Strategic Review of Retail Planning Policy

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Strategic Review of Retail Planning Policy




Prepared on behalf of
City and County of Swansea
August 2013


DTZ, a UGL company
One Curzon Street
London
W1J 5HD
www.dtz.com



Contents

1   Introduction                                                              2
2   Out-of-Centre Retailing                                                   3
3   Qualitative Assessment of Retail Hierarchy                                21
4   Foodstore Development                                                     39
5   Conclusions and Recommendations                                           45


Appendices

1   Swansea Enterprise Park: Key Planning History                             52
2   Parc Tawe: Key Planning History                                           57
3   Fforestfach Retail Park: Key Planning History                             59
4   Parc Cwmdu: Key Planning History                                          62
5   Morfa Retail Park: Key Planning History                                   64
6   Pontardulais Road Retail Park: Key Planning History                       68
7   Map of Existing Foodstore Operators                                       71
8   Existing Foodstore 15 Minute Catchment Drive Time Maps                    72




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1     Introduction

1.1   DTZ has been appointed by The City and County of Swansea Council (the Council) to provide a review
      of their current retail planning policy and strategy and to provide recommendations for retail
      planning for the administrative area going forward. This includes an assessment of the retail
      hierarchy, the impact of out of centre retailing and the importance of prioritising suitable locations
      for future retail investment.

1.2   This report follows work previously undertaken by DTZ for the Council, including a Property Analysis
      and Development Strategy that underpins the adopted Swansea City Centre Strategic Framework
      (SCCSF) Supplementary Planning Guidance (2007). Since publication of the SCCSF, DTZ has been an
      advisor to the Council on the changes to the retail and property markets, which have both been
      subject to significant fluctuation in recent years. In the retail context, this advice has been clear that
      the impact of out-of-town retailing will collectively continue to erode the in-town offer and that it is
      only where the quality and quantity of the latter, and associated issues (other uses, accessibility,
      parking, environment and the like) are strong, will this not be the case.

1.3   This report has been prepared by DTZ who were commissioned by the Council as part of a consultant
      team to review its retail strategy, which also includes retail specialists FSP and consumer insight
      specialists Emotional Logic. The analysis provides a detailed evidence base to underpin the Swansea
      City Centre regeneration agenda and future policy development. In this respect, one of the main
      priorities for the City and County of Swansea is to focus investment in retail and leisure development
      in the most sequentially preferable locations. This is in order to significantly improve the vitality and
      viability of the City Centre, and to support the complementary regeneration of district centres. The
      Council recognise the importance of strengthening their planning policy position to facilitate major
      City Centre development, and deterring further out-of-centre retail development and the erosion of
      the City Centre and district centre retailing.

1.4   This report reviews the impact of out-of-centre retailing in the City and County of Swansea, the role
      and purpose of the identified retail centres and the strategy for managing foodstore planning
      applications. In the context of the Council’s adopted planning policy framework and previous
      decisions on retail planning applications, the purpose of this analysis is to identify the key issues in
      the retail locations across the administrative area and the impact of out-of-centre retailing upon the
      Council’s priority to regenerate and strengthen the City Centre as its retail core.




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2     Out-of-Centre Retailing

      Introduction

2.1   This Chapter considers the impact of retailing at locations outside of the City Centre and the
      designated district centres within the City and County of Swansea.

2.2   The Chapter comprises a review of the existing planning policy framework for retailing within the
      administrative area of Swansea, a review of the available planning history information for out-of-
      centre retail parks and consideration of the lawful use of retail premises at Swansea Enterprise Park.

2.3   Conclusions are drawn upon the extent to which out-of-centre retailing is controlled in the current
      planning policy context to ensure the prevention of harm to retailing in the City Centre and district
      centre locations.

2.4   The extent to which historic planning permissions restrict and set precedents for retail development
      at out-of-centre retail parks is also identified. This is in order to understand the context for
      development control decisions for such applications in these locations. Conclusions are drawn upon
      the extent to which previous planning permissions impact upon the amount and type of out-of-
      centre retail park development in the City and County of Swansea.


      Planning Policy Context

2.5   Planning policy for retail development in the City and County of Swansea comprises policy at the
      national and local level.

2.6   Planning Policy Wales (“PPW”) (Edition 5, 2012) contains national planning policies which set the
      framework for land use planning across Wales. It is supplemented by Technical Advice Notes (TANs)
      including TAN 4: Retailing and Town Centres (1996) which sets out the detailed national planning
      policy for retail development in Wales.

2.7   Strategic planning policies and proposals for the unitary authority area are contained in the adopted
      City and County of Swansea Unitary Development Plan (UDP) (2008).




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2.8   Relevant adopted Supplementary Planning Guidance (SPG) is contained within pre-UDP SPGs,
      published prior to the adoption of the UDP, and post-UDP SPGs, published after the adoption of the
      UDP. The UDP takes precedence over the former, which include the Swansea Enterprise Park
      Planning Policies SPG (1996). The latter include the District Centres, Local Centres and Community
      Facilities SPG (2010) and the Swansea City Centre Strategic Framework SPG (2007), which was
      formally adopted as SPG in 2009.

2.9   In terms of emerging planning policy, the Council are at the initial stages in the preparation of the
      City and County of Swansea Local Development Plan (“LDP”), which will replace the UDP when
      adopted.

2.10 The Council consulted on the LDP Strategic Options Consultation Draft (2012) and LDP Vision and
     Objectives Consultation Draft (2012) documents from July to October 2012. These documents
     respectively comprise potential strategic development options upon which the LDP could focus and
     potential overarching aims of the LDP to underpin the strategic options.

2.11 The Draft LDP has not yet been published for consultation by the Council. The forthcoming stages of
     the LDP will include the publication of the LDP Preferred Strategy in 2013, followed by the LDP
     Deposit Plan. The Preferred Strategy will identify the Council’s proposed way forward in strategic
     planning terms by identifying the proposed scale of population and household growth and key
     drivers for the plan, including aspirations for economic growth. It will set out the overall spatial
     development strategy for Swansea, the key strategic development areas and the broad strategic
     policies.

