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Chapter 8 - TOWN CENTRES & SHOPPING

8.1 INTRODUCTION

8.1.1 Shopping remains an activity integral to people's lives, fulfilling essential needs such as buying food to eat and clothes to wear as well as enabling other social requirements to be met. So the quantity, quality and location of shops has a significant effect on our quality of life. Town Centres therefore serve as the community focus not only of most shopping facilities, but also of services, leisure and cultural venues, thereby providing a range of retail, service and arts-based employment. As a result, policies in this Chapter cover the wide range of issues and land uses relating to town centre functions. In particular it includes policies for all centres in the borough, as well as for shopping & other activities. It generally covers the A1, A2, A3, B1a, C1, D1 & D2 Use Classes. These will also have an impact on other UDP policy areas, for instance, on employment provision, requirements for transport, provision of cultural facilities, and the quality and attractiveness of the civic environment.

The Council's Powers

8.1.2 The Planning Authority's powers to influence retailing are limited by the fact that the development and letting of shops is almost entirely undertaken by private enterprise. Powers under the Town & Country Planning Act 1990 (as amended) give the Planning Authority control over the change of use of retail shops to food & drink uses, but not between different retail uses. In fact, it is only with the proposed changes to the Use Classes Order, that it will be possible to control between food & drink uses (A3 and new A4 & A5 Classes). The Planning Authority may, in limited instances be able to control the size and type of shop units in new shopping development, through planning conditions and planning obligations with developers. It has powers to control the installation of new shop fronts and the display of certain advertisements. The Planning Authority also has compulsory purchase powers, which can be used for site assembly where resources permit.

8.1.3 Other Council units can introduce traffic calming and parking measures or enforce legislation concerning health & safety, food, trading standards, and hours of trading.

8.2 BACKGROUND

8.2.1 Traditionally, town centres have fulfilled a wider role than simply as places to shop. They were a focus for community, cultural and entertainment activities, as well as providing a base for business and financial services such as banks and building societies. Their image and appearance are important to local community life and identity and they are a priority for environmental improvement in the Council's strategy of regenerating the Borough and its neighbourhoods. Town centres are also generally accessible to the whole community, both for those with the use of a car and the significant number of households that do not have a car. The overall objectives of Brent's UDP, to enhance the environmental quality of life in Brent, to promote regenerative investment and to ensure access to facilities for all, can therefore be furthered by policies and proposals in the Plan that affect town centres and shopping.

8.2.2 Within Brent, as elsewhere, a hierarchy of shopping centres has evolved over a considerable period of time. These range from the Borough's two major town centres of Wembley and Kilburn, which cater for a range of shopping and service needs, to small local shopping centres and parades which provide a purely local service. Centres in Brent reflect the diversity of the Borough as a whole. Certain medium sized or smaller centres are relatively prosperous and, although suffering from the widespread problems of traffic congestion and poor environment for pedestrian shoppers, are generally bustling and full of vitality. Ealing Road town centre especially, has grown in status and evolved as a specialist centre for the large Asian community, serving not only the local area but also the wider area of north west London. On the other hand, certain of the larger centres in the Borough, such as Wembley, Kilburn, Harlesden and Willesden Green are less prosperous: although they continue to provide a valuable service for the local community, they are in need of an injection of new investment, especially the provision of new shopping or leisure facilities and environmental, parking and traffic improvements, if they are to continue to fulfil their role. Although Harlesden has undoubtedly benefited from the City Challenge, a programme of ongoing management and improvements are needed to prevent a deterioration of gains and attract much needed further investment into the centre.

Retailing Trends & Changes In Brent

8.2.3 Retailing is a dynamic sector, which has evolved considerably over the last two decades. In line with national trends, there has been a rapid expansion, since the 1980's, of out-of-town centre superstores within the borough, characterised by larger floorspace (20-50,000 sq. ft), more efficient stores with associated free car parking. In part, the type and location of these new retail developments, have reflected changing tastes and shopping habits as well as new retailing methods and formats, for instance 'drive-through' restaurants and mini-supermarkets at petrol-filling stations. These factors, together with changes in consumer behaviour influenced by higher levels of car ownership, increased numbers of women in the workforce, and the drift towards the surburbs, have encouraged bulk-buying and an increasing number of shopping trips by car.

