Scottish Government

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

9. Conclusions

9.1 The analysis so far in this report has adhered to the study team's approach to the six key areas of issues, as set out in Sections 2 to 7. Various implications emerged from the analysis of these issues, as summarised in Section 8 and it is clear that there is significant overlap in the various policy implications.

9.2 In this section, common implications have been clustered, to draw 12 key conclusions for the Scottish Executive Development Department to consider as part of a practical overview. These conclusions include the main findings and also detailed recommendations emerging from the study.

Key Conclusions

9.3 This section should be read in conjunction with the flow chart presented in Appendix 5. This flow chart has been prepared as follows:-

• Listing all the implications for policy which were summarised in Section 8 (vertical column).
• Making a horizontal dimension, to introduce the study team's defined 12 areas of detailed conclusions.
• A matrix exercise, whereby each recommendation is justified on the basis of "connection points" with the implications for policy. Graphically, this shows the sourcing of each conclusion and the clustering of different issues emerging to justify the key finding or recommended action.
• The conclusions are covered in this section. The strategic recommendations are dealt with in the next section.

9.4 We deal with each of the detailed recommendations in the headings below.

Conclusion 1:Revisit National Policy Objectives

9.5 The first conclusion is for the Scottish Executive Development Department, in consultation with other departments of the Executive to address national policy objectives for town centres, urban centres, accessibility, mixed uses and other key points which will shape future national policy.

9.6 The flow chart shows that a fresh approach to national policy objectives is justified by a number of "GC" implications, from our appraisal of general changes. The increased profile and constant monitoring of a strong retail sector and a need to understand a cyclical development activity, along with accessibility, new locations for commercial activity and their status all point to a need for central government to reassess the policy context.

9.7 Specifically, the study team believes there is scope for a higher profile for government policy for the future of urban centres in Scotland. This needs to link to other areas of central government activity such as:

• The Cities Review - placing an emphasis on quality of life, civic improvements and recapturing population growth in urban areas.
• The continued promotion of an efficient, competitive and innovative retail and commercial sector.
• Policies which guide development towards "competitive places". The activities of Scottish Enterprise are important in this regard and there can be increased linkages between their efforts to promote economic renewal and a higher position in national policy for the future town centres and urban locations for various commercial and other uses.
• Efforts to improve the quality of our living environment through the promotion of good design, efficient transport systems and improved public realm.
• In a similar way to the notable increase in profile for transportation issues in recent years at central government level in Scotland, the study team recommends that town centres and the emerging broader theme of multi-functional urban centres should rise up to the national agenda for a stronger level of debate and resource commitment.

Conclusion 2: Redefine "Town Centre"

9.8 The second conclusion overlaps with the proposals in Conclusion 1. Traditionally, central government policy has referred to "Town Centres and Retailing". From various findings in the assessment of general changes in retailing and the definition of centres, there are key implications for future policy on defining "town centres".

9.9 The flow chart shows the different implications which relate to this conclusion, including various points on general changes in the sector, as well as the multi-locational dimension of centres in urban areas and the need to address status and levels of importance for different centres for future planning policy. This will require an audit of appropriate centres and locations according to their strength of function and future retail capacity assessments will have to contribute to this exercise.

9.10 Specifically, implication GC9 posed the question of a broader dimension for future policy to cover retail, financial/professional, restaurant/pub, etc., leisure and other uses (see next conclusion).

9.11 This study has made various references to the future growth of urban areas in Scotland benefiting from a pattern of inter linked sustainable centres which assist in providing the best quality of mixed provision in accessible locations. This approach to "polycentric" urban areas suggests a new approach which embraces a more positive policy towards multiple locations, particularly in the larger urban areas. This moves away from the "monocentric" tone of the previous NPPG8 guidance. It suggests that future SPP guidance can move from looking at a notional single town centre, to a broader context of sustainable, accessible and viable urban centres of importance, which will make a positive contribution to urban planning objectives.