2.12 The LDP Deposit Plan will identify the Council’s proposed land allocations and build upon the
     strategic policies of the LDP Preferred Strategy to set out detailed policies and proposals for the
     future development and protection of land within Swansea. The Deposit Plan is not anticipated to be
     published until 2015.

2.13 This report reviews adopted planning policy and makes recommendations for which elements need
     to be changed to ensure an appropriate and sustainable balance of retail development across the
     City and County of Swansea in locations outside of the City Centre. This is in order to ensure the
     establishment of a successful retail hierarchy in Swansea, which cascades down from the City Centre
     as the priority location for high street A1 retailing. These recommendations feed into the suggested
     new planning policies for inclusion in the LDP to form a new retail strategy for the City and County of
     Swansea set out in Chapter 5 of this report.

      National Planning Policy

2.14 Chapter 10 of Planning Policy Wales (“PPW”) contains national planning policy for retailing and town
     centres.




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2.15 Key objectives of PPW are to promote established town and district centres as the most appropriate
     locations for retail, leisure and complimentary uses, including enhancing their vitality, attractiveness
     and viability. In this respect, PPW promotes the restoration of redundant buildings and public realm
     improvements in existing town and district centres (para. 10.2.5).

2.16 The accessibility of town and district centres by public transport, walking and cycling is a central and
     “essential” objective of PPW (para. 10.1.1 and 10.2.6). It further states that “access by car and short-
     term parking can also help centres to compete with existing out-of-centre locations, but they should
     be managed to minimise congestion, pollution and parking problems which would otherwise reduce
     the convenience, attractiveness or competitiveness of these centres” (para. 10.2.6).

2.17 PPW seeks for “development plans to identify changing pressures and opportunities and devise
     appropriate responses to them” and to “identify measures to reinvigorate centres, or to manage
     decline in the relative importance of a centre as other centres expand” (para. 10.2.1).

2.18 With regard to the allocation of sites for retail development, PPW seeks for retail and leisure uses
     which need to be accessible to a large number of people to be located in town centres and for
     “smaller scale retail provision, including appropriately sized supermarkets, [and] leisure facilities” to
     be located in district and town centres (para. 10.2.9).

2.19    A key consideration in the allocation of sites for retail development is whether there is a need for
       additional provision. Quantitative need should be given precedence before qualitative need is
       considered, and “where the current provision appears to be adequate in quantity, the need for further
       allocations must be fully justified in the plan”. Such justification could include where: the proposal
       supports the strategy and objectives of PPW and the LDP; the site is in a highly accessible location
       which would contribute to a reduction in car journeys; the proposal would contribute to the co-
       location of facilities in and vitality of existing town and district centres; and where the scheme would
       alleviate a lack of convenience provision in a disadvantaged area (para. 10.2.10).

2.20 Where there is an identifiable need for new retail development, local planning authorities are
     required to adopt a sequential approach, with a preference for town centre locations, then edge-of-
     centre sites, then district centre sites and only then out-of-centre sites which are accessible by a
     range of transport choices.

2.21 Floorspace, convenience, attractiveness, quality and traffic should all be taken into account when
     allocating sites for retail development (para. 10.2.12).




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2.22 With regard to planning applications for retail and leisure schemes best located in a town centre,
     PPW seeks that the following matters are taken into account: compatibility with the up to date
     development plan strategy; need for the scheme (unless the application is in relation to a site in a
     defined centre or site allocation); the sequential approach; impact upon existing centres; “net gains
     in floorspace where redevelopment is involved, and whether or not it is like-for-like in terms of
     comparison or convenience”; the take-up rate of allocated sites; accessibility by a range of transport
     modes; impact upon travel patterns; and the “best use of land close to any transport hub, in terms of
     density and mixed use” (para. 10.3.1).

2.23    Where need is a consideration for planning applications for retail development, PPW requires
       precedence to be accorded to establishing quantitative need. It further states that the decision
       maker must justify the weight given to any qualitative assessment. Moreover, “regeneration and
       additional employment benefits are not considered qualitative need factors in retail policy terms,
       though they may be a material consideration in making a decision on a planning application” (para.
       10.3.3).

2.24    PPW requires that local planning authorities retain an adequate level of food shopping provision in
       existing town and district centres and states that out-of-centre food supermarkets is not permissible
       if this would lead to the loss of general food retailing in the centre of smaller towns (para. 10.3.8).



2.25 Where appropriate edge-of-centre or out-of-centre retail developments are approved, local planning
     authorities are required to place conditions on the initial permission and on any subsequent variation
     allowed. This is to control any future aspirations that retailers might have “to change the range of
     goods they sell or the nature of the sales area, for example by subdivision to a mix of smaller units, or
     to a single ‘department’ store” or to redevelop, extend or add mezzanine floors to the retail unit”.
     Furthermore, “applications to remove or vary such conditions should be considered in accordance
     with” (para. 10.3.11).

2.26    Where suitable sites for bulky goods retail uses are not available in town centres, PPW seeks for
       these to be located at edge-of-centre sites, or where these are not available, at locations accessible
       by a range of transport modes. Retail parks are only considered to be appropriate where they are
       accessible to public and private transport (para. 10.3.12).

2.27 With regard to applications to renew planning permission for retail, leisure and other uses best
     located in town centres, PPW seeks that these are determined in accordance with the up-to-date
     development plan, PPW and the sequential approach (para. 10.3.16).




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2.28 TAN4 reflects the need for a sequential approach and requires that all applications for retail
     developments of over 2,500 sq m are accompanied by a Retail Impact Assessment. It also requires
     car parking standards to achieve an adequate level of town centre parking to reflect the range of
     town centre uses the range and level of public transport alternatives.

