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Retail Planning Guidelines for Planning Authorities January 2005

Retail Planner Guidlines

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Page 1: Retail Planner Guidlines

Retail Planning

Guidelines for Planning Authorities

January 2005

Page 2: Retail Planner Guidlines

© Government of Ireland

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PlanningGuidelines

ContentsPage No

Policy Context 1Background 1Retail Hierarchy 2Pressure For Development 4Spending Growth and Floorspace Requirements 5

Policy Objectives 6The Role of Town Centres 8Vitality and Viability 9Town Centre Strategy 10

Development Plans 12Function of Development Plan Retail Policies 12Detailed Strategy 13General Strategies 16Large Convenience Store Floorspace Cap 16Timescales and Requirements for Liaison 18

Assessing New Developments – General Principles 19Development Plan Policies 19Location of Development 20Impact On Vitality and Viability 23The Greater Dublin Area 24

Assessing New Developments – Specialist Types ofDevelopment 25Regional Shopping Centres 25District Centres 26Large Foodstores 27Discount Food Stores 27Retail Parks and Retail Warehouses 28Non-application of Retail Warehouse Cap in certain areas covered by Integrated Area Plans under the Urban Renewal Act, 1998 31Factory Outlet Centres 33Retail Warehouse Clubs 35Shops in Small Towns and Rural Areas 35Village Shops 37Local Shops 37Petrol Filling Stations 38

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Application of Floorspace Caps 39

AnnexesAnnex 1 Glossary of Terms 40Annex 2 Assessing the Vitality and Viability

of Town Centres 45Annex 3 Assessment of Additional Retail and

Commercial Leisure Floorspace Requirements 49

Annex 4 The Assessment of Retail Impact 52

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Policy ContextBackground

1. These Retail Planning Guidelines provide acomprehensive framework to guide local authorities inpreparing development plans and assessingapplications for planning permission and to guideretailers and developers in formulating developmentproposals. These guidelines update and replace thepolicy on retail development set out in the LocalGovernment (Planning and Development) GeneralPolicy Directive (Shopping), 1998. The guidelinespublished in December 2000, which came into effectfrom 1 January 2001, have been reviewed insofar asthey relate to retail warehouses. These revisedguidelines contain new policies regarding large retailwarehouses and take effect from 1 February 2005.These guidelines are Ministerial guidelines underSection 28 of the Planning and Development Act, 2000.Section 28 provides that planning authorities and AnBord Pleanála shall have regard to Ministerialguidelines in the performance of their functions.

2. Retail Planning Guidelines were first issued in 1982under The Local Government (Planning andDevelopment) General Policy Directive. This Directiveprovided general advice regarding large scale additionsto existing retail shopping capacity. It has now becomeapparent that this Directive did not provide sufficientlyfocused and specific criteria for assessing proposals orfor preparing development plans.

3. Consequently in June 1998 the Minister issued the LocalGovernment (Planning and Development) GeneralPolicy Directive (Shopping) 1998. This Directiverepeated much of the generalised advice contained inthe early Directive. The principal change however, wasto place an embargo on the grant of planningpermission for any supermarket (or an extension to one)in excess of 3,000 square metres. The accompanying

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circular letter to this Directive indicated thatcomprehensive Planning Guidelines on shoppingdevelopment were to be prepared. Elsewhere in Europethere are national planning guidelines relating to retaildevelopment in individual member states of the EU. Inmainland Europe many countries have introducedfloorspace caps on retail development whilst in the UKthere is clear focus on locational priorities.

4. In April 1999 the Department of the Environment andLocal Government published Draft Retail PlanningGuidelines for public consultation. A number of writtenresponses were received. The Department, inconjunction with the Department of Enterprise, Tradeand Employment also commissioned a study byGoodbody Economic Consultants of the Economic Impactof the Draft Retail Planning Guidelines on the Retail Sector.That report and the written consultation responses havebeen reviewed. A further consultation process, inrelation to a review of the floorspace cap on retailwarehouses, was initiated in August 2003. Account hasbeen taken of points raised in the latter consultations inthe preparation of these revised Retail PlanningGuidelines.

Retail Hierarchy5. The retail hierarchy reflects both the primacy of Dublin

in the settlement structure of the State and small scale,low residential densities in rural areas at the other endof the settlement pattern. Generally speaking, retailfunctions reflect four broad tiers of urban development.The classification is indicative and the specific retailfunctions provided by each tier overlap in manyrespects; below Dublin, there are no clearly defined cut-off points between levels of the hierarchy.

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6. Metropolitan Dublin, which contains a little over 30 percent of the total population, accounts for 41 per cent ofall comparison turnover and 31 per cent of convenienceturnover1 . As well as providing the broadest range ofcomparison goods shopping, it supplies retail functionsof a specialist nature not found elsewhere in the State.

7. Cork, Limerick, Galway and Waterford, with acombined urban population amounting to 10 per cent ofthe State, account between them for a further 19 percent of comparison turnover and 15 per cent ofconvenience turnover. Together with Dublin, thesecentres provide a range of high-order comparisonshopping which is largely unmatched elsewhere.

8. A third tier of towns cannot be precisely defined butincludes Athlone, Carlow, Castlebar, Clonmel,Drogheda, Dundalk, Ennis, Kilkenny, Letterkenny,Monaghan, Mullingar, Newbridge, Portlaoise, Tralee,Tullamore and Wexford. The combined population ofthese towns amounts to six per cent of the State totaland they account between them for a further 18 per centof comparison turnover. The vibrancy of these centres,some of which are now attaining functions previouslyfound only in higher order centres, is demonstrated bythe fact that at least 75,000 square metres of comparisonfloorspace (as well as 45,000 square metres ofconvenience floorspace) was added to these centresbetween 1987 and 1996.

9. The first three tiers in the hierarchy account for 78 percent of comparison turnover. They also account fornearly two-thirds of convenience turnover.

10. However, there are a further group of towns which mayalso be regarded as third tier shopping locations, albeitto a more limited extent. These contain convenience

_________________________1 Data relates to 1996: consultants’ estimates

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goods outlets on a par with settlements listed above.Most have national supermarket chain representation.Examples are Arklow, Athy, Ballina, Cavan, Dungarvan,Enniscorthy, Killarney, Longford, Mallow, Midleton,Naas, Navan, Nenagh, New Ross, Sligo, Swords andThurles. Many of these towns also have significantcomparison goods shopping.

11. The density of third tier centres is related to overallpopulation density. It is highest in the East and South-east and falls off towards the West and North. The lastnamed centres are of particular importance in lessdensely settled areas of the State, where they provideurban anchors for a rural economy which is undergoingrapid change.

12. The fourth tier of the hierarchy comprises a largenumber of small towns in the 1,500 to 5,000 populationcategory. There are some 75 in all, comprising six percent of the State population, most of which providebasic convenience shopping, either in smallsupermarkets or convenience shops and in some cases,lower order comparison shopping such as hardware,pharmaceutical products and clothes.

13. Beyond these tiers, shopping at the most local level isprovided by corner shops in suburban areas and villagestores and post-offices. The rural shop and post-office isrecognised as having particular importance insupporting social and economic life in remoter ruralareas.

Pressure For Development14. Over the last decade there has been increasing pressure

for retail development. Between 1987-1998 some400,000 square metres has been implemented inschemes over 2,000 square metres. Currently there areproposals to develop a further half million squaremetres of additional floorspace.

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15. Over this period a number of European retailers havesought to enter the Irish market by renting space andoperating new retail formats. Others have begun aprogramme of new development. Some overseasretailers have gained access to the Irish market bybuying out indigenous retail companies.

16. There is an increasing demand for larger store sizes.This is difficult to achieve in traditional town centreswhere prime retail pitch often comprises relativelysmall scale historic buildings in an attractive setting.Furthermore, it is becoming increasingly difficult toaccess prime pitch easily by car and park nearby.Consequently there has been a move over the last fiveyears or so to decentralise large scale retail provision toout-of-centre locations.

Spending Growth and Floorspace Requirements17. The principal underlying reason for market interest in

development is the sustained rate of growth of the Irisheconomy. The 1990s was a decade of exceptional growthfor the Irish economy. GDP grew by about 7 per centper annum on average (9 per cent since 1993).Employment has expanded by over a quarter andunemployment has fallen and is continuing to fall2.

18. Forecasts over the last few years suggest that GDPannual volume growth rates will continue at a high ratein the short term. In the longer term more moderategrowth is expected as workforce growth is reduced,lessening the structural capacity of the economy togrow.

19. The sustained level of growth in Ireland since the mid1990s is unprecedented in Western Europe at thepresent time and is fuelling substantial annual increasesin consumer spending on retail goods. The factorswhich are generating economic growth are also those

______________________2 Unemployment rate, ILO basis, is expected to average 6.7 per cent of the labour force in

the period 2000-2005.

