Proposed Mixed Business and Retail Development ... - Gladman

Proposed Mixed Business and Retail 

Development, Barbush, Dunblane 

Commentary on the Application of the 

Sequential Approach 

December 2010 

reference: Document3 

Contact: Keith Hargest 

Tel: 0131 443 8813 

Email: keith.hargest@btconnect.com

Barbush, Dunblane 

Note on Application of the Sequential Approach 

1 Introduction 

1.1 This note provides further comments on the interpretation and application of the sequential approach to 

the identification of potential sites for a new foodstore in Dunblane. In particular it considers the 

categorisation of proposed alternative foodstore sites at Dunblane Golf Course and Kippenross (Vico- 

Tesco) as well as the proposal by Gladman Developments Ltd at Barbush, Dunblane. 

1.2 This note has been prepared specifically as a response to comments made by planning officers at 

Stirling Council sent by e-mail to Dunblane Community Council dated 2 nd December. In this e-mail it is 

stated that “We consider the other Vico and Ristol sites to be in 'edge of centre' locations despite being 

located within the Green Belt and Countryside. The Structure Plan defines an edge of centre as follows: 

'A location within easy walking distance of the town centre, and usually adjacent to the town centre and 

providing parking facilities that serve the centre as well as the store, enabling one trip to serve several 

purposes'. This definition is merely a description of a location and what benefits it can offer being next to 

the town centre. There is nothing in the Development Plan or in Scottish Planning Policy that precludes 

a location being considered edge of centre if it is also countryside and/or Green Belt.” 

1.3 It is considered that certain aspects of this statement are correct, however, the key aspect of the 

application of the sequential approach in these cases is whether or not the alternative sites can be 

accurately described as “edge of centre”. This matter is addressed in some detail in the Retail Impact 

Assessment submitted on behalf of Gladman and full reasons as to why neither of the alternative sites 

can be categorised as edge-of-centre is given in the RIA. In contrast the e-mail from Stirling Council is 

simple an assertion with no justification provided. 

1.4 In order to explain fully the basis for categorising potential retail (or other town centre uses) sites under 

the sequential approach regard should be given to each of the following: 

• The Development Plan: 

o 

Clackmannanshire and Stirling Structure Plan. 

o 

Stirling Council Local Plan (including Alterations). 

• Scottish Planning Policy – including earlier statements of SPP prevalent at the time the 

development plan was approved/ adopted. 

• Stirling LDP Main Issues Report . 

• Relevant Legal Cases. 

December 2010 2



2 The Policy Framework 

The Development Plan 

Stirling Structure Plan 

2.1 The parts of the Structure Plan relevant to the sequential approach were approved by Scottish Ministers 

in 2002. Policies S4 and S5 require the application of the sequential approach for retail development 

proposals. The glossary of the Structure Plan defines this as follows: 

SEQUENTIAL APPROACH - This approach is adopted when selecting sites for new retail, commercial leisure 

developments, other key town centre uses or housing. First preference should be for town centre sites, 

where sites or buildings suitable for conversion are available, followed by edge of centre sites, and only 

then by out of centre sites in locations that are, or can be made, easily accessible by a choice of means 

of transport. 

2.2 Categories of sites are identified as follows: 

TOWN CENTRE - The term town centre is used to cover town and district centres which provide a broad 

range of facilities and services and which fulfil a function as a focus for both the community and public 

transport. It excludes retail parks, neighbourhood centres and small parades of shops of purely local 

significance 

EDGE OF CENTRE - A location within easy walking distance of the town centre, and usually adjacent to the 

town centre and providing parking facilities that serve the centre as well as the store, enabling one trip to 

serve several purposes. 

OUT OF CENTRE - A location which is separate from a town centre but within the urban area, including 

programmed extensions in approved and adopted development plans. 

2.3 As will be noted below these definitions are identical to those provided in National Planning Policy 8 

Town Centres and Retailing which was prevailing at the time the Structure Plan was approved. 

Stirling Local Plan 

2.4 The relevant part of the Stirling Local Plan is Alteration 1A which was adopted in 2007. Policy ED12 in 

this Alteration sets out criteria to be met by all new retail development – in relation to the sequential 

approach it refers back to Structure Plan policies. 

2.5 The Alteration does, however, provide a glossary of definitions. Although there are some changes in the 

wording (e.g. the reference to “broad range of retail and retail service facilities” in the definition of town 

centres) none of these modifications are significant in terms of the general application of the sequential 

approach. However the redefinition of town centres emphasises that the key issue, in terms of the 

sequential approach, is the relationship between development proposals and sites and the retail/retail 

service functioning of the town centre. It follows from this that it is more important to consider the 

physical and functional relationship between a proposed development site with retail/retail service 

December 2010 3



activities in a town centre than the location of the town centre boundary as drawn on the Local Plan 

map. 