      Unitary Development Plan

2.29 Adopted UDP planning policy defines locations outside the City Centre as being those set out in the
     first three columns of Table 2.1 below:

       Traditional District        Modern District              Employment Location         Other Retail
       Centre                      Centre                       with a ‘Retail Zone’        Locations Not
                                                                                            Identified in Planning
                                                                                            Policy*
       • Clydach                • Parc Fforestfach       • Swansea Enterprise               • Parc Cwmdu
       • Gorseinon                                          Park                            • Parc Morfa
       • Killay                                                                             • Pontardulais Road
       • Morriston                                                                            Retail Park
       • Mumbles
       • Pontarddulais
       • Sketty
       • Uplands
      Table 2.1: Retail Locations outside the City Centre Identified in Adopted Planning Policy
      (Source: Swansea UDP (2008) and the Swansea City Centre Strategic Framework SPG (2007))

      * Whilst retailing also occurs at other out-of-centre locations other than those listed in column 4 of Table 2.1,
      only the above locations are considered to have sufficient critical mass and cohesiveness to warrant
      classification as specific retail destinations going forward.

2.30 In addition, retailing in the City and County of Swansea takes place at Parc Tawe, which is defined
     within adopted planning policy as forming part of the City Centre, however in practice this acts as an
     edge-of-centre retail park. These locations are reviewed in detail in Chapter 3.

2.31 The UDP Spatial Strategy promotes as its primary focus the reinvigoration of the City Centre and
     waterfront, and also seeks to ensure appropriate levels of growth at urban settlements across the
     County to stimulate the regeneration of old industrial communities. A core element of this strategy
     is “to develop a modern, attractive and vibrant waterfront area integrated with a revitalised City
     Centre. Delivering a significant enhancement to retail facilities that reinforces Swansea’s role as a
     regional centre will be central to the City Centre revitalisation”.

2.32 Key objectives of the UDP which are relevant to this study are:

        •   Objective 2.d: to reinforce and improve the City Centre as a vibrant regional focus for business
            and administration, shopping, culture and leisure;




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        •   Objective 2.e: to improve the range, choice and quality of shopping opportunities accessible for
            all sections of the community and visitors to the area; and
        •   Objective 2.f: to resist further out of centre/town retail development.

2.33 Strategic Policy SP6 states that the City Centre will be the primary focus for new retail development
     and that the improvement and enhancement of District Shopping Centres will be supported. These
     are considered to be the best locations for new retail development and such development will not
     generally be supported at out-of-centre sites. Additional edge-of-centre shopping will only be
     permissible where it would not prejudice established shopping centres.

2.34 Improving accessibility across the Swansea administrative area is a key strand running through the
     UDP. Strategic Policy SP14 favours the location of new development in areas that are highly
     accessible by public transport, walking and cycling and which will minimise dependency on the
     private car. Sympathetically designed proposals which facilitate sustainable travel choices and
     promote accessibility by a range of transport modes are encouraged.

2.35 Need and accessibility are key requirements for new retail development set out in Policy EC4. This
     policy states that all new retail development proposals will be assessed against the need for
     development and will only be permitted where the site is the most sequentially preferable option.
     “There would be no material adverse impact upon the attractiveness, vitality and viability of the City
     Centre and other established shopping centres, the proposal is compatible with the function, scale
     and character of the centre within or adjacent to which the site is located”. The site is required to be
     in a location which is accessible by foot, bicycle, public transport and car and the scheme must
     satisfactorily address design, environmental and highway considerations.

2.36 The UDP designates two types of district centres, ‘Traditional’ and ‘Modern’. Traditional District
     Centres comprise Clydach, Gorseinon, Killay, Morriston, Mumbles, Pontarddulais, Sketty and
     Uplands. Parc Fforestfach Retail Park is designated as a “modern superstore-based district shopping
     centre that caters primarily for car borne shoppers”. In practice, it operates as an out-of-centre retail
     park which is distinct from and has different characteristics to the other district centres in the
     Swansea administrative area.

2.37 With regard to designated district centres, Policy EC5 seeks for development to be of an appropriate
     type and scale to maintain or improve the range and quality of shopping facilities within the district
     centres, along with improvements to the physical environment and accessibility of such centres for
     public transport users, cyclists and pedestrians.

2.38 Policy EC6 seeks for appropriate small-scale local shopping and neighbourhood facilities to be
     encouraged in areas of acknowledged deficiency to meet local need.




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2.39 The UDP Strategy Map designates Swansea Enterprise Park as an Employment Location. Within this,
     the UDP Proposals Map designates an area as the Enterprise Park ‘Retail Zone’. In the Enterprise
     Park Retail Zone, Policy EC7 states that retail development is sought to be restricted to the sale of
     “bulky goods items that do not pose a threat to the vitality, attractiveness and viability of the City
     Centre and surrounding town [and] district ... centres”. It further states that proposals for new retail
     development outside the retail zone will not be permitted. Therefore, at the Enterprise Park, only
     bulky goods retailing is permissible within the designated ‘Retail Zone’ and no retailing is to be
     allowed outside of the ‘Retail Zone’.

2.40 The UDP seeks for retail warehouses (i.e. bulky goods) to be directed to suitable locations within
     existing retail centres first, then to the edge of existing retail centres. Only where such sites are not
     available, suitable locations at established retail parks will be considered (Policy EC8).

2.41 Policy EC9 resists retail development in out-of-centre locations, with the exception of: “small scale
     local shopping facilities required to meet local needs”, “retail warehouses engaged in the sale of bulky
     goods that do not pose a threat to the vitality, attractiveness and viability of the City Centre and
     surrounding town and district shopping centres”, units requiring large showrooms and factory outlets
     in connection with manufacturing centres on industrial estates.

2.42 Policy CC2 places the highest priority upon enhancing shopping facilities through the refurbishment
     and redevelopment of the City Centre retail core. It resists proposals for retail development which
     would be detrimental to objectives for the enhancement of this retail core.

2.43 Policy CC3 defines the St. David’s/ Quadrant area as the highest priority for redevelopment in the
     City Centre. Proposals that would put its comprehensive retail-led regeneration at risk, or which
     would adversely affect the enhancement and redevelopment of shopping facilities elsewhere in the
     retail core, will not be supported.