8.2.4 As required by Government planning policy and guidance, the Council has carried out and updated a 'Health Check' process (town centre performance assessments), the detailed results of which are published separately. The documents set out a number of indicators, which depict the relative health of Brent's centres. These include for instance, the shopping habits & views of local residents, pedestrian flows, the level of vacancies, the range and type of shops and services present, including the number of multiples, the relative rank order of centres in London and the state of the town centre environment. The results of this process have informed the review of the Council’s planning strategy and policies set out in this chapter.

8.2.5 In 1980, there was only one large store outside the Borough's town centres catering principally for car-borne shoppers. This was Comet on the North Circular Road, which had a floorspace of 840 sq. metres. By 1990, however, there were 32 large stores outside town centres, with a total floor area of over 100,000 sq. metres (over 1 million sq. ft.), more than the total retail floorspace of Wembley, Harlesden and Willesden Green combined. These large stores consist mainly of retail warehouses, for example MFI and B&Q, selling household goods such as furniture, carpets and DIY materials, but also include 4 large superstores selling mainly food (e.g.,Tesco at Brent Park and Safeway at Honeypot Lane).

8.2.6 There are also a number of large stores just outside the Borough which have undoubtedly had an impact within Brent. Of particular importance was the opening of Brent Cross shopping centre in 1976, just over the Borough boundary in Barnet. There have also been several more recent large foodstore developments just outside the Borough such as Tesco in the former Hoover building on Western Avenue and Safeway opposite Brent Cross. The scale of this out-of-centre development has undoubtedly inhibited investment in the Borough's main town centres.

8.2.7 An analysis of the location of new retail development over the last ten years shows that by far the largest of this (approx. 73,000 m2) has occurred outside the Borough's town centres, over six times as much as development within town centres (approx.11,000 m2). The main exceptions are the developments in Ealing Road, Kenton and Harlesden mentioned above.

Shopping Habits & Perceptions of Centres

8.2.8 Results from the 1999 borough-wide Household Shopping Survey indicated that up to 34% of residents do their main food shopping by means other than the car, and confirm the inaccessibility of the out- of- centre stores for many of the borough's residents. This has led to the existence of what have been termed by policy analysts, 'Food Deserts', where good quality food provision has fled town centres and those on low incomes have to buy more expensive, poorer quality food as they cannot travel out of town to shop. Most residents did their main non-food shopping at Brent Cross (28%), Harrow (16%) and Central London (10%), with just under one-fifth using Wembley or Kilburn. The quality and variety of shops, the environmental quality of centres, availability of parking and other facilities, were understandably, significant factors in residents' shopping decisions, as did their perceptions of the safety of centres, when choosing where to spend their leisure time.

8.2.9 The present pattern of shopping provision, with a large amount of food and bulky household goods shopping undertaken outside the Borough's established centres, is now well established and is likely to persist into the foreseeable future. Trends in retail development are to a large extent dependent upon the health of the national economy. It is especially important that efforts are made to improve the attractiveness of the Borough's centres so that they can take advantage of investment opportunities when there is a general renewal of investment in retail development and continue to be the main focus for shopping and other service, cultural and entertainment activity.

Rank Order of Brent's Centres

8.2.10 The number of multiple shops has been declining in Brent's larger centres relative to most competing centres nearby and this is reflected in the position of Brent's centres in the rank order of centres across London shown below in the Hillier Parker ranking of centres within London. Since 2001, only the top 10 centres in Greater London have been ranked, and Brent’s centres no longer feature within this hierarchy.



8.2.11 This shows the changes in the relative position of centres over a period of time. Although the ordering of centres for each year was based on different indicators (primarily an assessment of retail turnover or retailer representation), it does provide a broad indication of the relative importance of individual centres when compared to other centres across London. The general picture of decline in the relative importance, and therefore the attraction to shoppers and other visitors, of Wembley in particular, is clearly shown.

