Memorandum by the Office of the Deputy
When I appeared before the Committee on 20 July,
I undertook to write to you to clarify the issue of extensions
to out-of-town shopping centres. The particular point raised was
whether the wording of draft PPS6 would allow individual retailers
to circumvent the general policy on extensions to such centres,
by applying for extensions on a store-by-store basis, and thereby
not being subject to the sequential test.
It might be helpful to start with a summary
of the policy as proposed in the draft PPS6. Paragraph 2.12 deals
specifically with regional and sub-regional shopping centres.
It states that:
"The Government does not consider it likely
that there will be a need for any new out-of-centre regional or
sub-regional shopping centres . . . or the expansion of existing
ones. If such a need is identified, however, it should be addressed
through the Regional Spatial Strategy . . .. There may be a need
to improve public transport to existing out-of-centre facilities,
but this will not justify extending them."
Thus any potential extensions to these centres
should, under the proposed policy, be identified in principle
in the Regional Spatial Strategy (RSS), as part of the wider retail
strategy for the region, with particular reference to need. The
relevant local planning authority (LPA) should then reflect this
strategic priority within local planning policy, as an allocation
if appropriate. Paragraphs 2.23-2.24 state that LPAs should take
account of the following when making decisions to allocate sites,
as well as all other relevant matters:
assessing the need for development;
securing the appropriate scale of
applying the sequential approach
to site selection;
assessing the impact of development
on existing centres; and
ensuring the locations are accessible.
Paragraph 3.31 of draft PPS6 deals with planning
applications for extensions to existing development, stating that:
"Applications for the extension of existing
developments may raise specific issues. The impact on the town
centre of the proposed extension should be given particular weight
if new and additional classes of goods or services for sale are
proposed. In addition, where establishing need is concerned, local
planning authorities should establish that the evidence presented
on the need for further floorspace relates specifically to the
class of goods proposed to be sold. The sequential approach is
not a relevant consideration in relation to extensions, but local
planning authorities should still have regard to the accessibility
of the proposed development."
This proposed text makes it clear that planning
applications for extensions to existing development are not subject
to the sequential test, although further consideration should
be given to the impact and accessibility tests.
As currently drafted, these references in the
emerging PPS6 fail to address clearly the issue raised by the
Committee of a potential creeping extension of an out-of-town
shopping centre through the piecemeal extension of individual
stores. This issue has been raised in consultation responses,
and is something that we will be looking at as PPS6 is finalised.
I would also like to raise another matter. Having
read the transcript from the session, I find that I may have inadvertently
confused the Committee in my answer the Question 32. The needs
test and the scale test are of course separate, and address different
The needs test looks at both quantitative and
qualitative considerations, giving greater weight to the former.
Paragraph 2.28 of draft PPS6 advises that, in assessing quantitative
need, local planning authorities should assess the likely future
demand for additional retail and leisure floorspace, based on
existing and forecast population levels and expenditure in relation
to the classes of goods to be sold, within the broad categories
of "convenience" and "comparison" goods.
In contrast, paragraph 2.33 of draft PPS6 addresses
the issue of scale, and states that uses which attract a lot of
people should be located within centres that reflect the scale
and catchment of the development proposed. The scale of new facilities
should be directly related to:
the role and function of the centre
within the wider hierarchy and the catchment served;
patterns of existing development
within the centre; and
the scale of existing buildings.
Design, aesthetic and amenity issues are further,
I would like to thank the Commitee for bringing
these matters to my attention, and for their interest in the emerging