Retail and Main Town Centre Uses - Supplementary Planning Guidance 2024

Contents

1. Introduction

2. The Sequential Test - Policy RET1

3. Assessment of Need and Impact - Policy RET1

4. Retail Impact Assessment - Policy RET2

5. Needs Assessment - Policy RET2

Appendix 1: Glossary of Terms and Abbreviations

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1. Introduction

1.1 This Supplementary Planning Guidance (SPG) provides additional guidance specific to retail and other town centre development in Mid and East Antrim Borough.

It is intended for use by applicants, the public and by the council in the assessment and delivery of planning proposals for retail and other town centre development within the Borough.

1.2 Supplementary Planning Guidance represents non-statutory planning guidance that supports, clarifies and/or illustrates by way example, policies included within the current planning policy framework, including development plans and regional planning guidance.

The information set out in this SPG is therefore a material planning consideration in determining planning applications and should be read in conjunction with the existing planning policy framework, most notably the Strategic Planning Policy Statement (SPPS) for Northern Ireland and the Mid and East Antrim Borough Council Local Development Plan (LDP).

1.3 The Retail policies aim to protect and sustain the vitality and viability of our established town centres and small town centres so they can perform to their maximum potential in meeting the needs of the citizens and visitors and contribute to the economy of Mid and East Antrim.

They promote established town centres as the appropriate first choice location for retailing and other main town centre uses and require a sequential approach to the identification of sites for retailing and main town centre uses, to minimise the impact of out of centre retailing and to protect and enhance diversity in the range of town centre uses.

1.4 In order to aid the effective implementation of relevant retailing policies, the Council considers it prudent to produce this guidance.

It is aimed at providing further clarity to landowners, developers and agents. It does not introduce new policy.

It aims to ensure that the existing policy is implemented and applied consistently and effectively through the development management process.

1.5 Mid and East Antrim Borough Council encourages and welcomes early engagement with applicants to agree the scope of any sequential and/or impact test.

Applicants are advised to utilise the council’s Pre-Application Discussion (PAD) scheme, where appropriate, to discuss any planning issues and agree the scope of the assessment at an early stage before the submission of a planning application.

1.6 Primarily, this SPG provides guidance on the implementation of Policies SGS7, RET1 and RET2.

1.7 For additional guidance relating to main town centre uses which are considered sensitive in nature please refer to the Sensitive Uses Information leaflet.

These uses include amusement centres, bookmaking offices, restaurants, cafes and fast-food outlets, taxi offices and public houses.

2. The Sequential Test – Policy RET1

2.1 Policy RET1 provides the proposed policy approach in relation to the sequential test for planning applications for retail and other town centres uses.

Policy RET1 (First Half)

Proposals for retail development will be permitted within town centre and small town centre boundaries where defined. For other locations, a sequential approach to site selection will be applied in the following order of preference: a) Edge of Town Centre boundary (i.e. adjoining it or normally within 300 metres); and b) Out of centre locations (i.e. outside the town centre boundary but within settlement limits) where sites are accessible by walking, cycling and public transport. Proposals for other town centre uses (cultural and community facilities, leisure, entertainment and businesses) shall also follow the same sequential approach.

What is the Sequential Test?

2.2 The sequential test is an approach that seeks to direct relevant development to within town or small town centres before an edge of centre or out of centre site.

It supports the viability and vitality of town centres by placing existing town centres foremost in both plan-making and decision-taking.

2.3 In the Mid and East Antrim context, there are four tiers in the Retail Hierarchy - town centres, small town centres, local centres and village centres (including designated small settlements).

Policy RET1 refers to the top two tiers of the Retail Hierarchy.

2.4 The sequential approach guides retail and other town centre uses to sites within town centre or small town centre locations first.

If no town or small town centre sites are available, suitable or viable, developers should consider an edge of centre location.

Only when town or small town centre locations or edge of centre locations are thoroughly examined and ruled out, can consideration be given to an out of centre location.

In such cases the developer will still be required to demonstrate that the proposal will not harm existing centres in the catchment.

