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.

3.6 The adopted Local Plan under Policy R3 states that the range of comparison goods to be sold from locations outwith town centres such as retail parks will be limited by condition to exclude clothing and footwear, jewellery or watches/clocks, books, CD/DVD’s and games software.

James Barr/Zurich-Threadneedle 4 MIR Submission

4.0 JUSTIFICATION FOR PROPOSAL & CONSIDERATION OF MATERIAL ISSUES

4.1 The Development Plan has endorsed the use of the above noted retail goods restrictions at Carnegie Retail Park but it has to be acknowledged that these policies are now over 20 years old and are no longer relevant to today’s retail market.

4.2 The Main Issues Report confirms that the planning system cannot control modern consumer tastes and trends and this statement itself highlights the conflict in the current policy approach. The Proposed LDP should aim to meet the needs of the residents in Dunfermline and in retailing terms the Proposed LDP provides an opportunity to the Council to respond to these changes in retailing trends. In particular there is an opportunity to encourage a wider range of uses at an appropriate location on the edge of the town centre where the benefits of such changes can be maximised.

4.3 Indeed there is a potential conflict with the restrictions that apply to Carnegie Retail Park (as applied by planning condition) to the range of restrictions considered appropriate in the recently adopted Dunfermline and West Local Plan.

4.4 The adopted Local Plan under Policy R3 states that the range of comparison goods to be sold from locations outwith town centres such as retail parks will be limited by condition to exclude clothing and footwear, jewellery or watches/clocks, books, CD/DVD’s and games software. This range of goods are less restrictive than the range of goods permitted by the restrictive planning consent that presently governs Carnegie Retail Park.

4.5 Having regard to the matters raised it is clear that Carnegie Retail Park needs to find a new role in the retail hierarchy of Dunfermline and West Fife. In this context its future cannot exist on DIY, electrical, furniture and garden goods alone. Whilst we acknowledged that a wider range of goods has been allowed from units 2/3 a more significant shift in the retail parks role and function is required.

4.6 The SPP 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.

4.7 In this regard Paragraph 56 of SPP 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.

4.8 SPP clearly advises that the Development Plan should provide a policy context to maintain and improve commercial centres. Therefore the Proposed LDP offers an ideal opportunity to re-think the role of Carnegie Retail Park, as a policy of “status quo” which simply adopts the same policy approach that has been in force for the last 20 years will not assist Carnegie Retail Park or indeed Dunfermline Town Centre.

James Barr/Zurich-Threadneedle 5 MIR Submission

4.9 Carnegie Retail Park as a Commercial Centre in the network of centres requires to be supported through a more flexible policy approach to allow it to respond to changing circumstances and identify a sustainable future role in the retail hierarchy.

4.10 In this regard we consider it is important that recognition is given to the site locations on the edge of the town centre. The sites location can bring benefits to the town centre by encouraging linked trips and providing complimentary retail facilities in formats not available in the town centre.

4.11 Whilst the town centre is the preferred location for new retail development it is recognised that town centres also function as hubs for public transport system. Consequently, if new developments are located in or adjacent to them, in preference to out of centre locations, the need for travel by private car could be reduced. This has a further advantage in that it contributes towards social inclusion by allowing new developments to be more accessible to those without access to private cars. In addition, if the investment takes place in centres, rather than outside them, their role can be reinforced and the centres revitalised.

4.12 It is our position that Carnegie Retail Park has excellent connectivity to public transport and the town centre and in this regard there is the potential for linked trips. An enhanced role in the Network of Centres will seek to compliment Dunfermline town centre by providing a new focal point at an appropriate site adjoining the town centre or even as part of a wider town centre allocation. In doing so it would be anticipated that the remainder of the centre could significantly benefit from this as any new investment would act as a catalyst to others and offer the possibility of linked trips.

4.13 In this context it is our view that a re-defined Carnegie Retail Park could make a positive contribution to the development and regeneration of Dunfermline Town Centre as an appropriate edge of centre location that is both functionally and visually linked to the town centre.

4.14 Evidence exists to support the view that an edge of centre development can be of assistance to the vitality and viability of a town centre and therefore support the town centre and the network of centres. It is our opinion that Carnegie Retail Parks edge of centre status could provide benefits to the town centre and could play a larger role in developing and improving the quality and level of retail provision as the park could build upon existing public transport linkages.

4.15 Indeed the sites location and relationship to the town centre has been identified as far back as 1992 where it was noted by a Scottish Office Reporter that “...I consider that there is an established, functional linkage between the town centre and the retail park based upon its physical proximity, complimentary shopping facilities, provision of well sited, free parking and the existence of a defined, well use pedestrian linkage.”