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which are driving consumer spending: net immigration,largely of skilled and economically active persons, andincrease in the numbers reaching working age andrapid increases in female participation rates. Thesechanges in the labour force are reinforced by increasesin educational attainment and therefore earnings.Household size and economic dependency rates arefalling.

20. Continuation of these growth trends is likely togenerate a requirement for substantial additions to theexisting stock of retail floorspace. The specificrequirement for additional development will depend onthe long term performance of the economy, trends inconsumer spending and the way in which retailers reactto changing market conditions. The majorityrequirement is likely to be for comparison goodsfloorspace (including retail warehousing), althoughthere will be a continuing need to provide for additionalconvenience goods floorspace.

Policy Objectives

21. The challenge to be faced is how to accommodate theadditional development that is projected to be requiredin a way which is efficient, equitable and sustainable. Itis important to establish the optimum location for newretail development which is accessible to all sections ofsociety and is of a scale which allows the continued prosperity of traditional town centres and existing retailcentres. This can only be achieved if strategic retailpolicies and proposals are incorporated in thedevelopment plan system. In this way retaildevelopment can be guided by development plans.These Guidelines identify five key objectives whichhave equal weight.

22. The first objective of national policy is to ensure that infuture all development plans incorporate clear policiesand proposals for retail development.

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23. This first objective should in turn support a secondobjective of national policy: to facilitate a competitiveand healthy environment for the retail industry of thefuture. It is not the purpose of the planning system toinhibit competition, preserve existing commercialinterests or prevent innovation. In interpreting theseguidelines local authorities should avoid taking actionswhich would adversely affect competition in the retailmarket.

24. Retail development is most accessible to customerswhere it is well located within its catchment area and isaccessed both by public transport and the private car.The third objective of policy, therefore, is to promoteforms of development which are easily accessible -particularly by public transport - in a location whichencourages multi-purpose shopping, business andleisure trips on the same journey.

25. Consequently, the fourth objective is to support thecontinuing role of town and district centres. This willassist in reinforcing the investment in urban renewalwhich has been made already. These establishedcentres should be the preferred locations fordevelopments that attract many trips. This policy willalso support their role as centres of social and businessinteraction in the community. In order to achieve thisobjective the preferred location for retail development,should be within town centres, consistent with therequirement to achieve good access especially by publictransport. If there are no development sites availablewithin a town centre then the next preference should bea location on the edge of the town centre. Only wherethere are no sites, or potential sites, within a towncentre or on its edge, or satisfactory transportaccessibility (including park and ride) realisticallycannot be ensured within a reasonable period of time,should out of centre development be contemplated.

26. The fifth, and final objective is a presumption againstlarge retail centres located adjacent or close to existing,

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new or planned national roads/motorways. Such centres can lead to an inefficient use of costly andvaluable infrastructure and may have the potential toundermine the regional/national transport role of theroads concerned. However, as a limited exception,large retail warehouses may be considered for locationsclose to such road networks where the proposeddevelopment would be situated in an Integrated AreaPlan area in a Gateway (designated by the NationalSpatial Strategy) and where the road network hassufficient capacity to cater for the scale of developmentproposed (See also paragraphs 84a – 84e).

The Role of Town Centres

27. Town centres, together with district centres and majorvillage centres serving rural areas provide a broadrange of facilities and services and act as a focus for thelocal community. In this guidance the term "towncentre" is used to refer to district centres as well ascentres of smaller settlements. The Governmentattaches importance to the improvement of towncentres and in the following paragraphs (28-35) adviceis provided on approaches to planning for successfultown centres.

28. The town centre is the focus for a range of commercialand community activities, resulting in a mix of, ofteninterdependent, land uses which contribute to a senseof place and identity. It includes a combination ofnatural features: historic buildings, cultural, civic andgovernmental buildings, as well as public spaces. Thisphysical form and mix of functions, which will haveevolved over a considerable period of time, makes atown centre different from a shopping centre andprovides much of its character which can be furtherenhanced by introducing appropriate new uses intohistoric buildings. It also has a high level ofaccessibility to employment, services, and facilities forall the community.

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29. Shopping provision is a key component of town centres,and makes a major contribution to their vitality andviability. It is important therefore that they retainretailing as a core function. Considerable investmenthas already taken place in town centres and planningpolicies should seek to sustain and enhance their role,including new retailing developments and other keyuses. The role of town centres can change over time.Planning authorities should have regard to thechanging role of towns and the value of maintainingretailing when preparing development plans andconsidering applications for new development.

Vitality and Viability30. In order for town centres to achieve their full potential

and continually improve as retail destinations it will beappropriate and necessary for planning authorities toadopt a pro-active role in enhancing the vitality andviability of their centre(s). The concept of vitality andviability is central to sustaining and enhancing towncentres. Vitality is a measure of how active andbuoyant a centre is, whilst viability refers to thecommercial well-being of a town. In combination theyhighlight the relative strength and success in the retailhierarchy. This will depend on many factors, includingthe range and quality of activities in a centre, its mix ofuses, its accessibility to people living and working inthe area and its general amenity, appearance and safety.Although no single indicator on its own can effectivelymeasure the "health" of a town centre, the use of a seriesof them, described in Annex 2, can provide a view ofperformance and so offer a framework for assessingvitality and viability.

31. Planning authorities, especially in areas with a well-developed hierarchy of retail centres, should assessobjectively the relative strength of the main towns intheir area by carrying out a health check assessment.This should be undertaken using a consistentmethodology and updated regularly. Such health checksshould both inform and be undertaken within theframework provided by the development plan.

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Town Centre Strategy32. The outcome of the healthcheck appraisal of town

centres will indicate both areas of weakness andopportunity. It will be necessary to formulate acomprehensive response which makes better use of acentre’s resources and potential and address majordeficiencies. It should aim for a realistic vision for thecentre, drawing on the support of all interested partiesand an implementable programme of action.

33. It is not sufficient for planning authorities to merelyformulate policies which seek to preserve the presentshopping hierarchy without addressing the key issuesfacing town centres. It will normally be appropriate toaddress the following matters:

• The availability of development opportunitiesand the need to promote land assembly.

• Encouraging a diversity of uses in the towncentre throughout the day and evening.

• Ensuring accessibility by a range of transporttypes, including reviewing the car parkingstrategy.

• Creating an attractive and safe town centre forpedestrians.

• Undertaking effective management andpromotion of the town centre.

34. Positive action to promote change may include theidentification of development opportunities, siteassembly, better access for public transport, cyclists andpedestrians, and environmental improvementsincluding improving the attractiveness of townscapeand open spaces. Renewal opportunities may also arisewhere underused property and land might be broughtback into more productive use through joint action,using Section 212 of the Planning and Development Act,2000 or through other initiatives such as Integrated Area

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Plans. Improved town centre management could alsohelp in the co-ordination and implementation of a rangeof activities in support of the strategy.

35. The scope and opportunity for the greater use of publictransport is a long term challenge, but the process ofdeveloping such systems and encouraging their use canbe facilitated by choosing accessible sites in towncentres for retail and related development. In themeantime, ensuring good access to town centres isimportant in order to maintain their competitiveness.Heavy demand for access by car generates demand forparking spaces which can create congestion, pollutionand parking problems, affecting the convenience,attractiveness and competitiveness of the centre.Planning authorities should:

• Develop a comprehensive traffic managementstrategy, and in particular establish clear parkingpolicies.

• Ensure that parking provision serves the need ofthe town centre as a whole, rather than exclusiveuse of a particular development.

• Work with public transport operators to improveservices and facilitate the provision of park andride schemes associated with new developmentand to serve the town centre as a whole.

• Meet the access and mobility needs of disabledpeople.

• Improve access and safety for cyclists andpedestrian visitors through the introduction ofcycle routes, pedestrianised streets and park andwalk schemes and incorporating a carefulappraisal of the safety aspects of newdevelopment proposals.

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Development PlansFunction of Development Plan Retail Policies

36. The development plan system, including both Countyand City Development Plans, encompasses bothstrategic planning policies and programmes and morelocalised action initiatives (including the preparation oftown centre strategies). County Councils and CityCouncils will need to prepare retail policies for theiradministrative areas. However, because retail planningrequires consideration of the catchment area of retailcentres which usually do not co-incide with localauthority boundaries, paragraph 8 of Annex 3 sets outthose issues which may need to be considered byplanning authorities in relation to cross-boundary retailcatchments. Emerging regional plans should alsoreview the hierarchy of settlements and town centresand provide broad guidelines on priorities for thelocation of additional retail development across theregion. Such general regional guidelines should not beconstrained by administrative boundaries which cutacross catchment areas. The matters which are to beincluded in all future development plans for Countiesand Cities are:

(i) Confirmation of the retail hierarchy, the role ofcentres and the size of the main town centres.