2.5 For clarity, the centres will be defined at the Local Policies Plan (LPP) stage of the Mid and East Antrim LDP, but until the LPP is adopted the town centre boundaries and ‘commercial centre’ designations as defined in the existing Area Plans will be taken as the town centre boundaries.

This is set out in footnote 28 of the Plan Strategy.

2.6 The sequential test to site selection for retail and other main town centre uses will therefore require applicants to consider sites in the following order of preference:

Town Centre/Small Town Centre - Edge of Centre - Out of Centre

2.7 Where it is established that an alternative sequentially preferrable site or sites exist within the proposal’s retail catchment, an application which proposes development on a less sequentially preferrable site should be refused.

2.8 Compliance with the sequential test however does not guarantee that permission will be granted.

The council will have to consider all other material considerations in reaching a decision including an assessment of the impact and need of the proposal, if appropriate.

The following sections of this document provides further detail on impact and need tests.

2.9 Where proposals relate to extensions to existing retail development, the sequential test will also be applied.

This approach is in line with the SPPS which does not draw a distinction between new development or extensions to existing development in the application of the sequential test.

When is a sequential test required?

2.10 A sequential test should be applied when an application for retail or other town centre development is proposed either in an edge of centre or an out of centre location.

This is in line with Policy RET1 of the Plan Strategy and the SPPS.

2.11 The designated centres for Mid and East Antrim are town centres and small town centres as indicated in Policy SGS7 of the Plan Strategy, which sets out the Retail Hierarchy.

As outlined in paragraph 2.5 above the town centre boundaries of Ballymena, Carrickfergus and Larne town centres defined in Ballymena Area Plan 1986-2001, Carrickfergus Area Plan 2001 and Larne Area Plan 2010 and the Commercial Centres defined in the Ballymena Area Plan 1986-2001 for Ahoghill, Broughshane, Cullybackey and Portglenone should be used during the transitional period between the adoption of the Plan Strategy and the adoption of the Local

Policies Plan.

Whitehead is the only remaining small town in the Retail Hierarchy and it currently does not have a Commercial Centre defined in the Carrickfergus Area Plan 2001.

Therefore, until the adoption of the LPP, sites anywhere within the settlement limits are considered appropriate in terms of sequential preference.

Carrying out a sequential test

2.12 There are four key steps to follow when undertaking a sequential test.

Step 1 - Establish the appropriate catchment for the proposed development

Step 2 - Decide which designated centres should be assessed

Step 3 - Identify the sequentially preferable sites which should be assessed

Step 4 - Assess the suitability, availability and viability of these sites

Step 1: Establish the appropriate catchment for the development

2.13 The catchment is the area the proposal is intended to serve/draw trade from.

This will vary depending on the specific development proposed and the applicant will need to suggest an appropriate drive time from the proposal site, taking into account the size and type of development, the market in which the development will operate, any relevant characteristics of the business/operator model and where competitor developments are located.

2.14 For example, if a 1,000 sq. m food store came forward in a small town with little by way of existing competition, then it might be expected to draw trade from a quite a large catchment area, including several hinterland settlements.

However, if a 1,000 sq. m food store came forward in the suburb of a main town, then it might have considerable nearby competition which people would be unlikely to drive past, meaning its catchment area would be much smaller.

2.15 The map at Figures 3 (available in the downloadable document) demonstrates an example of an acceptable approach to defining a catchment for a retail application near the council boundary.

The map shows, in this case, a 15 minute drive time from the out of centre proposal site located to the south-west of Carrickfergus town centre, with the catchment extending into Antrim/Newtownabbey Borough Council area.

An incorrect approach would be to stop the catchment at the council boundary.

Scope of Impact Assessment

4.16 The basis of any assessment will normally consider potential impacts on designated centres within the catchment area, as well as a range of sites to consider under the sequential test.

In line with best practice impact should be considered over time, up to five years for most schemes.

4.17 Where proposals relate to a specific type of goods (for example, a DIY retail warehouse) it may be appropriate to focus the impact assessment on that specific sector, notwithstanding the need to consider the impact of the proposal on the overall vitality and viability of centres. In such instances, appropriate conditions to restrict the development in line with the impact assessment undertaken, will be imposed.

