EXECUTIVE SUMMARY
Introduction
SPP8 Town Centres and Retailing, published in 2006, sets out the Scottish planning policy framework for town centres and retailing. The SPP identifies a range of techniques that can be used to support planning for town centres and retailing and indicates that updated guidance for these techniques, notably for each of town centre health checks, town centre strategies and retail impact assessment, will be published in the form of a Planning Advice Note ( PAN).
This research provides the basis for the preparation of the PAN for these town centre and retailing techniques. The Research Specification identified the aim of the study to provide clear and up-to-date good practice guidance on methodologies encouraged within the SPP8 policy document. In this the research aims to:
- Identify and assess existing methodologies.
- Recommend and illustrate standard approaches.
- Present recommendations and associated justification.
- Produce the recommended text for a Planning Advice Note.
The research has been undertaken jointly by Hargest & Wallace Planning Ltd and Donaldsons LLP.
Context
Town centres and retailing are rapidly changing. The drivers of retail change reflect a combination of factors including changes in the nature of consumer demand, commercial pressures for innovations in the system of supply and the role of the regulatory economic and planning environment.
Furthermore, within the planning system, retail and town centre developments attract considerable attention. As a result decisions relating to this need to be soundly based and the techniques used to support decisions need to be robust and effectively implemented. To support this clear guidance on the techniques that can be used to support town centre and retailing is required. The principal focus of this research is to identify and recommend appropriate techniques and methodologies to support these functions.
Development Planning Techniques
SPP8 requires an assessment of the role of centres in the context of the broader network of centres including an assessment of how this role may develop through time. A range of retail planning techniques are available for supporting an analysis of the overall retail provisions for an area. These techniques include:
- Retail capacity assessment ( RCA).
- Strategic retail planning techniques ( SRP).
- Assessment of qualitative deficiencies of retail provision.
- Market assessments.
- Assessments of development potential.
- Town centre health checks ( TCHC) including vitality and viability Indicators (V&V).
Retail Capacity Assessment Techniques.
In SPP8 and in many development plans there is an express requirement to consider deficiencies in retail provision within an area. The most common quantitative technique used in the U.K. for identifying the extent of any retail deficiencies is the use of retail capacity assessment ( RCA). Retail capacity assessment is, in essence, a comparison of demand for retail (expressed through available expenditure for a study area) and supply (expressed as the turnover of existing/committed retail floorspace). Retail capacity techniques are used by a number of planning authorities in Scotland in support of development plans.
RCA has been the subject of a wide range of criticisms. These have identified difficulties with the general approach both in terms of conceptual issues (e.g. it is simplistic and does not relate to market realities) and practical issues (e.g. results are sensitive to small changes in data assumptions). These criticisms have substance and, although the technique continues to be widely used, this research recommends caution in the application of RCA as a planning technique. Subject to the use of appropriate safeguards RCA can have some potential value as one of a number of techniques that can contribute to the examination of the balance between demand and supply of retail floorspace in an area.
Examination of practice and guidance indicates a generally common approach that can be adopted for RCA comprising the following stages:
- Baseline surveys. A key requirement for accurate retail capacity analysis is the use of extensive up to date survey information.
- Identification of study/catchment area.
- Identification of base and test years for analysis.
- Estimation of current and future population and available expenditure (i.e. identification of retail demand).
- Identification of current and future retail floorspace and turnover (i.e. identification of retail supply).
- Calculation of retail capacity.
- Sensitivity and scenario testing.
The research concludes that there are significant reservations concerning the application of the conventional approach to RCA for understanding quantitative retail deficiencies and it is recommended that broader strategic techniques are used in place of RCA. If RCA is used it is recommended that it should be subject to rigorous sensitivity testing to establish the reliability or otherwise of the assessment. In all cases RCA techniques provide only limited information and should be used in combination with other techniques which address market, development, qualitative and other quantitative factors relevant to town centre and retail planning.
Other Strategic Retail Planning Techniques
In recent years greater consideration has been given years to developing techniques for supporting the analysis of retailing at a strategic level. This has, in part, been in response to some of the difficulties associated with conventional RCA techniques. These quantitative techniques are referred in this research as strategic retail planning techniques ( SRP). Three broad approaches to SRPs can be identified reflecting practice in both Scotland and elsewhere in the UK. Each can be regarded as a development or refinement of the conventional RCA approach. The basic approaches are:
- Subdivision of RCA study areas into broad zones to identify retail capacity for separate retail centres.