(ii) Definition in the development plan of theboundaries of the core shopping area of towncentres.

(iii) A broad assessment of the requirement foradditional retail floorspace.

(iv) Strategic guidance on the location and scale ofretail development.

(v) Preparation of policies and action initiatives toencourage the improvement of town centres.

(vi) Identification of criteria for the assessment ofretail developments.

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37. In dealing with these matters, planning authoritiesshould take account of the views of retailers, shoppers,property owners and transport operators (and in thecase of Dublin, the DTO). In assessing the need foradditional development for different types of retailing itis important that the assessments are based on arealistic appraisal of both expenditure change andmarket requirements. Plans should be based on up todate information regarding existing retail floorspaceand shopping patterns in the area. The range of detailand complexity required to address retail planningissues varies depending on the extent of urbanisation,population density and number of centres. InMetropolitan Dublin, Cork and other major urbancentres, there is a far greater requirement for detaileddevelopment plan policies than in largely rural centres.

Detailed Strategy38. Consequently it will be necessary for the more urban

counties to prepare retail strategies and policies for theirareas which are more detailed than in more rural areas.Furthermore, in some locations it will be necessary forcounties to co-operate with one another in preparingretail strategies. In the following areas the specifiedCounties and Cities should jointly preparecomprehensive retail strategies and policies addressingthe matters set out at paragraph 36(i-vi) with theintention of incorporating the strategies and policies inthe appropriate development plan:

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________________________________________________________Area Relevant County or City

Greater Dublin Area* Dublin City Council andCounties Fingal, DunLaoghaire/Rathdown andSouth Dublin, Kildare,Meath and Wicklow

Greater Cork County Cork and Cork CityCouncil

Greater Waterford County Waterford,Waterford City Council,County Wexford andCounty Kilkenny

Galway County Galway and GalwayCity Council

Limerick County Limerick, CountyClare and Limerick CityCouncil

Drogheda/Dundalk County Louth and CountyMeath

Athlone County Westmeath andCounty Roscommon

________________________________________________________

* As defined in the Strategic Planning Guidelines for theGreater Dublin Area.

39. The background studies to be carried out to underpinthe retail planning strategy should define theboundaries for the area to be covered.

40. In order to plan for future development, the relevantcounties should assess the broad requirement foradditional development over the plan period. Thisassessment should take account of both emergingdemands in the retail market and a general estimate offuture requirements based on projected changes in thelocal population and consumer spending. It wouldassist all parties if such estimates are founded on a

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common standardised approach. Advice on anappropriate approach is contained in Annex 3. Theseassessments of future retail requirements are intendedto provide broad guidance as to the additional quantumof convenience and comparison floorspace provision.They should not be treated in an overly prescriptivemanner and should not seek to inhibit competition.

41. In preparing strategic guidelines relating to the locationand scale of future development county councils willdisregard the potential benefits of commercial rateswhich may accrue to the Council (or any other Council)as a consequence of planned retail development. Theeffect on local authority financial resources of retaildevelopment is not a material land use planningconsideration which ought to be recognised.

42. The strategy to be incorporated into development plansshould provide guidance as to the general location(name of town, district or major village centre) of newdevelopment. In order to achieve greater certainty, itwill be necessary to provide a broad indication of thegeneral scale of development envisaged at variouslocations as well as the precise boundaries of the coreretail area of the town centres.

43. For the locations identified, the strategy should eitheridentify specific alternative sites for development, orwhere this is not possible, establish criteria for theselection of sites. Where a criteria based approach isfollowed the criteria adopted should be sufficientlyclear so as to allow clear evaluation of subsequentapplications for planning permissions.

44. The traffic management policies to be adopted for towncentres in development plans should include: the needfor convenient public transport facilities and buspriority measures, the provision and location of carparking (including park and ride, or park and walkschemes), routes for pedestrians and cyclists, anddisabled people to access the town centre and, the need

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for traffic calming measures. Any areas for specialinitiatives to improve accessibility for people withdisabilities, and for shoppers with prams or pushchairsshould be clearly designated.

45. Both the performance of the national economy and localmarket forces change over time. It is inevitabletherefore that any projection of change over the periodof a development plan may turn out not to becompletely accurate. This does not invalidate thebenefit of preparing longer term strategic advice,however. Counties and Cities should regularly monitortrends and events in their area and update their policiesaccordingly at intervals of not less than six years.

General Strategies46. In the remainder of the State counties not identified in

paragraph 38 as being required to prepare a detailedretail planning strategy will prepare a more generalstatement of strategic intentions and future policy. Thematters to be addressed are as set out at paragraph 36(i-vi).

47. In addressing items (iii) and (iv) it should not benecessary to estimate in any detail the futurerequirement for additional development. A broadassessment of requirements for additional developmentreflecting the local evidence of market interest and theneed to provide good opportunities for retail provisionto serve the main population centres in the countyought to be sufficient in order to formulate appropriatepolicies and criteria for dealing with new developmentproposals.

Large Convenience Store Floorspace Cap48. The June 1998 Local Government (Planning and

Development) General Policy Directive (Shopping)imposed a universal upper size limit on foodstoredevelopment throughout the State. A variety of viewshave been expressed on this point during the

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consultation stage of preparing these Guidelines. TheGoodbody Report indicates that economies of scale infood store operations may not be pronounced and are inany event exhausted at a level not much over 2,000square metres. Consequently the imposition of afloorspace cap above this threshold would not havepronounced anti-competitive effects. In fact, byencouraging competition at the local level, one effect ofthe imposition of a cap could be to reduce the potentialfor creating local monopolies.

49. Based on this analysis and experience elsewhere inEurope the principle of applying a floorspace limit onfoodstore development is well founded. The existingsize cap on foodstore development is judged torepresent an acceptable balance between the competingrequirements of different interest groups. It has alsobeen found not to reduce competition at the level of3,000 square metres. It is appropriate, therefore, tocontinue with the principle of the floorspace cap on allfoodstore development.

50. There are good reasons to differentiate the floorspacecap between the Greater Dublin Area and the remainderof the State, however. The greater size and density ofpopulation in the Greater Dublin Area, the closeproximity of residential areas to established towncentres and the size of populations contained within thecatchment areas of retail centres in the Greater DublinArea provide a justification for increasing the size limiton foodstore development in this area. Broadlyspeaking, foodstores in the Greater Dublin Area arelikely to be able to command an enhanced turnovergenerated by the local catchment area. Reflecting thisfact and the need to meet the rapidly growing retailrequirements of Dublin the size cap on sales floorspacewithin the Greater Dublin Area is set at 3,500 squaremetres. In the remainder of the State the floorspace capon foodstore development is set at 3,000 square metres.

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51. These floorspace caps should apply to newdevelopment or extensions to existing schemes whichwill result in an aggregate increase in sales floorspace.This limit should apply to the total net retail sales spaceof superstores and the convenience goods net retailsales space of hypermarkets delineated on applicationdrawings.

52. County Councils and City Councils in preparing retaildevelopment strategies for their areas should bemindful of these floorspace limits on foodstoredevelopment. In very exceptional circumstancesCounty Councils outside the Greater Dublin Area andthe other four City Council areas could introduce asmall downward revision to the floorspace cap inappropriate circumstances where the size of existingtown centres is small in relation to the scale of the cap,and the potential for convenience goods expendituregrowth is limited. However, if a planning authoritywishes to propose a small downward revision to thefloorspace cap the justification should be fullysubstantiated by an expert study and account should begiven to the conclusions of the Goodbody Reportregarding the need to avoid actions which wouldcontravene competition legislation. Furthermore,account should be taken of the conclusions of theGoodbody Report regarding the scale of development atwhich economies of scale are exhausted, i.e. availableevidence suggests that economies of scale for foodstoresare exhausted at a store size of approximately 2,000square metres. Any reduced floorspace cap should notbreach this limit.

Timescales and Requirements for Liaison53. Planning authorities (except in the Greater Dublin Area)

were given 12 months from the date of publication ofthe guidelines published in 2000 to commencepreparation of the necessary retail policies andproposals for their areas. These were to be publishedand incorporated into the relevant development planswithin 18 months from the date of publication of the

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original guidelines. In the Greater Dublin Area therewas an urgent need to put in place a comprehensiveand detailed retail planning strategy. The planningauthorities in the Greater Dublin Area have prepared aretail planning strategy together with accompanyingpolicies. These were to be published and incorporatedinto the relevant development plans within 12 monthsfrom the date of publication of the 2000 guidelines.

54. In preparing retail planning strategies and policies (bothdetailed and general strategies) county councils shouldliaise closely with the appropriate town councils.Unless these smaller authorities have faith in thestrategy and accompanying policies they will be lesslikely to implement policies in exercising theirdevelopment control functions.