4.16 These comments are largely echoed in the consideration of the Matalan application in 2011 which the Report of Handling states “the close physical relationship between this site and the town centre is apparent, and allows for joint trips to be made for town centre uses as well as more bulky goods purchases.”

James Barr/Zurich-Threadneedle 6 MIR Submission

4.17 This close physical relationship to the town centre requires to be acknowledged in policy terms and integrated into a wider strategy to support Dunfermline Town Centre.

James Barr/Zurich-Threadneedle 7 MIR Submission

5.0 CONCLUSIONS

5.1 This representation seeks a change to the role and function of Carnegie Retail Park.

5.2 The range of acceptable goods that can be sold from Carnegie Retail Park is too restrictive and fails to recognise the opportunities for other retail opportunities which could be promoted to support the continued investment and growth of the Retail Park.

5.3 The Proposed LDP requires to follow the advice of SPP and 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. The Proposed LDP should provide a positive context for the physical improvement or sustainability of Carnegie Retail Park as a Commercial Centre.

5.4 In summary, this representation seeks to remove the 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. 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.

5.5 For clarity we would be seeking the following from the Proposed LDP :

1 acknowledge Carnegie Retail Park’s edge of centre location by inclusion in extended town centre boundary or by categorising it as an edge of town centre/commercial centre. A plan showing the extended centre is enclosed in Appendix 2

2 set a different policy position in relation to the edge of town centre location of Carnegie Retail Park to include unrestricted comparison and convenience retail use by re-defining its future role and function as a town centre retail park/shopping park

3 clearly define Halbeath Retail Park as an out of centre/commercial centre for bulky comparison goods

5.6 On this basis, we request that the restrictions on the range of goods that can be sold from Carnegie Retail Park be changed to allow a wider range of goods as noted and a more flexible policy approach should be adopted to allow the retail park to maintain and improve as an edge of town centre Commercial Centre.

James Barr/Zurich-Threadneedle 8 APPENDIX 1 NATIONAL MULTIPLE BULKY GOODS RETAILERS ACTIVE IN SCOTLAND

1994 TO 2013

TARGET LIST SIZE REQUIRED RETAILER COMMENTS (Sq Ft) FURNITURE RETAILERS Scottish based bed retailer based Archers Sleep Centres 7,500-10,000 on high street and retail parks Went into administration in May 2008. Opus, trading as B&M, Au Naturale Interiors 10,000 acquired large majority of Scottish retail park units. Acquired several Au Naturale stores in 2008 and have selectively B&M Home 10,000-25,000 expanded since. Already present at Halbeath Acquired by Steinhoff. Already Bensons Beds 5,000-10,000 present at Halbeath. Ceased trading Perth & Edinburgh Co-Op Concepts 30,000 and are no longer persuing this format. Two stores committed in Scotland CSL 12,000-20,000 for 2013. Traditionally trade from 20-30,000 sq.ft however are currently trialling DFS Furniture 10,000-30,000 their first 10,000 sq.ft store in Stirling. Entered Scottish market in 2006 after acquiring Off to Bed. Already Dreams 5,000+ present at Carnegie but now in administration Went into administration October Durham Pine 7,500+ 2005. Went into administration in Jun Habitat 10,000+ 2011. Homebase now own trading name. Steinhoff’s principal furniture offer which they are seeking to promote, Harveys 10,000-12,500 where possible, in a 2 in 1 format with Bensons Beds. Already present in Halbeath Went into administration June 2011. Homeform 10,000 Went into administration April 2012. Instyle 7,500+ Went into administration May 2007. Klaussner Furniture 5,000-10,000 Currently trading Braehead and Kutchenhaus 10,000 Aberdeen – entered market 2009. Withdrawing from Scotland.

1 Went into administration Jan 2009. Management buyout to World of Land of Leather 10,000 Sofa’s then into administration again in January 2011. Combination of concessions and Laura Ashley 5,000+ standalone stores. Went into administration Jun 2011. Life & Style 10,000 Ceased trading their retail offer on Linda Reid 12,000+ 2009. Have confirmed no longer acquiring Magnet 10,000 retail park units. Standalone and trade park only. Acquired by Sterling Furniture. Martin & Frost 20,000 Went into administration Nov 2008. MFI 10,000+ Currently expanding. Next Home 10,000+ Entered Scottish market in 2011. Oak Furniture Land 7,500+ Acquired by Dreams Nov 2006. Off to Bed 7,500 – 10,000 Moving away from retail parks. Pagazzi 10,000 Acquired by Steinhoff in Nov 2009 – company liquidated July 2011 whilst Reid Furniture 10,000+ retraining the brand on certain outlets. Most stores now closed. Went into administration Jul 2008 SCS Upholstery 10,000+ and bought by PPH Ltd. Steinhoff have now merged this Sleepmasters 7,500-8,500 brand with Bensons. Scottish based multiple – also trade Sterling Furniture 10,000+ Buick, Thompsons World of Furniture, Martin & Frost & Vogue. Acquired by Steinhoff. The Bed Shed 5,000+ Acquired by Sterling Furniture. Thompsons World of Furniture 20,000 Acquired by Sterling Furniture. Vogue Furniture 10,000+ Management buyout of Land of World of Sofas 10,000 Leather – went into Admininstration Jan 2011. Entered Scottish market in 2009. Wren Kitchens 10,000 Selectively expanding. TEXTILES