2.6 From these definitions and the wording of the Structure Plan policy it is evident that there is no dispute 

between the applicants, their consultants and Stirling Council planning officers that, in the light of the 

above definitions: 

• None of the proposed retail sites in Dunblane can be categorised as a town centre site since all 

three sites are clearly located outwith Dunblane town centre. 

• That the Barbush site is an out-of-centre location in that it lies within the urban area of Dunblane. 

2.7 However there is dispute as to whether or not certain sites can be accurately described as “edge-ofcentre”. 

The development plan definitions have, in essence two requirements to be met for a site to be 

defined as edge-of-centre i.e. (i) that the location is within easy walking distance of a town centre and (ii) 

providing parking facilities that serve the centre as well as the development. The second requirement 

will be both dependent upon meeting the first (i.e. the car park, in order to serve the centre, must also be 

with easy walking distance of the centre) and must be made available to users of the town centre (i.e. in 

normal practice this means that parking should be free for a period of time to allow users to undertake 

normal activities etc in the town centre). This latter requirement will normally be a matter of operational 

practice by the owners/operators of the retail development and can be subject to conditions/legal 

agreement attached to a planning consent. 

2.8 In essence therefore, the key issue to be addressed in categorising a site as “edge-of-centre” is whether 

or not it is considered to be within easy walking distance of the town centre – noting in the Local Plan 

that it is the retail/retail service functions of the town centre that is crucial to the definition of the town 

centre. As noted the definitions of edge-of-centre and out-of-centre are derived directly from the 

prevailing Scottish/National Planning Policy that was in place at the time the plans were prepared and 

adopted/approved (and, indeed, remain in place at the current time). It is, therefore, highly relevant that 

the issue of how one assesses whether or not a site is within “easy” walking distance was specifically 

addressed in SPP8 published in August 2006 (i.e. it was prevailing at the time that Alteration 1A was 

adopted). In order to fully understand the application of the sequential approach as set out in the 

development plan one must have regard to relevant Scottish Planning Ppolicy. 

National/Scottish Planning Policy 

2.9 At the time of the approval of the Structure Plan in 2002 NPPG8 provided national planning policy for 

retail development. This set out the sequential approach and the definitions of town centre, edge-ofcentre 

and out-of-centre. The definitions used in the Structure Plan quoted above are the same as 

those used in NPPG8. 

2.10 Through a number of appeals during the late 1990s and early 2000s it became apparent that a frequent 

dispute was whether or not proposed retail sites could, or could not be described as edge-of-centre. In 

response to this when SPP8 was published in 2006 this included an explanation of whether or not sites 

can be regarded as edge-of-centre (para 18): 

December 2010 4



2.21 It inevitably follows from the above that, in accord with both the development plan and Scottish Planning 

Policy, if the Golf Club and Kippenross sites are not edge-of-centre then they cannot be considered as 

potential retail sites under the sequential approach – they would then not be either town centre, edge-ofcentre, 

other commercial centre or out-of-centre sites. The sequential approach does not contemplate 

such a site as a potential location for retail development regardless of the availability of alternatives. 

Policy Framework: Conclusions 

2.22 From the above the following points can be concluded in relation to the application of the sequential 

approach: 

• The Barbush site is out-of-centre. 

• There are no suitable or available town centre sites. 

• The development plan policy in relation to the sequential approach reflects Scottish Planning Policy 

(except that it does not include “other commercial centres” and the definition of town centres is 

amended slightly in the adopted Local Plan Alteration 1A). 

• Guidance on how to interpret edge-of-centre locations is provided in SPP8 – the current SPP is 

consistent (although less detailed) with this Policy. 

• A range of questions/tests can be considered to identify whether or not a site is edge-of-centre. 

• From the Local Plan a key consideration is the relationship between the proposed development site 

and retail/retail service activities in the town centre rather than the boundary of the centre as shown 

on the Local Plan map. 

• It would be unusual to identify an edge-of-centre site which is not physically adjacent to the defined 

town centre (and adjacent to retail/retail services facilities in accord with the adopted Local Plan 

Alteration 1A). 

• If either of alternative sites do not satisfy the definition of edge-of-centre then their location is such 

that neither are in locations that would be considered as potentially suitable for a town centre use or 

retail development regardless of the availability/suitability of alternatives. 

December 2010 7



3 Consideration of Alternative Sites as Edge-of- 

Centre 

3.1 The key issue when considering the sequential approach for Dunblane is whether or not either the 

Kippenross or Golf Club sites can be accurately described as edge-of-centre reflecting the above policy 

framework. 

