Primark – Written evidence (HSC0047)
About Primark
Primark is an international fashion retailer employing more than 80,000 colleagues across 16 countries in Europe and the US. Founded in Ireland in 1969 under the Penneys brand, Primark aims to provide affordable choices for everyone, from great quality everyday essentials to stand-out style across women’s, men’s and kids, as well as beauty, homeware and accessories. With a focus on creating great retail experiences, Primark has over 440 stores globally and continues to expand across new and existing markets.
The UK is Primark’s largest market with 193 stores across the devolved nations, the majority of which are in town and city centre locations. Primark stores have evolved over the years to offer a range of services to complement the shopping experience. Today you can find beauty and beauty studios, food and drink cafes and outlets – including Tasty by Greggs and Disney Cafes. Joining the line up in 2022 was the introduction of Wornwell, a collaboration with the Vintage Wholesale company, offering pre-loved vintage clothing in store. Last year, Primark introduced a Click + Collect service to 57 stores across Greater London, north west England and North Wales, offering customers another way to shop and another reason to visit their local high street. It recently announced plans to invest more than £100m in its UK stores in 2024.
Applying a single definition of a high street is not simple and, in our view, should not be restricted to towns and small cities. The high street, which is not necessarily a single street, is sometimes defined as the heart of a town occupied mostly by commercial and retail occupiers. The purpose is arguably to serve as a hub for all types of businesses, retailers, shops, and restaurants. This provides a convenient and accessible location for all nearby residents to meet their daily needs.
As a focus for local communities, the high street offers a range of shopping (for goods and services) and social activities, many of which are shared experiences that cannot be done online. Larger cities are effectively a series of local hubs serving the needs of local residents and, with the exception of destination shopping streets, such as London’s Oxford Street, providing the same function as the high street in a town or small city.
People really care about their high streets and research Primark commissioned from Public First in 2020 showed that 82% of people think their high street is important for people to have pride in their local area. However, over half thought their local high street had declined in the last decade and 84% thought more should be done to support the health of UK high streets.
Primark’s research showed that, when it comes to their local area, people like to have a mix of shops, cafes, restaurants, entertainment, healthcare facilities, financial services, cultural venues and easily accessible green spaces. In its survey those over 65 are most likely to buy goods on their local high street and over half said that it was important that “those who don’t shop online have access to stores”.
As well as offering an enjoyable shopping experience, a flourishing high street increases local employment opportunities and supports more local businesses. Independent stores are attracted to high streets that have larger brands that they know attract footfall. It’s about getting the right balance. Communities need to work together to develop plans for their high streets that recognise the needs of their particular area and demographic. This should include ensuring that high streets are accessible for all through integrated transport links.
High streets are facing significant economic challenges. The costs of operation due to the burden of tax (through universal business rates - UBR) and wage inflation transport costs, set against a backdrop of declining footfall and customer expenditure, due partly to competition from online shopping, is making the economic benefit of retail in many high street locations marginal. The fundamental review of UBR in 2020 has not led to the fundamental reforms needed and finding ways of reducing the UBR burden on retailers should be a priority for any government wanting to support high streets.
Economic incentives in the form of UBR holidays or other tax breaks, subsidised or even free parking at certain time periods, subsidised/free public transport and an attractive public realm are critical to attracting retail businesses to view the high street as a viable business model. Planning policy also needs to be reviewed and greater recognition given to the fact that there is an over-supply of retail space and some empty premises may need to be repurposed in order to support the regeneration of some high streets.
All stakeholders have a role to play – from central government to local authorities, BIDs, other business communities, local police forces and residents. Retail, in particular, involves different Government departments, eg Department for Business and Trade, HM Treasury, Department for Levelling Up, Housing and Communities, and it is important that there is better communication between them to address the many issues, including access to funding. Communication is also needed with the Home Office on retail crime and with those departments dealing with the societal issues that are driving some of the crime and anti-social behaviour.
Proactive and co-ordinated engagement with key retail anchors is required, as well as with smaller independent ‘interesting’ new retail tenants and property investors, to explore financial incentives to redevelop unused property. The acceleration of investment initiatives into town centres through levelling up and regeneration funds, business rates relief, as well as improvements to the public and private transport networks in towns, would greatly assist.
Government and Local planning policy have an important role and must protect high streets, whilst encouraging investment from national investors and retailers. With an attractive built environment and sustainable national retail, smaller independent retailers will open and thrive. The role of Local Authorities is critical in bringing forward comprehensive schemes in town and city centres where there are often complex freehold and leasehold ownerships as well as conflicting interests to address. Done successfully, such schemes can be transformative for high streets, bringing in new retailers, homes and new public realm and a transformed urban environment.
National planning policy has provided a long-established framework for the location of retail and other town centre uses. This framework is a common theme in local planning policies, requiring out of centre proposals to satisfy sequential and impact tests. This can include the identification of key redevelopment opportunities and areas for change within centres, together with enabling policies that promote new development.
It is important however, to ensure that local planning policies, and any associated Development Briefs advanced by Local Authorities, are flexible and avoid being overly prescriptive, which can affect future deliverability. As already noted, retail is a highly dynamic sector and local authority Development Plans often take many years to produce. It is therefore important that their policies can ‘stand the test of time’ and remain relevant to support the underlying objective of bringing forward new development and change to the benefit of the future growth and vibrancy of high streets, and contribute to the economic, social and environmental well-being of local areas.