Dunelm 15,000+ Entered Scotland in 2003 – now struggling and seeking to reduce Harry Corry 10,000+ overheads by seeking rent reductions. Likely to withdraw from Scotland. Owned by EWM – trade either as concession or dedicated store. Ponden Home 5,000-10,000 Already present within Harveys / Bensons Beds.

2 Went into administration 2008 – Roseby's / Fabric Warehouse 7,500-10,000 EWM t/a Ponden Home acquired 77 stores. Went into administration in 2003, 10,000 Room 2 superseded them acquiring Texstyle World certain stores but also fell into administration. CARPETS/FLOORS Went into administration in August Allied Carpets 7,500+ 2011. Off pitch operator trading from secondary / trade locations. Behar Carpets 3,500 Acquired by Nixon & Hope in 2012 – see General George below. Recently closed nearby store. Scotland only - mainly in secondary Carpetways 5,000-10,000 / trade locations. Nationally dominant. Already Carpetright 5,000-10,000 present at Halbeath. Now acquired by Nixon & Hope Floors-2-Go 4,000-5,000 following administration in Aug 2011. Bought out of most recent administration in April 2012 by General George 7,500+ Nixon & Hope together with Floors 2 Go and Behar.. Off pitch operator trading from J & W Carpets 5,000+ secondary / trade locations. Acquired by Carpetright in 2007. Storey Carpets 10,000

ELECTRICAL RETAILERS Pulled out of UK retailing Nov 2011. Best Buy 30,000+ Acquired by PC World 1998. Byte Computer Superstores 10,000+ Currently in administration. Comet 10,000-35,000 Corporate strategy to integrate with Currys 10,000+ PC World in 2 in 1 format. Already present at Halbeath. Wound up in 2009. Factory Shack 5,000+ Maplin 5,000 ‘Harder’ electrical offer. Went into administration Jan 2009. Miller Bros 10,000-15,000 Corporate strategy to integrate with PC World 10,000+ Currys in 2 in 1 format. Already present at Halbeath. Went into administration Aug 2006. Powerhouse 10,000 No longer trades retail stores. Scottish Hydro Electric 10,000+ Acquired by Powerhouse in 2001. Scottish Power 10,000+

AUTOPARTs Nationally dominant. Already Halfords 5,000-10,000 present.

3 Went into administration Sep 2008. Motorworld 1,000 - 4,000

OFFICE FURNITURE

Merged with Staples 1996. Office Depot 10,000+ Acquired by DSG to trade as PC Office World 15,000+ World. Currently disposing of stores. No Staples 10,000+ active requirements in Scotland.

DIY

Part of Kingfisher – have recently picked up a number of Focus stores B&Q 25,000-100,000 following their administration. Represented at Carnegie RP. Went into administration May 2011. Focus DIY 15,000+ Acquired by Focus DIY in 2000 who Great Mills 30,000 subsequently went into administration. Part of Home Retail Group. Softer Homebase 25,000+ end of the DIY spectrum. Already present at Halbeath. Acquired by Homebase in 1999. Texas Homecare 20,000+ Acquired by Focus DIY in 2000 and subsequently by Travis Perkins in 2005. Currently targeting smaller Wickes 15,000-25,000+ format stores and potentially smaller specialist Kitchen & Bathrooms formats of c.5,000 sq.ft.

Change by Sector:

Sector 1994 2013 +/- Change % Change Furniture 35 16 -19 -54% Textiles 5 3 -2 -40% Carpets / Floors 8 4 -4 -50% Electrical 11 3 -8 -73% Autoparts 2 1 -1 -50% Office Furniture 3 1 -2 -67% DIY 6 3 -3 -50% Total: 70 31 -39 -56%

Please note calculations include multiple fascias operated by parent companies and those who have subsequently commenced trading following acquisition of the trading name.

4 APPENDIX 2 CARNEGIE DRIVE, DUNFERMLINE

Proposed edge of Town Centre/ Commercial Centre boundary

Town Centre boundary