Planning matters blog

In Position: A Vision for Town Centres in Wales

Jack Collard 30 Jun 2023

On 2 May 2023, Welsh Government released a new position statement (‘Town Centres’) that offers up a series of actions and activities to support the ‘Town Centre First Policy’: a policy position integrated across existing national planning documents that seeks to focus the delivery of new development within town centres.

But what was included in this position statement and what does it mean for the future of Welsh Town Centres?

Current Town Centre Policy in Wales

In recent years, Welsh Government has invested heavily in supporting Town and City Centres through a wide range of funding programmes. The most recent set of grants came last year when a further £100m of funding was be made available to support town centre regeneration between 2022 and 2025[1] (see table below for a full list of funding generated since 2014).

This grant funding has been supported by strong planning policy in relation to town centres in Wales. ‘Town Centre First’ is a policy position that has been embedded into planning policy documents produced by Welsh Government (see Technical Advice Note 4[2]) and in 2021 this position was bolstered through the introduction and publication of the National Development Framework for Wales (Future Wales: The National Plan 2040³) which makes it clear that the sequential test applies to uses other than retail, recognising that successful town centres are diverse in their composition, and more than just shops.

The policy has also been worked into the previous and current iterations of Planning Policy Wales (Editions 10 and 11[3]), whose purpose is to set out the detail of land use policies in Wales. The ‘Town Centre First’ approach requires local authorities to put “the health and vibrancy of town centres as the starting point of locational decision-making”[4]. Although the policy has been a part of the wider planning framework within Wales for some time, its inclusion as a standalone policy (Policy 6) in the National Development Framework is a demonstration of further commitment to Welsh Town Centres.

This is not least given that the policy requires Strategic and Local Development Plans to now identify (through a sequential approach) the most appropriate town centre locations for “significant commercial, retail, health, leisure and public service facilities”⁴. That said, local authorities should act pragmatically when applying the sequential test, and not refuse planning permission based purely only on a proposal being located outside of town centre, when sites in such locations are not suitable nor available.

For those unfamiliar with Welsh planning policy, PPW and TAN4 broadly echo planning policy for town centres set out in the NPPF in England– though it also requires consideration of the qualitative and quantitative need for new development. In this context, Welsh local authorities are armed with a strong suite of planning policy tools (such as sequential and impact tests) to support town centre development and resist development in inappropriate locations or where a clear need cannot be demonstrated.

However, despite the above supportive policy context for Town Centres in Wales, many centres have experienced well documented[5] challenges over recent years, and are still grappling with high levels of vacancy and low levels of property demand[6].

The Position Statement: ‘Town Centres’

It is against this background that Welsh Government issued a new position statement (Town Centres) on 2 May 2023 which identifies a series of actions and activities to be picked up through cross and local governmental interventions, beyond just the creation of new planning policy, that can support the delivery of the already embedded Town Centres First policy.

The actions and activities can be split into three categories and are summarised as follows:

1. Town Centre First Policy

Re-location Plan: The development of a long-term plan for the location of a diverse range of public services into town centres, supported by asset management strategies and governance structures of public bodies;
Public Sector Spending: Development of a better understanding of the revenue and capital spending and procurement frameworks of key public sector institutions (eg health, education bodies) to ensure that they are aligned with the Town Centre First policy; and
Housing Consortia: Establishment of ‘consortia’ of social landlords and private developers to support and encourage town and city centre living.

2. Policies relating to Out of Town and Connectivity

Planning Power and Re-Use: Strengthening the implementation of the Town Centre First policy in planning, and empowering local planners to refuse developments which do not meet policy requirements and to plan for the adaptive re-use of out-of-town developments;
Transport Plans: Ensuring that Regional Transport Plans take into account the Town Centre First policy; and,
Sustainable Transport: Exploration of “demand management” schemes to support change in the way we travel, address carbon targets and support investment in sustainable transport.

3. Joined Up Delivery:

Placemaking Plans: Ensuring that the Transforming Towns Programme is targeted at the places where it can support transformational opportunities and under a placemaking plan which has been developed locally;
Specialist Body Functions: Development of options to support the delivery of specialist support, including the future remit of the Design Commission for Wales; and
Climate Considerate: Identification of opportunities to ensure Green Infrastructure and nature-based solutions, using circular economy principles, are embedded, and prioritised in decision-making when undertaking works in public spaces within town centres.

