Vision
The Best City Ambition is our overall vision for the future of Leeds focussed on improving outcomes across the 3 Pillars of health and wellbeing, inclusive growth and zero carbon. The Council is committed to 'Inclusive Growth' and 'Sustainable Infrastructure; and the role our centres play is important for both these ambitions. Our communities rely on our centres both economically but also in providing a focus for infrastructure and activity. Leeds City Centre is also a hub for the ambition to improve our cultural offer not only locally but regionally providing a focus for economic and social activity.
The National Planning Policy Framework (NPPF) is supportive (para 86) of town centres and retail stating that Planning policies and decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management, and adaptation. However National Planning Policy also recognises that the role and uses within our town centres have changed nationally.
Current issues
The landscape of retail and our centres has changed significantly over the last decade. The move to online shopping, accelerated by the pandemic, has reflected a gradual shift in our shopping patterns and the way we use our centres. The Core Strategy defines a network of 61 centres across Leeds which includes the City centre, Town Centres and Higher and Lower Order Local Centres. They all play an important role as part of the City, and to the local communities which they serve. There are a number of existing planning policies in the Core Strategy which address the vitality of our centres, including specific policies on the role of Leeds City Centre, the types of uses acceptable in and on the edge of town and local centres, shopping parades and small scale stand-alone food stores, the approach to new food stores, the creation of new centres and the sequential and impact assessments required for proposals for main town centre uses.
The introduction of the Class E (Commercial, business and service) came into effect from the 1 September 2020. The new Use Class E allows flexibility to move from some 'main town centre uses', e.g. retail, food and drink, offices, but also includes other uses which are not defined as "main town centre uses", e.g. medical services and some industrial uses without the need for planning permission. Policies RTC2 and 3 of the Site Allocations Plan set out policy for primary and secondary shopping frontages and these refer to percentage requirements for the minimum amount of A1 (retail) uses within a frontage. These policies are now out of date as the A1 use class no longer exists. The NPPF has also deleted reference to primary and secondary shopping frontages altogether. This means there is no longer a requirement for these frontages in national planning policy. However, there are clearly benefits to retain these frontages as they provide a strong focus for town centres.
The potential implications of this are that the Council's planning policies predate use class E and as such are potentially out of date, including shopping frontage policy and sequential test policy.
The 'Hot Food Takeaway SPD' adopted (2019) sets out guidance restricting takeaways around secondary schools, limits clustering of takeaways and protects general amenity of surrounding areas. Since it was adopted there have been changes to national guidance which allow planning policy to have regard to evidence indicating high levels of obesity and more control with litter associated with takeaways. There may be scope to widen the remit of the SPD or address new national policy.
The City Centre boundary was defined through the UDP in 2001. The City has changed significantly since this time and consideration should be given to updating it to reflect current and future development needs. As part of this there will a need to consider what the purpose of the boundary is in planning terms and how this could be best reflected over the next plan period.
Within this overall context it is also a requirement of national policy that Local Plans should set out a strategy for the pattern and scale of retail and leisure provision.
What might new policy do to address this?
LLP 2040 will need to consider the implications that changes to national planning policy, as well as the pandemic and ongoing changes to shopping habits, has for how the role of centres is supported through the planning system. As part of this, the limits to what local planning authorities can control will need to be recognised, as many changes can occur within centres without the need for planning permission.
There are a number of areas which may be addressed as part of policy formulation. These include whether new and/or amended policy required to take account of Class E and the impacts of the pandemic for centres across Leeds. This will need to consider the potential for policy giving clarity over the implementation of Use Class E and what it means in terms of acceptable uses in and on the edge of centres, and the implications for Primary and Secondary Shopping frontages. Options may include leaving policy as it is and producing an internal guidance note to assist interpretation, or amending policy so it sets out guidance on how to interpret use class E. However, there is a risk that by amending frontage policy this will undermine the principle of frontage policy and this may leave centres more vulnerable. The LLP 2040 could also consider updating design policies for shopfronts, advertisements and signage, to reflect modern business requirements and support the attractiveness of centres.
At present the need for many commercial and service uses within Class E are met through changes of use (both permitted and through planning applications), the redevelopment of former employment sites and mixed-use developments. The approach to Class E uses could be specifically considered through LLP 2040, to determine whether this is sufficient going forward, or whether a more proactive approach can be taken in planning for these uses to include permitted development rights to include those to residential. Consideration may also need to be made of the role of out of town centres, or the establishment of any new centres, over the next plan period to 2040.
Leeds City Centre boundary was drawn up over 20 years ago, and the city has changed significantly since this time. Consideration should be given to updating it to reflect current and future development needs. A review of the boundary could reflect up to date priorities and evidence, and as part of this there will be a need to consider what the purpose of the boundary is in planning terms, and how it could be best reflected over next plan period. In terms of boundaries there could be a number of geographical options.
As noted above, National planning policy has been updated on hot food takeaways and LLP 2040 could include specific policy on this, building on current guidance which is provided in an SPD (or the SPD could be updated).
In addition, it is recognised that a sizeable proportion of the allocations in the City Centre are designated for mixed use development, reflecting that a range of different uses would be acceptable on these sites. At the development management stage these sites tend to come forward as all residential or all office proposals, with some commercial uses. Consideration is needed of how we account for this when making future allocations.
Within this overall context a review of policy also represents an opportunity to consider overall requirements for the scale of new retail particularly within a national context of reduced footfall, and where online shopping, as a proportion of total retail sales, has jumped from 13.% to 30.2% since the Core Strategy was adopted in 2014.
What do we need to get there?
- E Class- Depending on the nature of proposals these will need to be assessed to determine what evidence base is required however there are new town centre assessments which can assist, these explore a number of indicators.
- Leeds City Centre- a review of the boundary and uses would need to be undertaken to establish evidence base.
- 'Hot Food Takeaway SPD' current research is being undertaken to assess the impact of the SPD and the potential to go further.
- Evidence base around the City Centre to deliver housing, office and other main town centre uses for mixed use sites.
Have your say
The consultation runs for 6 weeks from Friday 10 February until Friday 24 March 2023.
Complete the online survey
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