- Use of models of expenditure flow between model zones and a wide range of retail destinations as a basis for the identification of retail capacity.
- Use of models of expenditure flow between model zones and a wide range of retail destinations as a basis for identifying the separate retail characteristics of centres and application of trends and scenarios for assessing the impact on the operation of retail centres in future years.
The purpose of these SRP techniques is to provide a comprehensive and strategic picture of retailing and the factors that influence retailing, to offer a contextual position for more detailed retail matters in the locality and to act as a basis for developing policy.
The principal difficulties with SRP techniques relate to the construction and validity of the retail model which underpins the assessment and the way that information is used. In particular: the high cost of preparing SRP models; the reliance of the model on accurate base data; and that, at present, there is no accepted standard method for design, implementation and interpretation of the techniques.
Complementary Retail Planning Techniques
The research identifies that additional retail planning techniques are required to complement the use of RCA or SRP techniques in providing an overall understanding of retail provision within an area. Three of these, assessing qualitative retail deficiencies, market assessments and assessing development potential, are considered in outline in this research. In addition town centre health checks are identified to be of key importance.
Identifying Qualitative Deficiencies
Qualitative deficiency is expressly identified in both SPP8 and in many development plan policies as a factor to be taken into account in identifying the potential for additional retail floorspace. At present there are no standard techniques that have been developed for the identification of qualitative deficiencies. From the research undertaken the identification of qualitative deficiencies will reflect the following factors:
- The distribution of and accessibility to retail provision for different communities.
- The presence of different types of retail operation.
- The physical quality of the provision present and in comparison to other centres.
- Whether the shopping experience is undermined by indicators of over-trading.
- The reasons identified as to why shoppers travel to competing retail locations.
Market Assessments
Any analysis that seeks to understand current and future retail provision in centres should be supported by market assessments undertaken by specialist retail surveyors. These should assess the current and future demand for retail space by type and location, including:
- The strengths and weakness of centres in comparison to other centres.
- The attractiveness to retailers of existing space in centres.
- The role of demand for space from both local independent and multiple retailers.
Assessing Development Potential
It is important to establish whether or not centres have the physical capacity
to accommodate development. The research therefore recommends that consideration should be given to assessing the physical capacity of centres to accommodate retail space. This will require specialist expert advice. This should address the following types of issues:
- The attractiveness of sites/premises to retailers.
- The capacity of sites to accommodate different types of development.
- Land assembly and deliverability.
- The viability of development.
Town Centre Health Checks
Overview
In this research a Town Centre Health Check is identified to be the process of collecting information on a range of individual vitality and viability indicators for town centres.
SPP8 defines vitality as "a measure of how lively or busy a town centre is". It therefore refers to how busy a centre is at different times and in different parts. It defines viability as " a measure of its capacity to attract ongoing investment, for maintenance, improvement and adaption to changing needs".
The research concludes that there is limited experience in undertaking systematic town centre health checks in Scotland. Nearly all authorities collect some information but this is usually limited in scope and frequently undertaken through one-off studies rather than routine data collection, monitoring and analysis. The research concludes that the value of TCHC by local authorities is not fully realised and, as a result, TCHCs are not considered a priority for resources. There is clear need for a PAN to assist planning authorities and others to undertake TCHCs. This should encompass the overall process, the way that information should be used, data sources and applicability to different types of centres.
The research identified considerable merit in collecting TCHC information. This includes the following key functions:
- To provide an understanding of how town centres are performing and inform their future direction in an increasingly competitive environment.
- To inform Development Plan formulation, Town Centre Strategies and Action Plans.
- To assist in prioritising/justifying investment and resourcing decisions for town centres and to monitor and evaluate the impact/benefit of investment decisions made.
- To provide information for prospective investors/marketing.
- To provide information on actual usage of the town centre by customers to inform strategy/policy.
- To provide a baseline for assessing the significance of impacts on town centres arising from commercial retail and leisure developments.
- To identify trends over time and establish whether conditions are improving, static or declining.
The wide range of potential uses for TCHC information is indicative of the benefits of the process for both statutory planning functions and for town centre monitoring, management and strategy formulation and implementation.
