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

3.47 A further research exercise was to compare responses across the public and private sector questionnaires. One area where this data showed interesting results was on the different kinds of land uses considered important to the vitality and viability of town centres;

Table 3.9 The importance of uses - comparing public / private opinions

• For electrical goods, the private sector was just below 40% stating this to be an important category. The public sector had nearly 60%.
• For furniture/furnishings, the public sector was again higher at more than 40%, the private sector placing these goods at less than 20% important.
• The public sector was strong on convenience/food use (more than 80%). The private sector were just over 40%.
• Public sector uses were strongly supported by the public sector, (nearly 60%), less so in the private responses (less than 20%).

Table 3.10 Combined Respondents Views on important uses in centres.

3.48 Table 3.10 combines both interest group responses in order to give an overall impression of the kinds of uses which are valued in centres. This shows that Civic Space, Car parking, Public Transport, Food & Drink and Fashion/mainstream retailing uses are considered to be the most important uses in centres with over 80% of respondents answering that these uses are important. The table demonstrates the low level of importance attributed to bulky DIY, carpet and garden retail uses with more than 50% of the combined respondent groups answering that these uses are unimportant.

3.49 Focusing on key issues of agreement between interest groups, Table 3.11 below clearly shows a low level of importance placed on bulky DIY, carpet and garden retail uses when the two audience groups are put together. Indeed, there is more than 50% responding that these uses are unimportant. On the other hand, there is strong support (over 80%) for car parking, public transport/services and food/drink establishments. These combined responses help to give a sharper focus to future policy by indicating the kind of uses which would be appropriate to encourage in town centres, and helps shape policies to make some allowances for out-of-centre development.

Table 3.11 Combined Respondents Views on Selected Uses

3.50 Table 3.12 below combines respondents views on the main factors which define town centres. This table confirms that Shopping/Retail Core, Primary & Secondary Retail, Public Transport Infrastructure, Focus of public activity, offices and definitions in local plans are important measures of town centre status.

Table 3.12 Factors Which Define Town Centres

3.51 In relation to the question on whether well established locations outwith town centres should be afforded town centre status, twice as many private sector respondents supported this idea than public sector respondents. Combining all respondents together, there was a 37% "yes" response to established locations out with town centres being afforded town centre status. However, more than half of all respondents still showed a negative reply.

Table 3.12 The Status of locations out with Centres.

3.52 In terms of whether to encourage formal hierarchy/strategic networks, the public sector was generally more supportive (Tables 3.3 & 3.7 above). Combining the respondent groups, just over half were in support of some form of hierarchy or strategic network. However, amongst the various responses which were more flexible, it is interesting to see 48% stating otherwise.

Defining Centres - General Performance Of NPPG8.

3.53 Before leaving the analysis of the public/ private sector surveys it is useful to draw some implications about the effectiveness of NPPG8 as a tool for policy and decision making and for defining centres.

3.54 The study found that there were varied views between private and public sector respondents on the effectiveness of NPPG8 as a guide to policy. However, the study team felt that the most telling results were the combined results which showed that respondents were most satisfied with NPPG8 as a guide to policy and decision making on promoting diversity & mixed use, vitality and viability indicators, the sequential approach, ensuring sustainable development and sustaining the vitality and viability of centres. The combined chart below shows that respondents were least satisfied with NPPG8 guidance on preparing & promoting town centre strategies, identifying town centre sites, encouraging an efficient & competitive retail sector and promoting design quality. All of these factors suggest there is scope to look more closely, not only at the definition of centres, but at improvements to the fabric of centres, promoting new developments and encouraging improvements in the retail offer. Finally, a key issue for the definition of important centres and setting a framework for their future development is the need to prepare and promote town centre strategies ( see Section 5).

Table 3.13 The Effectiveness of NPPG8 as a Guide to Policy.

Town Centre Managers

3.55 The corollary of defining a centre is to manage that centre well, through careful monitoring of its vitality and viability and new development and promotional opportunities. In Scotland, these tasks are frequently the focus of town centre managers and the study team (through a specific IRS exercise) researched the feedback from the Association of Town Centre Management in Scotland. This included a focus group, a selective topic guide and also a supplementary questionnaire.

3.56 On the importance of uses and facilities to maintain a vital and vibrant town centre, Table 3.14 below indicates the sample response from the 21 TCM schemes in Scotland, collated from the supplementary questionnaires. It shows the different average score for different uses. It has to be noted that these represent only eight out of twenty-one schemes in Scotland. Respondents were asked how important particular uses/facilities were in maintaining a vital and vibrant town centre (Table 1).

