The Scottish Government

« Previous | Contents | Next »

Listen

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

4. Sequential approach - Flexibility/Realism and Defining Edge of Centre

4.1 The original client Brief was clear in its emphasis on the need for research in NPPG8 to look at whether planning authorities and developers have demonstrated flexibility and realism in applying the sequential approach. The Brief questioned whether it was realistic to expect developers/retailers to change their normal formats and how new retail formats could be reconciled with a sequential policy approach. Linked to this was the question of whether the guidance should continue to apply to non-retail uses. In addition, there could be evidence of emerging of forms of leisure/shopping which include a leisure activity which is as important as the retail function.

4.2 Another issue in the Brief which is directly linked to the sequential approach is the clarity on defining sites which lie at the "edge-of-centre". The strength of the links between a proposed retail site and an existing town centre will depend upon various factors and the Brief to the consultant team was keen to look into these factors, including barriers to linkages, easy walking distance and the importance of different decisions based upon different local circumstances.

4.3 Because of the emphasis on the sequential approach issue, the study team set this topic at the centre of the research effort and useful results were gathered from most of the eleven tasks included in the desk and survey research.

Findings From Desk and Survey Research

4.4 From the literature review, retail profiles and other sources, there were varying levels of reference to the sequential approach, flexibility and realism and ideas in relation to improving this area of NPPG8 policy. The key findings are set out below:

Literature Review

4.5 Most of the IRS general trends research is summarised in Section 2 and 3 of this report. The general nature of this research did not reveal any specific reference to the sequential approach or edge-of-centre issues. However, the points raised in the previous section on the definition of centres and the importance of competitive place, in terms of retailing, suggest that the future strengthening of the more successful centres will continue to place the sequential approach at the heart of land use decisions related to new retail formats in the future.

4.6 The CBRE literature search was undertaken in addition to the IRS bibliography and this revealed some further references from the professional press in relation to the sequential approach.

4.7 Paragraph 13 of NPPG8 calls for flexibility and realism from developers, retailers and local planning authorities when applying the sequential approach. A planning academic/ commentator argues that this could be successful if local authorities, developers and retailers communicate better, be more understanding, and undertake analysis and viability testing. It is argued that " there had been a temptation for local planning authorities to make sweeping statements about the possibility of available sites".

4.8 The same commentator argues that local planning authorities need to undertake reviews on what sites are available in the town centre and publish frequent reviews that support Local Plan policy. Perhaps local planning authorities need to recognise that their town centre boundaries will have to be amended to accommodate changes in market requirements. " Perhaps it is time for flexibility and realism to include more of the open-book approach to development viability appraisal, and with greater understanding on the part of the local authorities."¹¹

4.9 It is not the guidance itself which has been criticised but its interpretation. In particular it has been argued that local planning authorities are not being flexible and realistic. Local planning authorities have identified potential sites but this is only a fraction of the effort required to progress a realistic development opportunity. In addition local planning authorities are presenting potential sites in theory but in practice these are not readily available.

4.10 According to one commentator caution should be a high priority when dealing with the sequential approach if it is interpreted in spatial terms. Thus " in centre and edge-of-centre developments are automatically seen as 'good' regardless of their size, provision of car parking or any other aspect which means they are either unsustainable or detrimental to existing centres". Using the same logic, out-of-centre developments are automatically labelled 'bad'. In other words it might be better to evaluate proposals against other factors rather than simply evaluating them against location. ¹²

4.11 It has also been argued that it is possible to have a town centre development that can still have all the characteristics and detrimental impact of an out-of-town centre. The example given here is the Buchanan Galleries scheme which passes all the sequential tests yet it has the make up of an out-of-centre development. As a result of this it has been argued that the sequential approach can be a crude method on which to base retail planning policy and perhaps it needs to be amended to take into account other issues such as the scale of the development and existing facilities. ¹³

4.12 With NPPG8 making it harder for out-of-centre developments to be approved it has been increasingly vital for developers to ensure that their site will qualify at least as an edge-of-centre site. However what qualifies as an edge-of-centre site has been debated and has resulted in inconsistencies, although it is argued inconsistencies have emerged because local authorities assess each site on its own merits or because the local authority has strong local views. Part of the problem could be due to the fact that NPPG8 does not include any indication of an optimum distance that might qualify as "easy walking". Whereas, PPG6 offers general guidance of 200-300 metres.