The relevance and importance of different V&V indicators will vary according to the overall function being pursued. Different indicators have different roles for the above functions. Some indicators are more useful for statutory planning functions and others more useful for strategy formulation or town centre management.
A number of general issues relating to the TCHC process have been identified from the research including:
- The range of V&V indicators is too great for some authorities to manage, especially where there is no history of systematic data collection and where resources are limited.
- The usefulness of indicators varies by size of town. Not all of the V&V indicators are relevant or easy to interpret in market towns and other small centres.
- Local authorities frequently target the most easily collectable data because resources are constrained but these are not necessarily the most useful.
- Health check resourcing is a significant practical issue for most local authorities.
- Indicators are not always defined consistently or explicitly, which makes comparisons over time and between places difficult.
- There is a lack of good quality time-series data, collected at regular intervals.
- There is no common practice for the selection of towns and data for comparison. As with the indicators themselves, the selection of comparative data is often driven by availability rather than usefulness.
A database setting out TCHC/V&V information will support benchmarking of centres which will, in turn, significantly improve the usefulness of the information collected through this process.
In general the research considers that TCHCs should be undertaken at least once every two to five years and preferably more frequently than this. It is recommended that easily collected V&V Indicators should be identified annually.
Vitality and Viability Indicators
A full review of the following vitality and viability indicators is presented in the research:
- Pedestrian flow.
- Prime rental values.
- Space in use.
- Retailer representations and intentions.
- Commercial yield.
- Vacancy rates.
- Physical structure of the centre.
- Surveys of consumers/town centre users/employers/employees.
- Crime and safety.
- Accessibility.
- Environmental Quality.
- Turnover, available expenditure and competing investment.
- Tourism.
For each of these indicators (or sets of indicators) the research sets out information on: a description of the indicator (including definitions where appropriate); advantages, disadvantages and issues arising from its use; information sources; applicability to different types of centre; and applicability to different planning functions, with a comment on the relative usefulness of the indicator.
Town Centre Strategies
For the purposes of this study, a Town Centre Strategy ( TCS) is defined as "a technique for establishing a detailed framework which enables action for improvement of the centre(s) to be realised, informed by up to date monitoring and review of the centre(s)." An important aspect of TCS is that it provides a process which facilitates a dialogue with key organisations and stakeholders involved in the use, management and future prospects of a town centre.
The current policy references to the role and preparation of TCSs are contained in SPP8 and PAN59 "Improving Town Centres" (1999). SPP8 encourages actions to support the improvement of town centres to create "distinctive and successful places" and notes that a range and scale of interventions are appropriate to town centres. Town centre strategies are identified as a key tool to delivering improvements. PAN59 identifies possible items for action including the need for an inclusive, partnership approach to formulating and delivering town centre strategies.
The research concludes that further advice is required on the preparation and implementation of TCS's but that it is inappropriate to provide advice on standard methods of preparing them because they need to adapt to and reflect specific local circumstances.
Main Role and Purpose of a TCS
The main purposes of a TCS include:
- Informing the future role/direction of the town to enable setting of objectives.
- The allocation of resources/prioritisation of actions.
- Providing a framework for action plans.
- Identifying specific sites/uses.
- As a means of getting key organisations involved/building consensus.
The Town Centre Strategy Process
The following stages are typically used for the preparation of a TCS:
- Identifying the scope of study and brief.
- Contextual/policy review.
- Stakeholder engagement: the effective and early involvement of key stakeholders is identified as a fundamental part of the preparation and delivery of a TCS. Key stakeholders may include retailers, local businesses, members of the public, user groups, other public sector partners and organisations, key landowners and investors.
- Assessment of the performance and role of centre: this stage should be informed by up to date health check monitoring of the town centre.
- Opportunities and capacity for change: to assess the physical and market capacity for change in the town centre, within the context of the policy review.
- Analysis, options appraisal and identification of preferred options and proposals for action: this is likely to cover a variety of potential interventions including environmental improvements, transport/accessibility, master planning, development briefs and other non-physical proposals and interventions.
- Action plan/implementation strategy: this is a key part of the strategy process which sets out the specific actions required to deliver the objectives of the strategy and the identified projects. It should clearly set out clearly: the basis of action; the organisations responsible; resourcing; timescales; and funding sources.
