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Research Study on the Effectiveness of NPPG 8 Town Centres and Retailing

3. Defining Centres, Their Use Mix and Status

3.1 The original client Brief retraced the evolution of national planning guidance on retail development through different revisions of policy. It emphasised the 1998 version of NPPG8 currently in force, which brought a further clarification of the government's commitment to town centres. Linked to this emphasis in the current guidelines is a central objective of the research project which is to investigate the location of new developments, the attractiveness of town centres and the impact of new development on the vitality of town centres. However, in addition, the research specification sought to look at actions to improve town centres, to attract retailers and to provide a supply of new development opportunities. Allied to this central issue was the status of existing out-of-centre developments, in particular whether they should be regarded as "town centres". Although these do not have the traditional range of facilities and services found in a longer established town centre, there might be arguments to allow these centres to expand and diversify and to build up a critical mass to allow improved access by public transport and other benefits.

3.2 As a result of these key points in the Brief, the research methodology has been designed to undertake an investigation of locational issues in new retail development, the success of established town centres, the definition of a town centre or district centre, the role of out-of-centre retail facilities and evidence/opinions in relation to a possible fresh approach to all the centres in an urban area and their role and status in future national and Development Plan policy.

Findings From Desk and Survey Research

Literature Review

3.3 From the IRS research sources (a fuller summary is included in the previous section of this report) it is important to have regard to the drivers for change such as political structure, economic trends, socio-cultural and lifestyle aspirations. These drivers, along with demographic change, innovations in products and processes and environmental change amongst retailers led to some key questions on the future size and scope of retailing and a competitive structure amongst retailers to find optimal locations. IRS concludes that Scotland will have to continue to accommodate modernisation of retailing and an annual level of sales growth which will require new formats and new floorspace. The benefits of providing the new accommodation for sales growth will be matched by the possible costs of previous floorspace lying vacant and falling into disuse and eventual reuse.

3.4 IRS also points to the importance of format developments, as retailers continue to innovate in response to changing consumer demands. There is evidence of change towards a smaller number of unit outlets, but an increasing size requirement and standard layout for merchandise. In addition, IRS advise that locational developments and issues of accessibility will increase in importance alongside the competitive effects of retail developers seeking the optimal locations. Retailing is likely to remain competitive at many levels with the effect that some locations will become marginal prompting a requirement for the planning process to manage physical decline in a positive way. Although IRS point to changes in technology and innovations on e-retail, it is unlikely that these changes will cause a significant shift away from the quest for continued modernisation of floorspace. Therefore, the need to define appropriate centres for retailing and linked activities will continue to be a priority in Scotland, as innovation and change in retailing continues.

3.5 Our second area of literature research was the CBRE summary of retail planning issues in professional property, planning and other circles involving practitioners whose work links them to the physical planning process.

3.6 NPPG8 provides definitions of; town centres, edge-of-centre and out-of-centre sites. However developers are forming a variety of interpretations. ¹

3.7 The current version of NPPG8 was initially seen as a turning point in the Government's intentions for out-of-centre development and provided clarification of the Government's commitment to the importance of protecting town centres.

3.8 With the emergence of NPPG8 it was recognised in the professional press that there was a requirement for the planning authorities and the private sector to work together to promote town centres. ² In order to achieve this, it has been suggested that existing centres will have to be enhanced and must use their strengths in the added value of heritage, culture and leisure.

3.9 A shift in bulky goods away from town centre locations could be seen as a opportunity to encourage people back to using public transport for comparison shopping in town centres ³. A similar view is held by a property professional who argues that the way of enhancing town centres is through elevating the importance of a town centre by the modes of transport other than the car and promoting greater diversity through mixed use development. ⁴

3.10 Unlike the English guidance note PPG6, NPPG8 places district centres along with town centres in definitions of locations for new development. The PPG6 approach however is to put smaller centres in second positions on par with edge-of-centre sites. ⁵ In addition it has been commented that PPG6 places significantly greater importance on assessing in-centre options which includes the re-use of existing buildings.

3.11 If a suitable site could not be found within the town centre then the other option is an edge-of-centre site. Edge-of-centre is usually "adjacent" in defining the relationship of an edge-of-centre site to its relative town centre. This is a concept which has been interpreted with much subjectivity. The subjectivity of this issue will be discussed in the next section.