4.13 The interpretation of this by Scottish Reporters at Inquiries has caused confusion. At inquiries some Scottish Reporters have assumed 300 metres as a maximum distance and this has resulted in some decisions that have been argued to be inconsistent with NPPG8. Although NPPG8 does not include any optimum distance it does provide the phrase 'usually adjacent' in defining the relationship of an edge-of-centre site to the town centre.

4.14 Again, commentators have debated this issue. One example given by a planning professional is that in Renfrew the site of a proposed foodstore was determined to be "clearly" and "decisively" separate from the town centre due to it being greater than 300 metres away. However the route was free from barriers or busy junctions. In other cases however, for example, in Perth, a non-food proposal was deemed to be adjoining the town centre although it was separated by an area of land and a road. ¹⁴ A less successful example is a site in Fraserburgh that was regarded as 'not functionally adjacent' to the relevant retail area within the town centre. This was not because of a road but because of the difference in character between the areas.

4.15 Further criticism from property professionals is that the sequential test applies only to major retail developments and that it has been argued that this contains "geographic loopholes". This is because local planning authorities differ in opinion as to what 'major' means.

Retail Profiles

4.16 Most of the useful findings from retail profiles has already been reported in the previous two sections. In relation to the sequential approach, the Scottish pipeline floorspace data ( see Section 2) does however show an important finding, that town centre applications and consents in Scotland have held strong throughout the last five years, with an increasing relative level of town centre floorspace coming through in the last two years in particular. Previously, a boom in retail warehouse park formats have shown a proliferation in out of centre development. However, the more recent trends now suggest that the town centre shopping centre format is a more popular form of new Scottish retail floorspace completion in recent years. At this point, it is perhaps worth noting that the 2000 retail development survey by the Scottish Executive Development Department, taken from local authority returns, shows a similar pattern of town centre and edge-of-centre, representing the stronger elements of floorspace completions in the years 1998 to 2000.

4.17 Overall, from different retail profiles, this suggests to the study team that there has been success in applying the sequential approach, by reason of the evidence that significant levels of town centre/edge-of-centre space are being completed.

Retail Data And Assessment Techniques

4.18 This part of our research is of less direct relevance to the sequential approach. However, the study has presented an overview of retail impact assessment (Section 7) and one important point is the appropriate circumstances for retail impact to be investigated. Where the sequential approach has determined a site to be a reasonable physical contribution to the successful future vitality of the town centre; it is questionable whether a full retail impact or capacity assessment should be undertaken. Therefore, decisions about the sequential positioning of new retailing are increasingly important, in order to perhaps curtail the amount of effort invested in retail capacity/impact exercises and to focus more closely on the physical manifestation of new retailing and other the commercial facilities and whether this ties in well with existing fabric in town centres, to the benefit of the long term vitality and viability of the centre.

Review of policies and decisions

4.19 Structure Plans and Local Plans consistently include a specific policy in relation to the sequential approach, and this largely incorporates elements of paragraphs 12 to 16 and 45 of the NPPG as they relate to the sequential approach. Policies tend to group compliance with the sequential approach together with other related issues including deficiency and vitality/viability issues. The Finalised Edinburgh and the Lothians Structure Plan elevates the sequential approach to dominate the two main general retail policies (RET1 and RET2), and the Plan specifically cross references the definition of 'centres' to the sequential approach.

4.20 Glasgow and Clyde Valley Structure Plan focuses more on the capacity for new retail development in defined centres with an integrated strategy which accounts for quantitative, locational and qualitative issues as well as relationship to the wider issues of supply and demand.

4.21 Local Plans similarly interpret the sequential approach in line with the main references in NPPG8, although wider interpretations are more in evidence. The Finalised East Renfrewshire Local Plan, for example, in addition to the standard policy seeking to protect town centres, includes a policy requiring major retail development proposals to be located in or "adjoining" specific town centres and there is no reference to the sequential approach in respect of these or alternative locations.

4.22 There appears to be limited differentiation between urban and rural locations in respect of the sequential approach, notwithstanding the concerns of many that such a differentiation is necessary. For example, the Finalised Orkney Local Plan includes a policy in relation to out of centre retail development broadly consistent with the NPPG8 paragraph 45 criteria, including the sequential approach.