- Reporting and disseminating findings: this is important for deriving value from the TCS process and may include internal reporting, information sharing and decision making within a local authority but also dissemination and discussion of findings with key stakeholders as a means of debating issues and seeking consensus on future action.
Key Components to Successful Strategies
From the research a series of common ingredients for a successful TCS have been identified. These include:
- Early stakeholder engagement, including involvement of the public and private sectors.
- Strong public sector leadership to demonstrate commitment and provide confidence to the private sector.
- Sustained resourcing and appropriate levels of responsibility/remit for implementation of the Strategy and Action Plan.
- Strong project management and early identification of conflicting agendas.
- A clear structure or vehicle for implementation agreed between the key parties.
- Senior level management support and political will to take projects forward to the delivery stage.
- An action plan with clearly identified priorities, timescales, responsibilities/named individuals and funding sources.
- Proactive use of Council/public sector property assets as a catalyst for regeneration and private sector commitment.
- Promotion and use of CPO powers, where appropriate, to assemble key sites to facilitate regeneration/improvements.
- Ongoing monitoring and review of the strategy.
- Ongoing communication of results and updates on progress to key stakeholders and the local community.
Retail Impact Assessment
Introduction
Impacts arising from retail developments include each of economic, social and environmental effects on surrounding areas and communities. The conventional approach to Retail Impact Assessment ( RIA) is, however, to focus upon economic impacts, that is to consider the impact on retail businesses and centres in terms of trade lost or diverted.
In SPP8 paragraph 40 refers to the requirement for an "impact analysis" to be undertaken in support of certain development proposals. In the context of the preceding part of the SPP this implies an assessment of impact upon the vitality and viability of the network of centres. In this research, therefore, retail impact assessment is taken to mean: a technique for assessing the quantitative and qualitative impacts of a proposed retail development on existing and/or proposed retail floorspace/centres including assessing the significance of the impact on the current and future vitality and viability of the centres impacted upon. The primary purpose for RIA is, therefore, to assist in decision-making relating to planning applications and appeals.
RIA techniques have been used in the UK since the 1960s. Since the 1980s there has been a general accordance of the appropriate method to be adopted for RIA in a planning context with the result that the predominant approach currently used by retail planners is a " step-by-step" approach for RIA.
Overall Approach for RIA Method
The research identifies that there is a general consensus in support of guidance to be issued for the preparation of RIAs. It concludes that, reflecting the purpose of the method and the requirements of the planning system, the step-by-step approach for RIA is the most appropriate that should be used. It also concludes that the recommended method should not be prescriptive but should adopt a flexible approach that can be adapted to suit local circumstances.
In this method the key requirements for the RIA method are:
- To understand the existing and future retail characteristics of the area. This includes identifying existing and future population, available expenditure, floorspace and retail turnover.
- To understand the characteristics of the proposed development and how it interacts with existing and future retail in the area. This includes identifying the turnover of the proposed development and the areas from which it draws trade.
- To identify the impact of the proposed development on existing and future floorspace. This includes identifying the amount of trade diverted from existing floorspace, the impact, and the significance of impact that this has on the operation of that floorspace.
A number of criticisms of RIA methods are identified in the research. It is important that the preferred technique should, insofar as it is possible, address these criticisms in the recommended method. The principal criticisms and the responses to these are:
- The use of a wide range of assumptions at many stages of the analysis creating considerable areas of doubt in the accuracy and reliability of forecasts. Response: seek agreement of assumptions between planning authorities and applicants at the outset of the RIA.
- The lack of justification for the assumptions used in RIAs. Response: include explicit justification of assumptions used in RIAs.
- The sensitivity of the results to changes in the assumptions used. Response: use sensitivity testing in RIA.
- Weaknesses in obtaining accurate base data. Response: Encouragement of improved data to be derived from a range of sources including increased use of household survey data.
- The lack of independence of RIAs which results in a level of distrust regarding the reliability of RIAs submitted in support of planning applications and appeals. Response: The research does not support the general preparation of RIAs by either planning authorities or "independent" organisations. Where appropriate planning authorities should seek independent review of RIAs submitted by applicants.
- The limited qualitative assessment of impacts arising from proposed developments. Response: Incorporation of qualitative interpretation of the quantitative impacts identified in RIAs.
