London Borough of Camden Camden Local Plan Background Paper Retail and town centre evidence

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Camden Local Plan Retail and Town Centre Evidence 1 London Borough of Camden Camden Local Plan 2016 Background Paper Retail and town centre evidence June 2016

Camden Local Plan Retail and Town Centre Evidence 2 1. Introduction... 3 2. Policy context... 3 3. Evidence... 4 4. Local Plan approach... 6 5. Conclusion... 8

Camden Local Plan Retail and Town Centre Evidence 3 1. Introduction 1.1 This paper provides describes how the evidence produced in the Camden Retail and Town Centre Study has been used to inform development of the retail and town centre policies in the Local Plan; in particular policy TC1 Quantity and location of retail development, and policy TC2 Camden s centres and shopping areas. 1.2 The paper demonstrates that the policy is sound, complies with national and London-wide policy and guidance and is supported by robust evidence. 2. Policy context National Planning Policy Framework 2.1 The National Planning Policy Framework (NPPF) states that 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 (NPPF paragraph 23). 2.2 It also states that local planning authorities should: define a network and hierarchy of centres that is resilient to anticipated future economic changes, and 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. 2.3 Paragraph 24 of the NPPF states that local planning authorities should apply a sequential test to planning applications for town centre. This test should require applications for town centre uses to be located in town centres, then in edge of centre locations, and only if suitable sites are not available should out of centre sites be considered. London Plan 2.4 Policy 4.7 of the London Plan sets out the Mayor s policies for retail and town centre development. It states that retail, commercial, culture and leisure development should be focused on sites within town centres, or if no in-centre sites are available, on sites on the edges of centres that are integrated with the existing centre and public transport. 2.5 The London Plan states that in plan preparation local authorities should identify future levels of retail and other commercial floorspace need (Policy 4.7Ca) and undertake regular town centre health checks to inform strategic and local policy and implementation (Policy 4.7Cb).

Camden Local Plan Retail and Town Centre Evidence 4 2.6 Policy 4.8 of the London Plan set out the Mayor s approach to the retail sector. Key elements include: Bringing forward capacity for additional comparison goods retailing particularly in International, Metropolitan and Major centres, Supporting convenience retail in neighbourhood centres, and Managing clusters of uses. Mayor of London Town Centres supplementary planning guidance 2.7 The Mayor s Town Centres supplementary planning guidance (SPG) seeks to co-ordinate the development of London s network of town centres across the capital in line with the hierarchy set out in the London Plan. The SPG also givers more detail on the Mayor s approach to planning decisions and plan preparation. It encourages local authorities to: Promote a viable and diverse mix of retailing, Assess demand based on up to date estimates and evidence, Understand the need for modern fit for purpose spaces, Develop local and proactive plans to accommodate additional retail, and Define primary and secondary frontages. 3. Evidence Camden Retail and Town Centre Study 2013 3.1 LB Camden commissioned GVA to produce the Camden Retail and Town Centre Study 2013. The study is a comprehensive borough-wide review of retail provision within Camden s town centres and central London frontages and provides an update of previous retail studies for the borough undertaken in 2004 and 2008. 3.2 The study provides the Council s retail evidence base to inform the Local Plan policies on town centres and retail provision, and sets out recommendations for the borough s six town centres and three central London frontages. Town centre challenges 3.3 The Camden Retail and Town Centre Study highlights the challenges that face the high street. The study states that while the UK economy is continuing to struggle following the recession household finances will gradually improve, reverting to modest growth. Within London, the retail sector appears to be more resilient to the impacts of the recession than other regional and smaller centres.the town centre has been the main