Retail Development in Town Centres

8.2.12 Although there has been little investment in terms of new shopping developments within the Borough's town centres, a number of the larger town centres still retain a range of service uses, restaurants and fast food outlets normally associated with successful centres. Brent centres have generally seen a steady decline in the number of good quality shops within them. This has been particularly pronounced in Wembley where the range and quality of shops has declined steadily since the opening of Brent Cross in the mid-1970's and more markedly in recent years with the closure of such stores as C&A and British Home Stores.

8.2.13 Despite the obvious problems of many of Brent's centres, it is not a picture of decline everywhere. Ealing Road has grown in strength as a specialist, Asian-led shopping centre, as evidenced by its expansion and the level of activity which has resulted in major conflict between traffic and local residential amenity. There have also been some notable successes during the last four years in achieving some large new retail development in town centres; with the Sainsbury store in Kenton (1995), and Budgens in Harlesden, (1995) within the new Manor Park development achieved with the help of City Challenge funding. There has also been the development of Lidl (1998) and other stores within a Wembley Stadium retail park adjacent to the Wembley Park centre, stemming from the needs of non-resident office workers and those visiting the Stadium and nearby Arena, Conference Centre and Exhibition Halls. The most recent development is Asda (1999) in Chalkhill near Wembley Park.

8.2.14 However, these developments in town centres have occurred in tandem with closures of some other town centre stores, and proposals by a number of food retailers to substantially extend their existing superstores. It is notable that Wembley and Kilburn are the only major centres in north-west London that have not attracted a large shopping redevelopment scheme in recent years, though the Council is continuing its efforts to attract such investment into Wembley.

Vacancy Rates & Non-Retail Uses

8.2.15 The decline in many of Brent's town centres is reflected in the increase in the level of vacancies. In general vacancy rates increased between 1987 and 1997. Many centres in the inner part of Brent, suffered from a particularly severe loss of retail shops and experienced very high levels of vacancies. Centres where there were high vacancy rates (over 15% in1999) within the primary shopping frontage include Kensal Rise and Kenton, while Neasden, Kingsbury , Harlesden, and Colindale all have vacancy rates of over one-tenth. In 2001, Neasden, Kenton, Sudbury and Kensal Rise had vacancies of over 15% in the primary frontage, with Kingsbury and Wembley having over 10%, and by 2003, improvement is shown by only four centres; Burnt Oak, Kenton, Kensal Rise and Sudbury, having a vacancy rate of over 10% in their primary frontages.

8.2.16 The level of non-retail frontage is, as would be expected, higher in the secondary shopping frontage than the primary frontage for nearly all of Brent's town centres. Certain centres, such as Sudbury, Wembley Park, Kensal Rise, Kenton and Neasden, had over half of the primary frontage in non-retail use in 2003, an improvement on the 2001 situation which had also included Queens Park and Willesden Green. Levels of A3 uses vary across all of the town centres; Cricklewood, Kilburn, Willesden Green, Harlesden, Wembley, Kenton, Kensal Rise and Sudbury above 15% with Colindale, Neasden, Wembley Park and Queens Park at over 20% in 2003.

8.2.17 The policies and proposals set out in the following sections reflect the economic and social importance of town centres in the life of the Borough. In addition, the particular problems of Ealing Road, Queens Park and the Kilburn and Harlesden town centres require specific approaches which are included in a separate section at the end of this Chapter.

8.3 STRATEGIC CONTEXT

8.3.1 Government retail policy has undergone a change in emphasis, the first being the need to move towards more sustainable developments which reduce the reliance on the car. This was introduced in guidance on Transport (PPG13), in 1994, which stated that major trip generating developments such as large stores should be located where they facilitate multi-purpose trips and are capable of being well served by public transport, usually town centres. The second aim, in recognition of the damaging effect out of centre developments have had on town centres, was to prevent further damage by limiting the growth of out of town shopping. The principle of limiting further out of centre development has also been extended to other major trip-generating uses traditionally found in town centres, of which there has been out of centre development in recent years, especially cinemas and other leisure uses.