It is also necessary, as part of the sequential approach, to consider whether the sites can 

genuinely be regarded as reasonably available – the fact that a planning application has been lodged for 

a site does not indicate that the site is available. 

3.2 It should also be recognised that the sequential approach is only one of a number of important planning 

policy considerations which need to be considered in addition to the sequential approach. Indeed it can 

be quite reasonable for the planning authority to conclude that a site which is not sequentially preferable 

should be the preferred location for development of a foodstore as a result of a combination of planning 

benefits associated with the proposal and/or planning disbenefits associated with potentially sequentially 

preferable alternative sites. 

Dunblane Golf Course 

3.3 This site is not located within the urban area of Dunblane but forms part of the Green Belt in the adopted 

Local Plan. It is not located in any area proposed for the extension of the urban area in the development 

plan. Although the boundary of the application site is located on the east side of the Perth Road the 

retail area of the site is located some distance from the boundary of the town centre and significantly 

further from the principal retail area of the town centre. Although parts of the site are less than 300m 

from the retail area of the town centre its linkages to the town centre are poor: 

• Access to the site from the town centre requires access along a significant gradient – the western 

part of the proposed site is approximately 17m (55 ft) higher than the nearest part of the High 

Street. 

• There is no visual linkage between the site and the principal retail frontages in the town centre. 

• There are non-commercial uses (residential properties) between the site and the town centre. 

3.4 Regard should also be had to the character of the site once developed. The site comprises a golf 

course and this use will remain to the west of the site. To the south is Kippenross which comprises 

parkland/plantations whereas to the north is an area of low density housing. It is clear that the character 

and setting of the site following development will be completely different from the town centre – this site 

will not operate as an extension of the town centre, rather it will be quite separate. 

3.5 It follows from this that the site cannot be regarded as either an edge-of-centre site. Given its location 

outwith the urban area of the town (and it is not included within any planned extension identified in the 

development plan) it is not, therefore, an out-of-centre site. 

3.6 In the RIA it was noted that there are other important deficiencies associated with the site in planning 

terms: 

December 2010 8



• The site cannot be regarded as available within a reasonable timescale. As noted in the RIA the 

occupiers of the site object to the proposal. The Golf Club indicate that their lease runs until 2044 

and that the owners need to give at least 4 years notice to the Club if redevelopment is proposed. 

There is also an obligation on the owners to provide replacement facilities of at least the same 

quality. The Club indicates that it will take at least 10 years before the site can become available for 

development. 

• The proposal will adversely affect an important sporting facility within the community and that, even 

if all the required measures were implemented by the developers it would, according to the Club 

“threaten the Club’s future existence and will, without doubt, reduce the quality of the golfing 

facility”. 

• The site is, as noted, located in the Green Belt. The development of this area will result in the loss 

of part of the important landscape setting of the town. 

• In the LDP site assessment process the Council’s own assessment of the site considers that the 

site is detached from the town centre and is “unlikely to feel integrated” and [the site is] 

“problematic with regards to maintaining landscape character or making new, high quality 

landscapes that would contribute positively to the setting of the quality of Dunblane”. It is considered 

that this is a reasonable assessment of the site. 

• The development would result in significant adverse landscape impacts and loss of amenity. The 

site is clearly environmentally sensitive and an important asset for the landscape setting of the town. 

3.7 The conclusions from the above analysis are that, in terms of the sequential approach: 

• Although located comparatively close to the boundary of town centre there are a number of factors 

that mean that the site will not be able to integrate with the existing retail/retail service area of the 

town centre. In particular the site is not well related to existing retail and retail service uses in the 

town centre. The site cannot be accurately described as edge of centre. 

• The site is outwith the existing and planned urban area (in the approved/adopted development plan) 

and is, therefore not an out-of-centre site. 

• It inevitably follows from the above that the site fails to satisfy the sequential approach. 

In addition there are a number of other important planning considerations that indicate that the site 

should not be developed for the proposed retail development. The site is not available within a 

reasonable timeframe, its development would adversely affect an important community and sporting 

resource, and it would adversely affect the landscaping setting of the town. 

Vico-Tesco Site: Kippenross 

3.8 A comparable analysis can be undertaken for the Kippenross site: 

December 2010 9



• Linkages to the town centre suffer similar problems to those identified for the Golf Club. The 

western part of the site is approximately 200 m from the beginning of shops in the High Street but if 

the store is located to the eastern part of the site then the distance will be more than double this. 

Pedestrian access would require the crossing of Perth Road which is a dual carriageway in this 

location and there are non-commercial/town centre uses between the site and the town centre. 