Camden Local Plan Retail and Town Centre Evidence 5 place where people shop for the last 30 years, however its role is set to change with trends suggesting that in future it will be used more for leisure and social activities. 3.4 In addition the Study anticipates that online sales (as a share of retail spend) will grow from 10.5% to 14.9% by 2017. In estimating retail demand, the Study made deductions for online sales. The study also states that it is important for Camden to protect the non-retail offer in its centres to provide an attractive shopping and leisure experience that cannot be provided online. Demand for retail floorspace in Camden 3.5 The Camden Retail and Town Centre study estimates that the demand for retail floorspace in the borough will increase. It estimates that convenience goods expenditure will rise by 21% between 2013 and 2031 and create demand for an additional c.11,700sqm net of convenience goods floorspace by 2031. Comparison goods expenditure is estimated to rise by 44% over the same period and create demand for an additional c.20,724sqm net of comparison goods floorspace by 2031 (GVA, page 61). This combined floorspace demand of more than 30,000sqm is required in addition to the floorspace that will be provided in the Kings Cross Growth Area. Town centre boundaries 3.6 The Camden Retail and Town Centre study examined the existing adopted town centre boundaries are did not make any recommendations for change, stating: On review of the town centre boundaries we consider that the defined town centre boundaries for each of the centres appear reasonable, and incorporate the full extent of retail provision in the centres. Due to the relatively constrained nature of the majority of the town centres in the Borough, and the resultant limited site opportunities to accommodate significant levels of retail growth, we consider that it would not be appropriate to reduce the extent of any of the town centre boundaries (GVA, page 82). Eating and drinking provision 3.7 The Camden Retail and Town Centre study states that the priority core function of town centres is retail, but there will be circumstances where a broader town centre function should be encouraged for town centres to remain competitive over the long term. The study states that none of the town centres have a particular deficiency in eating and drinking provision, and describes opportunities to improve the eating and drinking provision for each of the centres.

Camden Local Plan Retail and Town Centre Evidence 6 4. Local Plan approach 4.1 The Council has considered its approach to town centres and retail development in light of the trends identified in the evidence study and national and London-wide policy. The Plan: Promotes retail development in the Growth Areas, Town Centres, Central London Frontages, with appropriate provision in Neighbourhood Centres and Specialist shopping areas (Policy TC1), Maintains a sequential town centre first approach (Policy TC1), Manages the mix and balance of uses within centres (Policy TC2), and Protects primary frontages with a high proportion of shops to preserve the retail function of the centre, and allows a broader range of town centre uses including cafes, restaurants, and service uses on the secondary frontages (Policy TC2). Further detail is set out below. Town centre boundaries 4.2 The existing Local Development Framework sets out the boundaries for the Town Centres, Central London Frontages, and Neighbourhood Centres and these boundaries are shown on the Policies Map. The proposed boundaries for the centres for the Local Plan are set out in Appendix 3 of the Local Plan Proposed Submission. The Camden Retail and Town Centre study found the boundaries of the centres to be appropriate and did not suggest any amendments. Therefore the Local Plan town centre boundaries are the same as those on the current Policies Map, with the exception of a number of small amendments which are set out in in Appendix 3 to the Local Plan (Policies Map Changes), page 78. Policy TC1 Quantity and location of retail development 4.3 Local Plan Policy TC1 Quantity and location of retail development sets out the Council s overarching approach to retail development in the borough. It has been prepared to be in line with the NPPF and is drawn upon the evidence provided by the Camden Retail and Town Centre Study. 4.4 The Camden Retail and Town Centre Study provides an overview of the performance of each of the town centres and Central London frontages, and identifies potential development opportunity sites within them. This capacity analysis was used to inform the creation of the retail hierarchy set out in Policy TC1. The hierarchy of centres is the same as the hierarchy in the adopted Local Development Framework Core Strategy. 4.5 Policy TC1 adopts a town centres first sequential approach and defines a network and hierarchy of centres in the borough which is anticipated to

Camden Local Plan Retail and Town Centre Evidence 7 meet future economic changes, in line with the NPPF (paragraph 23) and the London Plan Policy 4.7. 4.6 The first part of Policy TC1 sets out what retail development is expected the Growth Areas. For the Growth Areas of King s Cross and Euston the Plan sets out the expected quantum of floorspace expected. For King s Cross this is 30,000sqm net additional retail (A1 to A5 use classes) and takes into account the King s Cross Central outline planning permission. For the Euston Growth Area approximately 16,450sqm of net additional retail (A1 to A5 use classes) floorspace is anticipated. This figure is derived from the Euston Area Plan. 4.7 The Plan does not specify anticipated floorspace ranges for the other centres. The floorspace to be achieved in each of these centres will depend on which sites are brought forward. The quantum anticipated over the Plan period is set out in baseline capacity forecast tables (Tables 7.1 and 7.2) of the Camden Retail and Town Centre Study. 4.8 Policy TC1 then states that: there will be additional provision of retail and related uses in the Growth Areas of Tottenham Court Road, Holborn and West Hampstead Interchange, and limited provision as part of redevelopment of the Kentish Town Growth Area, the Council expects additional provision of retail and related uses in the Town Centres and the Central London Frontages, with the exception of Camden Town Town Centre and Tottenham Court Road Central London Frontage, where significant additional provision is expected, appropriate provision of retail and related uses is expected in the Neighbourhood Centres, Specialist Shopping Areas and small shops outside of centres in Neighbourhood Centres, and there will be limited provision of small shops outside centres to meet local needs. Policy TC2 Camden s centres and shopping areas 4.9 Policy TC2 of the Local Plan sets the Council s policies managing the role and character of centres in the borough. This policy sets broader town centre policies and refers to Camden Planning Guidance 5 Town centres and retail for location-specific guidance on how the policy will be applied for individual centres. Frontages 4.10 The NPPF states that local authorities should: 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