4.18 If unconditional consent is sought for retail or other uses (for example, with no limitation on net sales area, unit sizes, range of goods and so on) then the supporting assessment should examine all of the potential impacts and policy compliance of the full range of possible permutations which would be permitted under the proposed planning permission.

4.19 In assessing the impact of the proposal on existing, committed and planned public and private investment, consideration should be given to a range of factors including:

• What stage they have reached e.g. are they contractually committed?;
• The policy ‘weight’ attached to them (for example, are they a key provision of the development plan?);
• Whether there is sufficient ‘need’ for both the proposal and the existing/committed/planned investment?;
• Whether they are competing for the same market opportunity, or key retailers/occupiers?;
• Whether there is evidence that retailers/investors/developers are concerned; and
• Whether the cumulative impact of both schemes would be a cause for concern.

4.20 Where the catchment extends into other council areas, the council may ask for input from the relevant neighbouring council(s) in identifying factors which should be taken into account in any assessment, and in providing any relevant information, such as monitoring data, retail and leisure studies, or town centre health check data.

4.21 The council’s most recent Retail & Commercial Leisure Need & Capacity Study should provide a starting point to inform any impact assessment, but the applicant should consider whether updates are appropriate depending on the length of time that has passed since this study, or its most recent update was published.

For growth rates, spend per head and special forms of trading etc. the most up-to-date data sources should be used to update figures.

Town centre vacancy rates can be found in council’s town centre land use surveys.

Other sources such as Experian GOAD are available however the extent of their survey may not follow the same extent as the designated town centre boundaries so a combination of sources should be considered.

4.22 Ideally a common data source should be used where possible when quoting figures such as turnover etc, however if this is not possible an explanation should be given as to why multiple sources are being used.

4.23 A judgement as to whether the likely adverse impacts are significant can only be reached in light of local circumstances (for example, in areas where there are high levels of vacancy and limited retailer demand, trade diversion from a new development may lead to a significant adverse impact).

4.24 Evidence showing that there would be no likely significant impact on a town centre or small town centre from an edge of centre or out of centre proposal, does not guarantee that permission is granted.

The council will have to consider all material considerations in reaching a decision including the sequential test and need, if appropriate.

Methodology for Step-by-Step Approach to carrying out a Retail Impact and Assessment of Need

Step 1: Identification of the Catchment Area

4.25 The identification of the catchment area, and the proportion of trade drawn from this area, is an important stage in the RIA and it will directly affect the assessment of trade diversion from competing centres and retail impact.

If the proposal is to be situated out of centre or at an edge of centre site, the applicant must consider the likely catchment of the proposal with reference to travel distances determined from survey of comparable facilities elsewhere in the borough.

If no comparable facilities are located within the Mid and East Antrim council area, then comparison should be considered for facilities elsewhere in Northern Ireland.

4.26 In addition to determining the catchments of the adjacent centres, the catchment area needs to be sufficiently wide enough to ensure that the influence of the proposal can be assessed.

Step 2: Determine the appropriate time frame for assessing impact, focusing on impact in the first five years (up to design year):

4.27 The base year for impact testing should generally be selected to represent the year when the proposal application has been submitted.

4.28 The design year for impact testing should be selected to represent the year when the proposal has achieved a ‘mature’ trading pattern.

This is conventionally taken as the second full calendar year of trading after opening of each phase of a new development, but it may take longer for some developments to become established.

Step 3: Examine the ‘no development’ scenario:

4.29 This should not necessarily assume that all centres are likely to benefit from expenditure growth in convenience and comparison goods and should reflect both changes in the market or role of centres, the impacts of online shopping as well as changes in the environment such as new infrastructure.

The effects of wider trends therefore need to be considered.

4.30 Longer term trends and local market dynamics are likely to indicate that some retail destinations are going to improve while others decline, irrespective of the proposed planning interventions.

Therefore, further factors need to be considered in examining the “no development” scenario.

Commitments/cumulative impact

4.31 Applicants must consider the effect of known commitments and consider the cumulative impact of the proposals in question.

