Scottish Government

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

8. Summary of Implications

Additional General Implications

8.1 In addition to the various implications drawn from the previous six sections related to the main six topics, there are further areas of the study research which have presented additional General Implications noted below.

GI - 1 - Overall Effectiveness of NPPG8

8.2 One of the more sweeping questions in the private and public sector questionnaire was the effectiveness of NPPG8 in its various criteria for assessing new developments. Specifically, the eleven criteria stated at paragraph 45 of NPPG8 were noted. Table 8.1 (below) graphs the combined respondents views on the effectiveness of NPPG8 criteria for assessing new developments. The table demonstrates that higher levels of positive responses (stating that the policy was clear and instructive) were given for the following criteria:

• Local amenity;
• compliance with other important land use policies;
• consequences of traffic increases;
• public transport access;
• Development Plan strategy;
• the sequential approach.

8.3 However, areas where the response was less robust included the following criteria:

• Qualitative/quantitative deficiencies;
• Design

8.4 From this, the implication is that issues such as design and qualitative and quantitative deficiencies might need further guidance. There was also a more neutral response in relation to aspects such as environmental effects, choice of means of transport and vitality/viability.

Table 8.1 Combined Views on the effectiveness of NPPG8 Criteria

8.5 As an additional point, it is interesting to compare the responses of public and private sector respondents concerning the helpfulness of NPPG8 in advising on action required for Structure and Local Plans. The charts below (Table 8.2)shows that 97% of public sector respondents answered that NPPG8 was generally helpful, whilst only 46% of private sector respondents thought that it is helpful. However, the study team suspects that, whilst local authorities are quite clear that they must proceed to prepare Development Plans which contain retail policy; there was significant feedback which suggested that Development Plans simply repeated national policy, without detailed regard to local circumstances.

Table 8.2 Structure and Local Plans

GI 2 - Supplementary Guidance

8.6 From paragraph 54 onwards of NPPG8, there are various types of retail and leisure developments specified. The combined results of the public and private survey are presented in Table 8.3 below. It can be seen that generally, less than 50% of respondents felt that these particular development types had high relevance to effective supplementary guidance. The guidance on Retail Parks was the only guidance which was valued highly by over 50% of respondents. Various qualitative comments in the questionnaire accompanying this question noted that different sectors including restaurants, amusement centres and financial/professional services have suggested that a fresh approach could be taken to retail frontage policies in city and town centres. In particular, a closer look at the level of activity generated to the street frontage to different uses and whether the use actually causes higher levels of impact on local amenity.

8.7 Further, there seems to be some evidence that combined commercial leisure schemes, factory outlet centres/shops and retail warehouse clubs are unlikely to see a major surge in activity in the foreseeable future. It might also be questioned whether food discount stores and retail parks in particular require specific guidance, as the level of development activity in these sectors has possibly passed through the boom stage.

8.8 Some of the study feedback has referred specifically to forms of development where policy needs to be updated. This mainly emerges from particular references made in discussion groups and interviews, by individuals who are close to specific issues through policy and decision making:

• New regional shopping centres are unlikely to be tabled as free-standing new centres in the future. The weight of planning policy on sustainable location and land use now sets a context where regional shopping centre developments are only likely to emerge as redevelopments of existing locations, or perhaps as centres of large urban growth areas.
• Specific reference to new district centres highlighted the difficulty in applying a suggested floorspace maximum (paragraph 56 of NPPG8 refers to 30,000 sq. metres gross). In particular, it was noted that new district centres would be defined in a relative context, dependent upon the size of the main city/town centre and other small centres in the local area.
• It was noted that, whilst there was specific reference to food discount stores, NPPG8 gave no specific guidance on convenience based large superstores. Some respondents suggested that specific guidance on convenience retailing, where there is less scope for expenditure growth, would be appropriate.
• The most frequent comment in relation to retail parks was the need for a stronger policy approach in future, to the conditional allowance of bulky goods retailing in retail park formats. Some recent developments have had unrestricted growth in fashion based retail sheds. It was suggested that this form of retail park threatens opportunities for fashion goods to be encouraged in existing centres and, perhaps in a better quality out-of-centre format.
• In relation to discount centres and factory shops, the emerging trend seems to be away from the factory outlet centres, and more towards a "tourist related retail" particularly along Scotland's major holiday and leisure routes. Some developers/operators and local authorities alike have made comments about a possible allowance for a restricted amount of tourist related retail, where this might provide benefit to local tourist activities.
• In terms of leisure facilities, the market for co-location of leisure/retail park formats has subdued with a more recent pattern of in-fill leisure developments in urban areas.
• Restaurants/pubs, etc., continue to innovate on format and location and not always in central locations; but there is some hesitation on rigorously applying a sequential approach to a restaurant/pub facility. In particular, there may be circumstances where it might provide benefit at a roadside location and be otherwise unobjectionable in planning terms. In addition, public house establishments raised the issue of separate control under licensing procedures and the need to review whether planning control is simply duplicating amenity controls under licensing.
• Amusement centres have apparently met with greater levels of acceptance in central locations and, subject to satisfactory amenity controls some types of amusement centres might be unobjectionable and not necessarily requiring a generally cautious and negative policy stance in future guidance. Another linked comment referred to betting establishments, and the need to update guidance on planning and other forms of control on these outlets.

8.9 The general implication for supplementary guidance is a suggestion that future national policy might benefit from a shorter format, without a detailed typology of different present and possible future retail formats. It would be more efficient for other national sources such as Planning Advice Notes and other background monitoring exercises to keep up to date with retail formats and to provide commentary on their content, trading style and locational implications. Table 8.3 helps to provide a summary of combined public/private responses on specific formats.

Table 8.3 Supplementary Guidance

GI 3 - Urgency for Review

8.10 As the charts in Table 8.4 below show, there has been a mixed response from the separate public and private sector audience groups on the type of review of NPPG8 which they think is necessary and the timescale for this review. Key points are, however, that only 17% of the public sector believe there is scope for an overhaul, with the rest of this audience group suggesting that there is no need for an overhaul or a need for clarification/fine tuning. Overall, public sector respondents think that the timescale for any review should be in the medium/long term. In relation to the same questions, 42% of private sector respondents believed that there was scope for an overhaul whilst 37% felt that there is scope for a rolling review. There is therefore a greater degree of enthusiasm among the private sector for changes to be made to NPPG8 than there is in the public sector. However, once again, the most popular timescale stated for any review by private sector respondents was medium to long term.

8.11 The implications for the kind of review and urgency for review strongly suggest that; whilst there is no immediate call for a complete overall of NPPG8, there is a view that it requires clarification and fine tuning and also evidence to suggest that a full review might be appropriate in the medium term. This obviously leaves matters for interpretation. However, the study team suggests that points of clarification and fine tuning could be addressed within the next 12 months and this period could also be used define further areas of specific research and assessment which will help to inform a review of NPPG8 which the study team believes should be undertaken within the next 12 to 36 months.

Table 8.4 Overall views on the need for a review of NPPG8

Implications From Sections 2 To 7 - Summary

Status for General Changes in Retailing - Implications for Policy

8.12 The literature review, assessment of retail profiles, floorspace data and survey returns revealed a number of indicators in terms of general changes in retailing:

• GC1 - The Strong Retail Sector Requires an Increased Profile
• GC2 - Dynamic Retail Sector Requires Constant Monitoring
• GC3 - Cyclical Development Activity - Acknowledge Future Development Patterns.
• GC4 - Accessibility a Key Issue
• GC5 - Multi-Locational Dimension - Managing Succession / decline
• GC6 - General Attitudes - Polarity
• GC7 - Re-Energise Retail Planning - Town Centre Improvement Fund?
• GC8 - Shoppers' Views - a Rolling National Survey?
• GC9 - Broader Dimension?