Table 3.14: Importance of uses/facilities to maintain a vital and vibrant town centre.
*Respondents were asked to consider the statements and to indicate their views according to a scale ranging from very important (5) to not important (1).

3.57 Higher levels of importance were recorded for public transport, food/drink establishments, fashion/main stream retailing and civic buildings. Less importance was placed on the likes of large office space, furniture/electrical retailers and bulk DIY/carpet and garden retail operators.

3.58 On the status of centres, the feedback from the TCM group centred on what central functions key centres need to encompass. Town centre managers considered that well established out of centre facilities could only be considered worthy of town centre status if they performed the essential community roles that traditional centres provide. It was questioned whether out-of-town centres or supermarkets currently perform such a function. In addition, town centres perform intangible roles that are difficult to quantify in planning policy terminology. On an intangible level, one critical function was to provide a sense of belonging and identity. It was questioned whether decentralised, more modern centres could engender similar sentiments, at least in the short term horizon.

Feedback From The Discussion Groups And Interviews

3.59 From the Stirling discussion group, the main points of feedback were as follows:-

• There should be some recognition of different forms of retailing, different locations and changing consumer patterns in identifying or defining new centres;
• Slavish adherence to lines on a map or boundaries does not reflect the reality of whether people are actively using an existing centre or could be encouraged to use it for a wider mix and range of uses;
• Mixed use development is important in the designation of new centres, although recognition of the key role of retailing in underpinning the health of any centre is of greater importance;
• There was a view that larger centres had over-presumed their importance and smaller existing off-centre locations which satisfy the necessary criteria could realistically secure a 'centre' designation;
• The key underpinning criterion should be the quality of public transport links;
• The debate should focus not only on new centres in addition to existing centres, but new centres as a replacement for under-performing existing centres;
• Further guidance from the Executive on the list of credentials would be appropriate in advising local authorities on how to designate new centres.

3.60 From the Perth Forum, there was limited discussion on this issue although the general consensus was that new centres must contain a full mix of retailers, and not simply be focussed on the multi-national sectors, given the important role, from a qualitative perspective, of independent traders in both the food and non-food sectors.

3.61 From the discussion groups with Advocates and planning solicitors, there was a debate in relation to what is meant by a "centre". Much Public Inquiry time was now involved in addressing the role and function of existing centres and the degree to which planning authorities can decide in which category a particular centre belongs. A revised SPP8 should provide guidance on what a centre is and Development Plans should be prepared at the local level to determine the category of centre according to individual circumstances.

3.62 It was recognised that the guidance does not include any clear criteria on how to define a centre, although there was a suggestion that if the guidance did include such criteria, then flexibility for Local Plans to define individual centres based on local circumstances would be appropriate.

3.63 Similar issues merged from the solicitor's discussion group with the criticism that over rigorous definitions for town centres could give unfair protection to existing commercial interests and this could stifle competition and prevent new innovative forms of retailing. A more flexible approach to defining town centres was considered necessary, particularly based upon an assessment of future opportunities for new development.

3.64 Concerns were raised at individual interviews about key aspects of NPPG8.

3.65 Some concerns were raised by local authorities in relation to how NPPG8 makes no distinction between town centres and other centres (e.g. district centres). This has implications for identifying district centres in local plans, and the potential future impact these might have on the town/ city centre. It was argued that this policy supports the expansion of district centres in principle and may potentially harm the future of higher-order centre. In relation to the under-performing centres it was suggested by a number of local authority planners that the centres should not automatically receive protection if a more appropriate and more sustainable alternative centre exists. This is a view supported by private sector interviewees.

3.66 There was broad agreement amongst both public and private sector interviewees that a criteria-based approach to defining new centres is appropriate and most important criteria include accessibility and proximity to catchment population. Regeneration is an important underlying function in relation to the identification of new centres in certain circumstances.

3.67 The private sector points to a longer-term visionary approach in identifying new centres, and policy guidance should seek to secure the maximum accessibility to the widest retail choice for all levels of society. Current policy, instead of facilitating this, often works against it.

Site Development Issues

3.68 The study team's specific research on the issue of site development issues concentrated mainly on achieving more planning results within identified centres, by way of land assembly, compulsory purchase, etc. This is reported in Section 5 of this report. However, as part of this analysis, it became clear that a sharper definition of appropriate centres through Development Plan policy would assist in providing future guidance for site development issues. For instance, investing considerable time and financial resources in land assembly in one particular centre will only be worthwhile if it is known that that centre will achieve some protection and status in the future. Another instance is the different levels of complexity and investment required to tackle land assembly/property title, heritage and other complications in the more traditional and historic centres as opposed to the relatively simple land assembly challenge in decentralised locations, where land ownership is less complex and sites are readily available. This might suggest that the "league table" for the definitions of centres (as noted earlier in the example of Edinburgh and Lothian Structure Plan) could be linked to some kind of assistance/general contribution regime. In other words, where the site assembly challenge is more difficult in the more historic centres, assistance might be available. Where the challenges are less significant in the more modern locations, it might be more likely that planning policy will seek general contributions towards improvements to transport, land use mix, etc.