4.32 In judging which commitments should be considered, it will be relevant to consider, amongst other things, the likelihood of them being implemented, and their potential scale and significance.

The range of factors to be considered are detailed at paragraph 4.20 above.

4.33 In the case of proposals which are not in accordance with an up-to-date local development plan and not within an existing centre, their effects on a planned investment in a nearby centre may be highly material.

4.34 Equally, any adverse impacts as outlined above should be balanced against the positive effects of the proposals, in terms of investment; employment generation; social inclusion; and physical and economic regeneration.

The ‘fall-back’ scenario

4.35 Where relevant, a further consideration is the so called ‘fall back’ scenario, i.e. where through an extant permission or permitted development rights it is argued that there is a ‘fall back’ position which may be implemented if the current proposal is not approved.

4.36 It is possible in some cases that a specific proposal may have a lesser impact than the proposal for which consent is being sought.

Alternatively, an application might provide the opportunity to impose planning restrictions which could mitigate impact.

However, in judging the relevance of a ‘fall back’ position, the following factors should be considered:

• First, the relevance of a fall-back position should be judged having regard to the likelihood of it being implemented.
  
  There is a difference between a purely ‘hypothetical’ fall-back position, and a position which could be implemented.
  
  If there is a realistic prospect that the fall-back position would be brought forward, then it would be necessary to attach appropriate weight to it in judging the impact of the proposal in question.
   
• Second, when comparing the impact of a proposal with a fall-back position, it will be relevant to consider the impact of the proposal together with the cumulative impact of other known commitments within the catchment, rather than just the ‘incremental’ impact of the difference between the two.
  
  This applies to all impact assessments, where the relevant test is the cumulative impact of the proposal in question.

Step 4: Assess the proposal’s turnover and trade draw:

4.37 This can be achieved by drawing on information from comparable schemes, the operator’s benchmark turnover of convenience and comparison goods, and carefully considering likely catchments and trade draw.

The relative offer of goods, and the geography of competing destinations, will both be key considerations in respect of determining trade draw.

Applicants should set out a transparent assessment of trade draw, detailing likely draws in both percentage and monetary terms.

Step 5: Consider a range of plausible scenarios in assessing the impact of the proposal on existing centres and facilities:

4.38 This may require breaking the study area down into a series of zones to gain a finer-grain analysis of anticipated impact (for example, by drive-time band or postcode sector).

This may also require inclusion of committed developments within the catchment area (proposals that have gained planning permission and can therefore be developed).

Step 6: Set out the likely impact of the proposal, along with any associated assumptions or reasoning, including in respect of quantitative and qualitative issues:

4.39 Any conclusions should be proportionate, for example, where a smaller proposal is concerned, it may be sufficient to give a broad indication of the proportion of the proposal’s trade draw likely to be derived from different centres and facilities in the catchment area and the likely consequences to the viability and vitality of existing town centres.

However, for larger proposals, which have more obvious trade draw repercussions, a more detailed assessment will be required.

As per earlier guidance, in all instances, the impact of the proposals should be clearly related to up-to-date health-checks of existing centres within the catchment area.

4.40 A Proposal in an out-of-centre location cannot claim to contribute to capacity figures shown in the councils Retail & Commercial Leisure Need & Capacity Study without also successfully demonstrating compliance with the sequential, needs and impact tests too.

Capacity is not a target to be reached.

There should therefore be no sense that an out of centre proposal necessarily ‘contributes’ to meeting a need without further justification.

It may be that, if there is no sequentially preferable site, and that impacts are acceptable, an out of centre proposal is helpful in some instances (e.g. if it contributes towards saving lengthy return journeys to far-away places).

However, it may equally be the case that an out-of-centre proposal would offer little or no help or might impact the town centre unacceptably. In that instance, the town would be better off without the proposal as the proposal does not contribute at all.

4.41 While thresholds are expressed in gross terms in regional policy and consequently in policy RET2, it is acceptable for impact to be calculated in net terms as normally the trading area of a proposal is used to align with the sales density to estimate the projected turnover of the proposed development.

