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

10. Strategic Recommendations

10.1 This conclusive section of the study presents some final strategic recommendations. As noted in the previous section, there was repetition of similar themes between the various implications drawn from the six different areas of the study. In assessing these implications, the study team has identified the 12 detailed conclusions in Section 9, which we suggest are appropriate for more detailed consideration within the Scottish Executive Development following this study.

10.2 However, we believe that common themes within the various detailed conclusions can be drawn together into six final Strategic Recommendations; which are overarching implications for the Scottish Executive. We present these below, with reference to key points from the original client brief and the study team findings.

Strategic Recommendation 1: Introduce a New Approach to "Urban Centres"

10.3 The original client brief raised questions about NPPG8 guidance and whether it should apply to non-retail uses, the balance between retail and other attractions, and the integration of a leisure component with new proposals.

10.4 These issues have been thoroughly addressed in Section 2 and 3, through the review of general retail changes and issues affecting the definition of centres. There is clear evidence of a continued competitive trend towards new development formats which increase retail floorspace. However, retail pipeline data, responses from questionnaires and discussion groups have revealed that much of the development activity can still be proposed in "single use" format. However, Section 3 introduced various charts which showed a wide spread opinion, that various different functions make up the vitality and viability of a sustainable centre. Main stream fashion, public transport, car parking, other commercial uses (food/drink/banks, etc.), and civic space lead the list. Residential, tourist, convenience retail and leisure venues also feature quite strongly as important uses to the vitality and viability of town centres (Table 3.10).

10.5 The study brief also enquired about the status of existing out of centre developments and whether or when they should be regarded as town centres. In the questionnaire, more than half of the private sector respondents and a quarter of the public sector respondents believed that well established shopping locations outwith town centres should be afforded town centre status. In addition, much of the interview and discussion group feedback suggested a fresh approach could be adopted, which introduces an audit of all centres in urban areas, assessing their long term sustainability. The study team have recommended that this can be carried out by way of the list of credentials presented in each centre, in particular accessibility, mixed use and the efficiency with which the centre serves its surrounding catchment. The study is recommending that certain, more successful centres, where significant infrastructure investment has been made could be allowed to expand and diversify in order to build up a critical mass and this, in turn should attract improved public transport access and other desirable land use and transportation advantages in the long term.

10.6 The study brief also enquired about the future role of smaller town centres and district, neighbourhood and suburban centres. It was noted that many of these centres, by virtue of their location or catchment area have limited prospects for significant change . The study team has found evidence from general trends, defining centres and issues relating to the sequential approach and support for new development; that some centres will thrive, whilst others will struggle to survive. The latter category will continue to be subject to the notion of "managed decline" already highlighted in NPPG8 (paragraph 32). The study team believes that a fresh approach to assess all the centres in an urban area will inevitably result in some locations being reviewed, in terms of their long term sustainability and qualification for protection through planning policy. Rather than a managed decline; it would be more appropriate to suggest that these centres will be subject to managed change, by way of alternative land use policy allocation, encouragement of alternative uses such as residential, business and other functions.

10.7 Another implication will be the challenge presented for retail locations which might be under-performing on public transport, mixed use, etc. A development plan approach which rewards the evolution of a centre (by way of adding improvements to transport, mixed uses, civic space, etc.) should present a challenge, for individual centres to respond to, by adding improvements to facilities over time.

Strategic Recommendation 2: Launch a New Profile to Promote Town Centre Initiatives

10.8 Another key point from the original client brief was the adequacy of support for town centres and the realisation that many centres still have some way to go to ensure that retailers and market expectations (in terms of size and type of retail units) are being met. In addition, the shopping experience has to keep pace with consumers' and retailers' expectations. The brief questioned whether there was a need to address further measures and actions to improve town centres.

10.9 As noted, in particular from detailed Recommendations 3, 4 and 5 in the previous section, there is clear evidence from this study to launch a new profile to promote town centre initiatives.

10.10 Section 2 of this report has highlighted general changes which clearly demonstrate that Scotland will see continued competition between centres in urban areas to provide for the growing level of household expenditure, particularly on non-food shopping and recreation and culture. As noted above, this process will inevitably lead to pressures amongst competitive places and the need to promote the centres with the strongest elements to serve the community well. However, general responses from this study's questionnaire in particular have found an overall negative attitude towards retail policy in the last five years. When probed, much of this response is due to the frustrations in achieving physical results in existing centres, by way of identifying and developing sequential sites and allocating sufficient resources to realise development opportunities.

