Retail & Role of Centres Supporting Paper

Retail and the Role of Centres

LEEDS LOCAL PLAN (2024 to 2042)

Retail and Centres Supporting Papers

Regulation 18 Consultation

June 2025

Supporting Paper: 

Paper A – Retail and Centres

Paper B – Commercial Market Analysis (Evidence Paper)

Paper C – Hot Food Takeaways

Paper D – Land-Based Gambling

Paper E – Place-Making: Drive-Thru’s

Paper A – Retail and Centres Supporting Paper

Why is it needed? 

The purpose of this paper is to set out the context for a review of existing local Plan policy in relation to policy on retail and the role of centres (to include Leeds City Centre, town centres and local centres). There has been unprecedented change over recent years for retail and centres and this has meant that there is a need to update policies to make sure that they are fit for purpose and relevant to the diverse needs across the Leeds district. There have also been changes in retail habits, in part shaped by the pandemic but also changes in national policy which recognises that our centres have and will continue to evolve. An overview of what that policy review will undertake is provided. As part of this review of policies which relate to centres and retail, all policies will be reviewed to ensure that they are up to date.  In addition, an update to Leeds City Centre boundary which is more strategic and requires more detail is set out.

This Paper and Paper B ‘Leeds Commercial Market Analysis Paper (Evidence Paper) are complementary and set out the basis of policy review.  Policy Paper B provides a commercial market analysis evidence base. 

What are these policies seeking to achieve?

Policies for retail and centres are now out of date and there is a need to update them in line with national guidance, this will include a consolidation of policies which are needed, those that are no longer required, those that are duplicating national policy or are now simply out of date and will be deleted. This will allow a simplified policy approach to be set out. 

Leeds Local Plan seeks to review all existing policies within the Local Plan to ensure these are still working as intended, are relevant and fit for purpose, and to identify any policy gaps that may have arisen since the Local Plan documents were prepared and adopted. This will result in updates to existing policy wording, as well as the deletion and replacement of some existing policies. The main driver for this is national planning policy as set out below, as well as national changes to how we now shop.

National Planning Policy Framework and Guidance 

The National Planning Policy Framework (NPPF) was first published in 2012, and sets out the national planning policies for England across a number of planning topics and provides guidance on how these are to be applied. The NPPF has undergone several revisions since first publication, with the latest revision at the time of writing having been published on 12^th December 2024. 

The NPPF sets out that the purpose of the planning system is to contribute to the achievement of sustainable development, including the provision of homes, commercial development, and supporting infrastructure in a sustainable manner, based upon three overarching and interdependent objectives: economic, social and environmental. Sustainable development at its highest level is defined as ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’. This presumption of sustainable development applies to all plans and decisions. 

Chapter 3 of the NPPF sets out guidance for local authorities in preparing local plans and what these plans and strategic policies should do, including: setting out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, employment, retail, leisure and other commercial development as well as infrastructure, community facilities and conservation and enhancement of the natural, built and historic environment. Strategic policies should usually look ahead over a minimum 15-year period from adoption, except in relation to town centre development. This needs to be underpinned by relevant and up-to-date evidence, being adequate and proportionate, focused tightly on supporting and justifying the relevant policies and take into account relevant market signals. 

Chapter 7 of the NPPF sets out guidance for retail and other main town centre uses, with planning policies needing to define a network and hierarchy of town centres and promote their vitality and viability, define the extent of town centres and primary shopping areas and make clear the permitted uses within these, retain and enhance existing markets and create new ones where appropriate, allocate suitable sites in town centres to meet the scale and type of development for retail, leisure, office and other main town centre uses looking at least ten years ahead (and where suitable sites are not available allocate appropriate and well-connected edge of centre sites), and recognise the importance of appropriate residential development in centres. 

This also sets out the need and requirements for sequential tests and impact assessments to proposals for main town centre uses which are not within a centre or contrary to an up-to-date plan, directing main town centres uses primarily to centres and only to out-of-centre locations in exceptional circumstances. 

Planning Practice Guidance (‘NPPG’)

The National Planning Practice Guidance (PPG) seeks to provide additional context and further guidance on how policies contained within the NPPF are to be interpreted and used, with the intention that both documents shall be read concurrently with both holding material weight in plan-making. The PPG covers an extensive list of topics and categories. 

‘Plan-making’ PPG (October 2021) sets out the statutory duty and role of development plans and how these should be prepared, presented and reviewed. The guidance document also sets out how to gather evidence to plan for business to understand local business requirements in order to assess the need for land or floorspace and economic development, including the quantitative and qualitative needs for all types of economic activity over the plan period, including retail and leisure development and the role, capacity and function of town centres and the relationship between them (including trends in performance of centres). 

‘Town centres and retail’ PPG (September 2020) sets out guidance on planning for retail and other town centre uses. Structural changes in the economy would need to be considered (particularly shopping and leisure patterns) and the impacts these may have on individual centres. Authorities are expected to define primary shopping areas within a plan, and where appropriate, primary and secondary frontages where their use can be justified. Other tools outside of the plan-making process include Local Development Orders. Future main town centre development needs outside of a centre would need to have regard to sequential and impact tests. 

The PPG recognises a wide range of complementary uses that can support centres if suitably located, including residential, employment, office, commercial, leisure, healthcare and educational development, as well as ‘pop ups’. Evening and night time activities are also identified as having the potential to increase economic activity within centres and provide employment opportunities, allowing towns to diversify and develop unique brands and offers beyond just retail, although considerations on crime, noise and security would need to be made.  These indicators have been used to assess local centre health.