2.44 Parc Tawe comprises two phases, Parc Tawe Phase 1 which lies to the south of the Parc Tawe Link
     Road and Parc Tawe Phase 2 which lies to the north of the Parc Tawe Link Road. A wide range of
     uses are considered to be appropriate in Parc Tawe Phase 1 by Policy CC4, including retail (A1 and
     A3), leisure (D2), hotel (C1), residential (C3), education (D1), office (A2 and B1) and car parking. The
     amount of retail (A1 and A3) and leisure (D2) must not exceed 19,000 sq m combined (gross),
     however this threshold has already been reached. Opportunities to promote the wider integration of
     Parc Tawe with the City Centre are sought. The supporting text to this Policy states that Parc Tawe
     Phase 1 is a very important gateway to the City Centre. It further states that “development and
     physical improvements will specifically be sought on the Strand/ Quay Parade Frontages whilst
     respecting the regeneration initiatives arising from the rest of the City Centre. This will help generate
     the activity and viability between Parc Tawe (Phase 1) and the rest of the City Centre”.




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2.45 Policy CC4 refers to Parc Tawe Phase 1 only, however the text supporting this policy recognises that
     proposals could come forward for the Parc Tawe Phase 2 site in the longer term and states that such
     proposals will be considered on their planning merits in accordance with the UDP and Swansea City
     Centre Framework principles (see below). Any scheme at Parc Tawe Phase 2 is required to be
     compatible with the proposed comprehensive development for Parc Tawe Phase 1 set out in Policy
     CC4 in the short to medium term.

2.46 Improvements to the accessibility of the City Centre are sought by Policy CC6, through:
          • Completion of the strategic road network around the City Centre;
          • Introduction of further park and ride facilities;
          • Improved public transport and bus and rail interchange;
          • Improved facilities for taxis;
          • Redevelopment of the Quadrant Bus Station;
          • Introduction of bus priority measures;
          • Introduction of City Centre circular bus route;
          • “Broadly maintaining the existing level of car parking to serve the City Centre, whilst
             promoting the better management of both on-street and off-street car parking”;
          • Improved pedestrian routes through the City Centre and connections with the waterfront;
             and
          • Provision of facilities to encourage cycling.

2.47 In addition, improvements to car parking provision serving the city centre are sought by Policy CC7.

      Supplementary Planning Guidance

2.48 The Swansea City Centre Strategic Framework SPG (2007) shows that the boundary of the City Centre
     extends along the River Tawe to the east, Swansea Rail Station marks the northernmost point,
     Alexandra Road forms the north western boundary, West Way and County Hall mark its western
     edge and Swansea Bay forms the southern boundary. The SPG promotes the creation of a vibrant
     mixed-use heart to the City Centre including the St. David’s/ Quadrant area, the Oxford Street/Castle
     Square area, Oxford Street West/ West Way area and the Wind Street/ Salubrious Place/ Lower
     Princess Way area. In the rest of the City Centre, the SPG promotes the creation of a high quality
     “European Boulevard” along Oystermouth Road, Victoria Road and Quay Parade. A key objective is
     to connect the City to the waterfront via Paxton Street, the Sailbridge and the Maritime Quarter. The
     SPG also promotes developing the identities and complementary roles of all districts including the
     Mansel Street/ Alexandra Road area, Kingsway/ Orchard Street area, the High Street and Parc Tawe.
     Parc Tawe is identified as a “more recently developed bulky goods retail and leisure area”.




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2.49 The District Centres, Local Centres and Community Facilities SPG (2010) identifies eight district
     centres in the City and County of Swansea, including Clydach, Gorseinon, Killay, Morriston,
     Mumbles, Pontarddulais, Sketty and Uplands.

2.50 The SPG identifies the primary frontages of core retail activity and secondary frontages of more
     mixed commercial character in each District Centre. It promotes the safeguarding of A1 shop units to
     ensure that retailing underpins District Centres and promotes sufficient vehicle parking provision.
     Where appropriate, A3 food and drink, A2 financial professional services and a complementary mix
     of non-retail uses, including B1 offices and D2 leisure facilities are also permitted.

2.51 Significantly, whilst the UDP designates Parc Fforestfach as a ‘modern district centre’, this SPG states
     that “this area comprises only 15 units in mainly large format, warehouse style buildings that are
     typical of out-of-centre retail parks, together with a large foodstore. It is also supported by a large
     area of adjacent free car parking that caters to the needs of the car borne shopper. In view of the
     markedly different character and form of Parc Fforestfach as compared to the traditional district
     centres identified above, this area has been excluded from the scope of this document”.

2.52 The Swansea Enterprise Park Planning Policies SPG (1996) was prepared prior to the UDP but remains
     adopted. The SPG states that Swansea Enterprise Park was originally set up as an Enterprise Zone in
     1981 to restore private sector activity to the Lower Swansea Valley by introducing tax benefits and
     relaxing or speeding up a number of statutory planning controls. This was to establish an area for
     businesses to develop and to create jobs. The Enterprise Zone status came to an end in 1991, leaving
     most of the area subject to “normal planning control”.


      Planning History

      Swansea Enterprise Park


2.53 On 28 December 1978 planning permission was granted for the development of an ‘industrial park’
     on ‘land to the south of the A48’ (ref. 2/1/78/1464/03).

2.54 On 21 May 1979, outline planning permission was granted to ‘build industry and ancillary distribution
     and warehousing (Use Class III, IV, X)’ on ‘land north of A48, Llansamlet, Swansea’ (ref.
     2/1/79/0000/11). For clarification, under the Town and Country Planning General Development
     Order 1973, Use Class III related to light industrial uses (now Class B1(c)), Use Class IV related to
     general industrial use (now Class B2) and Use Class X related to storage and distribution (now Class
     B8). It is not clear whether planning conditions are attached to this permission to restrict the type of
     Class B1(c), B2 or B8 development on the site.