Defining Centres - Implications For Policy

3.69 From the various findings above, the study team draws the various implications below. For later reference, these are coded as "D.C." implications, in relation to the issues identified for defining centres.

DC1: Centres Must Have Credentials

3.70 Throughout all the direct consultative exercises in this study, it is clear from the views of retailers, developers, local authority officials and other practitioners that, to be defined as a centre, there must be certain proven credentials. This is most clearly shown by the various tables in this section, which highlight respondents' views in terms of important land uses to assist the vitality and viability of town centres. As well as specific tabular feedback from the questionnaire results, and the town centre managers' survey, this was a frequent theme raised in the discussion and interview sessions. The implications for policy point to certain primary uses:

• Fashion/mainstream comparison retailing;
• Public transport hubs / services;
• Car parking;
• Civic space/buildings;
• Tourist attractions;
• Food/drink establishments;
• Financial/professional services;
• Leisure venues.

3.71 The implication is also that certain other uses appear to be less important to future planning policy on town centres such as bulky DIY, carpet and garden retailing. Also, there were lower responses in relation to electrical goods, furnisher/furnishings, large office/business space and education/healthcare, etc., facilities. There were differing opinions on convenience stores, with the public sector being more keen to include elements of food-based retailing in uses which are important to vitality and viability.

3.72 The above emergent categories are reflected in the study's investigation into sample policies, appeal decisions and from interviews. From the most recent city-region structure plans in particular there is evidence of a fresh approach to all centres / locations in the urban area, entailing some form of checklist to prove fitness for protection. It seems that this study has uncovered the first stages of a new approach which should in future look at the credentials presented by different retail centres/locations, for them to assert a sustainable status in the hierarchy (see DC3 below).

DC2: Multi-Locational Dimension

3.73 As noted in the previous section, there is also evidence of a gathering view that retail and other commercial activities are now clustering at various locations around urban areas. Five years ago NPPG8 policy was set out to protect the primacy of the "town centre" with some evidence that each urban area has consequently focussed on one main centre. However, there appears to be increasing evidence that local authorities, developers, operators and others now recognise the multiple locations which are providing commercial and other activities. These may be highly sustainable locations. The study has found evidence of some policies operating with a tunnel vision to the single most important centre in an area, and with a "policy blindside" to other locations which are worthy of assessment in the planning process (see below).

DC3: According Status/Importance

3.74 As noted in the previous two implications for policy, it appears that increasing status will be sought by locations which have been initially delivered as decentralised shopping locations. This implies that status might be accorded to other established locations, hitherto defined as out-of-centre.

3.75 However, the caution on this implication, is clearly to note that emergent centres in a new hierarchy will have to be subject to some form of filtering process, which is highly likely to be related to the list of credentials presented above. The existence of a strong multi-mode transport node is likely to lead the list.

3.76 An implication from this is the probability of various interests (long-term investment feuholders, tenant operators, trade associations and others) pursuing increased participation in the development plan process of defining centres. On the other hand, planning authorities will be required to justify policy choices, giving reasons for their selection of various qualifying credentials. Whilst this will be influenced by local circumstances, it should be guided by national policy on the key elements of a sustainable centre. It will also be interesting to see if the development control process uncovers an increased requirement from authorities, and indeed readiness on the part of the applicant; to gain additional facilities, in order to climb up the qualifying league.

DC4: Taking Stock - An Audit Of Centres/Locations

3.77 The three previous implications for policy point to a further important area. The study team believes that future development plan action will have to bring forward the importance of an exercise that audits all the centres in a given urban area. In the five years since the introduction of NPPG8 there has been the evolution of many new forms of retail, expansion to existing centres and the evolution of other recognised locations. However, it is only from recent Development Plans that evidence emerges of a review of centres of importance.

3.78 The effect of key credentials, multi-locational patterns and a quest for status will be a requirement to bring a sharper focus into "Action Required" in national policy. Paragraph 84 of NPPG8 alludes to exercises based upon deficiencies, demand and a framework of centres; but this will require sharper focus. The study team suggests that a requirement of planning authorities should be to prepare an audit of all centres and locations, which provide retail and associated activities in order to inform development plan strategy and this should seek to define relative status. Frequent updating with reference to good data and Town Centre Strategies will be vital.