Any strategy for town centres should be based on current evidence of the current state of centres and the opportunities that exist to accommodate a range of suitable development. These strategies can be used to establish the realistic role and function over the plan period, although focused on a limited period (e.g. next five years) given the uncertainty in forecasting long-term retail trends and thus should be regularly reviewed. Strategies should also set a vision for centres, establish their ability to accommodate main town centre uses (and need for expansion or consolidation), ensure land is used effectively, improve accessibility and overall quality, utilise complementary strategies and work with different stakeholders, and address environmental issues. 

In assessing the health of town centres and planning their future, the PPG identifies the following indicators: diversity of uses, proportion of vacant street level property, commercial yields on non-domestic property, customers’ experience and behaviour, retailer representation and intentions to change representation, commercial rents, pedestrian flows, accessibility (transport accessibility and accessibility, perception of safety and occurrence of crime, state of town centre environmental quality, balance between independent and multiple stores, evidence of barriers to new businesses opening and existing businesses expanding, and extent to which there is an evening and night time economy offer. 

The PPG also sets out guidance in relation to permitted development rights and the Use Classes Order, primarily changes of use within the same use class, some further changes subject to prior approval and temporary changes of use of up to three continuous years for some other uses to support start-ups and avoid vacancies. Further guidance is also given on how and when the sequential approach and impact test should be used and implemented.

Use Classes Order

The Town and Country Planning (Use Classes) (England) Order categorises various land and property uses into different classes, allowing change of uses within the same use class and between some different use classes without the need of planning permission. This has been amended several times since being first legislated in 1987, with extensive amendments most recently having been made in 2020. 

The Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 came into effect 1st September 2020 and has significant impact upon retail and town centre uses and policies within the Local Plan. The new Use Classes Order amended and revoked numerous use classes, with the broad changes including: 

Introduction of new Class E (commercial, business and service uses) and replacement with former Use Classes:

Introduction of new Class F1 (learning and non-residential institutions) and F2 (local community) and replacement with some former Use Classes;

Changes in shopping habits

A key driver for the review of policies is that the national landscape around retail has changed. The way we shop has changed hugely over the last 10 years. The retail landscape in the UK has undergone significant changes with online shopping being a much bigger player. More people are shopping online due to better internet access and more smartphone use. As a result, town centres have also seen significant change in the way they operate. The pandemic further brought changes to the accelerating trends around digital transformation and remote working. The long-term implications could transform how and where we live and work and use our centres. The landscape will continue to change and evolve for some time.

Existing Planning Policy  Context 

Adopted Local Plan

The statutory development plan in Leeds is made up of several plans, setting out the Council’s vision and strategy for the district up until 2033. The documents which make up the current Local Plan are, and those policies relevant to the scope of this paper are set out below. All these policies will be the subject of review to ensure that they reflect the national policy context and given unprecedented change over recent years for retail and centres relevant to the diverse needs across the Leeds district.  

Local Plan Review (2024) 

Local Authorities are required by the Town and Country Planning Act (England) Regulations 2012 to review the policies that make up the Local Plan, every five years. This considers whether policies are up-to-date and need to be updated. This was last undertaken in 2020, reviewing 185 saved policies within the UDPR (2006), Core Strategy (2014) which were not part of the selective review, and the NRWLP (2013). Following this, it was apparent there was a need in reviewing and updating numerous policies within the adopted Local Plan to ensure that these remain relevant, effective and up-to-date being justified by the latest available evidence and data, reflect current local need and priorities, and conforms with national planning policy and legislation, as set out within the NPPF (para. 33).  

Review of existing local retail and centres policy

A review of the identified policies above is considered necessary in order to identify any areas where retail and centre policies may no longer be up-to-date, relevant or are not consistent with national policy. Leeds has adopted a centres first approach to main town centre uses. And this approach will be kept in line with guidance set at a national policy level. 

The Core Strategy establishes the broad principles for development within City Centre and Town and Local Centres (which are identified in Policy P1), with the Site Allocations Plan providing further detail, where required, on the specific interpretation of centre boundaries. A review of local planning policy will seek to update the sequential and impact assessment the sequential test is used to guide commercial developments to a suitable location within a centres first approach. Consideration will be given to setting a local threshold and catchment as part of the review of policies, having clearly defined catchments for sequential and impact tests based on the use, size and location of a proposal. 

A review of shopping frontages will also be considered. Policies RTC2 and 3 of the Site Allocations Plan set out policy for primary and secondary shopping frontages and these refer to percentage requirements for the minimum amount of A1 (retail) uses within a frontage. These policies are now out of date as the A1 use class no longer exists. The National Planning Policy Framework (NPPF) deletes reference to primary and secondary shopping frontages but Planning Practise Guidance allows these in justified circumstances giving scope to retain if needed. Consideration will be given to frontage boundaries to ensure that they are up to date. We will retain the primary shopping areas for town centres in line with the NPPF.  

The introduction of the Class E (Commercial, business and service) came into effect from the 1 September 2020. The new Use Class E allows flexibility to move from some 'main town centre uses', e.g. retail, food and drink, offices, but also includes other uses which are not defined as "main town centre uses", e.g. medical services and some industrial uses without the need for planning permission. A review of policies which deletes references to old use classes and provides an update in relation to use class E will be set out. The implications of this are that the Council's planning policies predate use class E and as such are potentially out of date and would benefit from clarity in terms of the application of use class E. Policy will need to reflect commercial uses beyond retail uses to be in line with the updated use class E. 

The National Planning Policy Framework (para 90) requires that local authorities consider and define a network and hierarchy of town centres and promote their long-term  vitality and viability by allowing them to grow and diversify in a way that can respond to rapid changes in the retail and leisure industries, allow a   suitable mix  of uses (including housing) and reflects their distinctive characters. We will clarify the role and function of different centres, set expectations for what types of development will be supported, and define what makes a location a ‘centre’. We will review the boundaries of our centres to ensure that they are up to date to include the establishment of any new centres, over the next plan period. 

