a checklist for retail impact assessment

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TAMWORTH TOWN CENTRE
AND RETAIL STUDY
ADDENDUM ON NPPF POLICY
ON RETAIL DEVELOPMENT
June 2012
England & Lyle Limited
Gateway House
55 Coniscliffe Road
Darlington
DL3 7EH
Tel: 01325 469236
info@england-lyle.co.uk
1. Introduction
1.1
In July 2011 England & Lyle prepared the Tamworth Town Centre and Retail
Study for Tamworth Borough Council. The Study is intended to provide the Council with
evidence to develop policies in relation to retailing and town centre development. It will
be an important part of the evidence base for the preparation of Tamworth Borough
Council’s Local Development Framework Core Strategy.
1.2
The Council has decided to re-brand the Core Strategy as the Tamworth Local
Plan. At its meeting on the 9 February 2012 the Council resolved to publish the
Tamworth Core Strategy/Local Plan for a six week consultation period. Since this date,
dialogue has continued with adjoining authorities to secure a formal agreement in
relation to Tamworth’s future development needs. In addition, the government has now
published its revised National Planning Policy Framework (NPPF) which the Core
Strategy/Local Plan will need to show compliance with.
1.3
On this basis, to ensure compliance with the government’s ‘duty to co-operate’
and a ’sound’ Core Strategy/Local Plan, Tamworth Borough Council has decided to delay
the publication until early June. This will allow sufficient time for the Core Strategy/Local
Plan to be reviewed to reflect the outcome of both the ongoing discussions with
adjoining authorities and the publication of the NPPF.
1.4
The Council has extended the timescale of the Local Plan from 2026 to 2028 and
England & Lyle prepared a Supplementary Report in January 2012 updating the retail
expenditure and need assessment to 2028.
2. National Planning Policy Framework
2.1
The NPPF sets out policies for plan-making in relation to main town centres
including retail developments. These policies are stated in paragraph 23 of the NPPF
document which is quoted in full below.
“Planning policies should be positive, promote competitive town centre environments
and set out policies for the management and growth of centres over the plan period. In
drawing up Local Plans, local planning authorities should:
 recognise town centres as the heart of their communities and pursue
policies to support their viability and vitality;
 define a network and hierarchy of centres that is resilient to anticipated
future economic changes;
 define the extent of town centres and primary shopping areas, based on a
clear definition of primary and secondary frontages in designated centres,
and set policies that make clear which uses will be permitted in such
locations;
 promote competitive town centres that provide customer choice and a
diverse retail offer and which reflect the individuality of town centres;
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retain and enhance existing markets and, where appropriate, re-introduce
or create new ones, ensuring that markets remain attractive and
competitive;
allocate a range of suitable sites to meet the scale and type of retail, leisure,
commercial, office, tourism, cultural, community and residential
development needed in town centres. It is important that needs for retail,
leisure, office and other main town centre uses are met in full and are not
compromised by limited site availability. Local planning authorities should
therefore undertake an assessment of the need to expand town centres to
ensure a sufficient supply of suitable sites;
allocate appropriate edge of centre sites for main town centre uses that are
well connected to the town centre where suitable and viable town centre
sites are not available. If sufficient edge of centre sites cannot be identified,
set policies for meeting the identified needs in other accessible locations
that are well connected to the town centre;
set policies for the consideration of proposals for main town centre uses
which cannot be accommodated in or adjacent to town centres;
recognise that residential development can play an important role in
ensuring the vitality of centres and set out policies to encourage residential
development on appropriate sites; and
where town centres are in decline, local planning authorities should plan
positively for their future to encourage economic activity.”