8.13 The common themes emerging from the general changes in retailing are a requirement to promote a stronger understanding of changes in shopping, leisure and other key activities which relate to our urban centres. In parallel, the study team is advising a higher recognition not only in land use planning, but also in socio-economic and political circles for a strong retail based sector in Scotland. The higher profile in central and local government thinking will bring forward the issue of competitive place in our urban areas, to the benefit of town and other centres which can serve the community well.

8.14 Alongside this increased profile and better understanding is a need to accept further technical inputs which will address accessibility as a key issue and also the multi-locational dimension of retailing. This will entail a need to carefully manage the succession of centres which will thrive in future and also the managed decline of retail locations which have not succeeded.

8.15 Another associated area which gives concern is the apparent polarity of opinion between public and private sector. To an extent, this is perhaps an endemic pattern of one side finding some fault with the level of commitment or lack of flexibility with the other side; and perhaps this is to be expected in some measure, due to the complexities of public policy and market forces. However, much of the general opinion noted in this study has been negative and the study team believe that the overarching priority should be to inject fresh energy into exercises which positively promote town centre vitality and viability, thus the recommendation for a town centre improvement fund which brings an element of annual activity to assemble competent bids for significant improvements to the physical fabric of key centres in the hierarchy.

Defining Centres - Implications for Policy

8.16 From the analysis of desk research, and various survey research sources, there is ample evidence to suggest some key implications for policy on defining centres in the future. This was a key area of the client brief at the outset of the study. It was interesting to see some of the key facts revealed in the implications for policy.

• DC1: Centres Must Have Credentials
• DC2: Multi-Locational Dimension
• DC3: According status/importance
• DC4: Taking Stock - An Audit Of Centres/Locations
• DC5 - Accessibility: "Key Sites" and the Urban / Rural Distinction
• DC6 Absence Of Town Centre Strategy/Vitality And Viability Studies
• DC7 NPPG8 - Specific Weaknesses
• DC8 Lack of Clarity: Edge of Centre

8.17 The eight implications above have some overlap with the general change findings, in terms of the multi-locational dimension and an increased importance for urban centres in terms of status and recognition in the land use system. Further details emerge on the need for technical exercises to take stock of the different centres in any area and to carry out an audit of appropriate locations through observation of present and future retail based development.

8.18 An overriding finding, which will have a bearing on various recommendations in Section 9 is that the definition of centres must rely upon "a list of credentials" for a centre to prove that it can perform well as a sustainable location for the good of the shopping public through a healthy mix of uses, strong transport connections and other key factors, including car parking.

8.19 Again, accessibility emerges as a salient issue and recommendations refer to the importance of identifying "Key Sites" (as already defined in Scottish Executive research and now employed in national policy) and to address the important issues of car parking provision and allowances/constraints in relation to the use of the private car. There is also the clear distinction between urban and rural factors and the suggestion that future policy could be interpreted more closely to local circumstances, particularly in rural areas.

8.20 The key area of concern, which is highlighted elsewhere in the report is the absence of activity on town centre strategies and vitality/viability studies.

8.21 Finally, some specific weaknesses were observed from the questionnaire returns, not only in the preparation and promotion of town centre strategies, but also guidance to town centre management efforts, the identification of town centre sites, promoting an efficient and competitive retail sector and the promotion of design quality and an attractive environment. In addition, the definition of centres depends upon more clarity in relation to "edge of centre" and this relates to the sequential approach and site development findings elsewhere.

Sequential Approach - Implications For Policy

8.22 A key issue for the research was to obtain feedback on the application of the sequential approach, whether it is a competent device for guiding locational decisions and whether further clarity is required. The implications are as follows:-

• SA 1 A Sound Approach
• SA2: Comfortable Walking Distance
• SA3: More Flexibility And Realism
• SA4: Physical Definition - "Blue-Lining"
• SA5: An Expanded Centre Cannot Be An "Impacted" Centre
• SA6: Pre Testing - Not Post Testing
• SA7: Policy Parroting?
• SA8 Format - Disaggregation
• SA9 The Urban Density Aspect

8.23 The primary finding is the general support for the sequential approach as a sound method of guiding locational policy and decisions. However this general support will increase its effectiveness in future if it is related to the earlier findings on the definition of centres.