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2.55 Swansea Enterprise Park was set up as an Enterprise Zone where relaxed planning controls applied
     from 1981 to 1991. The available planning history does not provide clarity on what, if any,
     restrictions are placed upon retail warehouse buildings constructed at Swansea Enterprise Park from
     1981 to 1991. As the retail units were built as part of the Enterprise Zone, planning permission was
     not required and therefore no planning conditions were imposed. As these units have therefore
     been established for more than 10 years, we consider that they constitute unrestricted lawful retail
     (A1) units, where any type of retailer falling within the A1 use class could occupy these buildings
     without applying for planning permission (and thus without consulting the adopted development
     plan), should there be no physical alteration of the building occupied.

2.56 Many of the retail warehouses in Swansea Enterprise Park are reaching the end of their operational
     life. Planning permission would be required for the construction of a replacement building of the
     same or different size and for any alteration to or the extension of the existing building.

2.57 The UDP promotes bulky goods retail in part of the Enterprise Park and resists high street retail at
     this location. However if an application were to be submitted to demolish a retail warehouse on the
     Enterprise Park and replace it with a new building of the same size to accommodate a high street
     retail use, there will need to be a detailed appraisal of the specifics of the application to ascertain
     whether it is appropriate for the Council to refuse it on land use terms. Any refusal would need to be
     carefully considered due to the lawful unrestricted retail (A1) use on the site. The Council would be
     able to consider the application on material grounds such as in design terms, however the extent to
     which a redevelopment proposal could be considered entirely afresh would be largely dependent
     upon what could be argued is a reasonable ‘fall back’ position for use of the existing building for the
     same proposed use. This could vary depending on the nature, siting and location of the building or
     buildings in question. Developers are likely to argue that it is indeed unreasonable to refuse an
     application on land use grounds when that use is already established and no increase in floorspace is
     being proposed.

2.58 The above analysis also applies to proposals for external alterations to (such as to re-clad) an existing
     retail unit on the Enterprise Park.




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2.59 If a planning application were to be submitted to replace a retail warehouse on the Enterprise Park
     with a building with a larger retail sales area, the issues raised above would again apply for the area
     covered by the existing building, however in this situation it is more clear that the Council would
     need to assess the retail impact of the additional sales floorspace and must carefully consider this
     element of the application in land use terms. The applicant’s submission of a retail impact
     assessment is likely to be necessary to assess the impact of the additional element proposed in
     comparison to the existing building, although planning policy may only require this if the proposal
     exceeds 2,500 sq m. The same applies for an application to extend an existing retail warehouse on
     the Enterprise Park. However, the Council’s refusal of any such application on land use grounds is
     again problematic for the reasons identified above relating to the long established lawful use
     covering the existing retail building. Notwithstanding these problems there are considered to be
     very good planning reasons to prevent proliferation of unrestricted A1 retail space as this location in
     units that could become attractive to high street occupiers, as described below.

2.60 Due to the former Enterprise Zone status of the area, no planning history exists in the period
     between 1981 and 1991. A summary of the planning history relating to retail uses in the Enterprise
     Park since 1991 is provided at Appendix 1.

2.61 The extent of unrestricted retail floorspace developed within the former Enterprise Zone and the
     implications of this going forward is an important factor in formulating a robust new retail
     investment and planning strategy that prioritises the City Centre. The particular area of concern is
     the potential for the unregulated occupation of lawful retail units by high street (i.e. non-bulky)
     retailers at the Enterprise Park, which is contrary to the prioritisation of the City Centre for such uses
     in the UDP.

2.62 The Council own the freehold of the Enterprise Park and therefore as a landowner, have a degree of
     control over who they let their retail buildings to.

      Parc Tawe

2.63 On 9 June 1987 planning permission was granted for ‘leisure and retail development: multiplex
     cinema, public toilets and fast food units’ at North Dock, now known as Parc Tawe Phase 1 (ref.
     2/1/87/0656/03). Condition (g) states that ‘the permission now granted for the retail units ... shall
     only be used for Class I activity as defined by the Town and Country Planning (Use Classes) Order 1972
     and notwithstanding the contents of that Order specifically excludes food and DIY retailing from the
     scheme’. Under this Order Class I refers to Class A1, therefore this translates as a Class A1 use
     excluding DIY and food retail use (under the current Town and Country Planning (Use Classes) Order
     1987 (as amended) in use today) at Parc Tawe Phase 1.




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2.64 In 1996 planning permission was granted for ‘the development of 12,586 sq m of retail (A1) and
     restaurant (A3) use plus associated car parking and landscaping’ at Parc Tawe Phase 2 (ref. 95/1363).
     On 4 October 1996, planning permission was granted for the ‘development of 12,513 sq m of retail
     (class A1) plus associated car parking and servicing (amendment to planning permission 95/1363
     approved 17 May 1996)’ at Parc Tawe Phase 2 (ref. 96/0764). The planning conditions attached to
     this consent do not include restrictions to the type of Class A1 retail development on the site.
     Planning permission 95/1363 was however granted subject to a Section 106 Agreement which
     included a floorspace restriction. Clause 3 of the Third Schedule reads: “No unit of accommodation
     for use falling within Class A1 of the Town and Country Planning (Use Classes) Order 1987 forming
     part of the development shall have or be subdivided such that it has a gross floorspace which is less
     than 700 sqm (7,500 sq ft) without the specific consent of the Council”.

2.65 The A1 planning permission (excluding food and DIY) at Parc Tawe Phase 1 and the unrestricted A1
     planning permission for Parc Tawe Phase 2 have the same implications as outlined above in relation
     to the Retail Zone within the Enterprise Park. In this respect, there are similar concerns with regard
     to the risk of high street (i.e. non-bulky) A1 retailers locating at Parc Tawe without the need for
     planning consent. This is contrary to the aims of the adopted UDP for Parc Tawe, which although in
     the City Centre boundary is sought to be a bulky goods location, with high street retail to be focussed
     in the City Centre ‘Retail Core’. There is however some control that can be imposed through the
     Section 106 agreement at Parc Tawe Phase 2.

2.66 Key elements of the planning history for Parc Tawe are summarised at Appendix 2.

2.67 The Council own the freehold of Parc Tawe Phase 1 and have a degree of control over leasehold
     issues.

      Out-of-Centre Retail Parks


2.68 To understand the potential impact of retail parks upon the success of high street A1 retailing in
     Swansea City Centre, the key elements of available planning history in relation to key out of centre
     retail locations both within and outside the administrative area of the City and County of Swansea
     have been reviewed. Summary schedules are attached at Appendices 3 - 6.