Retail and leisure need (Commercial need) 

Issues related to retail and leisure need are set out in Paper B – Leeds Commercial Market Analysis Paper evidence Paper. 

As part of the review of policies, consideration will be given to any future retail and leisure need to ensure we continue to have enough land and buildings and set the right approach in supporting a vibrant and resilient retail and leisure market in Leeds, particularly ensuring for the vitality of the City Centre and Town and Local Centres, delivered through allocating mixed-use sites across the District, encouraging suitable active ground floor uses in new development, and supporting the new City Centre boundary and identified opportunity growth corridors, in order to provide a range of shopping and leisure opportunities, promote health and well-being, create local jobs, and stimulate a more diverse local economy.

Centre Health Checks

A Town Centres health check was undertaken in 2022/23 assessing all 61 town and local centres within Leeds. This examined each Town and Local Centre within the District with a site visit and assessing the overall centre and a unit-by-unit analysis using various criteria (as set out in national guidance). The aim of this work was to provide an evidence base for any future planning policy formulation for all local centres enabling a better understanding of local centre health and long term to understand trends given the national changes to retail and centres. 

 As part of this an analysis of overall health of a centre was carried out. This examined a number of criteria these included environmental quality (to include maintenance and public realm), accessibility (to include public and private transport), landmarks and anchors, vacancy and provided a rating for each centre. The survey work has carried out in house and provides an evidence base for planning policy on a consistent basis, which can then be built upon in future years to monitor trends. 

The health check reported that Local centres in Leeds are generally performing well and playing an active function for the local communities they serve, there is however variation between centres. Centres were rated overall from 1 to 5 based on the overall impression of the centre and how well it serves its local community and within the context of environmental quality and accessibility, 5 provided the best rating, 3 being in the middle and 1 being the worst. In terms of rating 3 centres were rated 5, these included Headingley, Chapel Allerton and Wetherby, 30 centres were rated also performed well, and 22 centres were rated 3 as being in the middle. 

This provides a positive result indicating that our town and local centres are playing an important role and when looked at holistically in terms of an overview of the centre to include environmental quality and accessibility and other criteria. None of the centres were rated at 1 and only 6 were rated as 2 (Beeston Hill, Armley, Holbeck, Lincoln Green, Lower Wortley and Stanningley Bottom).  What is clear from the evidence base is that what makes a successful local centre is very varied, each centre has its own character and own challenges. The national picture for the high street is that online shopping and the pandemic have directly affected the way we shop, and that trends such as working from home provide more locally based residents. There is a great diversity across Leeds, and this often has a correlation with the local environment and population. What provides a successful centre in one location may be very different in another area based on its local population and needs. Different centres perform different functions, and the role they play is relative to each other.  Centres such as Lincoln Green which are not performing as well have a range of factors which affect this such as environmental quality, and a changing population that has changed over several years. 

There are many differences between local centres in Leeds and in many ways, they are much more diverse places compared to the city centre. Some centres have relatively affluent catchments, others are in areas with high levels of deprivation. Some local centres have traditionally had important comparison as well as convenience retail, others have good urban design and accessibility. National and local planning policy can only influence and guide planning matters which require planning consent and not others such as online shopping and vacancies within centres.

Place matters as such local centres and the city centre have a major role in supporting the Leeds economy, in enabling people to access services, and as focal points to the city and its communities. In terms of retail, significant uncertainty still surrounds the commercial market in Leeds. This is highly susceptible to economic and policy impacts which cannot be impacted nor avoided within the Local Plan. Leeds is not immune from national retail failures, nor can consumer habits and spending patterns be accurately predicted to inform policy direction. The Local Plan shall therefore need to offer a flexible and pragmatic approach in responding to any challenges. The Planning system can also only control planning matters, an increase in online shopping and patterns means that whilst centres and their hierarchy can be strengthened, changes such as vacancy cannot be prevented by planning policy. 

Leeds City Centre boundary

As part of this review of policies the current Leeds City Centre boundary will be updated. Leeds City Centre is the largest centre for shopping and leisure in Leeds and serves a wider catchment area as a regional centre. The current City Centre boundary was set out in 2001 and therefore is now more than 20 years old. It has been a useful tool for guiding and facilitating growth in Leeds and contributed to the success of Leeds economically and culturally. 

The city centre boundary, as set out in the Local Plan, impacts planning decisions. This is because several planning policies are different inside the boundary compared to outside it. A larger city centre would allow better control of development, provide a tool for simplification and appropriate differentiation between the city centre and other areas. 

The proposal is to update the Leeds City Centre boundary looking to the end of the plan period of 2042. In doing this work to explore where the new City Centre boundary should be, options around this include whether it should remain in the same place, shrink or expand.

A hierarchy of Centres is established, with the City Centre performing a regional role, and locations of town and higher and lower order centres are identified to serve local community needs. One of the objectives of the Core Strategy is for the City Centre to remain a ‘successful regional facility’. As the centre of the City Region and District’s public transport network, the City Centre is a sustainable employment, shopping, leisure and cultural location, which can promote development that is less reliant on people travelling by car. It is a popular centre and forms a vital part of Yorkshire’s identity. 

City Centre context

An analysis of planning applications since 2019 (excluding refused, and tree and advertisement applications) shows 3668 planning applications within the boundary, and 3781 planning applications overlapping with the boundary. Several regeneration projects aim to improve access to the city centre from surrounding neighbourhoods, which could be further strengthened by an enlarged city centre boundary. 

Leeds City Centre is at the top of the Centres Hierarchy in the Leeds Local Plan. It is the principal destination for shopping and leisure in the city. Leeds City Centre has been transformed since the boundary was last updated in planning policy in 2001. Some of the transformation which has taken place since the boundary was last updated includes major retail and leisure schemes such as Trinity Leeds, Victoria Leeds, and the first direct Arena. Also, major office schemes such as Wellington Place and Sovereign Square have played an important role in aiding economic resilience supporting Leeds. 