8.3.2 PPG13 2001 states that 'planning polices will help to reduce some of the need for car journeys-by reducing the physical separation of key land uses - and enable people to make sustainable transport choices.' It also provides guidance on the location of major generators of travel demand (such as retail and leisure developments) and, in particular, makes it clear that these should be located where there is genuine and easy access by a range of transport modes. Town centres are the preferred locations for these. Town centre hierarchies, taking account of public transport accessibility, should be defined at the strategic level.

8.3.3 PPG6 - Town Centres and Retail Developments (June 1996)
Local planning authorities are required to:
• Adopt a plan-led approach to promoting development in town centres, both through policies and the identification of locations and sites for development. UDP's should indicate a range and hierarchy of centres, where investment in new retail and other development will be promoted and existing provision enhanced.
• Apply the sequential approach to selecting sites for development, for retail, employment, entertainment, leisure and other key town centre uses which attract a lot of people. This means that first preference for new retail development should be town centre sites, followed by edge-of-centre sites, district and local centres and only then out-of-centre sites in locations that are accessible by a choice of means of transport.
• Encourage appropriately-sized local supermarkets and seek to retain post offices and pharmacies in existing district and local centres. Their inclusion in out-of-town retail developments should be discouraged. The guidance expresses clear support for local centres.
• Promote mixed-use development and retention of key town centre uses. It is recommended that diversification is the best way of dealing with declining town centres and it is pointed out that different but complementary uses, during the day and in the evening, can reinforce each other, making town centres more attractive to local residents, shoppers and visitors.
• The Secretary of State has supplemented PPG6 with a Ministerial Statement in November 1999 that for out-of-centre sites not allocated in a development plan a need for the proposal must also be demonstrated.

Draft PPS6, which is intended to replace PPG6, was published for consultation in December 2003.

8.3.4 RPG3 Strategic Guidance for London (1996)
Strategic Guidance for London draws on the guidance set out in PPG6. It states that 'town centres should continue to be the main focus for the provision of shopping facilities' and supports measures to improve the environment and enhance the attractiveness of centres to shoppers. It also accepts that the needs of shoppers without access to a car 'should be met by shops which are easily accessible'. Local planning authorities are required to:

• Apply the sequential approach contained within PPG6, i.e. of preferred locations for new retail development, allowing out of centre development only where existing centres are incapable of providing good retailing opportunities.
• Note the hierarchy identified for London town centres, in which both Wembley and Kilburn in Brent are shown as major centres. It is emphasised that the hierarchy is not rigid and that centres may increase their position whilst others may revert to a more local role.
• Have regard to the effects of development proposals in their own and neighbouring centres. The role of town centres in acting as a focus for a variety of activities, such as services, leisure and entertainment, other commercial activities and housing is made clear and it is also appropriate to identify sites for primary health care which should be accessible by public transport. A number of other uses such as hotels and education uses are considered to be appropriate within town centres.
• Identify opportunities for change of use and mixed use in town centres, consideration should be given to introduce or increase the provision of residential, business or other community services. Boroughs should also formulate policies that encourage uses that serve the community and visitors, including policies for art, culture and entertainment, leisure facilities, restaurants and hotels.
• Devise policies to encourage the conversion of vacant premises to business and other service uses. The Guidance states that in town centres that contain vacant office and retail premises that seem unlikely to be reused for such purposes, conversion to other service and business uses should be encouraged.

