Carnegie Retail Park March 2013 Prepared for Zurich
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MIR SUBMISSION – CARNEGIE RETAIL PARK MARCH 2013 PREPARED FOR ZURICH ASSURANCE LTD and THREADNEEDLE PROPERTY INVESTMENTS LTD CONTENTS Page 1.0 INTRODUCTION ................................................................................................ 1 2.0 SITE DESCRIPTION & PLANNING HISTORY.................................................................. 3 3.0 PLANNING POLICY CONTEXT................................................................................. 4 4.0 JUSTIFICATION FOR PROPOSAL & CONSIDERATION OF MATERIAL ISSUES............................. 5 5.0 CONCLUSIONS.................................................................................................. 8 APPENDICES APPENDIX 1: BULKY GOOD RETAILERS ACTIVE 1994 TO 2013 APPENDIX 2 : PROPOSAL FOR REVISED COMMERCIAL CENTRE BOUNDARY MIR Submission 1.0 INTRODUCTION 1.1 This submission has been prepared by James Barr Limited on behalf of Zurich Assurance Ltd and Threedneedle Property Investments Limited in relation to Carnegie Retail Park. The submission should be treated as a ‘representation’ to the Main Issues Report. 1.2 It should be noted that this submission is made in tandem to a submission by Carnegie Regeneration Ltd. 1.3 The retail park has changed little since it was built in the 1990’s and there have been few new retailers introduced to the park for a number of years. The original consent affecting the site is restricted to what is commonly referred to as ‘bulky goods’ Context 1.4 In that context the number of retailers that are now available to occupy this retail park are significantly diminished due to mergers and companies going into administration. On average the number of retailers in the ‘bulky goods’ market has reduced by some 50%, higher in some sectors such as electrical. The shift in ‘bulky goods’ retailers over the last 20 years is set out in Appendix 1. 1.5 It is clear that the current economic position has resulted in falling demand, generally as a result of a drop in discretionary spending on products typically linked to the movement of the housing market such as a DIY, floorcoverings and furniture. 1.6 Some agencies estimate the future annual growth in bulky goods to 2019 to be 2.8% compared to a growth of 11.7% from 1991 to 2011. 1.7 In addition the rapid growth in the internet in recent years has increased the market share of non- store retail sales and the potential impact on shopping centres. Current estimates indicate that comparison sales relating to special forms of trading (which includes internet sales) will increase from 7% in 2002 to 21% in 2029. 1.8 To reflect this Retail Rankings indicates that during the economic downturn it was operators who expanded their operations online who managed the highest growth, with the highest growth being achieved by Ebay. Increasing sales linked to internet based companies such as Ebay and Amazon are also significantly affecting the trading performance of electrical retailers, evident in Comets recent demise creating a vacant unit at Carnegie Retail Park 1.9 The current economic position and the predicted trends in retailing have implications for the future of Carnegie Retail Park. As noted above, Carnegie Retail Park is a first generation retail park and has changed little over the last 20 years since it was developed. A more flexible approach to the site requires to be adopted to allow the retail park to develop and modernise. James Barr/Zurich-Threadneedle 1 MIR Submission 1.10 At present there are 2 vacant units in the retail park but it is anticipated that given the issues associated with other retailers in the park that the number of vacant units could rise. In addition the park is under competition from Halbeath Retail Park. Halbeath is at an out of centre location but has managed to secure a less restricted consent and therefore a wider range of tenants and floorspace than that available at Carnegie. That coupled with current proposals to expand and de- restrict the floorspace further at Halbeath Retail Park could present a number of challenges to the future viability of the park. 1.11 Higher vacancy rates and increased competition from Halbeath Retail Park could potentially undermine the vitality and viability of the retail park. It would have a negative impact on the appearance and attractiveness for shoppers, resulting in reductions in footfall and a negative impact on its viability. This could also have a knock on affect on the adjacent town centre. The Proposal 1.12 The owners are presently looking at options to address such problems through planning applications (in this regard it is acknowledged that planning permission was permitted to allow Matalan to trade from the park last year) but on review it is considered that a more significant proactive change will be required to ensure the sustainability of the retail park. 1.13 This representation therefore seeks to remove the policy restrictions that apply to Carnegie Retail Park and requests that the Proposed LDP supports a much wider range of goods that can be sold from this location. 