The universities, colleges and schools have invested in a wide range of high-quality new facilities. Connectivity has been improved by new bus corridor improvements, new cycle routes, and the Leeds Station Southern Entrance. Investment has taken place in ‘Gateway’ schemes, improving public realm, planting trees, creating cycle routes, and improving bus waiting facilities. Inward investment into Leeds City Centre has accelerated rapidly in recent years. South Bank, one of Europe’s largest regeneration developments has transformed this area of the city centre bringing in 1000 businesses, 4000 homes and a new city park to the city centre, this has had the effect of bringing communities back into the centre. 

The cultural offer has improved through recent capital investments, with future ones planned such as British Library North and the National Poetry Centre. Independent retail and a food and drink scene has developed. City centre residential development has particularly increased at the edges of the City Centre, with some high-quality schemes on site. The quality of place has improved significantly with new public realm and greenspaces, and with more planned including City Square/Leeds Station, and Aire Park to the South of the City Centre. The District Heating scheme and Leeds Flood Alleviation Scheme are enabling the city centre to respond to the challenges of climate change. 

The overall population density of the city centre is lower than several inner-city areas such as Harehills and Holbeck, and some suburban areas such as Chapel Allerton and Bramley. There are higher density areas of the city centre towards the North and West, as well as along the river, where there are new areas of residential development. The demographics are typical of city centre residents, with a median age of 23 (likely due to the large proportion of students – 55%, for comparison the median age in Little Woodhouse is 21 with a 73% student population) and 89% having never married or registered a civil partnership. 99% of City Centre residents live in a flat. 50% worked from home as of 2021 (compared with less than 20% in Inner-City East Leeds), indicating a higher proportion of people who live in the City Centre working in ‘office’ jobs. Of those that travel to a workplace, City Centre residents travel further than other Leeds residents.

Leeds Inclusive Growth Strategy 2023- 2030 

One of the aims of the Strategy is to maximise the potential of the City centre and local high streets.

Support our local centres and high streets to respond to changes in the economy and diversify, as well as being attractive, community centres to meet, shop, work and access services 

• 80% of households in the city are in ‘good’ or ‘walkable’ locations to existing services 

• 61 local centres and high streets across Leeds which serve as important hubs for local communities 

• 1.4 million square metres of retail space in 2022 equivalent to 196 football pitches 

• 70% units in local centres are independent businesses 

• 95% of retail units occupied in 2022 

• 93% of firms are adopting hybrid working models, with only 5% of businesses working entirely from an office

Each of the local centres and high streets possess a unique offer of retail, services and facilities, with many providing vital and easy access to fresh food and provisions. They are hubs for independent businesses and often provide much valued spaces where people can socialise, connect and celebrate local identity through events and festivals. As more businesses adopt more hybrid working models there are opportunities for local high streets. Leeds has a strong flexible workspace market, with demand remaining stable and outperforming many comparable cities across the UK. Growth of the City Centre has shown benefits into surrounding communities. The city centre will continue to be a key focus for investment, development and the delivery of new infrastructure. It is the most sustainable location for new jobs and homes. The Inclusive Growth strategy recognises that  the  success of the last 10 years and the compact nature of the city centre means that if we are to continue this momentum we need to consider how to grow beyond this footprint and deliver regeneration that will connect with and directly benefit the people living in surrounding neighbourhoods. 

What is the relationship between the City Centre boundary and Leeds Transformational Regeneration (LTR)?

On the 6^th of March 2024 the Government published ‘A vision for Leeds: a decade of city centre growth and wider prosperity’. This document, published jointly with Leeds City Council and the West Yorkshire Combined Authority, outlines proposals for a decade of growth and prosperity in Leeds, including:

• A new Leeds Transformational Regeneration Partnership, bringing together national, regional and local government to deliver the Leeds vision and unlock the delivery of up to 20,000 new homes.
• Plans for transformational regeneration across 6 key city centre neighbourhoods; Mabgate, Eastside & Hunslet Riverside, South Bank, Holbeck, West End Riverside and the Innovation Arc. 
• How investment in transport infrastructure will revolutionise connectivity in Leeds and across West Yorkshire.
• The importance of cultural anchor institutions for regeneration and growth in Leeds, including the British Library North and National Poetry Centre

Proposed boundary

A methodology was applied in assessing a new boundary for the city centre for the purposes of public consultation as below, this allowed a comprehensive approach to the identification of where a new boundary should be set.

The City Centre boundary (UDP Policy CC2) is recommended to be considered as part of a Local Plan Update.  There is a need to update the Leeds City Centre boundary to better align with future growth and development. This is important because the city centre has been a key driver of growth in various sectors, including residential, retail, and leisure and plays a major role not only in the identity of Leeds, but also regionally. The existing boundary has facilitated positive growth and helped to retain the role that Leeds plays regionally. A new boundary should create a visionary and fit for the future Leeds City Centre. The proposed areas of expansion provide areas of different character which all play different roles in creating a vibrant and varied Leeds City Centre. 

An expanded city centre is proposed. The City Centre has been a key focus for development over the last few years, reflecting the fact that it is a highly sustainable location for growth with a wide variety of existing shops, services and employment opportunities. Due to the dynamic nature of the City Centre, a large proportion of the development that has taken place has been on ‘windfall’ sites (sites that were not allocated in the existing Leeds Local Plan). There is significant opportunity for further development (on brownfield land) to take place within and on the edges of the City Centre over the plan period, which will be further enhanced by the investment proposed through the ‘Leeds Transformational Regeneration Partnership’.

For the purposes of public consultation, views will be sought on whether the existing city centre boundary should be retained, reduced or expanded.