Position Statement and Planning Highlights

The statement looks to support the longer term and more joined up planning of urban centres, through providing a series of planning and non-planning focussed cross-governmental and sector-specific actions, that can help ensure a Town Centre First approach is taken by both the public and private sectors well before proposals are appraised against national policy. Some of the actions within the statement seem to be more geared towards the planning industry, and noteworthy amongst these are:

The encouragement of Placemaking Plans for local adoption;
Supporting the adaptive re-use of out of centre developments; and
Supporting Local Authorities to refuse inappropriate development.

It is encouraging that the position statement looks to support local Councils in ways that go beyond the financial support provided in recent years, as alluded to above. Some Welsh councils have very clear city centre regeneration programmes, such as Swansea[7], while others, including Wrexham[8], have specific town centre focussed supplementary planning documents or masterplans, that recognise the challenges facing city and town centres. However, this is far from universal and many Councils are yet to properly acknowledge and lead the drive to repurpose their Town Centres in order to address their changing role and function. The position statement recognises that this is the case and that more targeted support, including a greater emphasis on Placemaking Plans and officer empowerment, is required to support the Town Centre First policy position.

The position statement’s reference to the re-use of purpose built out of town centre developments may also present opportunities and it will certainly be interesting to understand if and how current policy positions can be adapted to support and encourage change.

A ‘Town Centre First’ Approach Beyond Planning

Besides the planning focussed highlights, this position statement offers a whole host of cross-sector actions to support what is considered to be a key policy tenet for Welsh Government (given its specific inclusion as Policy 6 within the Future Wales: National Plan 2040) outlined above. These interventions, actions and proposals Planning policy and top-down Welsh Government intervention are only two aspects of a complicated matrix of policy, plans and stakeholders that influence the development of our Town Centres.

The statement is seeking systemic change to ensure that a Town Centre First approach is taken at every stage of the built environment development process, acknowledging the importance of climate considerations in urban centres and the complexities of public sector spending. It is ambitious; but if effective could enable a pro-active rather than re-active approach to town centre planning and regeneration.

Where From Here? The Next Steps

The actions set out within position statement are intended to support the overarching intentions of Town Centre First policy and now a timeline and demonstration of how each action would be implemented and prioritised is needed. These actions could be achieved through alterations to national or local policy or via the reporting and monitoring of consequential development management decisions including their impacts on physical development and overall town centre health and vitality indicators.

As part of exploring the actions, it will also be important to re-consider how town centre boundaries are drawn. The successful implementation of Town Centre First policy and some of the future plans outlined within the position statement will be reliant on correct and appropriate town centre boundaries. These need to be flexible enough to contract, and alternative uses supported where vacancy levels may be higher, but also allowed to grow as commerce in successful town centres flourishes.

In the event, a combination of effective policy and focussed grant funding, supported through the actions in Welsh Government’s recent position statement, could be the trick to helping to revive high streets across Wales.

[1] Transforming Towns Fund, Welsh Government [September 2022]

[2] Technical Advice Note 4, Retail and Commercial Development [November 2016]

[3] Planning Policy Wales, Edition 11 [February 2021]

[4] Future Wales: The National Plan 2040 – Policy 6 – Town Centre First, p. 71 [February 2021]

[5] Lichfields Blog: Broadening Horizons – Retail and Leisure Post Covid [April 2023]

[6] Welsh Retail Consortium Figures from their Recommendations to the Welsh Budget [November 2021]

[7] See Swansea Council City Centre Improvement Schemes and Strategies Page here

[8] See Wrexham Town Centre Masterplan [Adopted April 2016]

Diddly Squat agreement over Clarkson’s Farm proposals

Daniel Lampard 29 Jun 2023

Article originally featured in Thames Tap (UK Property Forums).

Living near Jeremy Clarkson’s Diddly Squat farm, Dan Lampard, senior director and head of Thames Valley for Lichfields, found the complex planning issues around it a compelling subject for family discussion. Here, he explains in detail the merits of one of the most well-publicised planning wrangles.

