 250,000 sq ft of logistics floorspace in addition to an Aldi, Starbucks, KFC and Greggs alongside Bloor Homes.

Matt Dugdale

MATT DUGDALE
Planning Director
Richborough Commercial

Richborough Commercial

Matt Dugdale is Planning Director for Richborough Commercial, and oversees planning strategies, applications and appeals. With experience in local authorities, commercial developers and consultancy, Matt has advised on a range of schemes across his career. His knowledge of the planning landscape is fundamental to the growth and expansion of the Commercial division. Matt is a chartered member of the Royal Town Planning Institute (MRTPI), and in 2024 was Chair of the North West Region, and subsequently elected to the RTPI General Assembly for 2025/26. He also represents Richborough Commercial on the British Property Federation’s (BPF) Industrial Committee.

Download the Industrial & Logistics Market Report 2025 in full here →

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