3.12 If no edge-of-centre sites are suitable then the only option is to look at out-of-centre sites in locations that can be made accessible by a choice of transport modes. It has been argued by commentators that the shift in the 1980s to out-of-centre sites has created new retail centres which are increasingly achieving recognition in emerging Structure and Local Plans and therefore should be protected and given more status. ⁶ The NPPG8 guidance however clearly states that beyond the sequential approach a strong case has to be made for a site which is out-of-centre. Not only does the sequential approach have to be examined but one also has to look at the overall effect of minimising traffic problems and maximising all transport modes and accessibility while attracting shoppers to the urban area.

3.13 An academic describes out-of centre as " Typically this has good road access, large amounts of free parking, major retail chains which act as anchor tenants, a large number of retail outlets housed in some form of enclosed mall and a range of non-retail activities, such as food outlets cinemas and childcare facilities" ⁷.

3.14 A planning professional discusses how in some cases local planning authorities have taken a more proactive approach towards out-of-centre developments which have customer loyalty, and have 'blue-lined' out-of-centre sites in Development Plans showing that out-of-centre sites can have some status. This also emphasises that existing supermarkets with ancillary shops, facilities and public transport perhaps should be recognised by the local planning authority and be given a Development Plan allocation. In other words out-of-centre may not necessarily be unsuitable development but might in fact be sustainable and worth protection. ⁸ This is a common view expressed that local authorities need to accept that out-of-centre shopping can be complementary to the city centre ⁹.

3.15 It has also been argued by property professionals that the restrictions on out-of-centre developments leave a loophole which undermines the paramount importance of the role of town centres. It is argued that in practical terms it is the market that determines where retail should be located. ¹⁰

3.16 On a broader scale a leading UK urban planning commentator promotes the understanding of expanding city-regions through the concept of the "polycentric city" - a system of interlinked focal points across the urban transport links, socio-economic, cultural and commercial facilities (Professor Sir Peter Hall, Institute of Community Studies).

Retail Profiles

3.17 The evidence from our data on retail profiles is presented in the previous section of this report. Certain items were relevant to the definition of centres. The national Scottish trends show that shopping makes up nearly 50% of average weekly household expenditure. Of this spend, a significant amount is on food and drink (essential convenience items). In the more leisure-based comparison sector, the significant categories are clothing/footwear and recreation/culture. This might have an implication that the location of centres around any urban area should reflect the strength of household expenditure firstly on convenience items and secondly, should provide for an adequate level of service to allow for less frequent shopping trips of a more leisure-based nature to seek items of recreation, culture and clothing. Taken along side data taken earlier that Scottish retail sales are approximately 19 billion per annum, these trends give a strong signal to central government guidance to continue with an emphasis on the importance of convenient locations in our built up areas, to provide for this important sector of the economy which makes up a significant level of household spend.

3.18 Our retail profile sources have also shown earlier that the national survey of local shopping patterns shows improvements in popularity, mainly amongst the higher ranking centres. The incidence of decline is more frequent amongst those centres which are more lowly ranked, in terms of retail offer and customer usage. This evidence gives us some indication of the "survive/struggle" succession amongst different forms of centres, as retail continues to evolve as an important sector in the economy.

3.19 The data on the pipeline of retail floorspace in Scotland highlighted the continued enthusiasm in the development industry for out-of-centre applications over the past five years. Although the previous section identified some evidence of the "planning filter" sifting out a reduced number of actual consents, from original applications, there was still a significant level of out-of-centre consents and retail completions over the periods analysed in the charts. Indeed, in the years 1999 to 2001, out-of-centre retail floorspace completions out-stripped town centre levels. Only in the last two years, has there been evidence to suggest the predominance of town centre locations.

3.20 However, combined with the floorspace patterns on convenience goods, we have concluded that these statistics show beyond doubt that Scotland's urban areas are now populated by a mix of different retail locations from town centres to out-of-centre shopping malls, retail parks, district centres, and superstore based developments. Indeed, some of the superstore evidence we have used for the study suggests that a number of foodstores which were processed through the planning system as "out-of-centre" are now considered by the Institute of Grocery Distribution to be "neighbourhood centres" by reason of their integration with other local facilities and surrounding population catchments.