4.23 There is no evidence from the Structure or Local Plan policies to suggest that authorities would prefer a specific distance to be stipulated in the definition of edge of centre, in line with English guidance. There is a clear preference for flexibility based on the individual circumstances of the case.

4.24 In relation to appeal decisions, the sequential approach is an important component in Reporters' and Ministers' decisions. The following points emerge:-

• the definition of edge of centre is regularly debated, and, in general conclusions focus on not only the distance between the application site and the town centre/primary retail core, but also the physical characteristics associated with the link between the two, the attractiveness of the experience and any visual integration;
• the potential of the application site to function as part of the town centre is a common consideration;
• there is evidence to suggest that new developments directed to established out of centre retail locations not currently recognised as centres in their own right are preferred to new free standing locations (Wallace Works, Perth; Halbeath, Dunfermline);
• disaggregation of proposals and formats has not underpinned appeal decisions in relation to the sequential approach, and there is evidence that Reporters and Ministers are reluctant to insist on disaggregation of, in particular, DIY and food proposals, to avoid the risk of diluting or losing the qualitative advantages associated with the proposals.

Transportation Issues

4.25 The overview by CBP on transport issues for this study has found that flexibility is required to take into account differing circumstances in different parts of Scotland on the sequential approach, as far as accessibility is concerned. The definition of edge-of-centre should not be too prescriptive to allow for specific circumstances to be taken into account.

4.26 Current guidance on Transport Assessments appears to suggest wider catchments being appropriate for walking distance (20 to 30 minutes or 800 to 1200 metres) than that used in many current assessments of town centre walking linkages for planning purposes. However, there are issues relating to the distance that would be give rise to linked shopping trips. In addition to walking, there is a potential to include public transport accessibility in the assessment of whether a site is "edge-of-centre". There are likely to be locations on major bus corridors and within easy walking distance of town centres that may be suitable for some sorts of development.

General Shopping Public Surveys

4.27 The selective review of shopping habits amongst the general public in the different Edinburgh, Glasgow, Perth/Kinross and East/West Lothian areas shows output in terms of linked trips for food and non-food (reported in the previous two sections). Linked trips is an issue which is at the heart of the sequential approach. From the surveys of shopping habits, it would appear to be appropriate to gear the sequential approach to other commercial activities such as financial/professional services and restaurants and cafes and leisure activities in and around established centres. However, the study team has to acknowledge the evidence here as being sporadic, from only a sample of surveys. It is suggested that further survey research is carried out into the shopping public, particularly on matters such as linked trips which will affect the future application of the sequential approach.

4.28 There is current debate in the planning profession about the compatibility of some modern retail formats which are too large to be accommodated under a rigorous application of the sequential approach. In terms of gauging household habits of the shopping public in Scotland, the study team believes that matters of new retail formats should be pursued further, by way of household shopping survey. For future retail policy, particularly on the sequential approach, it would be of great benefit to gain some updated information on urban and rural shopping habits throughout Scotland. In particular issues of whether the shopping public identify with the benefits of linked trips in established centres, by way of a full choice and range of retailing in different formats. Moreover, there are issues of whether the shopping public value some form of decentralised retailing in larger formats, using more spacious layouts, such as the display based large furniture units with the efficiencies of the flat pack dispatch. The major DIY and gardening outlets are other examples.

Public/Private Sector Questionnaires

4.29 The sequential approach was a difficult issue to explore directly through the questionnaire method. However, the research team used a multiple response format in Question 7 which asked for the level of agreement/ disagreement in terms of different statements relating to the sequential approach. The results for public sector respondents were:

• In defining 'edge-of-centre' most respondents were keen to follow 'easy walking distance to the centre' indeed, more than 20% suggested that 'any walking distance' could be appropriate. However, there were less than enthusiastic responses to specific dimensions in terms of metres (200 - 300 metres was specified) and some of the follow up comments suggested that much depends upon the kind of walking experience between the centre and the edge-of-centre site and also on the overall size of the centre in question.
• Other notable comments from the sequential approach question were the strong support for the sequential approach because the favouring of central locations helps town centres' vitality and viability.
• In addition, respondents backed the use of the sequential approach for leisure uses and believe that planning authorities have been flexible and realistic in seeking to allow development through the sequential approach. Nobody agreed that a lack of flexibility and realism by planning authorities might have discouraged some beneficial developments from going ahead.
• Finally, it is interesting to note a response of less than 40% in agreement when asked whether the presumption for central locations helps to promote an efficient, competitive and innovative retail sector.