1.14 It is our opinion that this requires to be promoted to support the continued investment and growth of Carnegie Retail Park and to ensure its sustainability. This would follow the advice of SPP as it would provide a positive policy context for Carnegie Retail Park as a Commercial Centre in the Network of Centres to attract investment to maintain and improve the commercial centre. 1.15 The proposal is therefore to identify Carnegie Retail Park as an edge of town centre/commercial centre where unrestricted Class 1 retail use (both convenience and comparison) is acceptable in policy terms. James Barr/Zurich-Threadneedle 2 MIR Submission 2.0 SITE DESCRIPTION & PLANNING HISTORY Site Description 2.1 Carnegie Retail Park is a first generation retail park and has changed little since it was built in the 1990’s. 2.2 The retail park is an established retail destination, located on the edge of the town centre just to the north of the town centre and Carnegie Drive. 2.3 The retail park presently consists of 9 units with 2 of the units currently vacant. Current tenants include B&Q, Halfords and Farmfoods. 2.4 The close physical relationship between the site and the town centre is apparent. Car parking as the site is widely used by shoppers visiting town centre facilities indicating a strong element of linked trips. Also since the redevelopment of the Kinsgate centre a stronger pedestrian link between the Kingsgate and Carnegie Retail Park has been created. Planning History 2.5 Outline planning permission was granted in March 1989 for the erection of 10451sq.m of retail warehousing (ref 87/0145). Subsequent Reserved Matters were granted in May 1989. 2.6 An appeal in 1992 (P/PPA/FA/203+204) permitted the use of convenience sales from units 2 and 6. 2.7 Since that time the retail park and the range of tenants has changed little over those last 20 years despite the retail market changing significantly. 2.8 The original consent affecting the site is restricted to what is commonly referred to as ‘bulky goods’. In this regard the range of goods to be sold from the Retail Park are restricted to the following: Carpets and floorcoverings Household textiles and soft furnishings Furniture Garden equipment DIY and home improvements Cycles and motoring parts and accessories Electrical goods 2.9 Following the 1992 appeal decision, Units 2 and 6 can also retail convenience goods. James Barr/Zurich-Threadneedle 3 MIR Submission 3.0 PLANNING POLICY CONTEXT Scottish Planning Policy 3.0 Policy objectives contained in the Scottish Planning Policy document (SPP) sets out Government guidance on Town Centres and Retailing. The policy supports the Scottish Government’s top priority of growing the economy, as well as its wider goals relating to social justice, sustainable transport, health improvements, an improved environment and a better quality of life. 3.1 SPP confirms development plans should identify a network of centres, and explain the role of each centre in the network. The network will, depending on circumstances, include town centres, commercial centres and other local centres, and may take the form of a hierarchy. Within the network the individual role of each centre should support and be supported by the role of other centres. The development plan can also specify a centre's function, for example a centre restricted to the sale of bulky goods. The SPP also confirms that networks will change over time, therefore any significant changes in the evolving role and function of centres should be addressed through development plans. 3.2 SPP advises that Commercial Centres are distinct from town centres as their range of uses and physical structure makes them different in character and sense of place. They generally have a more specific focus on retailing or on retailing and leisure uses. Examples of commercial centres include out-of-centre shopping centres, commercial leisure developments, mixed retail and leisure developments, retail parks and factory outlet centres. 3.3 Paragraph 55 of SPP confirms that the network of centres identified in the development plan will provide a context for the assessment of proposals for new development. Where proposals support a centre's role and function, as identified in the development plan, there is no requirement to provide a detailed assessment of need. The SPP also advises that investment to maintain and improve commercial centres should be supported where the centres are part of the network and where such investment will not undermine town centres. 3.4 In this regard Paragraph 56 advises that opportunities for improving the physical quality and sustainability of town and commercial centres should also be identified in the development plan, providing the framework for the development of town centre strategies. Dunfermline and West Fife Local Plan 3.5 The Dunfermline and West Fife Local Plan was adopted in 2011 and therefore is up to date.