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

7. Retail Assessment Methodology

7.1 The original client Brief questioned the role of retail capacity/impact assessments and whether they are consistently used and applied, whether there was scope for further advice and whether NPPG guidance adequately addresses the issue of qualitative deficiencies.

7.2 Throughout the study, retail data and assessment techniques were raised in a sporadic pattern across different research tasks. However, much of the input to the desk and survey research reports to the client group was from the accumulated knowledge of the study team from general practice in retail planning and also from a closer understanding of key points raised in the study consultation, particularly in the face to face interviews.

7.3 Another key source of information was previous studies on retail data and assessment techniques. This section firstly gives a summary of previous studies, secondly a report of findings from the desk and survey research and thirdly our views on implications for policy.

Previous Studies

7.4 The Report of Desk Research gives a summary of the 1991 Drivas Jonas report on Retail Impact Assessment methodologies for the Scottish Office Environment Department in December 1991. This was a thorough research project looking into the purpose of retail impact assessment in terms of national policy guidance and the decision maker's requirements. It concluded with a preferred methodology which suggested that national policy should reaffirm the strategic role in Structure Plans in identifying areas of deficiency. It recommended greater emphasis on the presumption in favour of continuing to provide improvements to the range and choice of shopping facilities. It suggested that local authorities should request retail assessments only where there are clear risks to existing "important shopping centres".

7.5 In addition, the Drivas Jonas report recommended that planning authorities should monitor the health of shopping centres if they are identified of being importance to the retail system. The focus of retail assessment should be contained to examinations of vitality and viability of important centres, in particular those where there seems to be a serious risk of failure. There was also a call for greater clarity on key factors which define vitality and viability and the basic steps for quantitative assessment including final impact assessment through a criteria check list.

7.6 Finally, the Drivas Jonas report recommended a need for a closer look at the nature and extent of information held by various authorities and agencies with regard to retail floorspace and shopping patterns and to consider some form of central government based uniform system of regular data collection and survey.

7.7 The second study of retail assessment methodology was a more recent study for the Office of the Deputy Prime Minister (ODPM) in England and Wales. The ODPM study was being finally drafted as the Scottish NPPG8 study was under preparation. Most of the work on the ODPM Good Practice Guide was carried out in 2002 by CB Richard Ellis. Although CBRE has not finalised the report as a complete client submission, background on the case raised the following issues for good practice.

7.8 The work included a suggestion that different assessments could relate to different Regional/Sub Regional studies, Local Area based studies and Site Specific studies. These different approaches can be subject to scoping statements which can be consulted between the commissioning body and other interested parties.

7.9 Greater focus on the relevant factors in retail assessments (and leisure assessments) can assist good practice, including various components of need defined as deficiencies in the range and choice of retail/leisure facilities, capacity for additional facilities and the need to achieve sustainable travel patterns.

7.10 Advice towards a common approach has been appraised including some of the distinctions between methods used for retail impact and leisure studies. Typical key inputs include definition of study parameters, surveys of existing provision, understanding the performance of the local retail network, assessing the capacity for change and implications for policy. The ODPM work has continued, to look at a step-by-step process. It is understood that work on this study has now reached completion and it is suggested that the ODPM Good Practice Guide would be a useful general source for practice north of the border.

Findings From Desk And Survey Research

7.11 Other sources engaged for the current study included an important background legal decision in relation to a Scottish retail case. The City of Edinburgh decision (House of Lords: City of Edinburgh Council v. Secretary of State for Scotland Session 1997/1998, Lord Clyde and Others) involved a food superstore at Colinton in south Edinburgh. Although the final decision related to many specific elements of the case in question, the fact that it reached the House of Lords for a decision on the accuracy of a decision by the Secretary of State for Scotland gives it increased importance. Full details of the case are reviewed in the Report of Desk Research to the client group. However, the important points were the findings by Lord Clyde, that one of the material considerations in the case was the attention to quantitative deficiency and need. In relation to retail need, Lord Clyde concluded that need, in his view, was:

7.12 ' the kind of necessity which would, for example, justify the sacrifice of some amenity for the purpose of the development". However, he accepted that " quantitative deficiency is a concept different from that of need". He went on to analyse quantitative deficiency within the evidence available from the Colinton case. Whilst this necessarily involved the particular Structure and Local Plan policies and criteria checklists to be applied in this case, he concluded that quantitative deficiencies can be assessed by:

• trends in consumer expenditure;
• expenditure reflected in the turnover of the available shopping facilities;
• comparing the amount of shopping facilities and the amount of customers in the area;
• reference to stores in the area trading at a level which is above what would be expected of them.

7.13 However it was expected that the inputs and figures adduced to prove these various aspects of quantitative deficiency can lead to dispute, but the decision maker would have to rely upon the available evidence produced. The only danger, in legal terms, would be for a final decision to be rested upon judgements entirely at the decision makers' instigation, without the benefit of any evidence at all.