How are we going to measure the impact of the policy?

Monitoring indicators (set out in national planning policy), in particular in relation to centre health, will include updating the local centre health checks selectively to provide an evidence base for planning policy on a consistent basis to allow the establishment of trends. This includes indicators identified by national planning policy as set out in Planning Policy Guidance. These indicators include diversity of uses, proportion of vacant street level property, commercial rents, accessibility, perception of safety, state of town centre environmental quality, balance between independent and multiple stores and extent to which there is an evening and night time economy offer. 

In addition, monitoring as part of the Authority Monitoring Report (AMR) new and existing retail, leisure and office developments in the city centre will be used to assess if the policy is supporting the vitality of the city centre. Also monitoring for any increases in investment, both public and private, in the city centre will be used, with a particular focus on the new city centre.

The success of this policy approach can also be measured by monitoring planning application activity for main town centre uses or large-scale residential development within any new city centre boundary, which would indicate whether the land use is consistent with a city centre location. Monitoring demographic information for the city centre will indicate whether an expanded city centre has enabled more families and other groups to live in the city centre.

Equality, diversity, cohesion and integration

Equality has been an integral consideration as part of any policy formulation from an early stage. Changes to up to date planning policy on retail, retail need, local centres and city centre boundary aim to improve accessibility for all to services and opportunities for all. An updated City Centre boundary fit for the future will aim to improve access to the city centre from neighbouring areas, many being highly deprived.  This would have a positive impact on integration between higher income city centre communities and lower income inner city communities. There could be greater engagement with opportunities in the city centre and local centres among low-income residents who may find it hard to afford modes of transport other than walking. Connectivity improves safety and perceptions of safety, including women’s safety as it reduces a reliance on private transport. Safety and perceptions of safety impact vulnerable people – Younger, Disabled, and Older people - to a greater extent. More space for cultural facilities would broaden access to culture and therefore increase representation in the arts.  

Paper B – Leeds Commercial Market Analysis Paper

(Evidence Paper)

INTRODUCTION

This paper has been prepared by Leeds City Council in order to assess the current retail and commercial market locally and nationally to provide necessary context as part of a review and extensive update to the Local Plan (Leeds Local Plan 2042; ‘LLP2042’). This will also help explore the current state of Leeds’ City Centre and town and local centres.

This builds upon a previous study (Leeds City Centre, Town and Local Centres Study, 2011) prepared for the Council by Colliers in 2011 which analysed Leeds’ centres and explored associated retail issues. This identified existing patterns of use and demand for retail and leisure uses, assessed quantitative and qualitative needs for 2016 and forward to 2026, carried out centre healthchecks, identified options to meet identified requirements within centres, and considered where new centres might be needed, being informed by market views and considerations. 

This formed part of the evidence base for the Leeds Local Development Framework (LDF), particularly for the adoption of the Core Strategy (2014) and the Core Strategy Selective Review (‘CSSR’, 2019), Aire Valley Leeds Area Action Plan (‘AVLAAP’, 2017) and the Site Allocations Plan (‘SAP’, as amended 2024).

It is acknowledged that significant changes have occurred to the retail and commercial market, the economy generally, and to the role of Leeds’ City Centre and town and local centres since this Study was prepared back in 2011. Thus, an update to this study is required to form part of the evidence base for the Council’s preparation for LLP. 

LLP seeks to review all existing policies within the Local Plan to ensure these are still working as intended, are relevant and fit for purpose, and to identify any policy gaps that may have arisen since the Local Plan documents were prepared and adopted. This will result in updates to existing policy wording, as well as the deletion and replacement of some existing policies.

This paper will firstly set out the current issues and opportunities within the current retail and commercial market in the U.K. and within Leeds, and explore how this is impacting Leeds City Centre and Leeds’ town and local centres. This will use all data and information available, as well as conduct healthchecks for all of Leeds’ local and town centres. 

The paper will be set out in the following manner:

• Section 2 will set out existing local, regional and national policy and guidance relevant to the scope of this paper, as well as summarise the local retail planning policy 
• Section 3 will set out the current state of the retail and commercial market across the country, providing the context on how the economy and external factors have impacted this through recent years.
• Section 4 does the same for the local retail and commercial market in Leeds and Yorkshire, highlighting changes in the market since this was last comprehensively studied in 2011. This will also set out the methodology and the headline results from the Town Centre Healthchecks which were conducted by the Council in 2022/23.
• Section 5 will summarise the key points and conclude potential policy directions for LLP, based upon the available evidence, and which would be subject to further public consultation

EXISTING PLANNING POLICY CONTEXT

National Planning Policy and Guidance

National Planning Policy Framework (‘NPPF’)

The National Planning Policy Framework (NPPF) was first published in 2012, and sets out the national planning policies for England across a number of planning topics and provides guidance on how these are to be applied. The NPPF has undergone several revisions since first publication, with the latest revision at the time of writing having been published on 12^th December 2024.

The NPPF sets out that the purpose of the planning system is to contribute to the achievement of sustainable development, including the provision of homes, commercial development, and supporting infrastructure in a sustainable manner, based upon three overarching and interdependent objectives: economic, social and environmental. Sustainable development at its highest level is defined as ‘meeting the needs of the present without compromising the ability of future generations to meet their own needs’. This presumption of sustainable development applies to all plans and decisions.

Chapter 3 of the NPPF sets out guidance for local authorities in preparing local plans and what these plans and strategic policies should do, including: setting out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for housing, employment, retail, leisure and other commercial development as well as infrastructure, community facilities and conservation and enhancement of the natural, built and historic environment. Strategic policies should usually look ahead over a minimum 15-year period from adoption, except in relation to town centre development. This needs to be underpinned by relevant and up-to-date evidence, being adequate and proportionate, focused tightly on supporting and justifying the relevant policies and take into account relevant market signals.