DC5 - Accessibility: "Key Sites" and the Urban / Rural Distinction

3.79 This section has alighted upon frequent evidence that the "polycentric" pattern for urban areas is also a pattern which presents improvements to accessibility and potentially sustainability.

3.80 Accessibility has already been noted in implications from general changes, in Section 1. It is also an important issue to emerge in other topic headings in the report.

3.81 Some of the most important input on the transport side of the study has highlighted accessibility and the previous Scottish Executive study (2001) into a methodology to identify "Key Sites" in Scottish urban areas. Indeed, the concept of Key Sites has now emerged in SPP2 for economic development and employment land.

3.82 Therefore, the study team believes that a key implication for future planning and transport policy will be to identify urban centres which produce optimal accessibility, focussed upon a selection of Key Sites, defined in the Scottish Executive Research Study as "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". The team believes this will highlight an issue of complementary public transport investment and indeed car parking policy.

3.83 Another key aspect in terms of the definition of centres from transport evidence is that there are distinct differences between urban and rural areas. The previous section highlighted some of these differences and this issue has been raised frequently in the discussion groups, interviews and questionnaire responses. There is a significant level of opinion in Scotland, that NPPG8 should in future allow for discretion at the local level, particularly where more remote rural areas have greater reliance on the private car, in order to access good quality retail provision.

DC6 Absence Of Town Centre Strategy/Vitality And Viability Studies

3.84 A key finding in this section is the dearth of activity in updated preparation of Town Centre Strategies and Vitality and Viability Health Checks as required in NPPG8.

3.85 The implication for policy is that, whilst paragraph 27 of NPPG8 sets out quite clearly the measures for vitality and viability, there is a low level of activity in actually employing these measures and updating data. Some planning authorities have made good efforts, along with town centre managers in this regard. However, many refer to the lack of resources as a reason why insufficient data is being collated.

3.86 The study team believe that an item of greater importance is the repeated reference to Town Centre Strategies. Paragraph 33 of NPPG8 makes it clear that " Failure to improve town centres will make them more vulnerable to the competitive challenges presented by new forms of retailing and other nearby town centres or out-of-centre locations." This is an important point. NPPG8 continues to require that planning authorities should adopt a pro-active role towards town centre change and improvement, working in partnership with retailers, other development interests, private investors, public agencies, infrastructure providers and the community. It is stated that an overall strategy should be agreed which indicates the scope of change, renewal and diversification. Frequent reference has been made throughout the study to the lack of activity in this regard. Set against the more strident tone used in NPPG8 for the requirement to adopt a town centre strategy, it is surprising that only low levels of activity have been recorded. This lack of activity cannot be tenable. If authorities wish to strengthen the focus on investment in sustainable centres, they will have to commit a constant flow of resource to town centre improvement and proving viable development options. This will have to be complemented by a monitoring database on vitality and viability measures (as noted in Figure 1 of NPPG8).

3.87 Elsewhere in this report, site development issues are addressed under Section 5, Support for New Development.

DC7 NPPG8 - Specific Weaknesses

3.88 Another implication for policy which the study has related to the definition of centres is the combined views from public and private sector on the effectiveness of NPPG8 as a guide to policy.

3.89 In terms of town centre definition, the study team identified concern as a result of less than 40% finding NPPG8 clear and instructive on the following aspects:

• As a guide to town centre management efforts;
• Prepare and promote town centre strategies;
• Identify town centre sites;
• Promote an efficient and competitive retail sector;
• Promote design quality and an attractive environment;

3.90 All these aspects are key ingredients to the good management, promotion and future development of town centres and entail land use, physical and design exercises to improve town centres.

3.91 In terms of NPPG8, the implication is that future guidance will have to be more explicit on the actions required, to help promote TCM activities, TCS preparation, identifying sites and improving design standards (the recent PAN 68 might assist the latter point). As drafted it tends to specify all the elements which should be protected in a town, rather than items of pro-active initiative, that can help to progress a town centre. It is debateable whether such issues should be in any revised NPPG8. Perhaps they are better placed in detailed best practice guidance in a revised PAN, which addresses TCS methodology and site development issues.

DC8 Lack Of Clarity: Edge Of Centre

3.92 The final key implication arising from the assessment in this section is frequent comment amongst professional commentators, discussion groups and the interviewee responses that the policy is unclear on the definition of "edge-of-centre".

3.93 Numerous comments referred to the lack of a clear and objective test of the availability of edge-of-centre sites, suitability in terms of physical aspects and also viability.

3.94 This issue links directly to the next chapter, which addresses the sequential approach.

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