Vociferous debates around television viewing in the Lampard household usually revolve around which channel to watch – or when anyone taunts me by supporting a football team other than Arsenal.

Over the Spring, for the first time, the whole family debated the merits of town planning as we all watched Jeremy Clarkson’s highly entertaining efforts to run Diddly Squat farm. We live near the farm, know some of the suppliers benefitting from the incredible success of the farm shop, and one of my children’s teachers made a cameo appearance as a member of the planning committee – so we were all entrenched in our positions.

The majority view was that during hard times, for farmers in particular, the council should be celebrating the success that Clarkson’s regeneration of the farm was bringing about. Conversely, being something of a Clarkson-sceptic and having been stuck in traffic jams caused by visitors to his farm shop I felt some professional sympathy with my town planning brethren in resisting this.

Many of the issues our family argued about were expanded upon in a recent appeal hearing in West Oxfordshire and the decision – something of a score draw – was released last week. Having read in the Witney Gazette that extra security measures were in place at the appeal, given the controversy – including death threats – that had arisen, I’m glad that our family disagreements were more controlled

The appeal decision, one of the most prominent in recent years, warrants analysis as to how such an extraordinary level of interest was generated and how planning can work through such divergent views.

In the beginning . . .

Clarkson owned the farm for a number of years before his collaboration with Amazon but generated little controversy. The whole farm is within the Area of Outstanding Natural Beauty (AONB) – forming a significant constraint in planning policy terms.

The current story begins when West Oxfordshire District Council (WODC) granted permission in 2019 for ‘a lambing shed and farm shop, including car parking and associated access’.

The application (submitted anonymously – ‘c/o agent’) raised few concerns (and none around the 10-space car park) with WODC officers concluding these works ‘would not have a significant harmful impact [on the AONB]’.

Their economic team concluded the proposals offered ‘important investments to allow the farm business to diversify as its reliance on subsidies inevitably reduces’.

Perhaps the only clue to future controversies was that the planning permission also encompassed ‘potential for occasional film-making’.

Fast forward a few months and the farm shop opened. The series records Clarkson eschewing traditional advertising and instead, tweeting his followers – with traffic Armageddon following. One of our friends made her TV debut in the inaugural traffic jam – telling Clarkson she was visiting the farm shop with her sick husband having just collected him from hospital – as you do.

The following couple of years, despite much of it being in Covid lockdown, led to further attempts by Clarkson to expand the economic base of his farm (sometimes without planning permission – as the subsequent enforcement action attests) with further traffic chaos resulting Clarkson himself, observing the traffic chaos and fast dissolving highway verges despaired to the camera: “I just didn’t think this through.”

The decider

These ongoing tensions culminated (for now) in a two day appeal hearing in Witney in March – with the appeal decision being released recently.

Unlike the rest of the series, the appeal hearing may not make compulsive viewing outside the town planning and transport planning fraternity, since there are likely to be too many references to planning units, primary uses and functional and physical relationships to boost the ratings.

In his decision, the inspector grappled with four main considerations. All of these arose from his observation that many of the issues stemmed from ‘the popularity of the appellant, Mr Clarkson, who is a well-known journalist and presenter’ and that, as a result, ‘Diddly Squat has become a destination for visitors from all over the world’.

Specifically, he considered:

Appropriate uses other than agriculture : The inspector commented on the farm’s incredible popularity with visitors, including the trend for them to take ‘selfies’ – surely the first reference to these in an appeal decision. The uses present go far beyond the permitted agriculture, farm shop and lambing shed. The latter, he commented, is not generally a place where ‘one would normally sit to eat food, selected from a more than basic bar menu . . . or drink beer pulled in the same way as your local pub’. – not surprisingly he concluded it had ‘changed from the use for which it was given planning permission’.
Transport harm : The inspector concluded that ‘this is not an ordinary farm shop, given the occupation and high profile of the appellant’. The 10-space car park was never going to be sufficient and unsurprisingly ‘parking has spilled onto the adjacent land’. Somewhat mildly he referred to the car park as being ‘oversubscribed’ with knock-on effects including parking on (and damage to) verges resulting in a ‘huge inconvenience for those who live nearby’.
Harm to AONB : Planning policy is clear that the scale and extent of development within an AONB should be limited. In his analysis, the inspector noted the volume of cars, signage, outdoor seating, catering vans and restaurant, which he concluded ‘has had a deleterious effect upon the character and appearance of the AONB and the tranquillity that planning policy seeks to protect’.
Economic benefits : Conversely, he went on to recognise that the ‘farm shop has been very successful’ and had ‘undergone a radical transformation in less than three years from a farm shop to a tourist destination’.Whilst some harm had arisen from these uses in a sensitive location he was in ‘no doubt that that the farm shop and other activities have contributed to the local economy’ and these ‘benefits are set against the background of any previous agricultural subsidies coming to an end’.