4.30 There were some helpful indications for policy from the public sector responses. It appears that there should be a flexible approach to locational decisions based upon circumstances at the local level in terms of walking distance between proposed sites and the centre. There is a strong belief that planning authorities are making efforts to be flexible and realistic and there is some reservation on whether the whole approach helps to promote efficient competitive and innovative retail sector.

4.31 The private sector questionnaire raised similar questions on the sequential approach.

4.32 In the same way as the public sector questionnaire, Q7 asked the private sector respondents what their views were on various statements in relation to the sequential approach:

• There were high levels of agreement to the statement that planning authorities could be more flexible, realistic and proactive in promoting new sites in the future.
• A higher level of agreement was recorded for larger formats of some retail stores offering good retail and planning benefits, suggesting that planning decisions should be more flexible to allow for these formats.
• It was suggested that a lack of flexibility and realism on the sequential approach by planning authorities might have discouraged some beneficial developments.
• It was accepted that favouring central locations for development does help the vitality and viability of town centres.
• On defining the edge of centre, most respondents felt that any walking distance or 'easy walking distance' were the more appropriate measures, rather than defined dimensions in terms of stated amounts of metres from the centre.

4.33 There were some further qualitative responses on the sequential approach and respondents suggested that it might be over zealously applied, depriving some centres of modern facilities. However, others suggested that a less rigid application of the policy and a more open positive proactive role in promoting new town centre sites would help local authorities in seeing better results from the sequential test and other promotional initiatives.

4.34 Another important point from the private sector side was other reasons given for locational decisions on selecting sites on central or edge of central locations. Property investment criteria, proximity to other established businesses and readily available premises made available by a developer were all significant responses with approximately 40% believing these to be important. However, more than 40% also stated that compliance with the sequential approach policy was a key factor in locational decisions, as well as taking advantage of a site identified/ or allocated by a local authority.

Table 4.1 Locational Factors which affect site selection.

4.35 The Report of Survey Research also provided the client group with data which combined the public and private sector responses to the questionnaire. Q6 focussed on whether NPPG8 was a useful tool for guidance on key topics; more than 50% of the combined respondents found the guidance clear and instructive on the sequential approach.

4.36 The chart below shows the views of combined respondents on the sequential approach:

• "any walking distance" is agreed by more than 30% of all groups as an appropriate view on applying the sequential approach to new sites.
• "adjacent to the centre" (40%) and "easy walking distance to the centre" (more than 50%) are the more popular responses in providing a definition of edge of centre.
• Overall, more than 50% believed that planning authorities could be more flexible, realistic and proactive promoting new sites in the future. However, it is interesting to see that nearly 60% also agree that planning authorities have already been flexible and realistic and allowed some developments to be approved for good planning reasons.
• Overall, respondents felt that the preference towards central locations had helped town centres' vitality and viability.
• Respondents were less enthusiastic to measuring in metres, the definition of edge-of-centre. Overall, there was no outstanding view that authorities had been lacking in flexibility and realism (however, there was no response from the public authorities on this point).

Table 4.2 Combined views on the sequential approach.

4.37 The previous section (Tables 3.4 and 3.8) presented respondents views on different factors which can be used to define the physical extent of town centres. This is equally relevant to the sequential approach findings and it is important to note the predominance of public transport/focus of public activity and primary/secondary retail frontages as indicators to define centres.

Town Centre Managers

4.38 The town centre managers (TCM) discussion group and questionnaire revealed a neutral response in relation to the sequential approach. Respondents gave their answer in a neutral position between the view that sequential approach policy was clear/instructive or unclear/misleading. On further probing, the TCM group provided some further comments with regard to the sequential approach.