3.21 From our knowledge of the base data used in the various statistics employed for this study, many of these locations that classified as "out-of-centre" have started to show changes over time to become locations which are well served by public transport, have a mix of food and non-food retail provision as well as other services and are starting to make their presence felt in the retail hierarchy as centres in their own right. Therefore, future analysis of retail profiles such as the floorspace pipeline and relative rankings of centres might well have to look at different definitions of "centres". It is no longer the case that "out-of-centre" always represents a standalone single retail unit with no associated uses or linkages to local neighbourhood or public transport. Therefore, looking at past patterns of national guidance on retail, a question should be raised as to whether this proliferation of more modern retail facilities in "decentralised" locations might, in fact, bring benefits by way of a subsidiarity of retail provision at the local level, through locations which can, in time mature to take the form of centres in their own right which do not undermine the prime town or city centre originally protected under earlier guidance. This notion of Scotland's urban areas being able to embrace a more "polycentric" model of development, rather than the single "monocentric" pattern is reflected in the background literature review and also in various discussion forums and interviews held as part of the study.

Retail Data And Assessment Techniques

3.22 One of the specific reports of desk research for the client group in this study was a thorough overview of previous studies into retail data and assessment techniques and a look at the current practice. From this review, we concluded that the definition of centres is becoming increasingly important for retail assessments. These assessments will lack relevance and focus, unless given clear guidance (ideally through an up to date Development Plan) on which retail locations are of considered to be of importance to land use planning interests in any particular local planning authority area. "Centres of importance" was raised as a critical issue in the 1991 Study of Retail Techniques by Drivas Jonas for the Scottish Office and it continues to be of vital input to a meaningful final analysis of capacity for retail growth and also in looking at levels of impact. For example, the severe impact level on a free standing superstore might be considered fair market competition; but a new free standing retail facility which is proposed to have a major impact on its competitors (which are located in central positions in an important town centre) requires a careful appraisal of impact. The final planning decision on new retail developments has increasingly been made in the context of the actual impact on centres of importance. However, as well as identifying the existing centre where there is a mix of retail and other uses worthy of protection; it is now also important to look at the kind of new development being proposed as part of any planning application. For example, it might be a development which is capable of embracing significant improvements to public transport, a mix of retail and other uses, connectivity to other social, economic and a community facilities and therefore might be eligible for some form of protected status in its own right in due course, if significant infrastructure investment is being made as part of the new retail-based proposals. This point is reflected again below from the other research sources.

Review Of Policies And Decisions

3.23 From the selected Development Plans and significant retail decisions analysed by the study team, there are some important findings in terms of the definition of centres.

3.24 There is broad agreement amongst both operators and practitioners that planning policies in Development Plans are rarely linked to Town Centre Strategies, as recommended at paragraph 33 of the NPPG. Equally, policies are rarely linked directly to up to date health checks, again as referred to in some detail at paragraph 27. As such, there is considerable acceptance on the part of local authorities that Development Plan policies are consistent with the broad thrust of NPPG8 in focussing development in town centre locations, and testing new out of centre development against the paragraph 45 criteria. Equally however, there is limited pro-active policy guidance in relation to the health of town centres and actual identifiable opportunities for meeting the policy objective to focus new development in the centre.

3.25 There is general agreement amongst all sectors and interests that a criteria-based approach to defining a centre is appropriate in principle, and that the main thrust of the criteria should focus on sustainable transport and meeting the needs of local communities. However Development Plan policies continue to identify only established centres both in terms of policies and allocations on proposals maps. There is clear evidence of acceptance on the part of local authorities that certain out of centre developments are beginning to display the characteristics of being a "centre" in their own right, but there remains considerable reluctance to seek to define these centres in Development Plans in the absence of clear advice in national policy. Reference has been made to examples of existing or emerging centres which have been subject to scrutiny on according status: including Braehead, the Gyle Centre, Fort Kinnaird and Ravenscraig.

3.26 Planning applications in respect of these centres continue to require detailed information in respect of the paragraph 45 criteria and decisions tend to be based on other material considerations as opposed to their consistency with a Development Plan.

