Examination of Witnesses (Questions 60-72)
MR BRIAN
RAGGETT, MR
JAMES LOWMAN
AND MR
STEPHEN WRIGHT
11 MAY 2009
Q60 David Wright: What you mean?
Mr Lowman: Impact on centre. Climate
change is in there, which we welcome. Diversity.
Q61 David Wright: How do you measure
that?
Mr Lowman: That is the challenge
we will put back. I do not have a solution and a formula in my
notes but those sorts of things need formulas developing alongside
them.
Mr Wright: To pick up on a point
that Mr Betts made earlier, it is a move from a quantitative towards
a more qualitative approach to assessment, and that means that
the safeguarding of town centres becomes much more entrusted to
local authorities, exercising their judgement in such a way as
to protect town centres, and to positively plan to protect town
centres.
Q62 Chair: Can we just try and tease
this out a bit? Let us just take the diversity bit. If you wanted
a quantitative as opposed to qualitative, would you have to say
things like there should be 25 different types of shops? I am
not sure how you could do diversity just as a metric. Surely it
has to be qualitative. It is not to do with just numbers, is it?
Mr Raggett: Yes, there is no doubt
that there will be interpretation in different ways in different
places with the policy as now proposed, and that is going to be
quite a challenge for planners, who will be perhaps coming to
this occasionally, as opposed to retail planning consultants,
who may be regularly coming to the same issues on behalf of their
clients. There are also some elements of subjectivity, whether
they relate to design or sustainability, as was raised a moment
ago, where there will probably be the need for some further guidance
as to how important those issues are in relative terms compared
with the impact on investment that has been regarded as a key
priority of the local authority in a particular town centre. I
would suggest therefore that, in refining the policy, there might
be a need for guidance to be given as to which of the now fairly
long list of elements should be regarded as the Premier League
or the First Division elements and which ones might be regarded
as relevant in certain places in certain circumstances.
Q63 David Wright: I am not trying
to be over-critical. I am trying to nail down specifically how
planning officers and ultimately local councillors would make
assessments on applications. When you are talking about refinement,
you are talking about, as you say, re-ordering priorities, making
sure that planning officials know exactly what kind of indicators
they should be judging, are you?
Mr Raggett: Yes. In my view, that
is necessary because there was not always a very clear interpretation
of the previous policy in terms of what was the appropriate balance
to be struck between quantitative and qualitative elements in
judging the assessments that were done in PPS6. It has got to
be moved forward if we are to avoid a fog in the future.
Mr Wright: I think the fog in
the future is the concern but it is within the gift of local authorities
as part of this policy working out to set out in their Local Plan
documents to some extent their aims, against which assessments
can then be judged. But it does place huge emphasis on local authorities
to plan positively.
Q64 Mr Betts: I am still a little
confused. There was general concern about the removal of the need
test. I am not quite sure whether you want to keep the need test;
whether you want it to stay as well as an improved impact test,
or are you saying to us that the extra guidance now in the impact
test, and possibly further guidance which you would like to see,
the impact test without the need test would do the job?
Mr Lowman: I would like to see
retention of the need test. I think that is important. We have
to understand the grain of government policy on this, and I think
it is nevertheless possible to have a robust town centre first
policy and also commit to trying to help us develop that post-
the need test but we would rather that were retained.
Mr Wright: To be absolutely frank,
I think many of us felt that the ship had sailed on the need test,
that the Barker Report recommendations had been largely accepted
by Treasury, certainly on this issue, that the DCLG and Government
looked set to replace the need test with something. Our line has
always been that we will support the removal of the need test
if what comes in its place is sufficiently robust to give that
same level of protection, if not more protection, to town centres.
Mr Raggett: I agree with what
Mr Wright has just said.
Q65 Andrew George: Given that, of
course, I would not expect you, as retailers, to recommend how
you might make the environmental aspect of the policy more robust.
Part of what the Government is trying to achieve, and certainly
in the consultation paper it says, and I quote, it was concerned
with "the promotion of town centre vitality and viability,
including consumer choice and the range and quality of the retail
offer". Would you concede or do you not concede that there
has ever been any circumstance in which an out-of-town supermarket
has contributed to the range and quality of the retail offer?
Do you think that there have been some circumstances where out-of-town
developments have in fact contributed to that consumer offer,
the range and quality and consumer choice, or would you say that
on many occasions in fact it has resulted in undermining the range
and quality of the offer within the town centre?
Mr Lowman: The answer is both.
It is perfectly conceivable, and there will be examples, where
an out-of-town development has improved the offer for consumers
in that area. Hence the reason for the policy, which I think there
is broad consensus on. There are also lots of examples where out-of-town
development has undermined town centres, has undermined the offer
and the richness of that offer as a whole.
Q66 Andrew George: Could you quantify
that a little bit more? Would you say that on balance it has worked
against the town centre and that the balance of planning assessment
has got it wrong?
Mr Lowman: Yes. I think, on balance,
out-of-town developments harm town centres and that is the reason
for this policy. I think it is concerning that we still have 60%
of development taking place outside of towns, still we have three
new-build supermarkets a month, and I think that overall is damaging
to consumer choice, and what consumers actually want, which is
of course a choice of stores, including large stores, but also
small shops within five minutes of where they live, a variety
of different offers, and vibrant town centres with a variety of
different offers. So on balance, it is something that concerns
us deeply, yes.