10.11 Section 4 noted various locational factors affecting the private sector's selection of more central sites and factors such as property investment, proximity to other businesses, premises being made available in suitable locations and a proactive planning policy to promote sites all feature as important. Section 5 produced a telling review on the support for new development. In particular, specific strategies to promote individual town centres, through environmental improvement, identification of development sites, vitality/viability monitoring and other exercises were not in wide spread evidence. Only 38% of public sector respondents recorded that they had been involved in town centre strategies in the last five years. For the private sector, this was only 7%. Against this, NPPG8 makes it quite clear at paragraph 33 that planning authorities should adopt a proactive role towards town centre change and improvement, working in partnership with retailers and other parties.

10.12 The study team has investigated this lack of enthusiasm and positive activity on focussed town centre strategies and, particularly from interviews, it appears that there is a call to provide greater resource and energy and planning and development expertise, in order to promote town centres.

Strategic Recommendation 3: Sequential Sites - Improved Guidance

10.13 The original study brief focussed some of its principal objectives on the extent which developers and planning authorities have demonstrated flexibility and realism in applying the sequential approach. It was questioned whether it is realistic to expect developers and retailers to change normal formats. In addition, the brief questioned the definition of edge-of-centre and the form of linkages between proposed new sites and town centres.

10.14 Section 4 of this report has focussed on the sequential approach. It was found that this had been subject to much discussion amongst property and planning practitioners. The positive sign is that this discussion is fuelled by continued activity in trying to secure central sites. Data on the retail pipeline shows continued pressure for various kinds of retail formats. However, the last five years has shown significant levels of town centre and edge-of-centre space being completed, in parallel with continued pressure for decentralised locations. The review of Development Plan policies and decisions has shown regular debate on the definition of edge-of-centre, and the questionnaire surveys revealed various different views. Table 4.2 in particular highlights key findings from this study in relation to the sequential approach:

• The sequential approach is basically sound in favouring central locations for the future vitality and viability of centres.
• Overall, planning authorities have been flexible and realistic.
• However, in future, there could be more flexibility and proactive promotion of new sites, by planning authorities.
• The linkages to the centre from a sequential site should be judged by way of an easy walking distance. Specific comments from interviewees and discussion groups suggests that this should be linked to the local environment, major road barriers, attractive pedestrian routes which allow safe passage between the proposed site and the centre.
• Specifying the definition of edge-of-centre by way of a measured dimension is inappropriate.
• Whilst every effort should be made to try and accommodate main stream fashion formats in town centres, there are some other bulky goods or convenience based formats which are more appropriately located in larger units, offering economies of scale, accessibility benefits and possibly a decentralised site which creates another urban location which can be sustainable in the future, by reason of accessibility, mixed uses and other benefits.
• There was some evidence that favouring central locations for development might constrain the development of an efficient, competitive and innovative retail sector.

10.15 Throughout the study, there have been dichotomies between the natural inclination of the public sector to be cautious of some of the effects of unrestricted development growth and on the other hand, strong views from the private sector that various flexible forms of retailing should be allowed. This polarities of opinion has been evident in this study in relation to the sequential approach. However, the basic finding is that the approach is a sound method to allocate land use and to promote the future of sustainable centres. However, future changes to planning policy should perhaps be more focussed on the physical layout of existing centres and the scope for growth. The study has found that a rigid "blue line" definition of a town centre is too restrictive, and there is scope to provide for some kind of "blue shading" which identifies areas for extensions of town centres.

Strategic Recommendation 4: Transport for Shopping - Reappraise Key Trends/Patterns

10.16 Access to shopping was the key point highlighted in the original client brief. It questioned whether current retail patterns lead to some communities having inadequate provision and where the guidance should give emphasis to the social impact of new retail development. The role of retailing and supporting urban regeneration was also noted, as well as particular guidance on rural shopping.