2.2
One of the requirements which must be met by local authorities is to define a
network and hierarchy of centres. The Town Centre and Retail Study on which the retail
strategy in the Core Strategy/Local Plan will be based proposes a hierarchy of centres in
Tamworth that comprises:
 Tamworth Town Centre
 8 Local Centres, and
 17 Neighbourhood Centres
2.3
The Town Centre and Retail Study also recommends floorspace thresholds for
impact assessments of proposed retail developments outside centres. These floorspace
thresholds are consistent with the requirement in the NPPF paragraph 23 for local
authorities to set policies for the consideration of proposals for main town centre uses
which cannot be accommodated in or adjacent to town centres.
2.4
Paragraph 26 of the NPPF requires that when assessing applications for retail,
leisure and office development outside of town centres, which are not in accordance
with an up-to-date Local Plan, local planning authorities should require an impact
assessment if the development is over a proportionate, locally set floorspace threshold
(if there is no locally set threshold, the default threshold is 2,500 sq.m.). The
recommended thresholds represent the proportionate, locally set thresholds as
required above.
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3. Hierarchy of Centres
3.1
The Glossary in Annex 2 of the NPPF defines a “town centre” as:
“Area defined on the local authority’s proposal map, including the primary shopping
area and areas predominantly occupied by main town centre uses within or adjacent to
the primary shopping area. References to town centres or centres apply to city centres,
town centres, district centres and local centres but exclude small parades of shops of
purely neighbourhood significance. Unless they are identified as centres in Local Plans,
existing out-of-centre developments, comprising or including main town centre uses, do
not constitute town centres.”
3.2
With reference to the proposed hierarchy of centres in the Town Centre and
Retail Study, Tamworth town centre and the local centres are included in this definition
of ‘town centres’ in the NPPF but neighbourhood centres are excluded. However, NPPF
paragraph 23 requires local authorities to “set out policies for the management and
growth of centres over the plan period” and “define a network and hierarchy of centres
that is resilient to anticipated future economic changes”. Although the definition of
‘town centres’ in Annex 2 excludes neighbourhood centres, it is clear from the wording
of paragraph 23 that local authorities have a duty to define the network of centres in
their area and set out policies for these centres. In Tamworth there are no district
centres. The local and neighbourhood centres form an essential part of the network of
shopping and service provision in the Borough. It would be inappropriate for the
Borough Council to disregard the role that the neighbourhood centres play in meeting
the shopping and service needs of the local community. The neighbourhood centres
should be recognised in the network and hierarchy of centres identified in the Core
Strategy/Local Plan.
4. Floorspace Thresholds for Impact Assessments
4.1
The floorspace thresholds for impact assessment proposed in the Town Centre
and Retail Study are intended to be used for development management purposes. The
recommended thresholds are as follows:
Area for Application of Floorspace
Thresholds
Assessment Required
Tamworth Town
Centre
Tamworth Borough, outside the town
centre primary shopping area (unless
within the catchment of a Local Centre
or in the Ventura/Jolly Sailor Retail
Parks or the Tame Valley Industrial
Estate).
over 1,000 sq. metres gross
Local Centres
Within 800 metres of the boundaries of over 500 sq. metres gross
the proposed Local Centres, as defined
in Figure 5.
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Retail Parks and
industrial areas
Within the Ventura/Jolly Sailor Retail
Parks or parts of the Tame Valley
Industrial Estate, as defined in Figure 6.
over 500 sq. metres gross
4.2
The recommended floorspace thresholds apply to proposed retail developments
located within 800 metres of the boundaries of Local Centres. There is no intention to
apply them to proposed developments with reference to neighbourhood centres and so
there is no conflict between the application of these floorspace thresholds and the
definition of ‘town centres’ in the NPPF.
4.3
In assessing the likely impact of a proposed retail development as required in
paragraph 26 of the NPPF, local authorities have to judge “the impact of the proposal on
town centre vitality and viability, including local consumer choice and trade in the town
centre and wider area”.
4.4
The implication of this advice is that impact should be assessed on town centres,
including local centres, but that the impact on smaller centres such as neighbourhood
centres and local parades of shops, and individual local shops, is not a material
consideration. This is relevant to the future consideration of proposals for retail
development in Tamworth.
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