3.27 There is similar reluctance in respect of defining new centres as evidenced in appeal decisions, most notably the 2000 Gyle decision of the Scottish Ministers which departed from the advice of the Inquiry Reporter who concluded that the centre fell within the definition of "town centre" in NPPG8. The Ministers disagreed on the basis that the centre did not provide a broad range of services, serving as a focus for the community and for public transport, nor have a distinct physical form and mix of functions " that make it different from a shopping centre" (paragraph 8 of decision letter).

3.28 It is interesting to look at recent strategic policy for the two main urban areas in Scotland. Glasgow and Clyde Valley Structure Plan has taken an overall structural review of retail locations and has brought in to its strategic policies an acceptance of certain new retail locations of importance. Auchinlee and Ravenscraig have figured in this review, bringing them forward as locations which can provide for a sustainable mix of uses in a convenient location to surrounding catchments, with potential to show public transport benefits, mixed uses and other benefits to the general community. This complements the traditional approach of accepting Glasgow city centre as the dominant major focus and offer the more traditional satellite towns as sub regional centres such as Paisley, Hamilton, Dumbarton, East Kilbride, etc.

3.29 In Edinburgh and the Lothians the recent Structure Plan has tackled the definition of centres by way of two schedules. The first schedule details the more traditional centres such as Edinburgh city centre, Livingston, Dalkeith and other suburban and satellite centres. However, in addition the second schedule is introduced in order to acknowledge the existence of, and potential benefits of other significant retail locations which have developed within the urban area such as the Gyle, Cameron Toll & Hermiston Gate. This latter approach seems to give a strategic context for an implied challenge to all retail based locations, to try and work their way up a hierarchy to achieve recognition and protection. From our review of recent policy making and interviews with some of the key practitioners, it appears that this process is increasing in popularity, and its success will depend upon different definitions of the "credentials" for the centre to display, in order to assert its role in the urban hierarchy and achieve protection in future policy.

Transport Issues

3.30 The continued predominance of the car is one of the general trends noted in Section 2 of this report. However, there are some marked differences in the level of car usage in the larger urban areas, due to the choice of transport modes. Nevertheless, CBP recommends certain key issues for town centres including the importance of increasing the use of sustainable transport modes, improvement of access by public transport and the provision of an attractive and safe pedestrian environment and measures to manage the level of car usage. Ensuring 'accessible town centres' is a key factor identified in the review of transportation issues and this is reflected in the review of relevant NPPG17 and NPPG8 transport and planning objectives which seek to improve the competitiveness of town centres and overall accessibility.

3.31 A corollary of these transport themes is the need to define centres not only with a strong priority on public transport, but also on car parking. As Section 2 found, the continued use of private cars (or ease of having access to a car) for shopping, the incidence of off-peak travel and the shorter distances being covered; all suggest that future policy should look at a controlled element of car usage. This has implications for a balanced approach to car parking allowances and restrictions.

3.32 The study team's transport review has also highlighted the importance of the Scottish Executive's Key Sites Methodology Study (May 2001) as part of the Scottish Executive's transport research series. This work, by CBP defines Key Sites as those "sites that are highly accessible, or could be made highly accessible, by public transport networks and nodes, that could contain a higher density travel generating mix of uses".

General Shopping Public - Surveys

3.33 Our report of survey research included the various sample surveys from CBRE covering areas of Edinburgh, Glasgow, East and West Lothian and Perth and Kinross in order to give an urban and rural spread of shopping habits. These results are summarised in the previous section ( see tables in Section 2). Of importance to the definition of centres is the evidence of linked trips when people are undertaking their main food or comparison shopping trips. Main food shopping trips are associated with visits to other shopping facilities, banks/building societies and (less frequently) restaurants/cafes, leisure activities and other services. There is a higher incidence of linked activities as part of the comparison shopping trip. Bank/building societies, restaurants/cafes and leisure/other services all featured as additional activities undertaken on the same trip.

3.34 Another key point from the general household shopping patterns is the highly significant response that the factor "most liked" about people's local shopping centre was the fact that it was close to home and convenient. Although this is a simple and obvious point, the study team believes that it has a significant implication for future retail policy, which will have to focus upon convenience and proximity as one of the most important factors in retail location, as far as the shopping public are concerned. At this point, it is probably worth noting the potential challenge of reconciling this point with the fact that the average response for method of travel to main food shopping destination is still more than 70% car in rural areas (more than 50% in urban areas). For comparison shopping, similar patterns emerge (although car reliance is lower in urban areas).