Conclusion 3 New Guidance on a List of Credentials

9.12 Conclusions 1 and 2 tend to raise the question of how to apply a planning methodology, for the selection of important centres which will sustain Scotland's urban areas in the future for the best quality and quantity of provision.

9.13 This study has found clear evidence of the potential for a new approach which should take a careful look at the attributes or credentials of a centre to qualify it as a location of importance for future land-use policy.

9.14 A number of the implications for policy from our chapter on defining centres show clear evidence that future centres must have a quality of provision, infrastructure, use mix and other facilities which demonstrate the credentials for sustainable policies to protect their future. The result of this will be the necessity to accord status/importance to different centres, perhaps in differing degrees, accordingly to the local planning context. Future development plans will have to take stock of the various locations around the urban area and audit these to assess their suitability for future protection and encouragement. One of the key inputs to this exercise will be a survey of each centre's vitality and viability and its land use mix.

9.15 It is recommended that future SPP guidance seeks to review the glossary of terms and definitions in relation to town centres and to ally this exercise more closely with the contributing factors which qualify a sustainable centre.

9.16 As noted earlier in the report, one of the implications of this approach will be not only to promote and enhance the future of selected centres (see next conclusion); but also to pay regard to the natural process of decline in some other shopping-based locations in the urban area. Development plans will have to be selective about resource commitment to appropriate centres, but appropriate alternative land use, masterplan and design guidance will have to be employed in promoting the redevelopment of locations which are unlikely to thrive as retail centres in the future.

Conclusion 4: Re-energise Town Centre Planning Activity

9.17 One of our specific detailed conclusions is to create a surge in activity by the public and private sector, to promote town centres as efficient, competitive and innovative locations.

9.18 The six key areas of issues for this study have all presented implications for the amount of energy, resource and enthusiasm to promote new development and positive change in town centres.

9.19 The current NPPG8 makes frequent reference to the fact that local authorities should promote town centre strategies and other promotional activities and this is encouraged by way of reference to less desirable forms of retail development emerging, if town centre efforts are not progressed.

9.20 However, the study team believes that much more resource and vigour is required, to re-energise the retail based sector into higher levels of competitive activity to prove town centres as appropriate locations for future development. The study team has suggested an annual bidding process for a "town centre improvement fund". It is suggested that this could be a yearly round of bidding, for appropriate schemes which promote specific development sites, environmental improvement projects, accessibility improvements and other appropriate town centre management and promotional efforts. In the same way that the integrated transport fund has reinvigorated urban infrastructure planning, the town centre improvement fund could also promote a much more positive context for future activity.

Conclusion 5: Stronger Requirement for Town Centre Strategies and Vitality/Viability Studies

9.21 The conclusions above point to a future policy context which encourages a closer scrutiny of the performance of various centres throughout Scotland.

9.22 However, it has been noted from the study that there is a low level of activity in relation to town centres strategies and vitality and viability studies, in order to constantly gauge the performance of centres.

9.23 It is recommended that a stronger requirement is placed upon local planning authorities and others in partnership, to promote the continued assessment of vitality and viability and the preparation of town centre strategies. It is suggested that this increased activity could be significantly encouraged by the town centre improvement funding proposal in Conclusion 4.

Conclusion 6: Sequential Approach - Reasserting with Clearer Definitions

9.24 The sequential approach was a specific area for this research study and all the implications for policy point to the continued use of this approach as a sound basis for land use planning in town centres. Therefore, the study recommends the continued use of the sequential approach in future policy. It can be reasserted as a key element of land use policy, but definitions could be clarified:

• A flexible approach to the definition of "a comfortable walking distance" would be appropriate for future policy. This should observe the overall size of the centre in question and the existing experience of pedestrian movement between central anchor facilities and secondary/tertiary areas. A large city centre shopping experience usually engenders a more involved level of activity with greater distances covered between facilities, compared with a smaller town experience. Decisions will have to be made based upon the size of the centre, the physical and environmental opportunities/constraints to movement and a qualitative view on the comfort and amenity of walking routes between the site and the centre.
• More flexibility and realism on the part of both the public and private sector interests should be promoted. More resource commitment to the identification of appropriate sits on the public side can be matched by more flexibility on future retail formats on the private side.
• There appears to be some scope for larger bulky format retailing, ideally in sustainable central locations, but not necessarily in the prime town centre, if sites are unavailable and if the proposed format can be conditionally controlled, in order to stem a migration of mainstream comparison goods away from town centres.
• The physical definition of centres will be increasingly important with the "blue lining" exercise for town centre definitions to be augmented by a shaded area for appropriate areas for extension.
• It is suggested that the sequential approach is too often applied after a development proposal emerges. Pre-testing of sequential sites would be preferable, along with a closer look at site infrastructure, viability, etc.
• It is also recommended that future policy recognises the acceptance which should be given to a development which is judged to be part of an expanded centre. Too often, there is excessive analysis of the impact of a development which will, in itself, be part of the centre.
• There is frequent comment that a national sequential approach policy is repeated too precisely at local level and there should be scope for more local interpretation of policy.
• Finally, in future there could be an urban density aspect to further sequential policy. The outward spread of town centres could transform to an "upward" implication in terms of densities, height, mixed uses, etc.

Conclusion 7: New Supplementary Site Development Guidance/Statute?

9.25 This conclusion poses further questions for central government policy, as a result of various findings on the definition of centres, the sequential approach and, in particular on site development issues. The latter area of our research presented some key implications for policy. These included the need for best practice guidance for site development issues, a clearer focus on the use of compulsory purchase in site assembly, a register and review of potential retail sites and a potential to streamline compulsory purchase and other procedures.

9.26 The study team believes that many of the site assembly, viability and project management issues emerging under the site development heading could be common to other key areas of regeneration, employment growth, housing land, etc., in Scottish planning. Therefore, future supplementary guidance on site assembly, viability issues, etc., could be appropriate not only to back up future SPP guidance on retail issues, but other land use issues as well.

Conclusion 8: Reassess Transport Modes for Shopping Accessibility

9.27 The study findings on general changes in retail habits (particularly the importance of constantly monitoring household shopping preferences) and also on the definition of centres, the sequential approach and site development issues have highlighted a need to look afresh at transport modes and shopping activity.

9.28 The study believes that the overwhelming evidence of continued use of the private car for shopping activity, mostly at off peak times is an important factor. There is also evidence to show that most sectors of society have access to a car, even if they do not have car ownership. Furthermore, there is the important issue of access to shopping and other community facilities in the expansive rural areas of Scotland. This was an important point raised by many of the consultation groups in the study.

9.29 As a result, the study team recommends that the issue of transport should be reassessed in the context of shopping activities, new urban centres and other associated commercial, leisure, etc., facilities.

9.30 On the one hand, there could be scope to have a more positive policy towards the controlled allowance of private car usage, particularly for forms of shopping which require the convenience of accessibility. However, the study team's transportation specialists have recommended that this should be appraised in conjunction with an investigation into car park charging policy between central locations and the out of centre developments which have ample car parking, normally without a charging regime.

9.31 On the other hand, there is continued strong reason for improved public transport facilities to link with the future of shopping facilities. This point has strong links with the recommendations earlier on the acceptance of various new urban centres, as long as they demonstrate good transport links and various other credentials. The study team believes that strategic investment in public transport facilities should be at the heart of any credentials list which defines future centres.

Conclusion 9: Retail Assessment Methodology

9.32 Various detailed recommendations emerged from the review of retail assessment inputs and methodology in Section 7 of this study.

9.33 It is suggested that future national guidance could be supported by advice notes on the appropriate context for the use of quantitative assessments and impact appraisals. The study team does not believe that there is a strong case for a "first test" of retail need before a proposal can progress. Alternatively, it is suggested that the quantitative and qualitative scope for new retail facilities should be tested along side a sharper focus on vitality and viability issues in relation to centres of importance which could be subject to impact.