Chapter 7 of the NPPF sets out guidance for retail and other main town centre uses, with planning policies needing to define a network and hierarchy of town centres and promote their vitality and viability, define the extent of town centres and primary shopping areas and make clear the permitted uses within these, retain and enhance existing markets and create new ones where appropriate, allocate suitable sites in town centres to meet the scale and type of development for retail, leisure, office and other main town centre uses looking at least ten years ahead (and where suitable sites are not available allocate appropriate and well-connected edge of centre sites), and recognise the importance of appropriate residential development in centres.

This also sets out the need and requirements for sequential tests and impact assessments to proposals for main town centre uses which are not within a centre or contrary to an up-to-date plan, directing main town centres uses primarily to centres and only to out-of-centre locations in exceptional circumstances.

National Planning Practice Guidance (‘PPG’)

The national Planning Practice Guidance (PPG) seeks to provide additional context and further guidance on how policies contained within the NPPF are to be interpreted and used, with the intention that both documents shall be read concurrently with both holding material weight in plan-making. The PPG covers an extensive list of topics and categories.

‘Plan-making’ PPG (October 2021) sets out the statutory duty and role of development plans and how these should be prepared, presented and reviewed. The guidance document also sets out how to gather evidence to plan for business to understand local business requirements in order to assess the need for land or floorspace and economic development, including the quantitative and qualitative needs for all types of economic activity over the plan period, including retail and leisure development and the role, capacity and function of town centres and the relationship between them (including trends in performance of centres).

‘Town centres and retail’ PPG (September 2020) sets out guidance on planning for retail and other town centre uses. Local planning authorities can support town centres by taking a leading role in promoting a positive vision, bringing together stakeholders and supporting sustainable economic and employment growth. Structural changes in the economy would need to be considered (particularly shopping and leisure patterns) and the impacts these may have on individual centres. Authorities can set out a vision or strategy for centres within development plans or SPDs, and are expected to define primary shopping areas within a plan, and where appropriate, primary and secondary frontages where their use can be justified. Other tools outside of the plan-making process include Local Development Orders, Neighbourhood Development Orders, identifying land on brownfield registers and use necessary compulsory purchase powers. Future main town centre development needs outside of a centre would need to have regard to sequential and impact tests.

The PPG recognises a wide range of complementary uses that can support centres if suitably located, including residential, employment, office, commercial, leisure, healthcare and educational development, as well as ‘pop ups’. Evening and night time activities are also identified as having the potential to increase economic activity within centres and provide employment opportunities, allowing towns to diversify and develop unique brands and offers beyond just retail, although considerations on crime, noise and security would need to be made.  

Any strategy for town centres should be based on current evidence of the current state of centres and the opportunities that exist to accommodate a range of suitable development. These strategies can be used to establish the realistic role and function over the plan period, although focused on a limited period (e.g. next five years) given the uncertainty in forecasting long-term retail trends, and thus should be regularly reviewed. Strategies should also set a vision for centres, establish their ability to accommodate main town centre uses (and need for expansion or consolidation), ensure land is used effectively, improve accessibility and overall quality, utilise complementary strategies and work with different stakeholders, and address environmental issues.

In assessing the health of town centres and planning their future, the PPG identifies the following indicators: diversity of uses, proportion of vacant street level property, commercial yields on non-domestic property, customers’ experience and behaviour, retailer representation and intentions to change representation, commercial rents, pedestrian flows, accessibility (transport accessibility and accessibility for people with different impairments, health conditions or mobility requirements), perception of safety and occurrence of crime, state of town centre environmental quality, balance between independent and multiple stores, evidence of barriers to new businesses opening and existing businesses expanding, and extent to which there is an evening and night time economy offer.

The PPG also sets out guidance in relation to permitted development rights and the Use Classes Order, primarily changes of use within the same use class, some further changes subject to prior approval and temporary changes of use of up to three continuous years for some other uses to support start-ups and avoid vacancies. Further guidance is also given on how and when the sequential approach and impact test should be used and implemented.

Use Classes Order

The Town and Country Planning (Use Classes) (England) Order categorises various land and property uses into different classes, allowing change of uses within the same use class and between some different use classes without the need of planning permission. This has been amended several times since being first legislated in 1987, with extensive amendments most recently having been made in 2020. 

The Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 came into effect 1^st September 2020, and has significant impact upon retail and town centre uses and policies within the Local Plan. The new Use Classes Order amended and revoked numerous use classes, with the broad changes including:

• Introduction of new Class E (commercial, business and service uses) and replacement of the following former Use Classes:

• Introduction of new Class F1 (learning and non-residential institutions) and F2 (local community) and replacement of the following former Use Classes:

• Expansion to uses defined within the ‘Sui generis’ use class, as follows:

Town and Country Planning (General Permitted Development) (England) Order 2015, as amended:

Part 3 of the Town and Country Planning (General Permitted Development) (England) Order 2015 sets out further changes of use which can occur either without the need of planning permission or subject to prior approval. This has been amended several times since being legislated in 2015, with extensive amendments to Part 3 most recently having been made in 2021.

The Town and Country Planning (General Permitted Development etc) (England) (Amendment) (No 2) Order 2021 came into effect 1^st August 2021. The new GPDO reflected changes to the Use Class Order, but also introduced a new Class MA to allow changes of use from Class E to C3 dwellinghouse (replacing former Classes M and O), with restrictions on certain properties or localities and conditions. Two of these were to demonstrate vacancy for over three months and is below 1,500sqm, although these were later removed on 5^th March 2024 through the Town and Country Planning (General Permitted Development) (England) (Amendment) Order 2024.