Assessing New Developments – GeneralPrinciplesDevelopment Plan Policies

55. Development plans should provide an indication of thegeneral scale and form of retail development that isrequired in the future and this will constitute thecontext for making decisions on planning applications.As far as possible new development is to be sitedwithin town centres or, if no sites are available,immediately on the edge of town centres with apresumption against development elsewhere, exceptwhere district or neighbourhood centres are beingprovided to meet neighbourhood needs. A fullappraisal of the retail development potential of sitesboth in the town centre and on the edge of town centresshould be undertaken. It will be necessary to consideravailability and the underlying realism of possibledevelopment formats through general discussions withlandowners, retailers and developers. Newdevelopment should be capable of being accessed by avariety of transport modes without causing unduecongestion. In the development plan context the

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demonstration of congestion arising from car usageshould not be used as an argument against town centredevelopment locations, where adequate publictransport exists or could be provided, or wheremeasures to alleviate congestion can be provided.

56. In framing planning policies for specified main towncentres county councils should seek to ensure thatappropriate servicing arrangements can be providedwhich do not detract from the environmental quality oftown centres nor cause additional congestion. The scaleand form of new development should complementrather than detract from existing retail facilities anddirect, attractive pedestrian links should be providedbetween new developments, the existing central areaand both public transport facilities and car parks.

57. The intention of these guidelines is that developmentplans should provide the background guidance andcontext against which the retail sector and developerscan prepare proposals with a degree of certainty as tothe way in which any particular scheme will be judged.Where an application for development complies withthe policies and proposals of a development plan in allmaterial respects it should not be necessary for theapplicant to provide additional supporting backgroundstudies. However, the onus is on an applicant todemonstrate convincingly that his/her proposal doescomply closely with the development plan. Wherethere is doubt on any aspect of a planning applicationlocal authorities should require a detailed justificationrelated to the matter which is questionable. Allapplications for retail development should be assessedagainst the principles set out in this section of theGuidelines.

Location of Development58. The preferred location for new retail development

where practicable and viable, is within a town centre (ordistrict or major village centre). Where it is not possibleto provide the form and scale of development that is

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required on a site within the town centre thenconsideration can be given to a site on the edge of thetown centre so as to encourage the possibility of onejourney serving several purposes. An edge of centresite, for the purposes of these guidelines, is taken to beone which is within an easy and convenient walkingdistance from the primary shopping core of a towncentre. The distance considered to be convenient willvary according to local circumstances but typically isunlikely to be much more than 300-400 metres from theedge of the prime shopping area, and less in smallersettlements.

59. Having assessed the size, availability, accessibility, andfeasibility of developing both sites and premises, firstlywithin a town centre and secondly on the edge of atown centre, alternative out of centre sites should beconsidered only where it can be demonstrated thatthere are no town centre or edge of centre sites whichare suitable, viable and available. This is commonlyknown as the sequential approach to the location ofretail development.

60. In adopting the sequential approach in formulatingdevelopment plans planning authorities must liaisewith retailers, landowners and developers to ensurethat development plan proposals are practicable andreasonable. Unless the development plan has someprospect of being implemented it will not assist insustaining and enhancing town centres. Sites suggestedfor development should therefore be capable of beingaccessed and serviced. They should be viable for theproposed use and likely to become available within areasonable period of time.

61. Equally, when making planning applications the privatesector must be adaptable and flexible in appraisingpotential sites and buildings and should liaise with theplanning authority before submitting assessments ofsite or building suitability. Retailers should be prepared

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to make reasonable compromises and, if possible, adaptstandard development formats in order toaccommodate retail schemes on sites which are welllocated in relation to the sequential approach to retaildevelopment.

62. A particular issue that will arise in the appraisal ofalternative locations is the potentially contrastingperformance in terms of urban design, accessibility andtraffic congestion. Each case will have to be treated onits merits and a balance struck between a site’s relativeperformance against the various planning andtransportation factors to be evaluated. In relation tourban design, applicants should make every effort tointegrate successfully new retail development, much ofwhich will be of a scale larger than the existing urbangrain, into the townscape of existing centres. Attentionshould be given to the location of service yards andtreatment of car parking areas so as to avoid unsightlyviews and special consideration should be given to thedetailing of extensive frontages and flank walls.

63. It is likely that some retail development will take placein out of centre locations. Not all centres, particularlysmall and historic towns, will have sites that aresuitable in terms of size, parking, traffic generation orservicing arrangements for large-scale developments inthe town centre itself. In such centres, developmentshould be of a scale appropriate to the size of the centrein order to minimise the potential for adverse impact.In preparing development plans, county councilsshould specify criteria against which the merits of outof centre retail applications can be judged. Thesecriteria should cover matters such as the nature and sizeof retail formats for which out of centre locations maybe considered, the broad need (floorspace requirement)for additional retail development to serve an identifiedlocal community, size of development, quality of designand layout, effect on the nearby environment, effect onvitality and viability, servicing, accessibility by a variety

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of travel modes and car parking. Developers whensubmitting planning applications should formulate theirproposals within the framework of the specified criteria.It is not appropriate for applications on out of centresites to be pursued when there is quite clearly no needfor the scale of development proposed.

Impact On Vitality and Viability64. New developments can have an adverse impact on the

vitality and viability of established town centres. Thisis a consequence of the competitive environment inwhich retailing operates. Though it is not the purposeof the planning system to prevent competition, properplanning and development includes promoting healthytown centres, in the public interest. Where newdevelopments compromise this planning goal, theyshould be rejected.

65. In making an application for planning permission forretail development which local authorities consider tobe large scale in relation to existing town centres, theonus is on the applicant to demonstrate compliancewith the development plan and that there will not be amaterial adverse impact on the vitality and viability ofany existing town centre. In submitting evidence inrelation to retail impact the applicant shall address thefollowing criteria and demonstrate whether or not theproposal would:

• Support the long term strategy for town centresas established in the development plan and notmaterially diminish the prospect of attractingprivate sector investment into one or more towncentres.

• Cause an adverse impact on one or more towncentres, either singly or cumulatively with recentdevelopments or other outstanding planningpermissions, sufficient to undermine the qualityof the centre or its role in the economic andsocial life of the community.

• Diminish the range of activities and services thata town centre can support.

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• Cause an increase in the number of vacantproperties in the primary retail area that is likelyto persist in the long term.

• Ensure a high standard of access both by publictransport, foot and private car so that theproposal is easily accessible by all sections ofsociety.

• Link effectively with an existing town centre sothat there is likely to be commercial synergy.

Furthermore, in relation to large-scale out of town retaildevelopments, the developer shall submit a transportassessment3 showing how trips to and from theproposed development might affect the road networkand public transport links. If the proposed developmentwarrants an environmental impact assessment, thetransport assessment should form part of the EIS.

The Greater Dublin Area66. As previously indicated, a joint retail study was

undertaken by the planning authorities in the GreaterDublin Area. This study took account of the followingfactors:

• The quantum of retail development to beprovided in Dublin is much greater than anyother area of the State.

• The transport network will not support allfuture retail development being provided withinthe City Centre, and given the size of Dublin notall retail development should be providedwithin the City Centre.

• There is an urgent requirement to ensure closeworking and liaison between planningauthorities within the Greater Dublin Area.

_________________________3 See “Traffic Management Guidelines Manual” published jointly by the Department of the

Environment, Heritage and Local Government, the Department of Transport, and the DublinTransportation Office.

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Assessing New Developments – SpecialistTypes of Development

67. The general principles for assessing all newdevelopment are set out above. The weight to be givento certain criteria may vary with certain specialist typesof development. This section of the Guidelines dealswith specific retail and leisure development concepts.

Regional Shopping Centres68. Self-standing, large scale, retail malls developed in out-

of-centre locations can have a significant impact onestablished town centres. Elsewhere in Europe theyhave been justified on the basis of substantial growth inconsumer spending generated within majorconurbations of a million people or more. In the Irishcontext this form of development can not be easilysubstantiated, with the possible exception of withinGreater Dublin. Consequently, outside Dublin, there isno justification in any circumstances for large scaleregional shopping centres.

69. Within the Dublin area there are two large scaleshopping centres which have been planned as thecommercial centre of new towns – Blanchardstown andTallaght. A third centre, at Liffey Valley, providescomparison shopping only. The Strategic PlanningGuidelines for the Greater Dublin Area suggested thatthe future provision of retailing should incorporate:

• A wide distribution of reasonably sizedconvenience goods outlets at locations accessibleby car, with priority given to places also servedby good public transport.

• A set of established and developing centres wellserved by public transport, which together withthe City Centre, would offer a good provision ofcomparison goods.

• A limited number of retail warehousedevelopments at locations accessible by car.