7.14 From this judicial case and other sources, the 2001 book "Scottish Planning Law and Procedure", (Jeremy Rowan Robinson and others) addresses the question of need. This source suggests that lack of need for a particular development is not a planning reason which would normally support a refusal of planning permission. In the Hambleton District Council case, the decision was made on the basis that an applicant for planning permission did not have to justify an unobjectionable proposal. Rowan Robinson et al., continue with the example of the prevalence of several betting shops in an area not generally providing a basis for refusing permission for a further betting shop and reference to one Reporter's conclusions which stated "interference with normal commercial competition is not a proper function of planning control". It is suggested that need should be proven in exceptional cases where a strong policy of constraint is in operation to prohibit further development because of possible harm to interests of acknowledged importance. However in conclusion, Rowan Robinson et al., use a phrase in NPPG1 (and now repeated in SPP1) that " planning policies and decisions should not prevent or inhibit development unless there are sound reasons for doing so". From this, the authors conclude that " in Scotland an applicant should not, as a matter of policy, have to justify an unobjectionable proposal".

7.15 Perhaps the above detailed legal analysis leads us away from the original question of retail impact and assessment methodologies. The study team in this case believe that various questionnaire responses reported elsewhere, discussion group feedback and individual interviews have shown that NPPG8 is considered to be unclear in the context of retail need, retail capacity and retail impact assessments. The study team believes that available information from previous studies and important decisions and analysis by those more closely connected to legal procedures give us the following conclusive points:-

7.16 As well as these legal sources, the study has also identified various references to retail assessment methodology. In the review of literature, in particular commentary by planning professionals, a recent article on the issue of retail capacity points to the fundamental problems with assessment methodology. This covers issues such as retail capacity assessments not reflecting what is taking place within the market place and the requirement for very accurate data. Retail capacity relies very much on average turnovers. However when it comes to different retail sectors there can be huge variations between average rates. The retail capacity assessment is based upon existing patterns of flow. The assumption has to be made that the patterns will remain constant or the figures have to be amended to plot future patterns. However due to the nature of the retail market it is constantly changing and very dynamic and therefore future patterns cannot be guaranteed. "In terms of assessing new development retail capacity offers very little. What is suggested is that retail capacity needs to be used with a number of other information such as health check indicators." ¹⁵

7.17 In the GVA Grimley launching of Retail Development Report for the Scottish Office one of the findings was that NPPG8 not only applies to retail development but other forms of development and this needs to be recognised ¹⁶. In particular not only retail impact assessments have been produced for mixed used schemes but there has also been a requirement for leisure impact statements. Problems have arisen however when it comes to leisure impact statements due to major leisure proposals, for example, a multi-plex cinema not being defined in planning guidance or legislation. The result is that information has to be used from consultants in England ¹⁷.

7.18 Turning to another area of our research, the review of Development Plan policy and a selection of important planning application and appeal decisions; there is clear evidence that local authorities are preparing Development Plans on the basis of retail studies undertaken in their local area.

7.19 Such studies often refer to the "capacity" for additional retail floorspace over the lifetime of the relevant Development Plan. A prominent example is the Glasgow and Clyde Valley Structure Plan, the retail policies within which are substantially founded on a large scale capacity study across the Structure Plan area. Similarly, at the local level there is much evidence of Local Plan retail policies emerging from retail studies which set out a capacity assessment across the Council area (e.g. Angus Council, Perth & Kinross, Dundee City). This approach is in line with paragraph 84 of the NPPG, although there is evidence that local authorities are interpreting the issue of 'deficiency' as quantitative need for additional retail floorspace over the plan period, with a limited reference to qualitative considerations in the form of health checks (as envisaged at paragraph 27 of the NPPG).

7.20 In relation to decisions, there is a substantial body of evidence to suggest that the "deficiency" criterion in paragraph 45 of NPPG8 has been interpreted as necessitating a demonstration of capacity or need, in quantitative terms, for additional retail floorspace in a catchment area (B&Q, Halbeath, Dunfermline). There is also evidence in the decisions of planning authorities that failure to demonstrate quantitative capacity for additional floorspace is sufficient to justify refusal, even in situations where impact on vitality and viability is not proven to be unacceptable. There are inconsistencies between the interpretation of the deficiency criterion and in particular the importance of understanding deficiency in both quantitative and qualitative terms. There is also some confusion surrounding the relationship between the deficiency criterion and impact and further clarification on this issue, possibility through best practice guidance, would, in our judgement, be welcomed by both operators and practitioners.

7.21 There is no clear common ground in relation to the issue at paragraph 45 of the NPPG which states "where there is considered to be no requirement for further developments, additional sites should not be identified in the Development Plan". This is interpreted by most local authorities as justifying assessments of the capacity and qualitative need for new retail developments in their respective catchment areas. Concerns are expressed on behalf of retailers and developers, however, that this statement represents the need to justify both in-centre and out of centre proposals, in conflict with the broad policy thrust of the NPPG to strengthen town centres. This issue is further re-established in paragraph 49 of the NPPG which requires "all applications for major retail development over 2,500 square metres gross retail floorspace" to be supported by retail assessment information. Structure Plans have strictly interpreted this requirement (Clackmannanshire and Stirling Structure Plan, Clackmannanshire Local Plan).