4.42 If a proposal includes multiple areas of trading floorspace such as a main building and a separate building or outdoor area, such as a garden centre, impact has to be assessed based on the total of all trading floorspace.

4.43 If a proposal is claiming to improve the qualitative offer or increase diversity, choice and competition with its proposed goods type(s), an assessment is expected as a minimum, of existing diversity and choice and an assessment of what ‘gaps’ might exist which the proposed operator would fill, for example by listing existing retailers with similar offers and examining the overlap of trade.

4.44 A retailer’s commercial ‘need’ to be in a certain location is not evidence enough of qualitative need.

4.45 To date, the focus of impact assessments has been on retail proposals, particularly the key town centre impacts.

However, for other non-retail uses which are still considered ‘other town centres uses’ it is unlikely that several of the key impacts set out in policy will be considered in the same level of detail (e.g. trade diversion).

There may be cases, for example, where a key town centre site is earmarked for a particular mix of uses, which depends on securing key occupier requirements.

There may be a legitimate concern that a new development will cause displacement and/or deflect occupier demand to a less central location.

4.46 In every case it will be necessary to reach a balanced decision, having regard to the provisions of the development plan, the sequential approach and impact considerations.

5. Needs Assessment – Policy RET2

What is an assessment of need?

5.1 An assessment of need identifies the needs of consumers and the requirements of retailers, leisure operators and others proposing development for town centre uses.

5.2 The SPPS states that when undertaking an assessment of need, this should be proportionate to support the application and may incorporate a qualitative and quantitative assessment of need taking account of the sustainably and objectively assessed needs of the local town and take account of committed development proposals and allocated sites.

5.3 The basis of any needs assessment will normally consider the proposed expenditure growth of the council area and quantum need for floorspace, minus the floorspace required for committed developments.

5.4 A quantitative needs assessment requires the following steps:

• Identification of catchment area, base and design years for the assessment;
• Identification and projection up to design year of population and total available expenditure within the catchment area;
• Estimation of the proposal’s turnover; and
• Estimation of capacity within the development to include committed developments.

5.5 A Qualitative Assessment contrasts the existing quality of goods, services, or retail environment on offer within the defined catchment area, and whether the proposed development would help to address any existing deficiencies or ‘gaps’ in the market, and/or offer any beneficial broadening of choice and competition.

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Appendix 1: Glossary of Terms and Abbreviations