       Modern District Centre                         Other Retail Locations Not Identified in
                                                      Planning Policy

       • Parc Fforestfach                             • Parc Morfa
                                                      • Pontardulais Road Retail Park
                                                      • Parc Cwmdu


      Table 2.2: Out-of-Centre Retail Parks in the City and County of Swansea
      (Source: Swansea Unitary Development Plan (2008))



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2.69 Whilst in practice the following retail locations subject to this planning history review have the
     characteristics of out-of-centre retail parks (that is, they are located on out-of-centre sites with large
     retail warehouse units with a largely A1 retail offer), they are not specifically defined as being such
     within current adopted planning policy. As Table 2.2 shows, the UDP identifies Parc Fforestfach as a
     ‘Modern District Centre’ and the other four locations are not specifically identified as retail locations
     in the UDP.

2.70 At Parc Fforestfach, the available planning history shows that on 22 March 1995 outline planning
     permission was granted for the ‘erection of retail park, petrol filling station and fast food outlet’ (ref.
     94/1331). On 2 August 2000 planning permission was granted for the ‘redevelopment of existing
     district shopping centre comprising new Tesco superstore (10,000 square metres gross floor space),
     petrol filling station and 8 no linked retail units (11,670 square metres gross floor space), petrol filling
     station and 8 service yards and staff car parking areas, alterations to existing access off Pontardulais
     Road, closure of existing access off Carmarthen Road, construction of two new accesses of Ffordd
     Cynore, off site highway works to Ffordd Cynore and the Pontardulais Road Junction, provision of
     1,275 space customer car park, site landscaping and accommodation works (subject to S106
     agreement)’ (ref. A00/0366).

2.71 No conditions are attached to either of these decision notices to restrict the type of retail
     development. This has the same potential implications as the Retail Zone within the Enterprise Park,
     the A1 planning permission (excluding food and DIY) at Parc Tawe Phase 1 and the unrestricted A1
     planning permissions for Parc Tawe Phase 2.

2.72 A number of planning applications for new retail units, the extension of retail units, sub-division of
     retail units and construction of mezzanine levels within retail units have since been approved. This
     regular flow of planning permissions from 2001 to present is summarised in Appendix 3 and indicates
     that the expansion of retailing and restaurant/leisure uses at Parc Fforestfach continues to be a
     threat to the City Centre, largely due to its designation in the UDP as a Modern District Centre.




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2.73 At Parc Cwmdu, the available planning history shows that planning permission was granted in 1989
     for mixed industrial (B1, B2, B8) and retail floorspace, with a limit placed on net retail floorspace of
     70,000sq ft (6,500 sq m) (ref 89/0053). Subsequently a proposal for a 23,000 sq ft (2,100 sq m) retail
     unit was granted permission and occupied by a low cost foodstore (ref 92/1037). On 22 June 1994
     permission was granted for ‘general and light industry (Class B1 and B2) warehousing (Class B8) and
     retailing (Class A1 retail floorspace limited to a maximum of 47,000 sq ft)’ (ref. 94/0177). Permission
     was granted for the renewal of this planning permission on appeal in 1998 (ref. 98/0042) (see
     Appendix 4). The appeal allowed a variation in the outline planning permission by deleting Condition
     11, which stated ‘the retail element of the scheme shall be limited to a maximum of 47,000 sq ft gross
     retail floorspace. Any A3 uses developed on the site under this or any other permission shall count
     against this 47,000 sq ft allocation’. This was substituted with the following wording for Condition
     11: ‘the retail element of the scheme shall be limited to a maximum of 4366.3 square metres [47,000
     sq ft] gross retail floorspace’ (appeal ref. JWKD/DMW/98/088). Individual planning permissions for
     additional retail units followed in 2000 for floorspace of 40,000 sq ft (A00/0377), 10,000 sq ft
     (A00/1439) and 11,250 (A00/1578).

2.74 Since the original outline permission for the Cwmdu estate, subsequent planning permissions have
     granted in excess of 80,000 sq ft (7,400 sq m) of retail floorspace. The conditions attached to the
     various decision notices vary in their ability to restrict the type of retail development. Again,
     depending on the conditions attached to each consent, there are potentially similar implications in
     relation to the existing units as those within the Enterprise Park Retail Zone, the A1 planning
     permission (excluding food and DIY) at Parc Tawe Phase 1 and the unrestricted A1 planning
     permissions for Parc Tawe Phase 2 and Parc Fforestfach. It is significant however that the retail
     floorspace permitted by the original consent for the site has now been exceeded by subsequent
     permissions, which provides the opportunity to restrict any further additional A1 retail floorspace.

2.75 The planning history indicates that there are likely to be further applications to try and further
     expand retailing and restaurant/leisure uses at Parc Cwmdu. New retail floorspace at this location
     would be a potential threat to the vitality and viability of the City Centre, which is recognised in the
     site’s recent planning history records which include a dismissed appeal for a proposed Class A1 retail
     unit on a vacant site within the estate. The inspector found that the proposal would be at variance
     with national policies and the Council’s policy framework that resists out of centre retailing where
     this would compromise efforts to regenerate the city centre.




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2.76 At Parc Morfa, the available planning history shows that planning permission was granted on 28 June
     2002 for the ‘construction of sports stadium, leisure facilities (including health club, multi-screen
     cinema, ten pin bowling centre, alterations to existing tennis centre, hotel and restaurants) and
     provision of enabling retail development, petrol filling station and necessary infrastructure’ (ref.
     A00/1410).