7.22 Other points emerging in relation to retail impact are summarised as:

• overall health of existing centre and its relevant vulnerability is a key consideration in understanding the implications of impact (B&Q, Halbeath, Dunfermline);
• the "like competes with like" principle being consistently applied, and significant impact upon a particular sector within an existing centre of limited material weight if that sector is of limited importance to the overall functioning of the centre (B&Q, East Kilbride; Cuckoo Bridge, Dumfries);
• the potential for retail units within an existing centre to close as a result of a new development is not, in itself, a justification for refusal if the proposal would enhance the retailing function of the centre as a whole (Port Glasgow).

7.23 From the review of transportation issues from CBP, it is noted that there is recent guidance on Transport Assessments at a national level but this does not give detailed consideration on particular issues relating to retail studies. There is a need to ensure that any retail and transport assessments are co-ordinated where possible. This is usually difficult because a retail assessment is concerned with transfer of spend from different catchment zones, whilst transport assessments generally are person-trip based and typically use gravity type formulations to predict trip generation. There is very little data on trips that combine multi-use facilities, or between different facilities within an urban area, and on the nature of retail trips to new developments, i.e. whether these are new or transferred trips. It is suggested that further research into these areas would be appropriate.

7.24 Relevant points from our questionnaire survey research include the public and private sector questionnaires, where respondents raised various issues in relation to retail assessment methodology. Key points from the public sector questionnaire were:

• The most direct response was part of Question 13 where the public sector respondents were asked whether there could be improvements in data sources to help assess retail/commercial development in town centres. An overwhelming 89% felt that more data was needed to assess these situations (Table 7.1 below). Only 7% believed there was adequate data available. From this, clear evidence that those involved in planning authority policy making and decision taking, require better level data for their activities (this is investigated in more detail in Document 1).

Table 7.1 The Need for More Data.

• In giving responses on the possibility of status being applied to new centres out with traditional town centres, a number of respondents referred to the need for a clearer policy on allocating planning status to particular centres, in order to assist with retail assessments for capacity and impact purposes (Section 3 gives details).
• Only 40% of public sector respondents found the guidance clear and instructive on qualitative/ quantitative deficiencies (Table 7.2). More than 50% of public sector respondents believed that the guidance was not very helpful on assessing scope/ capacity for new development and identifying deficiencies on qualitative and quantitative terms.

Table 7.2 Qualitative & Quantitative deficiencies

• The public sector respondents were generally satisfied (65%) with the helpfulness of NPPG8 in circumstances requiring retail/ transport impact assessments (Table 7.3).

Table 7.3 Retail / Transport Impact Assessments

• Respondents were asked about their views on the guidance in respect to testing the expansion of existing developments. Two thirds found the guidance helpful in this regard (Table 7.4).

Table 7.4 The Expansion Of Existing Developments

• It is interesting to note that nearly 60% of public respondents found that the retail development in their area in the last 5 years had primarily been made by way of planning applications, rather than led by development plans (Table 7.5 below). This suggests that there is still an onus on the applicant to justify new retail development by way of retail assessment, particularly if this is planning application led, rather than through quantitative assessments in development plan policy and town centre strategies.

Table 7.5 The Source of New Retail Development

7.25 From the survey of private sector practitioners there were mixed views.

• In response to Question 13 on whether there could be improvements in data assessments to help assess retail/commercial development, less than 30% felt that there was adequate data available and a significant 64% suggested there should be more data available (Table 7.6). Further opinions added in the questionnaire specified key topics: site availability, floorspace, household surveys, retail capacity, turnover, consumer spending and the land use character of different town centres. Several respondents called for more unbiased data to be collected and processed by central and independent sources.

Table 7.6 The Need for More Data

• Only 32% of private sector respondents found the guidance clear and instructive on qualitative and quantitative deficiencies and more than 40% believed that the guidance was not very helpful on assessing scope/ capacity for new development and identifying deficiencies on qualitative and quantitative terms. A quarter or private respondents gave no response (Table 7.6).

Table 7.7 Qualitative & Quantitative Deficiencies

• The private sector respondents were less satisfied (46% found the guidance helpful) than public sector respondents with the helpfulness of NPPG8 in circumstances requiring retail/ transport impact assessment on a combined basis. (Table 7.7) Less than a third of private respondents found the guidance unhelpful. However, again, a quarter of respondents made no response.

Table 7.8 Retail / Transport Impact Assessments

• A half of respondents found the guidance helpful in respect to testing the expansion of existing developments (Table 7.8 below).

Table 7.9 The Expansion of Existing Developments

• Private sector respondents were asked their opinion on whether most retail development had been made by way of planning application or development plan. The most remarkable outcome from this response was that only 7% of private respondents felt that development had been brought forward by the plan led approach (Table 7.9). Although there was a high 'no response' rate, 50% felt that development had been planning application led.