4.39 With regard to the sequential approach, the current policy was perceived as workable, although different interpretations were possible. These attitudes, articulated within the focus group, were supported by the supplementary questionnaires. In assessing new developments through the eleven criteria tests of NPPG8, 'satisfying the sequential approach' was perceived to have the clearest and most instructive guidance.

4.40 However, there were a number of areas cited that would benefit from further refinement. Greater precision and disaggregation in defining what constitutes a town centre would be valued. As an example, it was suggested that TCM could adopt a generic blueprint that could zone the town centre. This would take the form of an immediate core, outer core and expansion core. As a consequence, the boundary of the town centre could exercise flexibility to take account of spatial growth or format development.

4.41 In addition to issues of definition, allowing site flexibility was paramount. In some instances, city centre sites are considered to be more problematic relative to out-of-town. Consequently, if guidance is too prescriptive and makes direct comparisons to an out-of-town context, this could militate against development. Essentially, future plans need to take account of the physical constraints that may exist in town centres.

4.42 With regard to formats, a number of contrasting viewpoints were expressed. Some respondents indicated that the application of the sequential approach was dependent on the format; as an example, behavioural patterns and consumer preferences could limit the suitability of a DIY/bulky goods retailer in a town centre location. In contrast, with a good location and infrastructure, together with servicing points, it was contended that these types of retailers could find a compatible town centre site.

4.43 TCM respondents were generally in agreement that the presumption in favour of more central locations has been good for town centres' vitality and viability. They were also in agreement with the application of the sequential approach to leisure and possibly other commercial uses such as offices and business space.

Feedback From Discussion Forums And Interviews

4.44 The Stirling Forum discussed the sequential approach issue in some depth and the key issues are summarised as follows:-

• There was consensus between both the public and private sector representatives that flexibility was again necessary in relation to the sequential approach and in particular there was greater need for local discretion in relation to certain aspects;
• As an example, rural authorities should be more able to deviate from the accessibility by public transport agenda, as this may not be a key concern;
• Similarly, policy should take account of differing retail sectors and formats and the current approach requiring everything to be tested against town centre protection policy was unreasonable;
• The key starting point should be the consideration as to whether the town centre is the best location, or whether an off-centre location would be preferable for a particular form of development serving a particular community need;
• In relation to edge-of-centre definitions, it was felt that the specific distances defeated the purpose of the definition and there was a need to be intelligent and flexible in relation to how sites link together;
• Further research on linkages and their benefits was needed;
• The benefits of the sequential approach, however, enable town centre core areas to reflect local circumstances, and these may change over time as a result of edge-of-centre development.

4.45 At the Perth Forum, much of the debate inevitably focussed on Perth and in particular, the implications arising from the appeal decision to allow an extension of the St Catherine's Retail Park at the Wallace Works site. A key issue in that decision was the lack of suitable alternative town centre locations, and on this issue there was the suggestion that concessions should be made in relation to conservation issues to accommodate redevelopment opportunities in the town centre. Private developers should be encouraged to work more closely with local authorities in delivering these opportunities. This issue should be addressed imminently to avoid another St Catherine's Retail Park being granted.

4.46 At the Advocates' discussion group there was support for increased flexibility for local authorities in identifying town centres and for decision makers in assessing whether a particular site was edge-of-centre. There was agreement that the national guidance should enable local authorities to apply an approach differently depending upon rural or urban circumstances, and that blanket application across Scotland was inappropriate and inflexible.

4.47 The paragraph 45 criteria in NPPG8 were cited as representing a development control tool which was regularly repeated in Structure and Local Plans. These were considered to be too rigorous and prescriptive, and more discretion for individual local authorities was necessary. The greater reliance on the car for accessing shopping needs should be capable of being reflected, depending upon individual circumstances and this was particularly important in rural Scotland. The issue of disaggregation was not readily apparent in decision making in Scotland, and retailers have tended to make it clear that planning authorities either have to accept the format unchanged or not at all.

4.48 The solicitors' discussion group considered the sequential approach and suggested that this issue and indeed the approach to defining centres should be flexible and be capable of being applied differently depending upon local circumstances (most notably between urban and rural areas). The key issue was the likelihood of a site functioning as part of the town centre, and adding benefit. An overly prescriptive approach involving specified distances would defeat the overall purpose of strengthening the town centre whilst enabling new development where no opportunities existed to locate within the existing centre.