The result is in . . .

It fell to the inspector to adjudicate in a context where the sheer popularity of an enterprise had left the planning system struggling to assess and then control it.

As with all planning decisions the inspector weighed all policy and other matters in the round – specifically the clear harms which he had identified against the ‘benefits to the local economy, employment, farm diversification and agriculture’.

Clarkson fell short of getting all he was seeking although the inspector suggested some sympathy at his ability to reduce the attractiveness of the farm to visitors noting he ‘could not stop the volume of customers arriving lawfully at the site save for closing the enterprise altogether’. He also sensed that, in future years the farm’s popularity may wane, noting there was ‘a lack of clarity over how long the successes of the farm shop will continue’.

Overall, and in the spirt of balance, he concluded that ‘a new car park would reduce the adverse effects of the current parking situation on the AONB and upon highways safety’ but would not see a complete end to parking off site and that a temporary solution would be appropriate to ‘limit the use to a period of three years and requiring restoration of the site following that period’.

In the same spirit of short-termism, he also permitted the use of the lambing barn as a café for three years but refused the other elements – most notably the restaurant.

The Lampards are looking forward to Series Three already.

Well-Placed – A good judge of (townscape) character?

Michael Lowndes & Judith Livesey 28 Jun 2023

The Government’s ‘beauty’ agenda has increased the focus on the design quality of new buildings and places and whether they are compatible with existing character. The constituent components of well-designed places are articulated in the National Design Guide with the National Model Design Code providing a further steer. But there is often tension in balancing the different aims of sustainable development; whether making efficient use of land or through pursuing viable low or net-zero carbon schemes while also contributing to an appropriate sense of place.

Unsurprisingly there are often differing opinions on the acceptability of the design solutions being put forward for their contexts, with debates typically revolving around the thorny issues of increased height or intensity of development, whether new buildings and places would complement or reinforce existing character or whether creating a new, well-designed, sense of place would be appropriate. What is surprising - and often frustrating - is that such concerns are not just raised where development is being introduced into historic townscapes but also in relation to sensitively designed schemes on allocated sites, in opportunity areas and locations where change would relate to unremarkable, sometimes poor, townscapes. Should recently proposed changes to the NPPF come forward, consideration of whether proposals are ‘significantly out of character’ with an area will gain greater importance, and may need balanced and well-evidenced assessment of beauty as measured by national and local design guidance.

Lichfields' Good Place Framework, Well-Placed, aims to directly address these issues. Drawing on robust analysis of existing character, an understanding of design policy and good urban design practice, the Good Place Framework provides a balanced analysis of whether development would deliver a well-designed place and how any competing design policy requirements have been reconciled.

A good understanding of existing character, sense of place and identity is the essential starting point. Robust character analysis needs to both underpin the design approach, including whether, in accommodating new development, townscape character should be respected or whether it could be reinforced or reinvented. Although existing townscape character is sometimes set out in local authority urban characterisation studies, coverage remains patchy and the quality and level of detail can be variable. Bespoke townscape character analysis is generally needed, ideally from an early stage of the design process, to fully understand sensitivities, opportunities and to inform design evolution.

While townscape and visual assessment is often helpful and provides a widely accepted approach for assessing the effects on townscape character and views, for some projects this may need to be combined with a more rigorous evaluation of the performance of a scheme against a framework of the local and national design criteria to help decision makers determine whether development would overall deliver a high quality design. Such assessment is particularly relevant and helpful when introducing new development typologies and when increasing height and intensity to optimise the use of land which to some extent will change the character of places (for example, intensification in a suburban context).