It is the conclusion of the study that the incorporation of the above will improve the reliability of RIA results, increase confidence in RIA as a technique and improve its value as a tool to support decision-making.
Stages to be included in RIA.
Stage 1. Scoping: planning authorities and applicants for retail planning applications should be encouraged to scope the RIA in advance of the preparation of the RIAs. This will include agreement as to whether the proposed development warrants a full RIA or whether a shorter, more indicative assessment, in the form of a retail statement, is appropriate.
Stage 2. Surveys: encouragement is given to the use of household surveys, in particular where:
- Development proposals are for large and/or complex retail developments.
- Where there is no up-to-date existing household expenditure information.
- Where there is significant uncertainty about the catchment area or trading characteristics of the proposed development
Additional surveys of town centre users/shoppers, businesses and comparable developments elsewhere have a limited role in RIAs and should be provided only occasionally.
Stage 3. Identification of the Catchment Area. The identification of the catchment area, and the proportion of trade drawn from this area, is an important stage in the RIA and it will directly affect the assessment of trade diversion from competing centres and retail impact.
Stage 4. Identification Existing Estimates of Population and Available Expenditure. This is required to understand existing trading conditions.
Stage 5. Identification of Future Estimates of Population and Available Expenditure. In stages 4 and 5 estimates of existing and future population in catchment areas should be based, in the first instance, on information provided through planning authorities. In the absence of this information it can be provided from other sources, notably through the General Register Office (Scotland) or from the Census. The most practical sources for estimates of available expenditure per capita are commercial data providers.
Stage 6. Existing Floorspace and Turnover. The identification of existing floorspace and its turnover is central to the assessment of retail impact. The research concludes that household surveys, if well designed, should be used to provide estimates of the turnover of existing floorspace. For small developments, or where centres are large compared to proposed developments and/or existing centres are not considered to be unduly sensitive to impact the use of estimates based on averages may be appropriate.
Stage 7. Turnover of Proposed Development. This will be an important factor in determining the calculation of retail impact. The estimate of the turnover of the proposed development should utilise a range of techniques including reference to market share within the catchment, average turnover levels and comparable developments elsewhere (the latter particularly for new forms of development). For small scale developments the use of national average figures combined with sensitivity tests may be appropriate.
Stage 8. Trade Draw. Trade draw identifies the origin (for example where they live) of those who spend money in the proposed development. It is a useful concept for assisting with other stages of the RIA including the estimate of proposed development turnover and estimation of trade diversion. For small or straightforward development proposals trade draw does not require to be undertaken explicitly as part of the RIA.
Stage 9. Trade Diversion. Trade diversion is distinct from trade draw and identifies the source of turnover of the proposed development from existing shops and centres. The research concludes that at this stage RIA can become highly subjective and there is no doubt that this stage is fundamental to the calculation of retail impact. Trade diversion assumptions will, therefore, need to be fully and carefully justified. Factors that should be considered for assessing trade diversion include:
- Characteristics of the competing shopping locations based on those which are most likely to be in competition with the development including similarity of retail offer.
- Scale of centres (in particular turnover in relevant goods categories).
- Intervening distance.
- Existing shopping patterns.
- Shoppers' travel habits and patterns.
- The relative attractiveness of centres.
Stage 10. Calculation of Impact. The actual calculation of retail impact is comparatively straightforward and is based on the deduction of the trade diversion identified (from Stage 9) from the turnover of centres in the test year (from Stage 6). As well as identifying the absolute loss of trade from a centre there are a number of additional ways in which this impact figure can be measured including:
- Percentage loss of trade.
- Residual turnover.
- Impact on market share of centres.
Stage 11. Sensitivity Testing. Sensitivity tests should be used to indicate how robust the RIA results are to changes in assumptions.
Stage 12. The Condition of Centres: Health Check Information. Information on vitality and viability indicators of existing centres should be provided to support the analysis of the significance of retail impact.
Stage 13. Significance of Impact. The research recommends that RIAs should include an interpretation of the significance of the impact arising from a proposed development. This should include reference to vitality and viability indicators of centres (from Stage 12) and address a range of issues that could result from the impact of the proposed development on the centre.
Other Issues for RIAs
There are a number of general issues that require to be considered relating to both data availability for RIAs, the applicability of RIA to different types of development and broader principles underpinning RIA as a technique.