It is worth noting that Article 4 Directions can be made by a local authority to disapply particular national permitted development rights across a given area. The NPPF (para.53) states this should be limited to situations where this is necessary to avoid unacceptable adverse impacts (including the loss of the essential core of a primary shopping area, but would unlikely to extend to the whole of a town centre), and should be based on robust evidence and apply to the smallest geographical area possible.

Local Planning Policy

Adopted Local Plan:

The statutory development plan in Leeds is made up of several plans, setting out the Council’s vision and strategy for the district up until 2033. This consists of retail policies within the Site Allocations Plan (2019, as amended 2024), retail, centres and spatial strategy policies within the Core Strategy (2014), and extant policies on shopfront design within the UDP.

Emerging Local Plan:

Leeds City Council is currently undergoing a review and update to the Leeds Local Plan, having undergone two separate stages but is set to be merged as one process moving forward later in 2025:

• Local Plan Update (LPU): the first of this sought to respond to the Council’s declared climate emergency, updating and introducing new policies on carbon reduction, flood risk, green and blue infrastructure, place making and sustainable infrastructure. LPU has undergone pre-submission public consultation. 
• Leeds Local Plan 2042 (LLP2042): this consists of a more comprehensive review of the Local Plan of topic areas not covered by LPU, with the initial scoping topics covering the spatial strategy, housing, economic development, role of centres, minerals and waste, transport and connectivity, and other topics covering conservation, rural development, agricultural land and contaminated land. Public consultation on this scope, alongside a Call for Sites process, was conducted early 2023, with these comments having been analysed to further refine the scope of LLP2042, alongside gathering and preparing the evidence base to support any new policy direction, with further Regulation 18 (Issues and Options) consultation to be conducted mid-2025.

COMMERCIAL MARKET CONTEXT

There have been significant changes to the commercial market and the wider global and national economic climate since the last study was prepared for Leeds City Council in 2011. This section shall consider the global and national factors which have influenced the commercial market, nationally and locally.

Global and national factors

U.K. Economy

Over the last decade, the U.K. economy suffered significantly, with events such as Brexit, Covid-19, the war in Ukraine, rising inflation and an emerging cost-of-living crisis all impacting upon national economic growth and consumer spending.

UK gross domestic product (GDP), which is a measure of economic growth based on the value of goods and services produced in a given period, increased by 1.1% in 2024, up from 0.4% in 2023 and follows two years of consecutive falling growth which was likely a result of the ongoing energy and cost-of-living crisis. Covid-19 also had a recent and significant impact on GDP, with GDP growth falling down to -10.3% in 2020, the lowest level of annual growth for over 75 years. Recent growth in 2024 could indicate a recovery in the national economy, with estimated growth for Q1 2025 at 0.7%.

Rising inflation rates has been attributed as one of the main factors causing the ongoing cost-of-living crisis, being exacerbated by the war in Ukraine. Consumer price inflation (CPI), the rate at which prices of staple household goods and services rise or fall, reached a peak high in 2022 at 9.1%, remaining at 7.3% in 2023, similar to levels seen in the early 1990s, but has fallen considerably in the last year to 2.5%, reaching near pre-Covid levels, but remaining slightly higher than the 2% target rate set by the Bank of England. Most recently, estimated CPI for Q1 2025 grew slightly again to 2.8%.

Rising inflation rates from 2020 has resulted in the Bank of England increasing interest rates, reaching a recent peak of 5.25% in August 2023, significantly up from 0.1% in December 2021. This was the highest bank rates seen since the fallout from the 2008 financial crisis and subsequent recession. This sudden surge in bank rates have likely increased loan and mortgage payments for many households, impacting upon the level of disposable incomes. However, bank rates have gradually been falling in the last year, reaching 4.25% in May 2025.

When adjusted for inflation, the mean disposable income for UK households grew consistently between 1994 and 2008, reflecting a period of time when inflation rates were high, and has remained fairly stagnant since this time and hasn’t grown consistently with inflation, with recent falls in the last two years, with an average disposable income of £42,684 in March 2024.

Despite this, overall household spending in the UK has continued to increase, up by 7% from 2022 in 2023, up 20% from 2018, and up 44% longer term from 2013. Covid-19 resulted in a temporary decrease in household spending in 2020, repeating a similar trend following the 2008 financial crisis, albeit at a more significant rate in 2020. To note, this domestic expenditure includes rental costs and imputed rental costs for home-owners, which has increased by 37% since 2013 and may not necessarily reflect increased retail spending.

For convenience goods, which includes the provision and sale of everyday essential items, including food and drink, alcohol and tobacco, and newspapers, domestic expenditure continues to increase, up 8.5% in 2023 from 2022, up 20% from 2018, and up 33.5% from 2013. Unlike total domestic expenditure, convenience good spending increased in 2020, with the only year for this to decrease being in 2015.

For comparison goods, which includes the provision and sale of typically non-essential goods that are purchased on a less frequent basis, including clothing and footwear, furnishings and household equipment, recreation and culture, and miscellaneous goods and services (personal care appliances and jewellery and other personal effects), has also increased, up 4% in the last year, 15.5% from 2018 and up 43.5% from 2013. However, comparison good spending was impacted by Covid-19, with spending decreasing by 11% in 2020, similarly to that seen for overall domestic spending.

This increased domestic spending has resulted in increasing retail sales for all sectors (excluding automotive fuel), with levels in 2023 nearly doubling since 1994. However, after stagnant sales between 2008 and 2011, and subsequent year-on-year growth between 2011 and 2021, there has been recent considerable decreases in retail sales for both 2022 and 2023 with a decrease of 6.6% in sales from 2021.

Thus, despite retail and domestic spending increasing and largely recovering compared to pre-Covid levels, this does not necessarily indicate increasing purchases but rather increasing costs. In May 2022, retail spending was up 13% from February 2020, but in the same time frame retail volume sales increased only by 2.6%.