Well-balanced, robust and authoritative analysis is required to determine whether this will lead to a well-designed and ‘beautiful’ place overall. This is not a generic exercise but one specific to each project and location.

Our well-placed product provides this analysis. If you need any more information, please contact Judith Livesey or Michael Lowndes

The march of the discount retailers

Peter Wilks 21 Jun 2023

Amongst the doom and gloom in the retail sector, discount operators continue to thrive. Aldi, B&M, Home Bargains, Lidl, and Iceland’s “The Food Warehouse” brand have embarked on rapid store expansion programmes over the last ten years, exponentially increasing their market share of retail sales. This trend has continued during the recent cost of living crisis. Indeed, whilst there are signs of a slowdown in some parts of the country, Aldi has recently announced plans to open at least 60 stores in London.

From niche to mainstream

Once looked down upon, discounters are many people’s favourite stores. Aldi and Lidl first entered the UK market in the early 1990’s and were viewed as value retailers that did not compete directly with the mainstream foodstores. However, with lower prices, derived from limited product ranges and minimalist store designs, they gradually won over customers.

Households moving away from one bulk weekly shop helped them grow, realising that value doesn’t necessarily come without quality. In terms of total retail sales amongst the main food store operators, the market share of these five discounters has increased significantly since 2014 – from around 14% to circa 22%.

A new race for space

As shown below, the discount sector has thrived, with B&M being the star performer, more than doubling its estate over the period since 2014, and Aldi, Home Bargains and Lidl all increasing their total floorspace by around 50% or more. In contrast, with the exception of M&S and the Sainsbury’s Local format, the other mainstream food retailers have experienced only modest growth, or indeed a slight decline in retail space over this period.

Non-food has joined the party

Whilst much of the growth in the discount sector has been driven by Aldi and Lidl, other chains have emerged with a stronger non-food emphasis. The largest of these – B&M and Home Bargains – operate both in town centres and retail parks, selling a broad range of products. Whilst the non-food offer is the main draw, they also sell ambient food produce, and other items often purchased as part of a weekly (or more occasional) food shop, for example, pharmaceuticals and cleaning materials. Home Bargains currently have around 600 stores but plan to expand to 1,000 outlets, employing over 40,000 staff.

Expansion is continuing

The number of discount stores has nearly doubled overall since 2014. Whilst some areas have now reached saturation point, store expansion plans are likely to continue in under-represented locations. Although the outlook for convenience goods (i.e. food) spending growth in the short term is relatively weak, there will still be a need for new foodstore development in many areas. This could result from geographic deficiencies in provision and/or areas with significant housing growth planned. In such circumstances, there is a decent prospect of demand emerging from discount food retailers.

The potential for further expansion is highlighted in the latest information from Kantar – a leading data analyst – which indicates that the market shares of both Aldi and Lidl have continued to increase over the last year. That of Aldi has increased from 14.1%, when measured over the twelve weeks to 17 April 2022, to 10.1% over the twelve weeks to 16 April 2023, with that of Lidl increasing from 6.6% to 7.6% over the same period. According to Kantar, total sales have increased by around 25% (in absolute terms) for both retailers.

Retail planning skills remain important

Local authorities need to direct any future demand to the most sustainable locations, in line with the sequential test, and ensure that there would be no significant adverse impacts, as required by the National Planning Policy Framework (NPPF). Any sequential and impact assessments need to be carefully considered by Councils, before it can be concluded that these tests are satisfied. Given our expertise in both preparing and reviewing such assessments, Lichfields are well placed to assist with this.

As well as filling gaps in provision, new discount retail stores can also deliver significant socio-economic benefits. By way of example, a typical Lidl store will generate up to 40 FTE (full time equivalent) jobs, with staff being drawn from their local community, with a new Home Bargains creating around 60 FTE jobs. These jobs will be in a variety of positions, including management, customer service, restocking, sales and cleaning, providing opportunities at a variety of skill levels.

Although store expansion programmes are not immune to the current economic headwinds, discount operators remain a shining light in an increasingly challenging retail sector. Having been embraced by the general public, they are certainly here to stay, and their continued expansion provides a valuable opportunity to help meet future needs.

Image credit: Gustavo Fring via Pexels

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