Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6363

Received: 13/09/2021

Respondent: Mr John Orchard

Representation Summary:

Whilst I am writing this response as a local resident, I cannot ignore that I have been a retail manager for nearly fifty years, in town centre management for thirty five years and am a trained and practicing geographer with the distinction of being one of a very small number that has carried out primary research into the real impact of business rates in town centres and less exclusively, town centre dynamics.

The policy(ies) are certainly in line with the NPPF and intentions of the government. However, I have been continuously critical of the background to the NPPF policies since they are, in my opinion, fundamentally flawed.

The policies and the language employed is all about the town centre being a retail space. I agree that that is how they have become, but that Is due to the culmination of policy (Town and Country Planning Act, 1947 (and subsequent Acts); Abolition of Resale Price Maintenance (1964) (and the precursor measures in the 1940s and 50s); and the resulting changes to the retail paradigm, land ownership and developing strength of specific vested interests including corporate retailers and professional planning bodies.

Retailing will thrive in places where there is a sufficient number of people with a disposable income, however, the retailers will identify the best sites based on their own business plans and models – these are not always in synch with thinking in planning departments.

The language employed now that we are into the third decade of the current debate on the state of the high street speaks of mixed use. The very thing that high streets were until 1964 and the change of the retail paradigm – which was then taken up by the planning professionals to produce separate zones of activity in our towns.

This policy seems to be enhancing the Town Centre First policy of the NPPF, but since that has a very chequered history in terms of its application, it is important that these policies are adhered to in a fair and equitable manner and not varied solely on the basis that a particular retailer dislikes it. Corporate retailers have no loyalty to any location and to build towns around their perceived needs is fraught with problems.

Over the past fifteen years one of my main functions has been to work as a consultant to the administrators of large corporate retail businesses in administration. Looking after large groups of stores and their staff during the really difficult periods in which they are under threat of job loss has focused my attention on the downsides of reliance on retailing as a basis for planning, and it has certainly eradicated any ideas that I ever had of seeing retailing as the basis of regeneration.

Our policies ought to reflect the mix of use, and local authority weight needs to be behind the identification by the people of what role their town centre should have. In the town in which I moved to in 1961 the main street was populated largely by shops, but also with some residential, and a large dose of other stuff, such as public halls, theatres, pubs, cinemas, banks professional advisers and the retail offer was a real mix of corporate brands and locally owned businesses.
The 1964 paradigm shift in retailing resulted in the marginalization in many towns of any other activity than retailing by the main brands. The subsequent movement towards out of town or edge of town sites created new and well-received retailing spaces, but in the absence of policy or effort by planners, the traditional sites started to see increasing numbers of voids.

The regeneration of any town can only be achieved by a series of separate but economically linked activities:

1) The establishment of high level wealth creating activity. Contrary to many reports, retailing does not create wealth it merely moves capital around, very often away from the town concerned.
2) The informed and joined up approach to land valuations, and the positive influence of the local authority on the valuations of town centre properties to effectively reflect the state of their situation.
3) The acceptance that there is too much retail sales floor space and that any new opening anywhere in the catchment will have an impact on existing stores.
4) That the current planning determinants by classes is no longer fit for purpose and works against the process of encouraging mixed use.
5) That business only consultations or business only improvement districts are restrictive and likely to provide flawed plans.

Bedford is a town that evolved throughout the medieval period. It did so without the need for positive planning. Instead it relied on markets being driven by demand and responding. It is a place that has an enormous potential given its architectural, cultural and topographical advantages.

The wholly predictable demise of all of the departments stores in the town offers opportunities, but also attendant threats. The Nexus report, which itself speaks loudly of the retail role and the rise and fall of certain brands in the town says nothing about how retailing will thrive without the overarching economic activity that was once provided by industrial activity or similar. That is a serious flaw in the report which is in any case already out of date. It is dangerous to base policy on flawed and outdated data.