Table 7.10 The Source of New Development

7.26 From the discussion groups and interviews, it was apparent there were concerns in relation to quality of retail data available and the possible need for some kind of national survey. It was also stated that town centre strategies were absent in most local areas and these should be given greater prominence. There seemed to be confusion between deficiencies in qualitative and quantitative terms and some concern that local authority policy was increasingly based upon capacity assessments - to a greater extent than envisaged by NPPG8.

7.27 Some local authority representatives had concerns about an over reliance on private sector generated data and possible bias in retail studies. Differing opinions were noted on whether there is a requirement for a need/capacity test. Public sector participants believed a broad based capacity approach is necessary, the private sector would prefer capacity to be one of a number of wider criteria.

7.28 Specific points from interviews again included difficulties encountered by local authorities in defining an appropriate larger retail study area (when local authority boundaries do not necessarily match up to these retailing areas). Again, matters of reliable independent data were raised. Another key issue which helps to inform retail assessments is the list of centres which are considered to be of importance and the attributes presented by each centre, to help to define its position in the hierarchy. Interviewees also drew attention to the question of need and made reference to the Lord Clyde decision referred to earlier in this section; and how this has assisted in clarifying the position in relation to Scotland, where quantitative deficiencies can be assessed, but as part of a broader set of criteria.

7.29 There was a general view that there needs to be improved guidance on qualitative factors in defining important centres, vitality and viability and the actual meaning of a forecast impact on any centre.

Inputs And Methodology

7.30 During the course of the study, the comprehensive reports of Desk Research and Survey Research included various detailed sources. One key source was an assessment of retail appraisal techniques, including the key inputs and methodologies commonly used. Two schedules were presented to the client group. The first was a schedule of key inputs and the second a schedule of methodologies. This was compiled from the collective experience of the research study team. These schedules are reproduced in Appendix 4 to this report.

7.31 Appendix 4 includes Table 7.10 on the key inputs including catchment area, population, test years, expenditure, floorspace and turnover issues.

7.32 Table 7.11 in Appendix 4 is a schedule of basic methodology which goes into more detail on how to approach the study area, surveys of catchment areas, modelling expenditure scenarios, general capacity and measuring impact.

7.33 As a result of these schedules of key elements used in retail assessment, we are able to draw the summary points set out below, by way of the six key issues in this study.

Retail Assessment Methodology And Data Sources - Implications For Policy

• In relation to Issue 1 on General Retail Trends, it is vitally important for up to date reliable data sources to be available throughout Scotland on population levels, demographic change, expenditure levels, expenditure growth rates and surveyed patterns of household shopping behaviour. In addition, data sources on the performance of different retail centres, floor space levels and turnover can also be very useful in the analysis.
• In terms of Issue 2 on the Definition of Centre, it is becoming increasingly important for retail assessments to rely upon an accepted planning context (ideally through the development plan) and which retail locations are considered to be of importance to land use planning interests in any particular Local Planning Authority area. 'Centres of Importance' was also raised as a critical issues in the 1991 Study of Retail Techniques and it continues to be a vital input to a meaningful final analysis of capacity for growth and impact levels. For example, the severe impact level on a freestanding superstore might be considered fair market competition; but a new freestanding retail facility which is proposed to have major impact on its competitors who are located in central positions in an important town centre, requires a careful appraisal of impact.
• Issue 3 involves the sequential approach and retail assessment methodologies have to be linked to appraisals of other alternative sites which might be more suitably located in planning terms to serve an established centre more effectively. Another connected point here is the prospect of 'internal impact'. A number of commentators have raised the important point that, once a proposed retail scheme is accepted as being well located to contribute to the future vitality of a recognised centre there should be no need to over analyse the quantitative impact this has on the rest of that centre. This suggests that assessments of sequential location should precede requests for lengthy analysis of retail capacity and impact.
• Issue 4 deals with support for new development locations and in this context, links with the comments on the sequential approach above. It is important to note that bringing forward new sites as part of planning policy and town centre strategies can only help to obviate unnecessarily detailed retail assessment.
• Issue 5 on retail deprivation and access to retail facilities might become more relevant in future retail assessments. Many believe there could be improved guidance on the linkage between retail and transportation/ accessibility assessment. In view of other comments in this section on the selection of relevant/ important centres, it is likely to become more relevant in future to look at the impact of retail proposals, in terms of bringing improved retail facilities to more deprived areas of Scotland.

7.34 Issue 6 is the specific topic of retail assessment which relates to retail assessment methodology and we summarise our findings in the following paragraphs.

7.35 NPPG8 guides local planning authorities on the preparation of development plans and town centre strategies, with clear reference to the employment of retail assessment techniques:

"In preparing development plans, planning authorities should take account of the broad forecasts of retail demand, deficiencies in retail provision (if any) and how the retail sector is likely to respond to that demand over the plan period, by reference to location and type of retailing" (Para. 84 NPPG8).

7.36 The above guidance is linked to the encouragement of planning for development and change (para. 86) and the need to monitor retail developments, at para. 91.