9.34 This focussed approach to retail assessment methodology will depend critically upon the definitions of centres of importance. Equally important, it will depend upon improvements to data sources (see next recommendation).

Conclusion 10: New National Retail Data Sources

9.35 The study concludes that the optimal approach to the future of the retail/commercial sector in Scotland would be a fresh Census of Distribution instigated at central government level. It is understood that there are resource implications to this kind of commitment. However, there are modern information technology advances which can help to capture geographic data as part of a survey framework which can sustain in the long term.

9.36 Other approaches could be beneficial, such as prescribing improved geographical data capture at the local level, but to accumulate this data through some form of recognised national data base. An independent retail data collection centre would be appropriate. This could be a holding centre for the considerable amount of information which is produced on an annual basis through the normal planning application appeal and other activities in the planning system. In addition, the study team believes that some form of annual household survey should be mounted at national level, in order to inform government policy, but also assist in local decisions.

9.37 Whilst there are constantly improving sources of data for population trends, expenditure levels and other demographic indicators; this study has found criticism in relation to reviews of retail floorspace in particular and the lack of commitment to vitality and viability studies on town centres.

Conclusion 11: Allowing Flexibility at Local Level

9.38 Various elements of the research, including general changes, defining centres and the sequential approach highlighted the need to avoid an over-rigorous national policy context and to allow flexibility at local level.

9.39 There was a particular reference to urban and rural distinctions and the need to allow appropriate local circumstances to influence policy.

Conclusion 12: Specific NPPG8 Changes

9.40 The preceding headings all deal with the grouping of different implications to common themes. However, other specific results of the research related to the time scale for the review of NPPG8, and the appropriateness of some of the specific areas of guidance. In this context, the study team draw the following particular conclusions:

• There is an immediate requirement for some form of follow-up action aimed at refining the current NPPG8, over the next 12 months, in the following particular areas:
• sequential approach (linkages from sites to centres, large formats and disaggregation - see para. 9.26);
• promotion of Town Strategies
• the appropriate context for the employment of retail assessment methodology including capacity and impact;
• the need for improved vitality and viability monitoring;

9.41 In addition, the study team believes that work could commence immediately, in order to bring about a review of NPPG8 and produce a new SPP in the next 12 to 36 months. It is suggested that a new and leaner SPP should address the following:-

• The overall title of the document and a broader reach for its implications on "urban centres".
• A town centre incentive for the promotion of identified centres, development sites, environmental improvements and other initiatives.
• A fresh approach to transportation policy and its links to the future of urban centres. Whilst the existing main stream policy of promoting accessibility is likely to remain, there should be a closer focus on appropriate facilities for the use of the car, including parking controls.
• Policy for assessing new developments could move away from the exhaustive criteria checklist (para 45), towards more general policy tests which relate to relevant centres, impacts, vitality/vitality, accessibility, etc. and allow for some local discretion.
• Deleting references to the typology of different kinds of development.

9.42 In parallel with the above changes to the NPPG/SPP, the study team believes that substantial supporting advice could be assembled at national level to cover the following areas:

• Promoting town centres;
• Assembling effective development sites, viability appraisal and realising opportunity sites.
• Retail assessment methodology and data sources;
• Designing places, public realm and civic space in town centres.

9.43 Overall, many respondents involved in this study made reference to a future SPP on town centre and retailing issues which would be much shorter and concise document, focussed to the key issues. In support, there could be fuller complementary guidance and advice notes which could be updated on a more frequent basis and could benefit from more improved monitoring sources and techniques.

9.44 In the detailed conclusions above, the study team believes that the terms of the original brief have been thoroughly appraised and tested in the various consultative and research exercises employed in this study. A considerable amount of background information is now available to the Scottish Development Department and the Central Research Unit to employ in its future reviews of policy. Section 10 condenses the final findings into 6 Strategic Recommendations and relates these back to the original aims of the Study Brief.