Public and Private Sector Questionnaires

3.35 From the public sector questionnaire, respondents were asked about the uses and facilities in town centres which were considered important for maintaining vital and vibrant town centres..

3.36 The greatest strength of feeling towards important uses (where more than 75% rated the use as important) were as follows:

• Fashion mainstream comparison retailing.
• Public transport/ services
• Food/ drink establishments
• Car parking
• Civic space
• Convenience/ goods/ household retail
• Residential uses close to centres
• Leisure venues
• Financial/ professional services
• Civic buildings
• Tourist attractions

3.37 On the other hand, respondents were not so positive about the importance of use in the case of amenity open space, education/ health care/ social facilities, electrical retailing and furniture and furnishings. It was also a particularly marked response of "unimportant", towards bulky DIY, carpet and garden retail (less than 10% viewed these uses as important to town centres'.

Table 3.1 - Important uses for Town Centres.

3.38 These results are giving a helpful indication for future national retail policy with a clear distinction of those uses which can contribute to town centre vitality and a view in the public sector that the more bulky goods retailing has less importance in town centre locations.

3.39 The definition of centres was also probed through Question 4 which asked whether well established shopping locations outwith town centres could be afforded town centre status. The public sector respondents showed 70% against this notion, but 24% in favour.

Table 3.2 The Status Of Locations Outwith Centres.

3.40 When respondents were asked for their views on whether a formal planning hierarchy should be used to plan for sustainable centres, or a strategic network, flexible local policies or other methods, just over one third were in favour of a formal hierarchy and approximately one quarter favoured strategic networks. However, it is perhaps worth noting that, amongst the public sector, 18% of respondents preferred some more flexibility on allocating sustainable centres through development planning.

Table 3.3 Hierarchy or Flexibility?

3.41 A supplementary issue to Question 7 were the views of public sector respondents to the factors which define a town centre and this shows the most common features for defining centres being shops/retail core, primary/secondary retail, focus of public activity and an area defined in the Local Plan. The first three are the more informative items and were also endorsed by private sector respondents. Other features showing a higher level of response included offices and areas where there is a diverse land use pattern.

Table 3.4 Factors Which Define Town Centres.

3.42 Private sector respondents were asked about appropriate uses to be accommodated in town centres in order to make them vital and vibrant places (Table 3.5 below). The most enthusiastic responses were in relation to car parking, public transport/ services, food/ drink establishments and fashion/ main stream comparison retailing. This is similar to the public sector response. There were also views that tourist attractions, civic space/ buildings and financial/ professional services are important uses in town centres. Question 3 brought a less enthusiastic response from the private sector in relation to the central location of convenience and household retail and education/ health care/ social facilities and a very low response in terms of the importance of bulky DIY, carpet and garden retail. In addition, there was a less enthusiastic response for electrical and furniture/ furnishings retailing in town/ city centres.

Table 3.5 - Important uses for Town Centres.

3.43 In terms of the status to be given to different centres, 53% of the private sector respondents felt that well established shopping locations outwith town centres should be afforded a status equal to 'town centres'. 36% were against this notion and 11% abstained (Table 3.6).

Table 3.6 The Status Of Locations Out With Centres.

3.44 When asked which approach was most suited to planning for sustainable centres, 42% of respondents felt that some form of formal hierarchy or strategic network could be useful. However, 40% were more in favour of more flexibility.

Table 3.7 hierarchy or flexibility?

3.45 Similar to the public sector, private sector respondents noted a variety of activities which can be used to physically define the extent of a centre (Table 3.8 below). The predominant factors were public transport, focus of public activity and primary/secondary retail.

Table 3.8 Factors Which Define Town Centres

3.46 Overall, it seems that the private sector view is to be more adventurous in defining the planning status for different centres that have now established themselves in the hierarchy and to have flexible planning policies for the allocation of centres. In addition, there seems to be a clear view that the bulkier forms of trading are less appropriate for town centre floor space, but there is still a place for strong town centre transportation facilities, mainstream fashion/ comparison, civic space and, notably car parking.

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