8.24 More specifically, a practical approach to the connectivity between sequential sites and the main centre is promoted through the responses in this study. Rather than a direct dimensional measurement of walking distance, there is general support for a "comfortable" walking route between a proposed site and a centre.

8.25 More flexibility and realism is encouraged on both sides of the public/private sector context. On the public sector side, the greater flexibility appears to be required through greater resource commitment and an improved skills base, to promote town centre opportunities, improve viability for potential future sites and to make attempts to apply the sequential approach as a pre-test, rather than as a post-test, i.e. preparatory efforts to inform the development industry of appropriate sites on the edge of centres. It is recommended that the physical definition of centres could be subject to the usual "blue line" delineation; but a further shadow area of potential development would be encouraged, in order to indicate appropriate locations for future retail and commercial expansion.

8.26 Another issue from the sequential approach is the common theme of repeating national policy to the word in Development Plans. This is evidence for a more flexible application of policy at the local level and this is highlighted elsewhere.

8.27 Another key theme emerging from the sequential approach is whether larger scale formats should be forced to disaggregate into smaller units in order to accommodate available premises or pocket sites around existing centres. Whilst this might be appropriate for the main stream fashion goods which are encouraged in the findings from the definition of centres; it appears that decisions in Scotland have been more tolerant of some of the convenience and bulky goods formats for out-of-centre locations. Indeed, some of the convenience formats have been developed in locations adjacent to centres which have been in need of redevelopment, expansion or regeneration. Alongside the findings on the "credentials list" from the previous heading, there appears to be an acceptance that bulky DIY, carpet, furniture and garden centre goods are appropriately located in larger units which might not be ideal candidates for sequential sites, and this appears to be supported from recent evidence from appeal decisions.

8.28 Finally, the sequential approach implications point to a continued future trend for further development in and around existing centres. As a result, it is unlikely that centres will continue to expand "laterally" with a single storey sprawl of ground cover. A key implication for future policy is the urban design aspect of increased density, as mixed uses are encouraged on the remaining available sites or redevelopment plots within centres. This is likely to have implications for massing, density and height of future developments in key centres.

Support For New Development - Implications For Policy

8.29 From a close look at the activities throughout Scotland on supporting new development and around existing centres, some important implications emerge for policy:

• SD1 - Sequential Site Identification Prior To Submission Of Proposals
• SD2 - Best Practice Guidance Required For Site Development Issues
• SD3 - Reference Required To The Use Of Compulsory Purchase In Site Assembly
• SD4 - Annual Register And Review Of Potential Retail Sites
• SD5 - Review Section 189, Town And Country Planning (Scotland) Act 1997
• SD6 - Streamline Compulsory Purchase Process

8.30 A number of the site development findings provide overlap with the earlier implications. It is clear that an advance exercise for sequential site testing would be appropriate, along with some fresh guidance for site development issues, in addition to PAN59 on town centre improvements. This recommendation is allied to the further implications for compulsory purchase methods to be used in site assembly, an annual register and review of potential sites and a streamlining of processes.

8.31 Overall, the study team believes that all of these issues highlighted from a review of town centres could also apply to other areas of land use planning on the identification of "effective sites". As density increases in Scotland's urban areas, it is likely that further supplementary guidance on site development viability issues, site assembly and other technical inputs will be a useful overall tool for effective urban planning.

Retail Deprivation - Implications For Policy

8.32 The findings from the assessment of retail deprivation are as follows:

• RD1 Strong, Dynamic and Prolific Sector
• RD2 Accessibility
• RD 3 - Deprivation -Need for More Precise Analysis

8.33 Although the original brief asserted that there might already be evidence of deprivation throughout Scotland in terms of retail provision, this study has not found wide spread evidence at the national level of falling activity, in terms of new retail formats. There is a strong dynamic and prolific sector and some evidence from existing household survey of the population generally finding retail and other services accessible except perhaps for the most remote rural areas.