Glossary of Terms

Capacity	Forecast resident spending within the catchment area, with which to support existing and additional retail floorspace.
Centre(s)	Refers to the main town centres of Ballymena, Carrickfergus and Larne, Small town centres of Ahoghill, Broughshane, Cullybackey and Portglenone (pre LPP the small town centres are known as Commercial Centres) Whitehead town centre (Pre LPP Whitehead Settlement Limit will act as the town centre).
Commercial Centre	Designation of the largest concentration of shopping within a town or small town centre.
Comparison Goods	Durable items for which customers are prepared to travel some distance to compare prices and quality. They include clothes, footwear, household durables, textiles, fashion accessories, toys, hardware and leisure goods.
Comparison Goods (Bulky)	This is a subset of comparison goods retailing. It describes those comparison goods which are difficult to accommodate in town centres because of their space requirements for large showrooms, parking and servicing. They typically include large items such as furniture, carpets, electrical/white goods and DIY goods, and are typically sold from retail warehouses.
Convenience Goods	Mainly groceries and other consumable commodities that are purchased regularly and usually locally. They include food, drink (including take home alcohol), tobacco, newspapers, magazines, cleaning materials and toiletries.
Edge-of- Centre	For retail purposes, a location that is well connected and within easy walking distance (i.e. normally 300 metres) of the town centre boundary. In determining whether a site falls within the definition of edge-of- centre, account should be taken of local circumstances such as barriers, railway lines or major roads.
Expenditure	Average annual expenditure levels for various forms of goods, multiplied by the population within the defined Study Area.
Experian GOAD	A retail property intelligence system that helps retail developers, property investors, planning professionals, and commercial agents to identify profitable locations for retail property development and investment projects. It offers comprehensive retail location plans and easy to use reports covering over 3,000 shopping areas in the UK and Ireland.
Financial, Professional & other Services	Services provided to visiting members of the public such as banks, building societies, employment agencies, legal services, estate agents and business services.
Gross Floor Area	This is the total floor area of a building measured externally.
Gross Retail Area	This is the total internal retail floorspace, as measured from inside the retail unit and includes sales space storage space and ancillary space, including offices, toilets and canteen.
Leisure Services	An Experian Goad category for town centre leisure units which includes bars, cafes, cinemas, nightclubs, take-aways, hotels, public houses, and restaurants. For clarity, it does not include facilities for leisure pursuits e.g. sports centres, swimming pools or health & fitness clubs.
Local Policies Plan (LPP)	The second part of the Local Development Plan, the LPP is prepared by Council following adoption of the Plan Strategy.
Main Town Centre uses	Retail development, Use Class A1 shops, Use Class A2 financial, professional and other services, Use Class B1 businesses, cultural and community facilities, leisure and entertainment, and town centre housing.
Market Share	The proportion of residents that visit a particular retail destination, derived from household survey results.
Net Retail Area	This is also referred to as sales space and includes the area of the unit which is devoted to the display and sale of retail goods. It includes checkout counters, packing zones, circulation space from check-outs to exit lobby, changing rooms and information areas. Net retail floorspace is calculated by way of internal measurement to the inner face of the wall.
Out-of-Centre	A location outside a centre boundary but within defined settlement limits.
Population Projections	Estimates of future population based on the most recent census and/or NISRA populations estimates and applying NISRA population trends.
Retail Floorspace	Total floor area of the property that is associated with all retail uses in square metres. May be expressed as a net figure (the sales area) or in gross (including storage, preparation and staff areas.
Retail Hierarchy	Towns, Small Towns, Local Centres and Village centres (including small settlements).
Retail Services	An Experian Goad category comprising for example dry cleaners, health & beauty, opticians, photo processing, post offices and travel agents.
Retail Warehouse	Large single-level individual store, with car parking, for the sale of bulky comparison items such as DIY goods, furniture, electrical goods, carpets and gardening goods.
Retail Impact	The potential effects of proposed retail development upon existing shops.
Sales Density	Turnover, per square metre. Various retail planning sources such as Verdict UK Food & Grocery Company Briefing Reports and Mintel Retail Rankings provide average (or benchmark) sales densities for national multiple convenience retailers.
Sequential Approach	A planning principle that seeks to identify, allocate or develop certain types or locations of land before others. For example, brownfield housing sites before greenfield sites, or town centre retail sites before out-of-centre sites.
Special Forms of Trading	Special forms of trading (SFT) are defined as sales via the internet, mail order, stalls and markets, vending machines, door-to-door and telephone sales, including online sales by supermarkets, department stores and catalogue companies.
Town Centre	Town centres which provide a broad range of facilities and services and which fulfil a function as a focus both for the community and for public transport.
Town Centre Health Check	Town centre health checks are an important starting point to ensure the vitality and viability of town centres are maintained/improved. Town Centre Health Checks are carried out by the council and their outcomes are fed into the assessment of impact of proposals on the vitality and viability of town centres. Applicants should make themselves aware of the existing/current health check for town centres as this information will be used by the council when assessing your application. Health checks will be carried out at least every five years.
Trade Draw	Trade draw is the proportion of trade that a development is likely to receive from customers within and outside its catchment area. It is likely that trade draw will relate to a certain geographic area (i.e. the distance people are likely to travel) and for a particular market segment (e.g. convenience retail). The best way of assessing trade draw where new development is proposed is to look at existing proxies of that type of development in other areas.
Turnover	Amount of Sales per Unit Area of Floorspace.
Viability	A measure of a town centres capacity to attract ongoing investment for maintenance, improvement and adaption to changing needs.
Viability	A measure of how busy a town centre is.

Glossary of Abbreviations

KSR	Key Site Requirement
LDP	Local Development Plan
PAD	Pre-Application Discussion
PS	Plan Strategy
RDS	Regional Development Strategy (2035)
SPPS	Strategic Planning Policy Statement for Northern Ireland (2015)