2.77 A number of planning conditions are attached to this permission to restrict the type of retailing at
     the buildings permitted at Parc Morfa “in order to minimise any adverse impact upon surrounding
     shopping centres”. These are:

          •   Condition 17, which restricts the following items from being sold at the permitted DIY/
              garden centre premises: items of clothing, food and drink, audio and video goods/
              equipment, computers, mobile telecommunications equipment, furniture other than self-
              assembly, flat-pack or garden furniture, sports goods and keep fit equipment;
          •   Condition 18, which states that “the use of Unit 2 (sport retail) is restricted solely to the sale
              of sports equipment, sports clothing and footwear, and other sports related goods, and for
              the provision of ancillary sports training accommodation. The premises are to be used for no
              other retail purpose than that specified (including any other purpose in Class A1 of the
              Schedule of the Town and Country Planning (Use Classes) Order 1987)”;
          •   Condition 19, which states that “the use of the non-food retail building will be restricted to
              the sale of the following bulky goods: carpets and floor coverings, furniture and ancillary soft
              furnishings; gas and electrical goods; DIY/hardware and garden products items; motor
              accessories; office furniture; and the sale of goods ancillary thereto. The premises are to be
              used for no other retail purpose (including any other purpose in Class A1 of the Schedule of
              the Town and Country Planning (Use Classes) Order 1987”; and
          •   Condition 20, which states that “none of the non-food retail units shall be subdivided so that
              the gross retail floorspace of a single user is less than 1,000 sq m”.

2.78 In terms of restrictions upon leisure uses, Condition 21 states that “the proposed health and fitness
     premises shall be used as a health and fitness club and for no other purpose (including any other
     purpose in Class D2 of the Schedule to the Town and Country Planning (Use Classes) Order 1987 ...
     without the prior approval in writing of the Local Planning Authority”.

2.79 A number of planning applications for new Use Class A3 restaurant units, the extension of retail
     units, subdivision of retail units and relaxation of planning conditions to increase the permissible
     floorspace of retail units have been approved since the initial planning permission for Parc Morfa
     (ref. A00/1410). This regular flow of approvals from 2002 to present is summarised in Appendix 5
     and indicates that the expansion of retailing and restaurant/ leisure uses at Parc Morfa continues to
     be a threat to the City Centre.




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2.80 The permitted multi-screen cinema and ten pin bowling centre have not been implemented at Parc
     Morfa and the permitted timescale for their delivery under planning permission ref. A00/1410 has
     lapsed. There is the risk that this might be viewed as setting a precedent for the development of
     leisure uses in this location, however this would pose a threat to the Council’s aspirations for the City
     Centre to be the focus for retail and leisure uses. This includes A3 leisure uses that would serve to
     significantly enhance the location’s appeal for ‘destination dining’ in preference to the City Centre.
     Current levels of A3 appear largely incidental to the retail use but, similar to concerns at other retail
     park locations in Swansea, future development that would deliver a greater critical mass of dining
     experiences at the retail park could threaten the viability of the City Centre going forward.

2.81 Parc Morfa is not identified as a retail location with the UDP. Any retail application that comes
     forward at Parc Morfa in the context of adopted planning policy will therefore be considered against
     the general planning policies which resist retail development outside defined retail centres. Any such
     application will also be subject to the sequential test and will largely be considered on the basis of
     retail need. This is in accordance with national planning policy contained in Planning Policy Wales
     (“PPW”) (2012) and Technical Advice Note 4 (“TAN4”).

2.82 The available planning history for Pontardulais Road Retail Park shows that a number of planning
     applications have been approved for the construction of mezzanine floors and to increase the range
     of goods sold at retail units at Pontardulais Road Retail Park. These are summarised in Appendix 6
     and indicate that the expansion of certain forms of retailing at this location continues to be a threat
     to the City Centre.

2.83 There are other out of centre locations across Swansea where a retail presence has been established
     but they do not necessarily take the form of an established retail park. This includes industrial
     locations such as at Garngoch where the further proliferation of retailing could have an adverse
     effect on efforts to direct retail investment into the City Centre.

2.84 Parc Trostre and Parc Pemberton are large out-of-centre retail parks, which lie on the edge of
     Llanelli, which comprise a mix of non-bulky and bulky A1 and A3 units. These are located outside of
     the administrative area of the City and County of Swansea and fall within the remit of
     Carmarthenshire County Council, however their catchment extends into the former. Parc Trostre
     and Parc Pemberton have experienced significant expansion, including alterations and enhancements
     to the retail units in recent years. Continued expansion of these retail parks is a key threat to the
     vitality and viability of Swansea City Centre, particularly as they lie outside of the control of the City
     and County of Swansea as a local planning authority.




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      Reflection

2.85 This section provides a reflection upon the above analysis of adopted planning policy and previous
     planning decisions.

2.86 In terms of national planning policy and adopted local planning policy, overall it is clear that the
     overarching goal is to prioritise the City Centre, particularly the Retail Core, as the focus for retail
     development, followed by district centres then out-of-centre locations.

       Complementary        Traditional          Modern District      Employment           Other Retail
       City Centre          District Centre      Centre               Location with a      Locations Not
       District within                                                ‘Retail Zone’        Identified in
       City Centre                                                                         Planning Policy
       • Parc Tawe          •   Clydach          • Parc               • Swansea            • Parc Cwmdu
                            •   Gorseinon          Fforestfach          Enterprise Park    • Parc Morfa
                            •   Killay                                                     • Pontardulais
                            •   Morriston                                                    Road Retail
                            •   Mumbles                                                      Park
                            •   Pontarddulais
                            •   Sketty
                            •   Uplands
      Table 2.3: Current Definitions of Retail Locations in the City and County of Swansea
      (Source: Swansea Unitary Development Plan (2008) and the Swansea City Centre Strategic Framework
      Supplementary Planning Guidance (2007))


2.87 Aside from the ‘Retail Core’, the classification of retail locations within adopted planning policy
     (shown in the first four columns of Table 2.3) is unclear, particularly terms such as ‘Traditional District
     Centres’ and ‘Modern District Centres'.

2.88 Moreover, three established retail locations (shown in the fifth column of Table 2.3) are not
     identified within planning policy. Planning applications in these locations are therefore judged upon
     their own merits on the basis of general retail planning policies set out in the UDP, rather than more
     stringent location-specific policies.