4.49 It was similarly important not to rigidly apply the sequential approach to differing formats of retail and the relationship between a retail warehouse park and a city centre was cited as an example where availability of alternative sites and impact were unlikely to be realistic concerns.

4.50 It was critical for the success of retailing in Scotland that policies should ensure that customers get what they want out of retail and not what policy wants them to get. A key example of this is larger format retailing, which is often difficult to locate in existing centres, but should this be a reason to resist changing formats?

Site Development Issues

4.51 From the study team's review of site development issues, it is apparent that the overarching issue is one of a need for greater effort and resource to be made available to local authorities and other agencies, to bring forward sites; but also a greater level of certainty as to which sites will be encouraged in policy terms. This suggests that the sequential approach should be adopted much more as an "advance - test" and a lead / facilitator to new development; rather than a "post-test", often applied with rigour to developments once they are tabled.

Sequential Approach - Implications For Policy

4.52 Our conclusions for the implication for future sequential approach policy are noted below:-

SA 1 A Sound Approach

4.53 The first overall conclusion for future policy is to suggest a continuation of the sequential approach as a sound approach to planning commercial development in urban areas. It is significant that 55% of respondents to the questionnaire found the sequential approach well versed in NPPG8 and clear and instructive. Further, 75% felt that the sequential approach was good for the vitality and viability of centres.

4.54 Although separate findings in this study suggest there could be a different approach to the definition of centres, once they are defined, the study team believes the sequential approach should be continued as a reliable basis for physical planning decisions.

SA2: Comfortable Walking Distance

4.55 Another key finding, primarily from the questionnaire surveys was the majority (more than 50%) of respondents believing that "easy walking distance" was the best definition to employ for the sequential approach and a significant number supported "any walking distance" dependent upon the quality of "place - linkages" between site and town centre. Whilst guidance in England and Wales makes reference to a dimension in metres, and certain policies and decisions have debated the issue of relative closeness; most of the main appeal decisions audited for this study have found that the final analysis is on the physical attributes of the walk between the proposed sequential site and the town centre. The physical aspects employed in the sequential decisions include barriers to ease of movement (such as road crossings), attractive environment, active frontages and security. This has implications for the actual definition of the town centre (see SA4 below).

SA3: More Flexibility And Realism

4.56 Overall, we have identified findings in this section that there is scope for an increased level of flexibility and realism, particularly from increased resources and activity on the public sector side. Some of this response was from the public sector itself, because of the lack of resources to promote town centre sites. Many respondents felt that the promotion of an efficient, competitive and innovative retail sector requires a great deal more investment in time and resource, to promote realistic sites in town centre and edge-of-centre positions. Equally, there will be a continued need for the development industry to use innovation and evolving formats, to answer the challenge of seeking central locations.

SA4: Physical Definition - "Blue-Lining"

4.57 Another key finding is the need for some clear guidance on the physical definition of a town centre and the area of potential for edge-of-centre development. Typically, local plans employ the proposals map coding of a blue line to delineate the town centre. Specific responses to the questionnaire, discussion groups and interviews have variously referred to primary/secondary shopping, key areas of activity, and public transport nodes/services, to help this definition. But the issue seems to be one of the firm and fixed nature of these lines. Various study sources have commented that a peripheral expansion area should be identified as an advance planning exercise, through a form of possible "blue penumbra" which shades areas where; subject to access, land availability and scheme viability, the planning authority would accept future development.

SA5: An Expanded Centre Cannot Be An "Impacted" Centre

4.58 Another key finding is the view that, once a decision is made to accept a retail development as a sequential site which can contribute to a future definition of the expanded town centre, then it is inappropriate to expend further resource and analytical time on the retail impact of that retail facility. Accepting a development as a contribution to an expanded centre should be sufficient to declare it as a competitive element within the centre, not a competing impact upon the greater centre.

4.59 However, there might be some caution to the expanded centre approach. Whilst this tends to be a sound approach in cases of non-food comparison floorspace growth; cases of food/convenience floorspace might raise issues of a new, sequentially-sited store, impacting on a store already located closer to the prime pitch and performing a strong role. This could simply result in healthy competition between the two, but in locations where there is a tight limit on convenience expenditure, there will have to be a cautious capacity/impact approach to assess whether a store at the more remote sequential site threatens to supplant the more proximate store.