8.3.5 The Draft London Plan (June 2002)
The Mayor of London’s Draft London Plan (DLP) highlights the importance of the retail, leisure and cultural sectors to London’s economy and World City status. It recognises the role of town centres in accommodating these and other activities such as offices and housing and the need for regeneration initiatives to help re-establish town centres as distinctive centres of community life. It also acknowledges the complexity of London’s pattern of town centres, and sets out a typology of 5 key categories of centres across London. These comprise:

• 2 International centres - Knightsbridge and West End are major locations for globally significant specialist or comparison shops.
• 10 Metropolitan centres - Primarily suburban of which none are in Brent, with cross-Borough catchments and over 100,000 sq.m of retail floorspace including high level/variety of comparison shopping, multiples and department stores.
• 35 Major centres - Primarily in inner London, which includes Wembley and Kilburn. These are important shopping and service centres with over 50,000 sq.m of retail floorspace, some leisure facilities and Boroughwide catchments;
• 156 district centres - Provide convenience or specialist shopping. These include 11 in Brent: Harlesden, Willesden Green, Burnt Oak, Cricklewood, Neasden, Kenton, Colindale, Preston Road, Ealing Road, Kingsbury and Wembley Park;
• Over 1200 Local/Neighbourhood centres - Provide vital local shops and services. There are 36 in Brent (See Appendix SH1)

8.3.6 The DLP thereby identifies a network of strategic town centres across London, consisting of these International, Metropolitan, Major and District centres. Policies for these include an obligation for the Mayor and Boroughs to support town centres by enhancing access, strengthening their wider role, carrying out regular ‘Health Checks’ and town centre management. The Mayor also expects Boroughs to assess retail need, capacity, and provide appropriate sites where needed, firstly within a centre, or if not available, on the edge of the town centre, or else, in or on the edge of other appropriate centres within the network. Out of centre developments should be resisted in all but the most exceptional cases. Boroughs are also expected to resist the intensification, expansion and renewal of existing out of centre retail developments.

8.3.7 Government guidance in PPG12 and Draft PPS12 (Oct 2003) also has implications for shopping development, particularly the the integration of land-use and transport policy when considering the location of new developments.

8.4 POLICY OBJECTIVES

8.4.1 In the light of the above, the main aim of the Council's planning policies towards town centres in the Borough is:
To improve environmental conditions within the Borough's centres, to regenerate the centres in terms of the facilities they provide and their physical structure; and to ensure that they are fully accessible to the whole community.

8.4.2 In order to achieve these aims, shopping policies in this chapter address the following objectives:

1. To maintain the vitality and viability of established town centres and to promote their physical and economic regeneration: in particular, to maintain and promote Wembley and Kilburn as Major Town Centres within London;
2. To ensure that major new shopping or leisure development sustains and enhances the vitality and viability of existing centres which provide accessible shops and services to the whole community;
3. To create an attractive and pleasant environment within shopping centres;
4. To identify and protect the primary retail areas within town centres to ensure that shopping facilities are conveniently located together whilst ensuring that centres can diversify and offer a range of services;
5. To ensure that local shopping facilities are available to residents who do not live close to the main shopping centres and to maintain a range of shops and services within them.

8.5 BOROUGH STRATEGY

8.5.1 Brent's town centres form part of a wider network of town centres in London defined in the draft London Plan. Such a network of Centres across the borough helps to define locations where an appropriate level of provision of shopping, services and other activities for the community may be made. Brent's Major Town Centres (as designated in the draft London Plan) are the heart of this network, providing for borough residents' bulk convenience shopping needs and a wide range of comparison shopping and other services. The category of town centre the draft London Plan defines below this is that of district centres. In Brent these clearly fall into one of two types. Main District Centres complement the Major Centres, usually include a food supermarket and offer a similar range of shops and services on a smaller scale, serving as a focus for business, social, community and leisure uses for the part of the borough which they serve. Other District Centres provide for convenience shopping, an element of comparison shopping needs and some other services. Local Centres provide for day-to-day convenience shopping needs for a locality.

8.5.2 Overall the Council's strategy is that shopping facilities, services and significant leisure developments that are needed by residents, should be easily accessible, on foot, by cycle or by public transport, by being located in the borough's town centres. This strategy is to ensure less mobile and/or less affluent residents have convenient access to good quality food shopping, services and leisure, by reducing the need to travel to these facilities, particularly by car. This is in line with the Council's sustainable development objectives of reducing the adverse environmental effects associated with reliance on the car (e.g. congestion, pollution) and positively contributes towards its equally important sustainability objectives of improving health and social equity.