Residential space is an important component of successful and vibrant centres, creating new footfall for centres. This should not, however, be at the expense of requirements of retail and other important town centre users by placing overly restrictive conditions on new retailers concerning noise, servicing, operating and delivery hours etc. There must be a balance struck between safeguarding the amenity of residents with an acknowledgement that those choosing to live in town centres should expect a level of activity that would not be present in a purely residential area.
National planning policy has provided a long-established town centre first framework for the location of retail and other town centre users. It requires that town centres should be allowed to grow and diversify in a way that can respond to rapid change and that opportunities/sites should be identified to meet likely growth over at least the next 10 years. National retail planning policy has adopted this consistent position over several years through the various updates made to the National Planning Policy Framework.
A key aspect of national town centre planning policy is the importance of housing in ensuring the vitality of centres. Housing development in town and city centres, including new forms of housing typologies, has experienced growing demand over recent years. If appropriately accommodated within centres, new homes will assist in attracting increased footfall and vibrancy throughout the daytime and into the evening, helping to support the viability of local businesses. Continued support for housing should remain an important facet of town centre planning policy, but should complement, not conflict with, the existing and future retail development of high streets.
The Government introduced Class E (Commercial, Business and Service), in September 2020, including in a single use class a broad and diverse range of uses including retail, cafes and restaurants; financial and professional services; indoor sport and recreation; medical or health services (to visiting members of the public); crèche, day nursery and day centres, offices, research and development and light industrial. This has largely met its intention of providing flexibility for businesses to adapt and diversify to meet changing demands, by removing the need to apply for planning permission to change between the uses listed in Class E.
Another change came into force on 5 March 2024, further increasing flexibility in change of use from Class E to Class C3 (residential) by removing the cap on the amount of floorspace that can be changed in this way, whereas previous provisions limited change of use from office only to residential. Whilst housing is important for high streets, this should not be at the expense of the inappropriate loss of retail and other commercial town centre uses.
In conclusion, national planning policy for town centres remains broadly appropriate, although there is a concern that changes to permitted development rights could cause a dilution of the retail offer of centres. A particularly important consideration is to ensure that Local Authorities have the staff and skills available to deliver national planning policy effectively, both in terms of plan preparation and in the making of robust and positive development management decisions.
The high street is not just a place to shop. People want to experience different things, whether shopping or social, leisure or culture activities. But they want to do it safely and any redevelopment of a high street should include reviewing the safety and security of those using it, eg lighting, configuration of routes to car parks, local transport including the location of bus stops, accessibility of parking – and to reduce the opportunities for anti-social behaviour.
Flexibility of the built environment is key, as it needs to be able to change with the ever-evolving requirements of a ‘modern’ high street. Can the high street be repurposed for a better mix of shops, hospitality, leisure and other activities, including experience-led opportunities.
Planners should ensure that as much open space without ‘dark’ areas, both physically and metaphorically, is incorporated within the architect’s design. The use of quality design and materials will be key, as will the need for any new developments to be environmentally sustainable. Incentives and support should be available to decarbonise older buildings and to encourage greater investment in renewable energy.
Councils need to ensure that those businesses operating on the high street are consulted on any key decisions that may affect their trade, desirability and viability and that their voice is given adequate weight in any debate. It is important that relevant stakeholders across the community are consulted and that those involved, such as local authorities and councils, have the expertise to work with all stakeholders – including residents and businesses - to plan, deliver and monitor redevelopment projects. Some kind of template, including best practice, would help to support this.
Whilst no one size fits all, there are several important elements that need to be considered:
The High Streets Taskforce is a valuable source of expertise and guidance. However, we have not seen a significant change in the high streets in which we trade. The results are limited and often short term. This may be due to some of those involved having limited recent experience of running a business in a high street environment and the issues that are faced.
Ultimately, in order to address the issue of redundancy and obsolescence towns still need far more financial support. Central and local governments have an important part to play to ensure that measures recommended by the Taskforce are properly funded.
Public transportation needs to be enhanced, especially for towns. This can be done by increasing the frequency, extending operating hours and improving the connectivity between various areas and modes of transport to encourage greater use of public transport. If public transport is not possible, improvements to parking, including the accessibility and cost of parking for all demographics, is vital. If this is not possible, implementing park and ride facilities on the outskirts of town centres should encourage people to use public transport and reduce the congestion. And ensure that local taxi services are available and affordable.
In addition, creating pedestrian zones and extending hours for both opening hours of businesses and public transport could facilitate better access to the high streets.
This should be funded through a combination of Central Government for large infrastructure projects and more local improvements via the Levelling up grant initiative.
We welcome any programmes designed to support high streets but there has been a mixed outcome in terms of tangible investment and subsequent transformation. It is not clear how the many funding initiatives announced in recent years work together. We believe that these should be better coordinated and, perhaps, even consolidated into a single programme.
It is not helped that many local authorities simply don’t have the resource to pull together funding bids, as these are complex. The application process should be reviewed to simplify it and provide greater transparency on how decisions are made. And there needs to be a robust review process to identify what works and what doesn’t, which should help to inform future decisions and shape the process.
The long-term success of the high street requires the continuation of financial support from local authorities and the government in order to halt the obvious decline in the majority of less well-off local authorities. Significant capital allocation is required to fast track the trajectory of transforming the high streets in key areas before it is financially unviable to do so.
22 March 2024