There is also no visual linkage between the principal shopping area of the town centre and the site 

and, as noted, there is a significant incline between the town centre and the site (the location of the 

store would be about 10m higher than the nearest point of the High Street and significantly higher 

than the beginning of the retail/retail service uses in the town centre). 

• Regard should also be had to the character of the site once developed. The site comprises a 

plantation/parkland and this use will remain to the west and south of the site. To the north is the 

golf club. It is clear that the character and setting of the site following development will be 

completely different from the town centre – this site will not operate as an extension of the town 

centre, rather it will be quite separate. 

3.9 For the above reasons the site cannot be regarded as edge-of-centre. 

3.10 As with the Golf Club site the Kippenross site is located outwith the urban area of the town and is not 

included within any planned extension of the urban area in the development plan. It is not, therefore, an 

out-of-centre site. 

3.11 The site also has a number of additional difficulties and has adverse impacts on other planning 

concerns: 

• There is uncertainty as to whether the site can be regarded as available. Development of the site 

requires the felling of the existing woodland and, although an application has been lodged for the 

appropriate felling license it is understood that this is not to be determined until the outcome of the 

LDP process is completed. If this is the case the site cannot be regarded as potentially available 

until the license is granted. 

• Its development will adversely affect the landscape setting of the town. 

• The Kippenross Estate which is identified in the Inventory of Gardens and Designed Landscapes in 

Scotland. Its development will therefore conflict with policies aimed at protecting these nationally 

important landscapes and gardens. On inspection of the Inventory the development in this location 

will affect the landscape setting of the estate when viewed northwards from Kippenross House. In 

addition it will adversely affect the Darn Road which is identified in the Inventory as a “Sunk Road” 

which was the old drove road between Dunblane and Bridge of Allan. The road takes the form of a 

narrow lane, sunk in paces to 2m in depth with dry stone walls on either side. 

• The impact on the historic landscape and heritage features has been noted by Historic Scotland 

who have confirmed in their letter of 4 th August 2010 to Stirling Council in which they state that, in 

relation to the proposed development of a Tesco store in this location that “it remains our preference 

December 2010 10



that a potential land allocation within the boundary of the designed landscape is not included within 

the proposed plan”. 

3.12 In summary the Vico/Kippenross site: 

• Does not satisfy the sequential approach – it is neither edge-of-centre nor out-of-centre. 

• There is uncertainty as to whether the site can be regarded as reasonably available. 

• The site is in the Green Belt. 

• Its development will adversely affect the landscape setting of Dunblane. 

• Its development will adversely affect the Kippenross Estate policies which are a designated historic 

landscape and garden. 

December 2010 11



4 Conclusions 

This note sets out clearly the basis for applying the sequential approach as set out in the development 

plan and Scottish Planning Policy. It applies the approach consistently to the proposed sites for a 

foodstore development in Dunblane and the conclusions from this are clear that neither of the 

Kippenross (Vico/Tesco) nor Golf Club sites can be accurately described as edge-of-centre sites. In 

addition both sites are outwith the urban area and neither are included within planned extensions of the 

urban area contained in the development plan. Therefore neither site is an out-of-centre site. 

Therefore neither site satisfies the sequential approach as set out in the development plan or in Scottish 

Planning Policy. Both sites are also unacceptable for other planning reasons – they are both in the 

Green Belt, their development will adversely affect the landscape setting of the town, the Golf Club site 

will adversely affect an important community/sports facility and the Kippenross site will adversely affect 

an important heritage site. 

The Barbush site is agreed to be an out-of-centre site. In the absence of suitable or available edge-ofcentre 

or town centre sites this site satisfies the sequential approach. 

In the RIA the Abattoir site is also identified although this is not the subject of a planning application. 

This site is identified only as possibly being available in a time period of 5-10 years and cannot therefore 

be regarded as available within a reasonable time frame. In addition the Abattoir site is too small to 

accommodate a foodstore for main food shopping requirements and access arrangements are substandard. 

This site is, therefore, unsuitable for the proposed development. 

Drawing all the above the benefits of the Barbush site are clear: 

• It is the only site that satisfies the sequential approach. 

• The principal two competing sites are in locations that are not contemplated as potential retail 

locations in the sequential approach. Furthermore both will result is substantial adverse impacts on 

important planning concerns. 

• The development of the Barbush site offers significant potential planning benefits associated with 

the development of business space. 

Keith Hargest 

Hargest Planning Ltd 

21.12.2010 

December 2010 12

Proposed Mixed Business and Retail Development ... - Gladman

Create successful ePaper yourself

Delete template?

Save as template?