8.5.3 The main elements of this town centre strategy are outlined below:

• An emphasis on the consolidation and improvement of
existing town and local centres, allowing for expansion of
shopping floorspace in appropriate locations, such as Wembley;
• Steering new major trip-generating development (shopping, offices & leisure) into the Major Town Centres, particularly Wembley and Kilburn;
• Ensuring that any expansion in District Centres has no adverse impact on the vitality and viability of Major Town Centres, i.e: Wembley and Kilburn;
• Attracting a wide range of uses to town and local centres,
particularly by encouraging the development of arts, culture and leisure facilities in appropriate locations, while retaining their basic retail functions;
• Recognising and supporting the specialist roles that are developing at certain centres, e.g. Ealing Road (Asian-led), Harlesden (evening economy) and Kensal Rise (restaurants) whilst controlling the impact on residential amenity;
• Supporting existing retail markets and allowing new retail or specialist markets, where appropriate, to extend the range of local shopping opportunities and employment, enliven centres and attract shoppers.

POLICIES AND PROPOSALS

8.6 TOWN CENTRES

Network of Town Centres

8.6.1 There are a number of centres in Brent which, because of their size, status, range of shops and other facilities and the extent of their catchment areas, can be appropriately designated as town centres. It is in these centres that the Council will concentrate efforts to achieve environmental improvements and ensure good accessibility for the whole community. In particular, there is a need to ensure ease of access to shops and other facilities from public transport. They have been divided into either major town centres within London, Main District Centres (and Other District centres) according to their size and the facilities they provide. This is in accordance with the draft London Plan and Strategic planning guidance. It is also recognised however, that centres continue to evolve and that relative positions in the hierarchy can change over time. Centres within Brent will be monitored and their categorisation reviewed if appropriate.

NB.* Certain centres, because of administrative boundaries, are divided between Brent and neighbouring London Boroughs. Policies within this Plan apply only to that part of the centre in Brent, although there will be close liaison with neighbouring Boroughs to ensure compatibility of policies and proposals for the centres as a whole.

8.6.2 Of the above town centres, Kilburn and Wembley are identified as Major Town Centres within London. Council policy seeks to maintain and improve shopping and other facilities in these two centres in line with their status as Major Town Centres. These centres are considered by the Council as priorities for regeneration and initiatives will be pursued in both centres, with bids for Government and other funding where appropriate. For Kilburn major regeneration initiatives will be pursued jointly with Camden. The Wembley Regeneration Area Inset chapter includes policies and identifies potential development sites for the regeneration of the centre. In both centres the strategies for regeneration are based upon diversification of use and focus on the need to expand leisure and entertainment activities as well as encouraging the more traditional shopping role.

8.7 LOCATION OF DEVELOPMENTS

8.7.1 Given that the main aims of Council policy are to improve shopping and other facilities and ensure that they are accessible to all sections of the community, including those without access to a car, then it is important that major developments should be directed to those locations which are most accessible by public transport, i.e. town centres. In this way, shopping facilities and other services can be conveniently located together and, for example, a visit to a food shop can be combined with a visit to other shops and services, thus reducing the need to make additional journeys. This is particularly important for those without access to a car such as the elderly and those with caring responsibilities. New retail investment is also vital if Brent's run-down centres are to be regenerated and thus continue to be important foci for their local communities. Major retail developments would provide the town centres with a considerable boost, increasing their attractiveness to shoppers and bringing infrastructure improvements in the form of better servicing, car parking and road improvements. These considerations also apply to other key town centre uses which generate high numbers of visitors such as leisure and entertainment facilities.

8.7.2 In order to promote major development in town centres, the sequential approach set out in Government policy will be applied when considering the location of new retail and other major
development such as cinemas. This means that first preference will be for development on sites in Wembley and Kilburn, then on the edge of these centres. If no suitable sites are available in these locations then development will be permitted in, then on the edge of Main District Centres and then Other District Centres, where proposals should be of a scale and function appropriate to that town centre. Only if there are no sites available in any centres, including where applicable those in neighbouring Boroughs, will development be permitted in out-of-centre locations with moderate, good or very good public transport accessibility.