Camden Local Plan Retail and Town Centre Evidence 8 (paragraph 23). To meet this requirement the Council defined the frontages in Appendix 3 to the Local Plan and included its overall approach to primary and secondary frontages in policy TC2. This states the Council will protect the primary frontages as locations with a high proportion of shops (A1) in order to maintain the retail function of the centre and protect secondary frontages as locations for a range of other town centre uses including A1 shops to create centres with a wide range of shops, services, and food, drink, and entertainment uses which support the viability and vitality of the centre. 4.11 The frontages in Appendix 3 are derived from Camden Planning Guidance 5 Town Centres, Retail and Employment. The GVA Study examined these existing frontage designations and found that: In general, the extent of the defined core and secondary frontages in Camden are considered to be appropriate (page 83). The Council reviewed and updated the frontages to reflect any changes in individual town centres since the frontages were introduced into planning guidance. The proposed primary and secondary frontages are mapped in Appendix 3 to the Local Plan. Appendix 3 also describes where these frontages differ from the existing frontages set out in Camden Planning Guidance. 4.12 Camden Planning Guidance 5 Town Centres, Retail and Employment adds further detailed guidance to this overall approach by setting guideline proportions of use classes for primary and secondary frontages to guide the implementation of the policy. The frontage guidelines are in Camden Planning Guidance 5 Town Centres, Retail and Employment, a Supplementary Planning Document, to allow the guidance to be updated as required to respond to changing market conditions and trends on the high street. The Council believes that this approach allows flexibility in the implementation of the policy to ensure the vitality and viability of the centres is protected and promoted in a changing retail market. 5. Conclusion 5.1 The approach to town centres and retail development in the Local Plan is consistent with national and London-wide policy and guidance through: Planning to provide for identified retail need, based on predicted demand, Promoting a viable mix of retail and related uses, Defining a network of centres, Defining primary and secondary frontages, Adopting a town centres first sequential test, and Being informed by the latest evidence in the Camden Retail and Town Centre Study. 5.2 The policies have been positively prepared. Policy TC1 sets out the Council s strategy to accommodate the quantum of new retail floorspace

Camden Local Plan Retail and Town Centre Evidence 9 estimated to be required in the Camden Retail and Town Centre Study, while also achieving sustainable development. The sequential test also permits development in edge or centre or out of centre locations if sites cannot be found in town centres. Policy TC2 sets out how the Council will manage the range of uses within each centre and defines the role of the primary and secondary frontages in line with the NPPF. 5.3 The proposed approach is justified by robust evidence and is the most effective and appropriate strategy when considered against alternatives. In the Sustainability Appraisal the Council explored three alternative approaches to town centre and retailing policy and proceeded with the current proposed approach as it was likely to be the most beneficial against the Sustainability Appraisal objectives. 5.4 The approach is effective and deliverable as the Camden Retail and Town Centre study has identified potential development sites in each centre where future additional retail floorspace could be developed. The policies are a refinement of the existing approach in the adopted Core Strategy and Camden Development Policies which was found sound at examination and has been effective in achieving low vacancy rates of 5.5% across all centres and a diverse and viable mix of uses (Camden Survey of Retail Frontages 2015). 5.5 Policies TC1 and TC2 are considered to provide a sound approach which applies national and London-wide policy in the specific circumstances of Camden. The Plan s approach is considered to be justified, effective, positively prepared and consistent with the NPPF and the London Plan.