2.89 The current retail hierarchy in the City and County of Swansea is therefore unclear, making the
     interpretation and implementation of the overarching policy goals for retailing set out in PPW and
     the UDP more difficult. Chapter 5 makes recommendations to redefine the shopping locations in the
     administrative area in order to clarify the retail hierarchy and to ensure the achievement of these
     goals.




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2.90 Further proliferation of unrestricted A1 retail space at the out of centre locations described above
     (including Parc Fforestfach) poses a threat to the future vitality, viability and attractiveness of
     Swansea City Centre. The emergence of significant new leisure floorspace (including A3) at these
     locations would pose a further threat through the creation of multi-use leisure and dining
     destinations which would be more appropriately delivered in the City Centre.

2.91 The existing retail units at Swansea Enterprise Park, Parc Tawe Phase 2, and Parc Fforestfach pose a
     particular high risk to the Council’s prioritisation for A1 high street retailers to locate in the City
     Centre ‘Retail Core’. These sites do not appear to be restricted to bulky goods by means of extant
     planning permissions and are considered attractive locations for high street retailers going forward.
     This is a difficult issue for the emerging LDP to address due to the limits of influence for new policies
     having regard to permitted development rights.

2.92 The available planning history information for out-of-centre retail parks is a concern as it indicates
     planning applications for the expansion of retailing at these locations have continued to be approved
     from the date of the original planning permissions to the present date. This includes at Parc
     Fforestfach, Pontardulais Road Retail Park, Parc Morfa and Parc Cwmdu. This is therefore a key
     threat to retailing (and leisure uses due to those at Parc Morfa) in the City Centre.

2.93 It is clear that all possible measures need to be taken to address these issues at Swansea Enterprise
     Park, Parc Tawe and the out-of-centre retail parks to ensure that emphasis is placed upon the
     strengthening of retailing in the City Centre supported by the remainder of the (redefined) retail
     hierarchy within the administrative area.

2.94 The City and County of Swansea have no planning powers over the out-of-centre retail parks at Parc
     Trostre and Parc Pemberton, which fall within the administrative area of Carmarthenshire County
     Council. It would be beneficial for the Council to explore avenues of collaborative working and cross
     partnership agreements with Carmarthenshire County Council in conjunction with the Welsh
     Assembly, particularly in view of Swansea’s proposed role as the driver for the City Region.




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3     Qualitative Assessment of Retail Hierarchy
      Introduction

3.1   This section of the report considers Swansea’s retail hierarchy and assesses the role and specific
      retail functions of locations outside the City Centre ‘Retail Core’. The assessment covers the retail
      locations identified in Table 3.1.


       Complementary       Traditional          Modern District      Employment          Other Retail
       City Centre         District Centre      Centre               Location with a     Locations Not
       District within                                               ‘Retail Zone’       Identified in
       City Centre                                                                       Planning Policy
       • Parc Tawe        • Clydach             • Parc               • Swansea           • Parc Cwmdu
                          • Gorseinon             Fforestfach          Enterprise Park   • Parc Morfa
                          • Killay                                                       • Pontardulais
                          • Morriston                                                      Road Retail
                          • Mumbles                                                        Park
                          • Pontarddulais
                          • Sketty
                          • Uplands
      Table 3.1: Current Definitions of Retail Locations in the City and County of Swansea
      (Source: Swansea Unitary Development Plan (2008) and the Swansea City Centre Strategic Framework
      Supplementary Planning Guidance (2007))

3.2   In addition to the above locations, retailing within the administrative area of Swansea experiences
      significant competition from Parc Trostre Retail Park and Parc Pemberton Retail Park in Llanelli,
      which lie outside of the administrative boundary within the remit of Carmarthenshire County
      Council. This is a strong pull for shoppers residing in western Swansea. The retail function of Parc
      Trostre Retail Park and Parc Pemberton Retail Park is therefore included in this analysis.

3.3   First, the position of the centres within the NSLSP 2011 UK retail location rank is reviewed. Second,
      a high level qualitative assessment of the role and purpose of the retail locations is provided in
      proforma format, identifying the mix of retail uses in each location and areas of visible deficiency in
      convenience goods retail provision and deficiency. This is informed by desk research and a number
      of site visits.

3.4   This section concludes by identifying the key issues in each of the identified retail centres and
      recommendations to improve retailing at each.




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      UK Retail Centre Ranking

3.5   The National Survey of Local Shopping Patterns (NSLSP) is the largest continuous household survey of
      consumer shopping destination preferences undertaken in Great Britain. Established in 1995, the
      survey has compiled almost 20m responses, creating the largest single database of consumer
      shopping destination preferences in the industry, with a further 3m records added annually. The
      survey provides a detailed, robust insight into resident and shopping catchments across Great Britain
      and allows individual locations to be ranked in a like for like manner.

3.6   By way of a regional comparison, the following table shows that Swansea City Centre is ranked 45.
      This compares to Cardiff, Bristol, Carmarthen, Newport and Llanelli city/ town centres, which are
      ranked 9, 12, 142, 144 and 237. In this context, Swansea City Centre is therefore a relatively strong
      performer at present, though its drop in the rankings show that it is being overtaken by other cities
      elsewhere within Great Britain. Cardiff and Bristol, having both experienced significant retail
      development in the last 5 years, possess robust positions at the top of the retail rankings. Whilst
      providing a strong attraction to their catchment residents, Newport, Carmarthen and Llanelli town
      centres do not pose as great a threat to retailing in Swansea City Centre. Development in
      Carmarthen has improved its ranking by just 16 places whilst Newport and Llanelli continue to be
      overtaken in the retail rankings.


                                           Rank       Rank
       City Centre                         2009       2011
       Cardiff                                 9         9
       Bristol                                12        12
       Swansea                                42        45
       Carmarthen                           158        142
       Newport                              136        144
       Llanelli                             219        237
      Table 3.2: Regional Comparison of Retail Rankings
      (Source: NSLSP 2009 and 2011)

3.7   In terms of the retail locations outside of the City Centre in the Swansea administrative area and at
      Parc Trostre Retail Park in Llanelli, they are ranked as follows:




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