1. The role of cumulative RIA. Cumulative RIA (i.e. assessing the combined effects of more than one retail development proposal on a centre or centres) will be appropriate in certain situations including:
- When more than one proposal is applying for planning permission (and there is the possibility that more than one could gain consent).
- Where recent consents have been granted and schemes have not yet reached their test year.
- Where there have been significant changes over a recent time period and the town centre(s) are still adjusting to impacts.
2. Treatment of secondary retail impacts. Although the research identified that secondary impacts (beneficial and adverse) would be potentially significant there are no reliable methods for quantifying these effects on centres. Therefore the research recommends that assessing these should be limited to a general description of impacts.
3. Business and Goods based approaches. The research recommends that RIAs should utilise a goods-based (and not business-based) approach for the estimation of each of available expenditure, the turnover of existing centres, the identification of potential deficiencies, and the turnover of the proposed development.
4. Data availability. In order to address difficulties regarding the availability and quality of data the research recommends the adoption of the following:
- Agreement at scoping as to appropriate information sources, including potential alternatives.
- Clear statement of information sources, prices bases and assumptions underpinning data so that these can be reviewed.
- Ensuring that data should be utilised in a consistent manner, for example common price base and units of measurement, or adjustment for different goods categories.
- Where there is significant uncertainty consideration should be given through sensitivity testing to assessing the effects of different data assumptions.
- The systematic collection of information through town centre health checks by authorities to provide key information which will support the assessment of the significance of retail impacts.
5. The requirement for RIA for different types of development. The research recommends that requests for full RIAs should only be made by planning authorities where there is either a clear requirement to do so in the development plan or SPP8, or where there are concerns about the existing and future condition of centres that benefit from policy protection. For developments less than 2500 sq m GFA, or which are located in town centres or otherwise not contrary to the development, regard should be had to the preparation of an indicative RIA which does not include all the stages described earlier. Notwithstanding para 40 of SPP8 it may be appropriate, in certain situations to undertake full or indicative RIAs, of retail developments proposed to be located in town centres. Such requests should reflect the concerns of the development plan and should be justified by the planning authority.
Conclusions
The principal recommendations and conclusions from the research relating to the role of town centre and retail planning techniques are as follows:
- Town centre and retail planning techniques should be used as a suite of techniques. When used in combination they provide an improved understanding of the existing function and future role of centres both individually and as part of the wider network of centres. This can be used to inform decisions on the future direction of centres.
- During preparation of SPP8 it was indicated that there is a clear need for a Planning Advice Note to be prepared to provide advice on good practice for undertaking the full range of techniques reviewed in this research.
- A wide range of public and private sector organisations are important for the future of town centres and for the effective implementation of the techniques covered in this research. There should be greater joint working between these organisations to support: sharing of data and information; sharing of skills and expertise; identification of complementary or competing proposals; and to establish common aims and objectives for town centres
- There is limited experience in Scotland with the systematic collection of information for town centre health checks. Health checks have considerable benefits and the information generated can be used in a wide range of ways for statutory planning functions, promotion, management and strategy formulation and implementation.
- A range of town centre and retail techniques are available to support the preparation of development plans. The principal quantitative technique used is retail capacity analysis but the research identified a significant reservation about the usefulness of this technique. The research recommends that, in preference to retail capacity, strategic based techniques should be used and that a range of town centre and retailing techniques should be used to support development planning functions.
- Town centre strategies were identified as a key tool for delivering improvements and regeneration in town centres. Key factors for success with there strategies were identified to be: early stakeholder engagement; strong leadership and political support; identifying sustained resources; a clear delivery vehicle and action plan; potential use of public sector assets; potential use of compulsory purchase powers; and effective communication of results.
- Retail impact assessment was identified as a key tool for supporting decision making in relation to retail development proposals. The research recommends using the step-by-step approach for assessment is recommended for use in Scotland subject to its flexible application for different types of retail proposal.
- The Scottish Government can support the role of town centre and retail techniques through:
The routine collecting of information on indicators of town centre vitality and viability from planning authorities or other relevant bodies.
The establishment of a national database of vitality and viability indicators for town centres in Scotland.
Supporting further training and education for professional planners for the full range of relevant town centre and retail planning techniques.
Undertaking further research for the review of techniques for assessing commercial leisure development and the assessment of qualitative deficiencies for retail and commercial leisure development.