8.7.3 In these circumstances developers will have to demonstrate a need for the development (in terms of a deficiency that cannot currently be met in a town centre, including proposals for their regeneration); and that there will be no significant impact on the vitality and viability of town centres, either in or outside the Borough. The requirement to demonstrate need should not be regarded as fulfilled simply by showing that there is capacity (in physical terms) or demand (in terms of available expenditure within the proposal’s catchment area) for the proposed development. The existence of capacity or demand may form part of the demonstration of need, but the significance of the factors which may show need will be determined according to the particular circumstances of each case.

8.7.4 Developers putting forward large development proposals (possibly incorporating a number of elements) need to be flexible about the format, design and scale of development. Rather than proposing large-scale development that can only be accommodated in an out-of-centre location, developers should demonstrate why they could not develop elements of larger schemes in town centre locations, tailoring, reducing or splitting projects so that they can be accommodated in preferred areas or on existing sites including converting, upgrading or extending existing town centre buildings. In particular, car parking should be reduced to below the maximum standards to fit schemes on more central sites and pharmacies and post offices should not be included in large out-of-centre stores.

8.7.5 For shopping purposes, an edge-of-centre location is normally taken to be within 200-300 metres of the primary shopping area. However, the existence and nature of pedestrian links between a store and the town centre, and the layout of the store can be equally important factors to consider, as well as the role it plays in relation to the centre. Without sensitive integration into the primary shopping area (quality walking links, removal of barriers, etc.), such 'edge-of-centre' stores simply 'turn their back' on the town centre and exert the same effects in undermining it as out-of-centre stores, whilst adding to traffic congestion at the centre. On the other hand, at Wembley, where the new Stadium and other facilities will be a major attractor of trips, good, attractive pedestrian links, with active frontages along those links, will mean that the acceptable distance of new development from the Primary area could be extended beyond 300 metres. This will depend upon whether such links exist or are planned at the time that development is proposed.

8.7.6 Given that the objective of the following policies is to sustain and enhance town centres by directing new development to them, and by limiting it in out-of-centre locations, then the policy must also apply to proposals for extensions to existing stores/facilities, proposed extensions to the range of goods sold, or range of activities, where this is restricted by conditions, and to relevant proposed changes of use.

8.7.7 The Plan identifies a number of sites within or on the edge of Wembley and Harlesden town centres which are suitable for large-scale development (see the inset plan for Wembley and Site Specific Proposals section). However, there may be other opportunities within the Borough's town centres either through redevelopment or by assembling sites of sufficient size which are currently in a multiplicity of ownerships. The Council will consider assembling sites through compulsory purchase as appropriate.

Retail Warehouses

8.7.8 In the last twenty-five years there has been considerable development in the Borough of retail warehouses which sell durable goods on former industrial sites outside the main shopping centres. If the Borough's town centres are to be regenerated by attracting private investment to undertake major shopping development or redevelopment schemes, then it is essential that there should be limits on the amount of development that is allowed to locate outside the main town centres.

8.7.9 The principal considerations in determining whether or not new shopping development should be permitted outside town centres is the likely effects on the vitality and viability of the centres, the application of the sequential approach and whether there is a need for the store. The plan's policies seek to minimise the effects of out of town development by limiting this to certain types of store which, because of their particular requirements, may be able to justify an out of centre location in accordance with the sequential approach to development set out above. Certain types of shop selling durable goods (usually called retail warehouses) may exceptionally be allowed to locate outside town centres. As the lines they trade in are not required on a daily basis, there is likely to be less impact of the vitality and viability of town centres. Also the nature of the goods sold, e.g. DIY Stores, Garden Centres, Furniture Stores, makes available and suitable sites in or adjoining town centres difficult to find. In addition, such proposals might not be compatible with the scale or function of a town centre. This does not mean that retail warehousing should be exempt from the sequential approach. In considering proposals for such stores account will be taken of the nature of goods sold and whether the format of a particular store is such that the benefits will be lost if the scale is reduced so as to be accommodated on town centre sites. It is acknowledged, however, that increasing use of home delivery is lessening the requirement for stores with large on-site warehousing and large parking areas for loading. Many showroom type facilities can equally be located in or adjoining town centres. Retail warehouses are also required to locate where there is reasonably good public transport access (moderate or better as defined in the Plan) so that they are accessible to the whole community.