10.17 The study has grouped most of these points under the heading of "Retail Deprivation"; but has presented this more as a question. Overall, the study finds little evidence that Scotland has seen falling trends in retail provision, particularly in the urban areas. The retail pipeline data shows increased levels of space being proposed through the planning system in the last five years. The feedback from discussion groups and other sources does not suggest that this is all being channelled to specific, more affluent areas, leaving deprived areas without new shopping facilities. However, the study has recommended a more precise geo-demographic analysis.

10.18 From other indicators already available through the Scottish Executive household survey, it appears that more remote rural areas are showing high levels of accessibility to the use of the motor car and also recording sound levels of satisfaction, in relation to access to shopping and community facilities.

10.19 Moving away from the question of retail deprivation in social terms; one of the key aspects of household survey evidence, national travel patterns and other sources gathered in this study is the continued use of the private car, often at off-peak times, for shopping purposes. In particular, this relates to the weekly incidence of convenience goods shopping trips, but also for non-food purchases.

10.20 In areas of public transport provision is more abundant, there is clearly a higher incidence of public transport usage for shopping purposes. The study team believe that significant efforts should continue, particularly in the larger urban areas, to improve public transport provision for shopping based trips.

10.21 However, there is evidence to suggest that policies of constraint on the private motor car for shopping purposes can cut against the clearly expressed preferences of the shopping public. This is one of the points which could be addressed through a more regular household shopping survey, rolled out on a national basis (as noted in implication GC8).

10.22 The study team believes that further detailed assessment could be made of current patterns of accessibility, popularity of different modes of transport, modern household lifestyle issues and convenience of accessibility and car parking. The latter point in particular has drawn attention to the transport specialists within the study team. It is suggested that the car park charging (and possible urban tolling) constraints which are normally applied to the traditional town centres, are absent in the decentralised locations and this might be an issue for "level playing" policy in the future. This point could be linked in the list of credentials identified earlier.

Strategic Recommendation 5 - Advice Note on Retail Assessment Data

10.23 The original client brief raised the role of retail capacity/retail impact assessments and whether they are consistently used and applied. It was questioned whether further advice was required, particularly on the issue of quantitative deficiencies.

10.24 This point has been assessed in detail in Section 7 of this study, with the following key findings:

• Scottish policy does not place a requirement on developers to prove a first test of retail need. From appropriate legal sources, existing policy and significant appeal decisions, it is apparent that quantitative retail assessment has an appropriate place in assessing capacity, deficiency and critical impacts. However, there is no national requirement to prove need, before a retail proposal is progressed.
• The questionnaire responses in this study record a strong call for improved data sources, to analyse retail issues. In terms of methodology, whilst there is general satisfaction on the linkages between retail and transport assessments; respondents were less satisfied on assessing capacity for new development and identifying deficiencies on qualitative and quantitative terms.
• The vast majority of development in the last five years has been brought forward by planning applications, rather than by a Development Plan led approach.
• The various implications identified in Section 8 and detailed recommendations in Section 9 indicate the need to refresh national guidance to reflect appropriate circumstances for assessing both quantitative and qualitative scope for new retail. There should be clearer guidance on the quality indicators, such as vitality and viability measures, and a closer focus on centres of importance, for impact assessment. In addition, it is noted that new sources of national data collection should be promoted. Ideally, a Census of Distribution would establish a fairly sound basis for future retail planning in Scotland. At least, there could be some of national data collection, including annual household survey returns, and an improved basis for geographic information systems.

Strategic Recommendation 6: Short and Long Term Changes to NPPG8

10.25 The focus of the study brief, was to assess the continued application of NPPG8 as a basis for retail planning. The study team was not required to redesign NPPG8, nor make exacting recommendations in terms of specific changes to the existing text. The client group preferred to be informed on general issues and areas for future improvement, if NPPG8 is updated at a later date.

• However, during the course of the study there were inevitable references to specific points in relation to NPPG8. Whilst there were some calls for immediate overhaul, the majority of respondents felt that, whilst there could be immediate fine tuning, an overhaul might be a medium term solution.

Overall Conclusion

10.26 The study team has appraised all the aspects of the brief and has defined six key issues for investigation. The detailed report on these issues is presented in Sections 2 to 7 of this report. Each section concludes team is most grateful for the extensive participation, commentary, detail and input to the questionnaire returns, discussion groups, interviews and other exercises involved in this study, and for the strategic guidance from the Client Advisory Group.

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