7.37 In its guidance on the assessment of new developments, NPPG8 contains a requirement that developers prepare information to assist the authority in its assessment of the proposed retail development (linked to the criteria tests in Para 45 of NPPG8):

"In making an assessment, a broad based approach should be adopted. It should rarely be necessary to attempt detailed calculations or forecasts of retail growth or of changes in the geographical distribution of retailing, as even small variations in assumptions about trends in turnover, population, expenditure and the efficiency of use of existing retail floorspace can lead to wide range of forecasts. Parties should where possible agree data and present information on areas of dispute in a succinct and comparable form" (para. 50 NPPG8).

7.38 The two extracts above suggest there is a useful purpose in employing retail assessment techniques, but a risk in over-reliance on excessive detail, due to their inexact nature and employment of subjective judgement. The headings below draw our conclusions based on reliability, appropriate content / circumstances and suggestions for improved inputs.

Reliability

7.39 Retail assessment methodology will always be vulnerable to inexact outputs, due to the nature of the input raw data and the analyst's judgements.

7.40 The material earlier in this section has shown how the combined inputs of study area definition, expenditure, growth, turnover, and modelled future scenarios all lead to an inevitable divergence of possible outcomes. In addition, the analyst can employ a variety of methodologies, which can add to the variety of results.

7.41 However, with an understanding of the necessary cautions on retail assessment techniques, planners can still employ the methodology in order to create a quantitative framework which can act as one of the determining factors in forming development plans/ town centre strategies and in helping decisions on applications/appeals.

7.42 Planning policy formulation and planning decisions are commonly undertaken in a context of differing opinions/ interpretations on the key issues. There is some expectation that retail assessment should secure a fixed assessment based upon quantitative inputs, which are beyond question. The study team believes this is unrealistic in a planning context where all decisions are based upon a finely-balanced judgement on the relative merits of differing schools of thought. On the other hand, it is unreasonable to expect all retail planning decisions to be made in a vacuum, with no information on the balance of expenditure, turnover and floorspace in the relevant local area.

7.43 Our conclusive recommendations below attempt to sharpen the focus of retail assessment by looking at the appropriate purpose/ circumstances for a retail assessment and to look at scope to improve the inputs to the process.

Appropriate Purpose / Circumstances

7.44 Inputs and methodology are examined in detail earlier. There is concern in planning authorities and amongst the retail sector that the planning system can over-labour the process with inappropriate requests for analysis. Here, we are suggesting the appropriate purposes for retail assessments:

1. Quantitative Capacity - from the findings of Lord Clyde in the Colinton House of Lords case, the basis of NPPG8 para. 84 above and the feedback elsewhere in this study, it is clear that broad assessments of the scope for new floorspace (by looking at the balance of existing/forecast expenditure and turnover) can assist in gauging quantitative deficiencies and the case for new floorspace. However, from Lord Clyde, SPP1 and other legal references (Rowan Robinson et al), it is apparent that a case for the assessment of quantitative capacity is not necessarily also a place for a presumption against all retail development unless an over-riding need is proven. National planning policy in Scotland makes it clear that a need does not have to be proven for an unobjectionable proposal. From this we suggest that retail assessments of quantitative capacity are appropriately placed to assist:

• Development Plans - in exploring a broad framework for an area's current and future expenditure levels, surveyed shopping habits, turnover levels and scope for floorspace growth. This should be done with regard to the dynamics of retail change, which can be measured by survey and from other data sources and in consultation with the retail sector.
• Town Centre Strategies / Interim Assessments - if the development plan has not been prepared with a parallel strategy for the centres in the area, or if current trends are suggesting that the development plan is becoming dated, a town centre strategy or interim appraisal might be required and a quantitative capacity exercise will be appropriate.
• Case for a Proposal - evidence from Document 2 of this study shows from the reports of our surveys that a high proportion of respondents believe that most retail development has not been brought forward by the development plan in the last 5 years, it has been planning application- led, in response to developers' perceptions of market demands, retailers' knowledge of popular formats and shoppers' demands. Therefore there must be an appropriate place for quantitative capacity assessments in the demonstrating the case for new retail proposals.

  2. Quantitative Impact - our second recommendation of appropriate circumstances for the use of retail assessment is to link the quantitative capacity assessment through to an assessment of the changes to the turnover levels of existing, committed and planned floorspace. This is commonly referred to as retail impact testing, but there is concern that retail impact assessments can fall short of a full and informative picture, or that they can be inappropriately targeted. It is our conclusion that impacts should be tested against a clear and well informed, up to date policy context on those retail/mixed use centres in the area, which are considered to have important status for good planning reasons. It is less relevant to have concerns about the impact of one freestanding store on another, and it is questionable whether an increase in floorspace at one location in an established centre should be tested for its "internal impact " on other floorspace in the centre. We suggest that quantitative retail impact assessment is an appropriate tool for:

• Testing Retail Strategy - linked to the point above on development plan and centre strategies, it can be useful to model the impact of possible floorspace/turnover growth scenarios on existing floorspace. This context is also relevant for questions of whether an unusual amount of turnover increase in one centre might upset the local retail system, through its competition with other centres. This might lead to some consideration of whether this is a level of "upset" worthy of planning concern, or "market change" best left to the market and to the natural forces of competitive place which prevail between centres (see interpreting impacts below).
• Case for a Proposal - where the proposed new location is not within, or well related to the identified/protected locations in the policies. It will be relevant to assess whether the new facility causes a challenging change for the centre - or a harmful impact upon it (see below).
• Interpreting Impacts - assuming the retail assessment has been employed with the purpose and circumstances noted above, the end result will face the planning policy / decision maker with a judgement on the impact resulting, and whether this is an impact which is better interpreted as a competitive challenge, or an impact which is raising concerns on planning interests of acknowledged importance. The following criteria will be important in this judgement:
• List of Important Centres - noted in the approved / adopted policy for the area, in order to focus on those impacted centres which are relevant in planning terms, and appropriate cases for closer investigation of the impact;
• The "Category Exposure" - of the impact e.g. is it an impact of convenience turnover on the convenience turnover of the centre? - if so, is the impacted convenience turnover of the centre the mainstay of its overall turnover, or a small fraction of a much larger non-food retail presence? Other variations can be the impact of a furniture-only store on a centre that has a broad range of retailers and is not solely reliant upon furniture retailers.
• The Health of the Centre - is a key consideration and should be assessed through a detailed appraisal of evidence on the vitality and viability of the centre. This might lead to evidence that the existing centre is frail or failing, due to the absence of the kind of retail facility as proposed outwith the centre. Alternatively, it might reveal a healthy centre that can sustain impact.
• Impact as One Consideration - the final judgement will have to take the identified impact and set it alongside various other issues such as the likelihood of the proposed format being accommodated in the centre, the possible land use, economic, transport and other benefits of the tested proposal, etc.

  3. Qualitative Issues - a factor of equal importance throughout all retail assessments should be a parallel analysis of qualitative aspects which affect retail patterns in the urban area and vitality and viability of centres. Vitality and viability indicators are clearly set out in Figure 1 of NPPG8 and these arise from previous research which has assessed appropriate indicators for the measurement of town centre performance. In addition, further measurements are employed by town centre managers and chambers of trade.

  Furthermore, as noted elsewhere in this study, the qualitative aspects of household shopping habits are increasingly important, in the view of the research team. Regular surveys can reveal details of the shoppers' attitudes towards retail offer in the existing centres, the depth and range of goods, the level of ancillary services and other keys factors which affect the quality of the centre, such as car parking provision, environment, late hours trading and other factors.

  These qualitative aspects all link back to some original themes in the 1998 issue of NPPG8. From paragraph 28 onwards, there is a clear reference to the use of indicators to show whether a centre may be at risk and the importance of responses which make better use of resources and address major deficiencies. A multi-disciplinary strategic approach is recommended which " should aim for a realistic vision for the centre, drawing on the support of all interested parties and an action programme that mobilises resources and promotes effective town centre managers". Particular attention should be drawn to the availability of development opportunities, land assembly, diversity of uses, transport, attractive environment and effective management and promotion of the centre. Improvements in quality and competitiveness are favoured, over policies which seek to preserve the present shopping hierarchy.

  These are all important qualitative aims and they link to the preparation of a town centre strategy which, elsewhere in this report has been highlighted as a key area for improved policy guidance and enhanced levels of activity amongst the public and private sector alike.

  In summary, the research team concludes that further guidance should be prepared on town centre strategies, site development opportunities, measuring qualitative aspects and the overall importance of vitality and viability in the assessment of impact on key centres of importance. In addition to a clearer focus through the quantitative approach, it is suggested that improved inputs on the quality side of the equation will improve final decisions and policy -making.

Improved Inputs

7.45 The preceding points have looked at what retail assessment should involve and when it should be deployed. The Institute for Retail Studies has carried out detailed work on retail data requirements. IRS believes that the data available for the understanding of Scottish Retailing is inadequate. At its most basic, policy is being proposed for retailing without any true understanding of the sector and its dynamics. We do not know accurately how many shops there are in Scotland, how they are performing or how their performance has changed over recent times.

7.46 This is not to say that data are not present in the system as planning authorities, consultants and academics have carried out various research activities over time. Official data sets have some of the data which could help our spatial understanding of the retail sector dynamics. Health checks are meant to be performed by town centre managers on a regular basis. Public inquiries and other major applications for development have associated impact and other studies. However, there are a number of problems in collating data from these sources such as coverage, inconsistency, confidentiality and availability.

7.47 The cover of Scotland in terms of surveys is incomplete. Different questions asked and the ways in which they are asked differ and are often inconsistent. Many consultancy reports are confidential including some officially collected data which is deemed commercially sensitive. In some instances, data are not available for the study or have a large price tag or, in some cases, are routinely destroyed after their immediate purpose has been served. If nothing else, it would suggest that there is a large degree of duplication and waste in the system and value for money is not being obtained at the national level.