8.7.10 The amount of pressure for and the scale of retail development on industrial land in the Borough has meant that the Council has had to restrict such development to certain Local Employment Sites where access by both public and private transport is reasonably good. The relevant policies for development on Local Employment Sites are contained in Chapter 7, Policy EMP9.

8.7.11 Traffic generation and environmental impact, as well as the effects on the vitality and viability of town centres, are likely to vary significantly between different types of store. Therefore, it will be necessary in granting permission for retail warehouses outside town centres to restrict the nature of the goods sold, in particular to prevent sales of goods that can best be provided in town centres.

Warehouse Clubs

8.7.12 Warehouse clubs are businesses that specialise in the bulk sale of a wide range of goods from large buildings with large car parks. They generally share characteristics of both retail and 'cash and carry' wholesale operations and operators may limit access to businesses, organisations or classes of individual and may agree to limit the number of lines sold. They often share many of the characteristics of very large retail outlets, in which case they should be treated as if they were retail businesses.

8.7.13 In considering proposals for warehouse clubs, similar criteria will be applied as for purely retail uses, including a requirement that there are no sequentially preferable sites and that it should not have an unacceptable impact on the vitality and viability of town centres. Where warehouse clubs are proposed on employment land such proposals will also be considered against the policies in the Employment Chapter which seek to safeguard employment land. In addition, to ensure that the retail element is not expanded or intensified in the future, it will be necessary to secure the non-retail element of the use by means of a section 106 agreement.

'Drive Through' Restaurants

8.7.14 'Drive-through' developments are becoming more common, particularly for food and drink uses. Being designed primarily around the private car, rather than for more sustainable modes, they can encourage car use. Except where they serve the needs of travellers along the North Circular Road, such facilities are better located in or adjoining existing centres, thus promoting their vitality and viability. (In this context 'drive-through' means where the design and/or location of the facility tends to be specifically focused around the needs of car-borne customers).

Development at Petrol Filling Stations

8.7.15 Shops in petrol filling stations are an A1 shop use. Often they are part of a composite use with car sales (sui-generis) and/or car repairs (B2). In the latter case proposals for the re-development of such facilities are covered by policies relating to business, industry and warehousing uses (Chapter 7). In recent years traditionally located filling stations have come under immense pressure from stations within supermarket developments. As a consequence many proposals have come forward to add additional retail, and/or 'drive-through' food and drink facilities to existing stations with a consequential further impact on town centres. Proposals for the development of retail or restaurant/ take-away uses at petrol filling stations will be determined in accordance with the sequential approach set out in policies SH3, SH4 & SH5 unless the development is small-scale or ancillary to the filling station. Any development should have an acceptable traffic impact and should not have an adverse effect on the amenity of adjoining residential areas

Combined Economic and Transport Assessments

8.7.16 All applications for major development of over 1000 sq m gross to which the sequential approach applies should be accompanied by a combined economic and transport evaluation. These should be in accordance with the methodology set out in the DETR report "The Impact of Large Food Stores…" 1998. These will form the basis for considering the economic and transport impact of development.

continue to next part of Chapter 8

Foreword

Introduction

Strategy

Built Environment

Environmental Protection

Housing

Transport

Employment

Town Centres & Shopping

Tourism, Entertainment & the Arts

Open Space & Recreation

Community Facilities

Waste

INSET PLANS

Park Royal

Wembley Regeneration Area

Site Specific Proposals

Glossary

Borough-wide maps