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70. The development of additional large regional scaleretail centres on greenfield sites or outside establishedcentres is not regarded as sustainable in relation totransport objectives. Consequently, there should be ageneral presumption against large scale out-of-centreretail development.

District Centres71. Purpose built district shopping centres are normally

provided within the built up area of major conurbationsor in the suburbs of large towns. They are usuallyanchored by a large foodstore and contain a range ofunit shops and non-retail service outlets (such as banks,post office or hairdressers). They perform an importantretail function for the local community living within a15-20 minute drive time of the site. There is no clearsize threshold for a district centre although, dependingon the density of population in the catchment area, theyare likely to comprise about 10,000 square metres in oradjacent to the main towns and up to 20,000 squaremetres within some parts of Dublin.

72. Development plans will identify the need for newdistrict centres or extensions of existing centres.Normally, the provision of additional centres will bebased on major growth in population or a clear provenlevel of existing underprovision. The Greater DublinArea represents the area where population is growingfastest and where there is likely to be underprovision ofretail facilities at present. Broad criteria for the locationof such centres will be indicated in emerging regionalplans. Although district centres can be provided asextensions of existing local shopping centres or villagecentres there may be a requirement to develop plannednew centres to serve major new residential areas.Development plans should address the locationalrequirements of district centres.

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Large Foodstores73. Large foodstores comprising supermarkets, superstores

or hypermarkets are an accepted component of theretail hierarchy. They serve mainly the large weeklyconvenience goods shopping requirements of families.They require large clear areas of floorspace togetherwith adjacent car parking as the majority (but not all) offamilies undertake their weekly bulk convenienceshopping by car.

74. Wherever possible large foodstores should be providedin a town, major village or district centre or on the edgeof the centre where public transport provision can bemade available for shoppers who do not have the use ofa car. In exceptional cases it will not be possible tobring forward sites which are in or on the edge of atown centre because of the site size requirements oflarge foodstores, environmental constraints in historictowns or because the road network does not have thecapacity for additional traffic and service vehicles.

75. Where a proposal for foodstore development involvesthe sale of a significant amount of non-food goods (as iscommon in hypermarkets) the application drawingsaccompanying a planning application should delineateclearly the area to be devoted primarily for the sale ofconvenience goods. As previously indicated atparagraph 50 a floorspace cap of 3,500 square metres isto be applied in the Greater Dublin Area and 3,000square metres elsewhere in the State. This cap willapply to the total net retail sales space of superstoresand the convenience goods net retail sales space ofhypermarkets delineated on application drawings.

Discount Food Stores76. Smaller discount food stores of up to 1,500 square

metres gross have a potential role in extending thechoice and range of retailing, particularly for certainsectors of the community. Their customer catchmentand retail offer is different to the mainstream

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superstores and supermarkets and their trade draw willbe different; this will be relevant when assessingimpact, although the effect on neighbourhood centresand other shops should also be considered. Discountfoodstores can effectively anchor smaller centres or localneighbourhood centres. Proposals should beconsidered in relation to the development plan and theprovisions of paragraph 65 of these guidelines. Re-useof existing non-retail and vacant premises in existingcentres should be encouraged unless there is clearevidence to suggest that there would be a significantimpact on the viability of smaller centres, due to thesize of the discount store.

Retail Parks and Retail Warehouses77. Retail parks have emerged as agglomerations of retail

warehouses grouped around a common car park sellingmainly bulky household goods. Retail warehousesrequire extensive areas of showroom space, often withminimal storage requirements. A substantial proportionof customers drive away with goods purchased in theboot of their car, on a roof rack, or in a van. In someinstances retail warehouse operators are able to arrangehome delivery.

78. In general retail warehouses do not fit easily into towncentres given their size requirements and the need forgood car parking facilities and ease of servicing. Insome instances it may be possible to locate retailwarehouse groups on the edge of town centres.

79. Experience elsewhere in Europe suggests that there arebenefits to be gained in grouping retail warehousesselling bulky goods on planned retail parks so thatnumber of trips by car are minimised and outside thetown centre so that there is relief from additional trafficwithin a congested town centre. Generally speaking,the evidence is that planned retail parks do not haveany material impact on town centres provided that therange of goods sold is limited to truly bulky household

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goods or goods generally sold in bulk. Where the rangeof goods sold from retail warehouse parks extends tothe type of non-bulky durables which is retailed fromtown centres then there is much more potential for anadverse impact on a nearby town centre.

80. Planning authorities when considering applications fornon-food retail parks need to consider the impact onexisting town centres. If the range of goods sold isconditioned only to the sale of bulky household goods,including carpets, furniture, automotive products andwhite electrical goods and DIY items then it is unlikelythat a retail park development in the range 8,000 –15,000 square metres would have a material adverseimpact on the more important town centres in the retailhierarchy, although at this scale there could be thepotential for an adverse impact on the smaller towncentres. If the range of goods extends beyond thesebulky goods categories or the size of the proposed retailpark significantly exceeds this size range, then localauthorities will need to consider the impact of theproposal in relation to the criteria set out at paragraph65 of these guidelines. If there are, or have been, anumber of similar applications in a short space of time(say three years), in the same area, then a planningauthority should require applicants to provide anassessment of the cumulative impact of more than oneretail park proposal.

81. Specific planning and competition issues arise inrelation to the size range of individual retail warehouseunits. It is necessary to address the separate matters ofminimum and maximum unit sizes. Generallyspeaking smaller units of much less than 700m2 grossfloorspace are more easily capable of beingaccommodated in town centres and, in any event, tendto sell a less bulky range of goods. Consequently, localauthorities may consider it appropriate to impose aminimum size condition preventing the construction orsubdivision of units into stores less than 700m2 in out ofcentre locations.

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82. Conversely, the development of very large single retailwarehouse units greatly in excess of 5,000 square metres(and sometimes of 10,000 square metres or more)focused upon a specific market segment, can have anunacceptable local monopoly effect on smaller shops intown centres, particularly in a country like Irelandwhich has no very large conurbations. Furthermore,these large scale development formats attract largevolumes of car borne customers and require a highquality road network with spare capacity. Theseconditions occur at present in relatively few locations inthe State. For the foreseeable future, therefore, largescale single retail warehouse units in excess of 6,000square metres gross (including any ancillary gardencentre) are unlikely to be acceptable in many locationsdue to their effect on the surrounding road network andtheir potential for creating local monopolies whichwould inhibit competition within local catchment areas.

83. Where it is considered warranted, local authoritiesshould impose appropriate conditions to prevent theprovision of single large units either through newdevelopment, coalescence or the linking together of twoor more stores. In general, coalescence or linkingtogether of stores would be considered to bedevelopment and therefore subject to a requirement forplanning permission. The 6,000 square metre thresholdshould apply in all cases, except where the provisions ofparagraphs 84a – 84e below apply.

84. Applications for individual retail warehouses outside atown centre or on its edge should generally bediscouraged in order to reduce the number of carjourneys. Furthermore, given their potential for visualimpact, close attention should be given to theimplementation of siting free-standing retailwarehouses along major road corridors, in order that agood quality of design can be achieved.

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Non-application of Retail Warehouse Capin certain areas covered by Integrated AreaPlans under the Urban Renewal Act, 1998

84a. There is evidence of consumer demand in Ireland forinnovative types of large-scale retail warehouses whichare capable of displaying a very wide range of goodsunder one roof, together with a range of customerfacilities. The scale of such outlets requires a regional, ifnot a national, population catchment. As stated inparagraph 23, it is not the purpose of the planningsystem to inhibit competition, preserve existingcommercial interests, or prevent innovation.

84b. An Integrated Area Plan (IAP) in the context of the 1998urban renewal scheme is intended to address thephysical, economic, social/employment andenvironmental regeneration of a declining area. IAPareas are identified as those urban areas which have thegreatest need of, and potential for, rejuvenation. IAPareas generally are areas in cities and large towns withstrong urban characteristics where the greatestconcentrations of physical decay and social/economicdisadvantage tend to occur. IAP areas are required tocontain sites or key developments with the potentialinfrastructure to cope with likely developments. Manyof these urban renewal areas, particularly in the cities,are located in areas suffering from both youth and long-term unemployment. The IAP process aims to give suchlocal people a stake in the rejuvenation of their areas, byfocusing on community attainment and sustainable jobcreation. The targeting of new forms of retaildevelopment into such areas would provide a valuablesource of employment for such areas.