7.48 IRS make a number of suggestions to help the situation, to gain a better understanding of the retail sector in Scotland:

• serious consideration should be given to the reinstatement of a Census of Distribution for Scotland. This would be legally enforceable and provide the sort of data that, until 1971, guided our understanding of the dynamics of change and retailing.
• IRS suggests that the Scottish Executive should fully fund the GIS developments being undertaken by the Centre for the Study of Retailing in Scotland (CSRS - HTTP://www.csrs.ac.uk/) which will provide an accurate benchmark for knowledge about the retail sector.
• A fixed agreed timetable and standard of data collection for town centre health checks should be proposed and monitored. Results of the health checks should be published and the raw data should be archived. Local Authorities should also be encouraged to follow set data collection approaches for their own areas when commissioning surveys and again they should be responsible for archiving raw data.
• Central collation of these various studies in a repository would be beneficial to our understanding of the sector in Scotland. Impact assessments, town centre healthchecks, consumer surveys etc could be made centrally available, possibly via the CSRS or other independent bodies.

7.49 From the review in this section and drawing from the interviews, surveys and discussion groups; the points below highlight some of the important inputs to the process and how they could be improved, in order to sharpen the focus of retail assessment:

7.50 Floorspace - there are problems with reliable data on retail floorspace in existing centres. There could be more research done on how planning authorities might be required to utilise Assessors' records and to mount a local survey (say every 5 years) to update on local convenience, comparison and other commercial floorspace in centres. Proposed new floorspace should also be centrally recorded when proposals are made, consented and built.

7.51 Turnover - depending upon the methodology used, turnover can either be an output of looking at modelled flows of spending, or calculated by applying a turnover density to unit floorspace. Either way, it is useful to have some national or area-based core data on average shop turnover per sq metre. Unless a fresh Census of Distribution is investigated by government, this kind of data is restricted to national agencies analysing the company reports of the larger retailers. But there is also a need to try and record local levels for independent shops. It would assist if national policy placed a requirement (rather than an expectation) on local authorities to carry out some interim sample surveys to seek information on local trading performance. This would have to allow for the fact that each trader has the right to maintain confidentiality but it could use bracketed averages and invite retailers to record the general band which they trade within.

7.52 Surveyed Flows/ Dynamics - judgements about the flow of trade draw and the market penetration of a retail facility are best informed by a recent record of surveyed patterns of household shopping. Retail assessments should be encouraged to employ this evidence, in order to inform the trade flow judgements and assist in the impact modelling of trade diversion. If this became a requirement of national policy, it is likely that a number of survey companies would look in detail at carrying out such surveys on a regular basis and making the data available to authorities and consultants for the purpose of retail analysis.

7.53 Critical Centres/ Relative Roles - as noted throughout this section, there is an increasing level of confusion regarding the rather "monocentric" presumption in NPPG8 where it is assumed there is only one single centre in any area. Many believe that guidance should be requiring a look at "polycentric" retail systems and encouraging a more modernised look at the various retail-based locations in the urban area, and the relative status of each location or centre. This would allow a sift of those centres which are afforded greater status and therefore protection for sound planning reasons, and a clearer focus can be placed on the use of retail impact results.

7.54 Impact Focus - once the relevant "impact centres" are clarified, it would assist the process if the guidance noted the different ways in which impact can impinge on a centre. As noted earlier, the category exposure of the impact is important, whether the recorded level is an impact on the centre as a whole, or on only one stratum of the overall turnover.

7.55 Vitality / Viability - another key impact focus is the actual evidence of strength / weakness of the centre itself and this can be assisted by vitality and viability measurements. These are itemised at para. 27 of NPPG8 and other research studies have expanded on their measurement and relevance (The URBED 'vital and viable town centres' study followed the publication of PPG6 and various other articles and studies have referred to measurement techniques).

7.56 The various measures detailed in Figure 1 at Paragraph 27 of NPPG8 are still very relevant and useful. However, we suggest that further best practice guidance on vitality/ viability indicators could be useful in future impact assessments and Town Centre Strategies, in particular for the promotion of centrally located sites and expansion opportunities in the relevant centres.

7.57 An overall conclusion from the above appraisal is the opportunity for Scotland to embark upon some form of national geographic database, to capture some critical information on the location of retail, Class 2 and Class 3 uses, their special characteristics, size and pattern of distribution. Efforts are being made to break ground on this kind of data capture through IRS. Recent work has completed a comprehensive geographic information system and it is suggested that further advances could be made through GIS, as an overall framework to gather spatial characteristics of the retail sector. Ultimately, this kind of data will be as important as national basic data inputs, discussed above.