8.34 However, the study has recommended a more focal analysis of some more key urban areas which may be displaying high levels of socio-economic deprivation, and whether their level of accessibility to modern mixed use retail facilities is improving.

Retail Assessment - Summary of Implications for Policy

8.35 The other view of retail assessment has summarised the following implications for policy:

• RA1 - Centres of Importance
• RA2 - Better Data
• RA3 - Capacity/Scoping/Impact
• RA4 - Impact - The Actual Implications: Quantity and Quality

8.36 The subject of retail assessment provided scope for a more thorough analysis which could have been subject to an entire research study. However, from the overview and key points of feedback this study identified the need to provide techniques of retail assessment which continue to be employed by practitioners throughout Scotland. This focus is best targeted at exercises of quantitative capacity for Development Plan policy and for testing new proposals. The study team does not believe that a first test of need is appropriate. This tends to intimate a general resistance to any new retail development. Whilst it is accepted that the planning system has a proper place to filter retail development schemes, techniques of retail assessment should still be appropriately employed, to measure scope for new development and the impacts which it will have upon a well defined list of centres of importance in the urban system.

8.37 The results of this approach are to recommend a clear audit of the centres of importance, such that retail impact exercises can be set in an appropriate context, rather than risking considerable time and other resources on analysing irrelevant impacts. In line with this is a call for significant improvements to base data at a national level, possibly on a geographic information basis. It is suggested that a central, national and neutral data source could be established which would capture various source material as it is presented in the retail sector in Scotland. In addition, it is suggested that some form of ongoing national survey of shopping habits would greatly assist future planning policy formulation in Scotland.

8.38 In parallel with the retail assessment recommendations which apply to quantitative aspects; there is the equally important dimension of qualitative measures. By its nature, quality is more difficult to measure, but the vitality and viability indicators in NPPG8 continue to have an important input to final decisions and the assessment of the actual implications of impact. Allied to this is the need to look at sequential sites, and efforts to improve town centres. Critically, this links back to the need to re-invigorate activity on the promotion of town centre strategies. With a clearer picture of the current health of the town centre, its future projects, programmes and budgets, the decision maker has a better guide to the actual implications of impact on a particular centre.

Additional Implications

8.39 Although the six defined study area topics have gathered most of the key implications from the Desk and Survey Research, additional implications were highlighted from the survey questionnaire in particular:

• GI 1 - Overall Effectiveness of NPPG8
• GI 2 - Supplementary Guidance
• GI 3 - Urgency for Review

8.40 The assessment earlier in this section in the General Implications shows that the overall effectiveness of NPPG8 records a view that the policy is generally clear and instructive across a number of key areas. However, qualitative/quantitative deficiencies and matters of urban design were highlighted as less robust with a suggestion that further guidance on best practice and policy would be appropriate. In addition, it is suggested that the typology of different kinds of retail format included towards the end the existing NPPG8 is now less relevant and with some refinements to policy on specific issues this could be removed, but accommodated in some form of supplemental frequent monitoring of retail trends in Scotland.

8.41 In terms of the type of review and urgency of review, the study team have concluded that refinement/fine tuning is appropriate within the next 12 months and from 12 to 36 months, it would be appropriate to look at a review of NPPG8 with some of the more fundamental points in this study being addressed in a 12 to 36 month period. The future format should work on the basis of a leaner SPP and further, better focussed PAN advice in support.

Conclusion

8.42 To conclude the summary of implications, it is useful to refer back to Section 1 which sets out the overall study methodology (and Appendices 1 and 2). From the 11 key tasks of research (desk and survey exercises), the study team believe that there has been a thorough review of opinions, facts and other sources which help to inform the six key topic areas identified for the study.

8.43 From this section's review of the implications for policy, it is clear that there are over lapping themes and repeated issues.

8.44 Section 9 brings these themes together in the form of specific recommendations.