84c. Accordingly, taking account of the submissions receivedin response to the consultation process initiated inAugust 2000, the Minister has determined that the 6,000square metre floorspace cap on individual retailwarehouses will not apply in those areas which are the

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subject of Integrated Area Plans (IAPs) under the UrbanRenewal Act, 1998 in National Spatial Strategy (NSS)Gateways (i.e.within the functional areas of Dublin CityCouncil, Fingal County Council, South Dublin CountyCouncil, Dun Laoghaire-Rathdown County Council,Cork City Council, Galway City Council, Limerick CityCouncil, Waterford City Council and in the towns ofDundalk, Letterkenny, Shannon and Sligo and thelinked Gateway of Athlone/Mullingar/Tullamore). Thiswill meet two policy objectives. Firstly, it should enablenew operators to enter the Irish retail market (orexisting operators to potentially operate larger formatsin such areas) thereby contributing to the fostering ofcompetition in the retail market. Secondly, it willcontribute to urban renewal in those areas covered byIntegrated Area Plans in the nine National SpatialStrategy Gateways. These are areas which have beenspecifically targeted for urban regeneration efforts.

84d. However, it should be noted that normal planning ruleswill continue to apply in such areas. Any proposal foran individual retail warehouse with a floorspace inexcess of 6,000 square metres gross in an area subject toan Integrated Area Plan, in order to be acceptable froma planning viewpoint would need to demonstrate thatthe proposal will:

(a) Be located close to a road network withsufficient capacity to cater for development ofthe scale proposed. In practice, larger scaledevelopments would have to be located close toa high capacity motorway or dual carriage-waynetwork and associated interchange;

(b) Be served by existing or planned publictransport services;

(c) Make adequate provision for those opting forhome delivery of goods other than by privatecar;

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(d) Be accompanied by a traffic impact assessmentdemonstrating compliance with the abovecriteria; and

(e) Take account of the vitality / viability criteria inrespect of city / town centres set out at para. 65of these guidelines.

84e. Taking the foregoing paragraphs together, it will be amatter for the development management process toapply the criteria in paragraph 84d above to anyproposal that may come forward from the privatesector.

Factory Outlet Centres85. At its simplest, this form of retailing involves the selling

of products at discount prices in an individual factoryshop usually located as part of or adjacent to theproduction facility. Such shops, which are an ancillaryuse to the main manufacturing activity, are not anestablished part of the retail scene in Ireland, thoughexamples of tourism related outlets for craft products(e.g. crystal) may be found. Proposals for individualfactory shops may be appropriate, provided the scale ofthe shop does not affect the viability of nearby towncentres or raise significant traffic and transport issues.

86. The concept of factory outlet centres originated in theUnited States. During the 1990s purpose built factoryoutlet centres have been developed in Europe, remotefrom manufacturing facilities. These include a groupingof factory outlets and other shops, focusing mainly onbranded fashion and other specialist goods andgenerally in out-of-centre locations. Initially devised asa means of disposing of seconds or surplus stock at theend of the season, they can become a mechanism formanufacturers to sell current products direct to thecustomer if appropriate controls are not exercised.Unless the sale of goods can be regarded as a useincidental to the manufacturing process, such outletsshould be treated as normal retail developments andassessed accordingly.

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87. The success of these centres depends on drawingcustomers and visitors from a wide catchment area,including tourists, and there may be implications forexisting tourist centres and established town centres,even those some distance from the proposal. Inparticular, they can lead to the diversion of expenditureon comparison shopping, particularly fashion andspecialist goods which forms a key component of towncentre turnover. Conversely, if a factory outlet centre islocated so that it links well with an established touristcentre or town centre and thus achieve commercialsynergy it can assist in raising the profile of a town andenhancing aggregate town centre turnover on retailgoods and leisure activities.

88. The relatively small population of Ireland suggests thatthere is market potential for only a limited number offactory outlet centres. Applications for thedevelopment of factory outlet centres should beconsidered in relation to the provisions of thedevelopment plan and paragraph 65 of theseguidelines. Because of the potential economic benefitsto town centres which can arise from the closeproximity of factory outlet centres and established towncentres, particular attention should be given to thelocation of factory outlet centres on the edge-of-towncentres or where a short, high quality public transportlink can be provided. It should be recognised, however,that factory outlet centres are unlikely to succeedcommercially in close proximity to the main towncentres in Ireland because retailers do not normallychoose to trade at a large discount in direct competitionwith their high street outlets. However, experienceshows that this constraint is unlikely to arise withsmaller or secondary town centres, especially those inareas which attract large numbers of tourists.Consequently, the most appropriate location for factoryoutlet centres is likely to be where commercial synergy

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can be achieved between an outlet centre and a towncentre which would lead to economic benefits for thelocal area. It is not considered that factory outletcentres would be appropriate for greenfield out-of-townlocations.

Retail Warehouse Clubs89. Retail warehouse clubs or discount clubs combine

elements of cash and carry wholesaling with sales toqualifying members of the public. This balance mayvary according to the operator. Despite restrictions onthose who may shop in them or the range of goods thatcan be sold, these outlets often share many of thecharacteristics of very large retail outlets, in which casethey should be treated for the purpose of this guidanceas if they were retail businesses and subject to thepolicy provisions of the development plan and therequirements set out in paragraph 65.

Shops in Small Towns and Rural Areas90. Small towns and villages are now less self sufficient

than 20 or 30 years ago. One result of this has been anincreasing dependence on larger settlements for theprovision of goods and services as well as foremployment. Over time, smaller towns have lost manyof the functions previously found within them -including retail functions. This process is cumulative.The closure of a single outlet may represent a generaldecline in local businesses in rural areas. Localeconomic self-sufficiency is weakened by this processand it forces those living in rural areas to relyincreasingly on urban centres for goods and services4.The overall policy response in relation to these trendsand the broad thrust of rural development policy is setout in the Government's White Paper on RuralDevelopment entitled Ensuring the Future - A Strategy for

_________________________4 NESC New Approaches to Rural Development No. 97, November 1994

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Rural Development in Ireland published in August, 1999.The policy set out in the White Paper was taken intoaccount in the preparation of the National SpatialStrategy.

91. Existing foodstores and supermarkets often play a vitalrole in maintaining the quality and range of shopping insmaller rural town centres and assist in anchoring thesurrounding rural economy, particularly in less denselysettled areas of the State. Planning policies should besupportive of local facilities in small towns and villageswhich provide an effective and valuable service to thelocal community. Such centres should continue toprovide not only for food, but also some comparisonshopping and should be the preferred location,especially for food stores. Where rural town centres arenot serving the community well, and there is asignificant amount of travel by car to other largercentres, then proposals for new retail developmentsshould be encouraged in or near the town centre, inorder to reduce travel and retain trade in the town.

92. In small towns and villages there is therefore a clearpresumption in favour of central or edge of centrelocations for new developments. As elsewhere, out-of-centre retail developments should not be allowed iftheir provision is likely to lead to a reduction in therange of local facilities in towns and villages or affectthe diversity of shops or lead to the loss of general foodretailing from the centre of smaller towns. The scope forsuperstores and other large scale retail developments islikely to be more limited in smaller rural towns thanelsewhere. Where appropriate, development plansshould indicate the maximum size of store, consistentwith maintaining a variety of shops in the centre andprotecting rural retail provision. In framingdevelopment plan policies on this issue, planningauthorities should bear in mind the need to avoidtaking any actions which would have an adverseimpact on competition in the retail market.

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Village Shops93. The village shop plays a vital economic and social role

in rural areas and is important for essential day-to-dayneeds, particularly for the elderly, disabled and thosewith no access to a car or poorly served by publictransport. Its loss can have an impact on thecommunity. The implications for village shops shouldtherefore be addressed when planning authorities areassessing new retail development proposals in nearbytowns.

94. Retailing should generally be directed to existingsettlements and development in the countryside shouldbe resisted. Exceptionally, retail facilities outside thedevelopment limits of settlements and beyond greenbelts could be acceptable in the followingcircumstances:• A shop which is ancillary to activities arising

from farm diversification.• A shop designed to serve tourist or recreational

facilities, and secondary to the main use.• A small scale shop attached to an existing or

approved craft workshop retailing the productdirect to the public.

• A small scale shop designed to serve a dispersedrural community.

Local Shops95. Local shops located in local centres or neighbourhood

centres perform an important function in urban areas.They can provide a valued service, catering particularlyfor the daily or casual needs of nearby residents or ofthose passing by. Local shops encompassing bothfoodstores and important non-food outlets such aspharmacies have significant social and economicfunctions; they offer a particularly important service forthose who are less mobile, especially elderly anddisabled people, families with small children, and thosewithout access to a car. For example, in peripheralhousing estates they may provide the only readily

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accessible shopping facilities. Where a planningauthority can substantiate clearly the local importanceof such shops in defined local centres, they shouldsafeguard them in development plans, throughappropriate land-use zoning.