SA6: Pre-Testing - Not Post Testing

4.60 The study has revealed a common practice of the planning authority setting the sequential test and awaiting candidates to present a case to be assessed. This is typically in the form of a tightly drawn town centre boundary and little guide on where expansion would be encouraged, with the analysis left open to the intuitive appraisals of the authority, after the birth of a development scheme. Investors, developers and retailers would prefer to see this appraisal work being carried out in advance, with a careful viability appraisal of sites and potential expansion areas ( see SA4/SA5 above).

SA7: Policy Parroting?

4.61 A frequent concern amongst "users" of development plans, and also those involved in advocacy and final decisions on larger cases have pointed to the common incidence of the NPPG8 sequential policy being repeated parrot-fashion in Structure / Local plans. This leads to debates at the decision stage as to what the national policy means by adjacent, or reasonable walking distance, rather than a more parochial debate about the merits of the case in question. This point links with other key findings on the theme of local discretion, to apply general national policy with an emphasis which fits specific local circumstances. The study team suggests that future national policy could set a context for the kind of local circumstances which might justify leeway at the local level (such as historic fabric constraint in some city centres and accessibility issues in more remote centres). One more immediate suggestion for future Strategic Development Plans is for criteria policies to be addressed at strategic policy level, with no requirement for Local Plans to restate them.

SA8: Format - Disaggregation

4.62 There is considerable debate from PPG6 south of the border on whether larger, more rigid retailer formats should be allowed to drift away from town centre / edge of centre sites, because of their advantage of scale / merchandise style. In this debate, there are firm opinions in stout defence of the sequential approach that larger formats of multi - offer under one roof should be disaggregated and built in separate smaller pocket sites around the town centre (in the leisure sector this has been likened to an extreme example of the single 10 screen multiplex cinema versus the separate location of 10 "mono screen" cinemas).

4.63 This study has not found a predominance of debate on this issue. In some notable cases, larger formats have generally been accepted in decentralised locations, through the survey returns, policy and especially the appeals reviewed in the study. This suggests that Scotland might be more tolerant of large retail formats and decisions have tended to look at the locational advantages of the proposed decentralised site for the larger unit and accepted the cases on its strengths in this regard.

4.64 On the other hand, a certain amount of presumption for town centre siting, and encouragement of different formats might have assisted in seeing the re-introduction of smaller convenience outlets in city centres.

4.65 The study team suggests that this evidence might result in a form of selective tolerance of larger store formats, particularly where the convenience of the proposed facility, or the bulky space-expansive display of goods might suggest a qualitative benefit to the shopping public. However, it has to be weighed against findings elsewhere (DC1 in particular) that fashion/comparison retailing remains as a high priority for town centre locations. The implication is a need to employ appropriate restrictive conditions on retail format in order to balance town centre benefits with large format advantages.

4.66 Another approach might be to assess the catchment draw of the large-scale shed format. Some have been established at a level that draws a supra-regional attraction, which has strategic (possibly national) traffic impact implications. A single highly successful modern format creating a national draw is evidence for introducing the same format at a number of more regional locations, thus reducing trip length and congestion and possibly locating the retail format in a sustainable centre, at the more local level. In Scotland, this evolving pattern has been seen with the likes of IKEA and Costco.

4.67 Another final point on larger formats is the possible regenerative/vitality and viability boost which can result from a larger unit being located as a new anchor store to an extended, or redeveloped centre, rather than in a free standing location. There is evidence in Scottish centres of larger convenience units forming a strong element in new centres and existing centres (Hamilton, Auchinlea, Springburn, Livingston, Edinburgh Waterfront, Dunfermline and Inverness all present examples).

SA9: The Urban Density Aspect

4.68 A final finding on the sequential approach is the future physical effect of applying a presumption in favour of central sites. With the conclusions elsewhere on the need to expect continual growth in retail and commercial developments and the need to improve development opportunities there is the resulting question of how this can be accommodated in centres which have already seen significant redevelopment and expansion. It is suggested that an outward spread of centres will evolve to show an upward spread in density and this might start to present urban design challenges, particularly in areas of strong heritage control.

« Previous | Contents | Next »