7.58 Scottish Retail Planning Sources - all of the above points of clarification suggest that improvements in detailed inputs will help future retail assessment. In addition, it is suggested that, at a national level, it should be possible for the Executive to try and collate a central library of retail source material. Although this would have a funding/resourcing implication, it would serve to improve the quality of analysis of one of the most dynamic and important sectors in the Scottish economy. It might be possible for a central data source to be collated independently through an academic body, or a data agency and the study team encourages consideration of the recommendation above, that the CSRS be approached to collate central data and to build on its existing on-line bibliography. The kinds of information that could be stored, accessed and analysed include:

• a required spare copy of each retail assessment presented with a planning application / appeal.
• copies of household surveys carried out in support of policy reviews or retail proposals.
• returns from planning authorities on retail floorspace being proposed, permitted and rejected.
• floorspace, turnover and any other source material from update surveys.

7.59 It is likely that the controls for requiring this data will have to be appraised. Local authorities would probably need to be formally required to contribute the information and some retail developers could legitimately claim the information as their own possession. But the general idea behind this suggestion is based on data which is placed in the public domain through consultative policy making and decision taking, but so easily lost into obscurity after the exercise is complete.

7.60 This is the limit of our desk research and general advice on retail assessment methodology and input data. We are aware that the broad range of this study and its focus on the main NPPG8 issues has limited the discussion of retail assessment issues. It will prove useful for further work to be done on the suggestions raised above and the forthcoming finalised CBRE Good Practice Guide on Retail Methodology for the ODPM should provide a useful source. In addition whilst IRS has contributed to this section on retail data sources, it has various other ideas for useful sources and collation of information, which could be expanded in further work.

7.61 A final comment on the limits of this study is on the absence of a specific look at using similar quantitative methodologies for the assessment of other uses that are considered to be important in town centres. The boom in commercial leisure activity has seen the sequential approach coming into play and some efforts to give a broad indication of market potential for the likes of multi-screen cinemas, but they have not been subject to the same detailed inputs and analysis as retail uses. Likewise, some believe that other commercial functions such as offices/business use should be encouraged in town centres, but there is no established methodology to look at capacity and impact in this context. We believe that other responses shown in Document 2 of this study are important primary sources, which show differing views on the importance of other non-retail uses in centres. It will be more important to form a general policy view on these uses, before attaching a general requirement for capacity and impact testing.

Retail Assessment - Summary Of Implications For Policy

7.62 The assessment set out above in the paragraphs on reliability, purpose/circumstances and improved inputs gives a detailed overview of the study team's views in terms of implications for future retail policy at national and local level. The headings below summarise our main findings on these implications.

RA1 - Centres of Importance

7.63 A repeated theme throughout this study has been the need for a fresh approach to all the centres in a given urban area and a survey approach which selects the centres of importance to future urban planning. This point was made in the 1991 Drivas Jonas study and it is equally important today. Retail assessment techniques and impact assessments are much better informed if it is quite clear which shopping centres are being analysed as potential recipients of the effects of retail impacts.

RA2 - Better Data

7.64 Overall, the study team believes that various sources of retail based information could be dramatically improved across Scotland through some form of national and independent data sourcing. The centre for the study of retailing in Scotland has been noted in this regard. Earlier, it was also recommended that some form of national household survey on retail patterns would be a useful continuing exercise. Copious information and data sources are produced in relation to retail proposals on an annual basis that there could be an arrangement in place to capture this information and record it for future use.

RA3 - Capacity/Scoping/Impact

7.65 The complex issue of retail assessment has been summarised in this section as an exercise which still has a relevant place in modern retail planning. However, the study team has concluded that retail assessment techniques can sometimes be "over utilised" without benefit to final decisions. In summary, the implication for future policy is to guide retail capacity assessments to look at the overall scope for new floorspace in producing Development Plan strategies. However, quantitative capacity is also a topic which can be assessed by the private sector in assessing the scope for new retail facilities in an urban area. In this regard, the background assessment of legal sources suggests that, in Scotland, the last five years of NPPG8 has proved no obvious requirement for a "need test". From one seminal judicial decision, and other sources, it is suggested that, whilst there might be a place for the assessment of quantitative deficiency, scope for new facilities and impacts arising; there is no overriding evidence to suggest that all retail proposals in Scotland should be subject to a first test of need. The frequent comment from the market is that this stifles the essential dynamic of allowing all retail formats to at least present their case for qualitative capacity and qualitative improvement. To presume a first test of need can too easily be interpreted as a first presumption against development.

RA4 - Impact - The Actual Implications: Quantity and Quality

7.66 There is a call for greater focus on the relevant centres to be tested, updated information on their vitality and viability and a closer look at the actual implications of an estimated level of impact which is often only expressed in trade diversion terms. Evidence produced earlier shows a low level of return, in terms of town centre strategies and vitality and viability health checks. These are critical areas to a full understanding of the land use implications arising from a calculated impact assessment. It would greatly assist future planning decisions and town centre promotion, to have an increased level of importance placed upon the preparation of strategies for the key centres and vitality and viability assessments on an ongoing basis. Future guidance should make a clear definition of the relative importance of quantitative and qualitative factors. Central government should address a comprehensive new national system of capturing critical data on a geographic basis, in order to accurately measure shopping quantity and quality.

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