Petrol Filling Stations96. Petrol filling stations can provide a wide range of retail

goods in an associated shop. In rural areas, somefunction as the local shop or small supermarket. Whilstthe important role of such provision is recognised, suchshops should, in general, remain secondary to the useas a petrol filling station. The size of shop associatedwith any petrol filling station should take account of thefollowing factors. Firstly large stores tend to attractadditional custom. This can lead to additional carborne trips primarily for shopping purposes. Secondly,large numbers of parked cars in station forecourts cancause disruption and queuing for those simply wishingto use the petrol pumps. Thirdly, the preferred locationfor retailing is in town centres, not an isolated siteoutside these preferred locations (sequential approach).

97. Notwithstanding the sequential approach, a shop of upto 100 square metres of net retail sales area may beallowed when associated with a petrol filling station.Where retail space in excess of 100 square metres of netretail sales area associated with petrol filling facilities issought the sequential approach to retail developmentwill apply, i.e. the retail element of the developmentshould be assessed by the planning authority in thesame way as would an application for retaildevelopment (without petrol filling facilities) in thesame location. In considering applications fordevelopment, attention should also be given to thesafety aspects of circulation and parking within thestation forecourt.

98. Petrol filling facilities ancillary to large foodstoreslocated in or adjacent to town centres often provide

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healthy competition in this sector of the market withoutadversely affecting town centres. It is not axiomatic,however, that all large foodstore formats should haveancillary petrol filling facilities, particularly where theobjective of planning policy is, wherever possible, to fitfoodstores on sites within or on the edge of towncentres. It will often be difficult to find a site in thistype of location with acceptable road access which issufficiently large to allow both a full sized store and apetrol filling station. Consequently retailers should notseek to claim that they are unable to assemble siteswithin a town centre or on the edge of one, simplybecause they face difficulty in assembling a site capableof accommodating a large foodstore and a petrol fillingstation.

Application of Floorspace Caps

99. As indicated at paragraph 53 it was intended thatplanning authorities outside the Greater Dublin Areawould incorporate retail policies and proposals in adevelopment plan within 18 months of the publicationof the guidelines published in 2000. Within the GreaterDublin Area, this period was shortened to 12 monthsgiven the urgency of the position. Until retail policiesand proposals in line with the recommendations ofthese guidelines have been incorporated intodevelopment plans by planning authorities, thefloorspace caps/thresholds specified in these guidelinesin the Section of the guidelines entitled "Assessing NewDevelopments – Specialist Types of Development"should be applied by planning authorities, i.e. planningpermission should not be granted for any newdevelopments which contravene the floorspacethresholds recommended in these guidelines. Planningpermission should also not be granted for any change ofuse which would result in a retail outlet contraveningthe floorspace caps/thresholds recommended in theseguidelines.

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Annex 1:Glossary of Terms

This glossary covers forms of retail development and types ofretail location. Because retailing is dynamic, it should be notedthat new forms of retailing may evolve which are inadequatelydescribed by current terminology.

Types of Retail Floorspace

Total mall floorspace – internal area (measured from insidewalls) of a covered mall including gross retail area, floorspacedevoted to incidental activities, entrance space centreadministrative office, toilets, lifts and escalators and walkways.

Net lettable retail area – total floorspace (measured frominside the shop walls) which is let to a retailer.

Gross retail area – this is the net lettable area – i.e. sales space,plus storage space, offices, toilets, canteen and circulationspace.

Net retail sales area – the area of a shop or store which isdevoted to the sales of retail goods (including the area devotedto checkouts).

Types of Retail Goods

Although there is a trend for "scrambled merchandising"whereby some retail businesses sell both convenience goodsand comparison goods, greater definitional clarity is obtainedby adopting a goods based retail classification. Retail goodscategories are defined by reference to the National Income andExpenditure Accounts and can be divided into conveniencegoods and comparison goods as follows:

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• Convenience - food- alcoholic and non-alcoholic

beverages- tobacco- non-durable household goods

• Comparison - clothing and footwear- furniture, furnishings and

household equipment (excluding non-durable householdgoods)

- medical and pharmaceutical products, therapeutic appliances and equipment

- educational and recreation equipment and accessories

- books, newspapers and magazines- goods for personal care and goods

not elsewhere classified

The value of repairs is excluded inall cases.

• Bulky goods - Goods generally sold from retail warehouses where DIY goods or goods such as flatpack furniture are of such a size that they would normally be taken away by car and not be manageable by customers travelling by foot, cycleor bus, or that large floor areas would be required to display them e.g. furniture in room sets, or not large individually, but part of a collective purchase which would be bulky e.g. wallpaper, paint.

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Types of Convenience Good Shopping

Discount food store – single level, self service store normally ofbetween 1000 – 1500 square metres of gross floorspace selling alimited range of goods at competitive prices, often withadjacent car parking.

Supermarkets – Single level, self-service stores selling mainlyfood, with a net sales area of less than 2,500 square metres,often with adjacent car parking.

Superstores – Single level, self-service stores selling mainlyfood, or food and some non-food goods, usually with at least2,500 square metres net sales floorspace with dedicated surfacelevel car parking.

Hypermarket – Single level, self service stores selling both foodand a range of comparison goods, with net sales floorspace inexcess of 5,000 square metres with dedicated surface level carparking.

Convenience Outlet – Single level, partially self service storewith no adjacent car parking, selling food and otherconvenience items, with a net sales area of not more than 500square metres, and a product range less than that carried by asupermarket. Such stores are characterised by longer openinghours than supermarkets.

Types of Comparison Goods Shopping

Retail mall – Purpose built centres (either in-centre or out-of-centre) incorporating a mix of larger stores and individualshops usually concentrating on comparison goods, togetherwith some convenience shopping and sometimes commercialleisure and/or a food court.

Regional shopping centres – Out-of-town retail malls generallyof 50,000 square metres gross retail floorspace or more,typically enclosing a wide range of clothing and othercomparison goods with extensive dedicated car parking.Regional shopping centres do not normally incorporate retailwarehouses.

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Retail parks – A single development of a least three retailwarehouses with associated car parking.

Retail warehouse – A large single-level store specialising in thesale of bulky household goods such as carpets, furniture andelectrical goods, and bulky DIY items, catering mainly for car-borne customers and often in out-of-centre locations.

Warehouse clubs – Generally out-of-centre retailers specialisingin bulk sales of reduced price, quality goods in unsophisticatedbuildings with dedicated car parks. The operator may limitaccess to businesses, organisations or classes of individual,through membership restrictions.

Factory shop – A shop adjacent to the production unit andspecialising in the sale of manufacturers’ products direct to thepublic.

Factory outlet centres – Group of shops, usually in out-of-centre locations, specialising in selling seconds and end-of-linegoods at discounted prices.

Types of Centre

Town centre – In this guideline, the term "town centre" is usedto cover city, town and district centres which provide a broadrange of facilities and services and which fulfil a function as afocus for both the community and public transport. It excludesretail parks, local centres and small parades of shops of purelylocal significance.

District centre – Either a traditional or purpose built group ofshops, separate from the town centre and either located withinthe built-up urban area or in a suburban location on the edge ofan urban area, usually containing at least one foodsupermarket or superstore and non-retail services, such asbanks, building societies and restaurants.

Local centre or neighbourhood centre – Small groups of shops,typically comprising a newsagent, small supermarket/general

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grocery store, sub-post office and other small shops of a localnature serving a small, localised catchment population.

Types of Location

Retail area – That part of a town centre which is primarilydevoted to shopping.

Prime pitch – That part of the retail area of a town centre orretail mall where pedestrian flows are greatest, competition forrepresentation is greatest and rents are noticeably higher thanelsewhere.

Edge-of-centre – A location within easy walking distance(usually not more than 300 to 400 metres) of the primary retailarea of a town centre, and providing parking facilities thatserve the centre as well as the new development thus enablingone trip to serve several purposes.

Out-of-centre – A location that is clearly separate from a towncentre but within the urban area, including programmedextensions to the urban area in approved or adopteddevelopment plans.

Out-of-town – An out-of-centre development on a green fieldsite, or on land not clearly within the current urban boundary.

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Annex 2:Assessing the Vitality and Viability ofTown Centres

1. The concept of vitality and viability is central tomaintaining and enhancing town centres. It willdepend on many factors, including the range andquality of activities in a centre, its mix of uses, itsaccessibility to people living and working in the areaand its general amenity, appearance and safety. Ahealthy town centre which is vital and viable balances anumber of qualities:

• Attractions – these underpin a town andcomprise the range and diversity of shoppingand other activities which draw in customersand visitors.

• Accessibility – successful centres need both to beaccessible to the surrounding catchment area viaa good road network and public transportfacilities, and to encompass good local linkagesbetween car parks, public transport stops andthe various attractions within the centre.

• Amenity – a healthy town centre should be apleasant place to be in. It should be attractive interms of environmental quality and urbandesign, safe, and it should have a distinctidentity or image.

• Action – to function effectively as a viablecommercial centre things need to happen.Development and improvement projects shouldbe implemented efficiently; there should beregular and effective cleaning and maintenanceand there should be co-ordinated town centremanagement initiatives to promote thecontinued improvement of the centre.

