This is the second in a linked series of posts. The next one reflects on existing out-of-town developments and what we need to do about them. The first was on the draft National Planning Framework 4 (NPF4). In that post the sequential test and the impact assessment of retail development was mentioned. The latter issue is the focus of this post.
These comments are informed by some informal work I have been doing with some local authorities around their response to proposed out-of-town developments, in the light of A New Future for Scotland’s Town Centres and the recommendations and policy background it contains. The focus is on whether our traditional model of retail impact assessments is fit for purpose, given the change in retailing, the climate emergency and now the draft NPF4, amongst other general contextual and especially policy changes. It is hardly a spoiler to note at this point that I conclude that we need to rethink impact assessments. Soundly based impact assessments (not just retail) are required if we continue to consider any out-of-town or indeed edge-of-town developments, but the entire basis and assumptions on which they are founded needs to be reconsidered. The current approach is simply not up to our needs. Why do I conclude that?
Looking at these recent retail impact assessments it is possible to identify some common issues. This is in part is because they follow the methodology set out in 2007 in the Scottish Government publication ‘Town Centres and Retailing Methodologies’ (though this publication seems hard to find online now, or maybe it was just me, so here is a link to a Technical note from Aberdeen which covers the approach). This though is the first part of the issue: are methodologies agreed in the mid-2000s and brought in to reduce disagreement or wrangling over data and numbers, really appropriate anymore? Predating the age of austerity, the rapid rise of online retail sales, let alone the climate emergency, their relevance must be questionable. Add in to that the recognition that town centres are more than retail and need to be considered in their widest sense, and policy developments around The Place Principle, 20-minute Neighbourhoods and Community Wealth Building. The world has changed, but we seem to be accepting the old approaches nonetheless.
To example further some of these issues, we can pose a few illustrations of topics in the operation of retail impact assessments:
(a) How is the rise of online retailing handled? If this is now c30% penetration in retail sales what does this mean for floorspace need and the future of existing floorspace?
(b) Out-of-home eating, and also food and meal delivery to home has exploded. Again, how is this being factored into changing convenience retail space needs?
(c) How has the modernisation of the convenience store sector been incorporated? There has been a remarkable transformation of many convenience operations themselves as well as changing consumer patterns in this sector.
(d) The impact of the pandemic is the latest challenge to travel patterns, and not just in terms of local and convenience. How are these new pattens being accommodated?
These points can be added to by some other practical and policy issues.
(1) The developments I have seen have chosen to put various components together (including drive-thru’s) and then used the sequential test to say only an out-of-town site can cope with them. This is despite each individual element being already present separately elsewhere. This declaration of a singularity seems arbitrary to say the least and in some cases there is no rationale for why these uses would be in combination.
(2) The methodologies need catchments to ascribe impacts. The definition of the catchment is based on car travel. Policy now is to reduce such travel so what does this imply for how we should define catchments? Perhaps we need to define them by who can not access such developments, rather than who can by car?
(3) There is an informal acceptable impact benchmark of c10%. This though predates the pandemic, climate emergency and the internet and given store numbers and floorspace issues, has to be called into question. Given our town centre first principle why is any adverse impact “acceptable”?
(4) There is also a current lack of concern about climate issues generally. If sustainability, community wealth building and net zero are the policy backgrounds, then how should (if they can at all?) retail impact assessments incorporate these? How do we for example reflect a desire for more local, community focused operations?
I am sure there are other issues, and some of these might be able to be ameliorated. I am also sure some proponents of out-of-town schemes will say they can accommodate any such problems. I am not though convinced. And this is where the weaker words of NPF4 bother me (see my last post); could we not just say no to such things, because of the issues we face in terms of place, society, economy and climate? It would be simpler, cheaper and faster to enshrine this even more firmly in policy and not permit the ‘wriggle room’ that the sequential test and retail impact assessments have often demonstrated in the past. A rethink at least, if not an abolition, is needed.
As said at the outset, this is the second in a linked series of posts this week. The first was on the draft National Planning Framework 4 (NPF4). The final one reflects on existing out-of-town developments and what we need to do about them.
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