Mr Wright: The planning system
has a huge number of variables to keep in balance and every week
some new ones are thrown at it, whether it is obesity or designing
out terrorism or whatever. There is a huge balance of considerations
that need to be weighed in the balance. The 2004 Planning Act
introduced sustainability, as many understand it, as the key driver
at the moment of the planning system. If we are going to look
at a sustainable planning system and all that that means, that
might mean that other issues have to play second fiddle to that,
have to take a back seat to that. We think that retail diversity,
consumer choice, is hugely important but it is for planning policy
to judge which considerations it perceives to be most important
and to rank accordingly.
Mr Raggett: All I would add on
behalf of the BCSC is that a very wide range of scale and type
of in-town and, to a certain extent, out-of-centre development
has been developed by BCSC members over recent years, but very
much the emphasis is now on town centres and almost all of the
planned development in relation to the non-food sector, anchored
by department stores, is in town centres now. The distinction
and the difference relates to supermarkets, which of course do
still propose significantly more edge-of-centre and out-of-centre
development. One thing I would say is that—it is a small
point perhaps—within annex A of the new PPS4 for there is
reference to some BCSC research which perhaps would give comfort
to the Committee normally, because it suggests that some 486,000
square metres of floor space is in the pipeline going to be built
in town centres in each of the next three or four years. That
was based on research conducted some 18 months ago and, through
my firm, Strutt & Parker, we did a little bit of checking
on how much of that was still in the pipeline and how much was
now on ice. I think roughly 75% or in some cases rather more of
the development that was in the pipeline, that was estimated to
be in the pipeline, is now either on ice or not happening. In
other words, there is not as much coming through the town centre
pipeline as was thought, and therefore now, if I can sum it up,
is definitely a good time to be cautious rather than radically
shifting policy.
Q67 Chair: I do not quite follow
that. There is less development for obvious reasons.
Mr Raggett: For obvious reasons
in relation to the economy, but if policymakers were feeling that,
actually, it is all going to be, relatively speaking, fine and
dandy because a significant amount of development is coming through,
therefore we can relax certain policies in relation to edge-of-centre
or out-of-centre development, as is, I am sure, very obvious to
members of the Committee, the economic circumstances have changed
and that is no longer the case.
Chair: I am not sure I follow that.
Q68 Andrew George: I am somewhat
concerned about that. This is a policy planning statement that
is going to sit for a number of years, and surely we cannot lay
down these broad guidelines on the basis of where the economy
is currently sitting. Presumably there is going to be an upturn,
and maybe another downturn—who knows?
Mr Raggett: Indeed. I think therefore
it is entirely right that policy changes, if any, are very minor
in nature. One of the difficulties that practitioners have is
how little hard information there is on the location of floor
space that is built. I think this Committee was promised by Nick
Raynsford some considerable time ago that there would be a substantial
improvement in the quality and nature of data on retail floor
space that was going to be put into the public domain. I am not
sure that that is still being worked through as frequently and
as regularly as was suggested back in 1999.
Q69 David Wright: Let us get this
right. What you are saying is that this planning policy material
should have a measure attached in relation to economic performance
so that we can knock out three indicators on page whatever if
the economy is in downturn but we have to reinsert them if the
economy is on the upturn.
Mr Raggett: No, I did not suggest
that.
Q70 David Wright: What are you suggesting
then?
Mr Raggett: I am suggesting that
if there is to be change to policy at a time when the economy
is clearly facing challenges, it is important that that change
does not encourage, through whatever interpretation of the wording
that is put into that policy, a significantly greater proportion
of out-of-centre or inappropriate edge-of-centre development.
Now is the time to focus more and more on town centre development,
however difficult that may be.
Q71 Mr Betts: Are you saying that
the uncertainty of change, which there always is when you change
any policy, could be more detrimental at a time when confidence
is already fragile amongst developers because of the economic
climate?
Mr Raggett: Yes. Confidence is
fragile and that is the issue you have just summed up.
Mr Wright: I think there is that
point and then the point that, because we are moving towards a
system, as I understand the proposals, that is more flexible and
is more open to interpretation, that could be interpreted locally
so as to deliver quick wins, if you like, quick employment wins,
quick regenerative aims, possibly at the expense of the longer
term planning gain. It is a long-term game. We last year opened
a department store in the new Liverpool One development, which
took over a decade from inception to completion because of the
land assembly issues, the planning issues, just the scale of the
development. There needs to be a consistent certainty in planning
policy towards protecting investment in town centres if that sort
of scheme is to come forward, especially in difficult economic
times.
Q72 David Wright: I understand that
now. You are saying we should have a more localised approach,
that it should be down to local communities to make those decisions.
That is basically what you are saying, is it not? You are saying
that local planners should have the capacity to look at the national
economic picture and then interpret this guidance. That is what
I am trying to understand.
Mr Wright: We agree that local
authorities should have the power to set their own priorities
and agendas but developers and industry need certainty, and some
of that certainty is around consistency of application of policy.
If there is more scope for wriggle room on the interpretation
of policy, there was less wriggle room ... There is still wriggle
room under the need test and we query—this is one of the
exercises that we are going through at the moment as we look at
the new proposals—whether there is more wriggle room there
for local authorities to take inconsistent views.
Chair: Thank you very much.
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