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2. Although no single indicator on its own can measurethe performance of a town in relation to these fourelements of all round "health" it is possible to gain agood appreciation by undertaking a health checkassessment using a variety of indicators. This providesa consistent framework for assessing vitality andviability. In this way the strengths and weaknesses oftown centres can be analysed systematically andplanning authorities will be able to ascertain how wellcentres are performing in terms of their attraction,accessibility, amenity and action programmes. Suchhealth checks should both inform and be undertakenwithin the framework provided by the developmentplan. Local authorities, in keeping their area underreview, should collect information on key town centreuses, including sites which may be suitable and maybecome available for retail and other non retail uses,with or without rehabilitation or redevelopment.

3. The most appropriate health check indicators aresummarised below:

(i) Diversity of uses: how much space is in use fordifferent functions – such as offices, shopping,other commercial, leisure, cultural andentertainment activities, pubs, cafes andrestaurants, hotels, educational uses, housing –and how has that balance been changing?

(ii) Retailer representation and intentions to changerepresentations: it may be helpful to look at theexistence and changes in representation,including street markets, over the past few years,and at the demand from retailers wanting tocome into the town, or to contract or close theirrepresentation.

(iii) Shopping rents: pattern of movement in retailrents within primary shopping areas.

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(iv) Proportion of vacant street level property:vacancies can arise even in the strongest towncentres, and this indicator must be used withcare. Vacancies in secondary frontages andchanges to other uses will also be usefulindicators.

(v) Accessibility: the ease and convenience of accessby a choice of means of travel, including thequality, quantity and type of car parking, thefrequency and quality of public transportservices, the range of customer origins servedand the quality of provision for pedestrians andcyclists.

(vi) Environmental quality: this indicator shouldassess the physical condition of a town (clutter,litter and graffiti) and the environmentalattributes (quality of shopfronts, landscapingand open spaces).

(vii) Customer views and behaviour: regular surveysof customer views will help authorities inmonitoring and evaluating the effectiveness oftown centre improvement and in setting furtherpriorities. Interviews in the town centre and athome should be used to establish views of bothusers and non-users of the centre. This couldestablish the degree of linked trips.

(viii) Perception of safety and occurrence of crime: thisshould include views and information on safetyand security.

(ix) Commercial yields on non-domestic property(i.e. the capital value in relation to the expectedmarket rental): this demonstrates the confidenceof investors in the long term profitability of thecentre for retail, office and other commercialdevelopments. This indicator will normally only

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be available for the larger town centres andshould be used with care as investor confidencecan be influenced by a number of extraneousfactors unrelated to a particular centre and formany smaller centres there are in any event onlya limited number of investment attractions fromwhich conclusions can be drawn.

(x) Pedestrian flows: the numbers and movement ofpeople on the streets, in different parts of thecentre at different times of the day and evening,who are available for businesses to attract intoshops, restaurants or other facilities. To beeffective this indicator should be monitoredregularly as it is the relative values (rather thanabsolutes) which are important together withclear evidence of changes over time.

4. These indicators should be collected and monitoredregularly for the main centres in the retail hierarchy inorder to provide baseline and time-series informationon the health of centres and allow comparison betweencentres. Planning authorities should co-operate withthe private sector in collecting data. The indicators willalso provide the necessary context for considering theimplications of retail impact assessments. In manyinstances it may be difficult to obtain all the healthcheck indicators, especially for local authorities withlimited staff resources. Where priorities on datacollection have to be established emphasis should begiven to indicators (i)-(vi), especially in the smallertown centres.

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Annex 3:Assessment of Additional Retail andCommercial Leisure FloorspaceRequirements

Introduction

1. This Annex provides guidance on the way in whichplanning authorities should assess the followingmatters relating to the requirement to assess marketdemand and the need for additional retail development:

• Existing retail floorspace. • Assessment of demand.• Assessment of the need for additional

development.

2. The purpose of county planning authorities addressingthese factors is firstly to enable the plan preparationprocess to be properly informed about the quantum andtype of development that the market is likely to bringforward. Secondly, in order to plan for the location andscale of additional development, the planning systemneeds to be informed as to the type of additionalfloorspace likely to be required in order to meet theprojected growth in population and consumerspending.

3. It is the purpose of the planning system to regulate theuse of land and the scale of development in thecommon good. To achieve this in relation to retaildevelopment, guidance is required which retailers anddevelopers can follow in the development controlcontext. Certainty and clarity will assist thedevelopment process. To ensure realism CountyCouncils must consult fully with the private sectorwhen preparing development plan guidelines.

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Existing Retail Floorspace

4. The starting point for any assessment of additionalrequirements is to measure both the health of retailcentres in accordance with the principles set out inAnnex 2, and to measure the existing quantum offloorspace. The last comprehensive survey of shoppingfloorspace in Ireland was the 1988 Census of Services.The Government does not propose to repeat a Census ofServices and it is necessary for local authorities toupdate the information on retail floorspace. This can beobtained either by checking the changes in newdevelopment and changes of use and demolitions sincethe 1988 Census of Services using development controldata, or by initiating a special retail floorspace survey.

Market Demand

5. A general picture of emerging retailer demand can beobtained from the following sources:

• Trends in planning applications for differenttypes of retail development.

• Review of relevant newspapers, journals andperiodicals.

• Consultations with retailers, leisure operators,and property agents.

6. Planning authorities should seek to identify the trendsin market demand from these sources so that they canbe taken into account when preparing developmentplans.

Assessment of Need

7. A broad assessment of the requirement for additionalretail floorspace can be provided by projecting thefuture change in population and the growth inconsumer spending. Projections of increased spendingshould seek to identify the change in the value of

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spending at constant prices, rather than prices whichinclude the effect of inflation.

8. County councils need to prepare plans for theiradministrative areas. These may not necessarily reflectthe catchment area for the various retail centres withintheir administrative area boundaries. Consequently it isnecessary to establish broadly speaking the real worldcatchment area for key centres and to make allowancesfor cross boundary shopping flows either into thecounty or out of it. In rural areas it is often possible tomake estimates of catchment areas in sparselypopulated countryside by reference to the relativedistance between competing centres and the presence ofstrong geographical boundaries such as major rivers,estuaries, motorways, railway lines or mountains. Inmore densely populated areas where there are betterroad and rail communications and where retail centrescompete more strongly with one another in thehierarchy it may be necessary to commission surveys ofshopping patterns.

9. Assessments of the change in retail spending which canbe expected to be generated within the catchment areaof retail centres can provide a useful mechanism foridentifying future retail development requirements.The projected growth in retail spending can readily beconverted into retail floorspace using appropriate salesdensity ratios for the different types of retail formats tobe provided. The Department of the Environment,Heritage and Local Government will liaise with theCSO to ascertain whether up to date information can beprovided on the net retail sales area and turnover ofbusinesses responding to the Annual Inquiry. This willenable trends in sales densities to be monitored. Theresulting estimates should be treated as broad planningguideline requirements which can be monitored andadjusted over time in the light of events on the groundand changing market conditions.

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Annex 4:The Assessment of Retail Impact

1. It is commonly accepted that there are six main steps tothe assessment of retail impact:

(i) Identification of catchment or study area.

(ii) Estimation of expenditure available within thedefined catchment or study area.

(iii) Estimation of the turnover of existing centreswithin the catchment area which are likely to beaffected by a new development.

(iv) Estimation of the turnover of the newdevelopment for which a planning application isbeing lodged.

(v) Estimation of the quantum of consumer retailspending available in the catchment area whichwill be diverted from existing centres to the newretail development; this assessment normallyhighlights the diversion of expenditure by zonewithin the catchment area.

(vi) Aggregation of the zonal diversions from eachcentre to the new development to provide anestimate of trade diversion; trade diversion isthen expressed as a proportion of a centre’sturnover at the target year to provide a measureof impact.

2. Many of these steps in the assessment of retail impactare relatively straightforward and make use of readilyavailable data. The one matter that is less clear cut inthe assessment of impact is step (v) which is where theestimate of trade diversion from each of the centres in

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the retail system to the proposed development is made.A variety of approaches can be adopted at this stage ofthe assessment, some more sophisticated than others. Itis not intended to impose a required methodology tothis stage of the calculation. It is important for allapproaches to be clearly substantiated, however,preferably using up to date information and surveyevidence as far as possible. Unsubstantiatedjudgements and assertions do not assist in providing aclear assessment.

3. Those submitting retail impact studies on behalf ofclients, or considering the work of others on behalf ofclients should at all times be aware of the need tomaintain professional objectivity. The purpose of animpact study is to provide clarity and guidance fordecision makers. Clear, well reasoned and impartialsubmissions should be made which seek to addressuncertainty and inform all parties.

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