Chart 8 below uses CHAPS payment data which tracks credit and debit card transactions in around 100 UK major retailers, and categorises this by ‘delayable’ (clothing, purchases and household good purchases), ‘social’ (travel and eating out), ‘staple’ (food and drink, communication and utilities) and ‘work related’ (commuting) spending. This provides information on how inflation over recent years, as well as lockdown restrictions, have impacted real spending.

‘Delayable’, ‘work related’ and ‘social’ spending plummeted at the start of the pandemic although slowly increased during lockdown restrictions when benchmarked against the February 2020 level, and generally increased throughout 2021 and 2022 (when inflation increased). ‘Work related’ spending remains much higher in May 2022 than February 2020 levels (likely due to rising travel costs), with ‘social’ remaining similar, and ‘delayable’ having decreased at the end of 2021 and currently remaining below the baseline. ‘Staple’ spending has remained fairly constant and above the baseline.

The ONS (How our spending has changed since the end of coronavirus (COVID-19) restrictions) has also analysed spending by Revolut bank users, indexing this against January 2020 levels, and has generally seen:

• continuously increasing spending on fuel (as a result of fuel prices increases) and retail from March 2020
• continuously increasing spending on entertainment between July 2020 and June 2022, with a sharp recent decrease falling below pre-Covid levels
• relatively consistent spending on food and drink, with a gradual increase from January 2022 above January 2020 levels
• large decreases of spending on travel and accommodation and eating out during lockdown restrictions, with increases in spending when restrictions have eased and currently exceed pre-Covid levels

To illustrate the extent and impact of the emerging cost of living crisis, which is driving up the prices of essential and convenience goods, Local Data Company has monitored the average price increases across a range of product categories between 2021 and 2023. Across the twelve categories, this shows prices have increased an average of approximately 23% over the 15 months monitored, with the largest increases being for dairy (+36%), bakery (+32%), frozen (+30.5%) and grocery (+29%), driven by record-high inflation, with those being relatively sheltered from increases being just for beer, wine and spirits (+5.5%).

Rise in online shopping

Using the internet as a means of shopping was first created in the mid-90s, with the formation of ecommerce sites such as Amazon in 1994 and eBay in 1995. However, it wasn’t until the early 00s until this became popular with the rollout of faster and cheaper internet connectivity for the general public and the emergence of new secure payment methods made online shopping easier and more accessible.

In 2007, internet sales represented only 3.3% of all retail sales in the UK. By 2019, following consistent growth each year, this reached 19%. Covid-19 saw a surge in online shopping in 2020 and 2021 when physical stores were closed to the public, reaching a peak of 37.5% in February 2021. This proportion fell to 30% in April 2021 as restrictions first started to lift and physical stores started to open and the proportion of online sales have decreased slightly since, with 2022 seeing the first year of online decline (-5%) and with the proportion remaining the same in the last year, indicating slower online growth in recent years. Nevertheless, online sales remain much higher than pre-Covid levels and represent over a quarter of all sales.

The value of internet retail sales (based upon total business turnover; using 2019 as a baseline of 100), also grew consistently between 2008 and 2020, seeing a significant increase in 2020 and further increases in 2021, with recent decreases and stagnation, although still remaining relatively higher than pre-Covid levels. 

Where this money is spent online tends to be fairly split by sector, with the highest proportion being spent on household goods (17%) and the lowest spent in non-specialised stores (11%) in 2023. 

From 2022 to 2023, increases of 13% were seen each for clothing and household good stores, 7% for food and non-food (department) stores, with only a decrease seen in ‘other’ stores by 1%. Longer term from 2013, there has been an increase of 510% in online household good sales, 276% in non-store retailing, 267% in non-food stores, 259% in food stores, 248% in clothing stores, and the lowest of 193% for non-specialised stores.

Retail floorspace

After consistent growth in the stock in retail floorspace in the UK, growing retail sales over the last decade has resulted in a gradual decrease in retail floorspace between 2018 and 2020, and which has decreased at an even more considerable rate following Covid-19. 

Convenience retailing

Convenience good stores are those that sell everyday essential items, including food and drink, alcohol and tobacco, and newspapers, and can range from smaller convenience stores and newsagents to larger supermarkets. 

This retail sector has seen considerable change in the last twenty years; shifting away from the opening of new larger stores of the traditional ‘Big Four’ supermarkets which dominated in the 1990s and early 2000s to the concentration of new, smaller convenience stores (such as Tesco Express, Sainsbury’s Local) and the realignment of their existing larger stores by improving their retail offer (e.g. with concession stores opening up inside), the shift towards online grocery shopping and reliance on delivery services, and the rise of the discount retailers Lidl and Aldi since the financial crisis which resulted in the sudden emergence of new medium-sized, concentrated stores (either being stand-alone or delivered as the anchor for new car-focused, typically out-of-town retail parks, which in any instance tends to be located in close proximity to a larger ‘Big Four’ supermarket). 

This can be seen with Morrisons being replaced as the fourth largest supermarket by Aldi in 2022 and 2023 with a market share of 9.3%, with Lidl closely behind at sixth with a market share of 7.5%. This contrasts to 2012 where Aldi and Lidl both had a 2.5% market share each, being joint seventh, and with very little growth seen in this time in any other grocer (with the exception of online retailer Ocado which emerged in 2014). 

Whilst this growth in the discounter supermarket sector is likely to continue in the short-medium term and at a faster pace than other supermarkets, recent articles from The Grocer have reported that this growth is set to slow down in coming years, with increased focus on warehousing and distribution. However, there have been failures of some discounter stores, such as Tesco’s venture with the introduction of Jack’s stores in 2018 and all stores closing in 2022, but some success with others with the emergence of Iceland Warehouse. 

As for 2024, the UK was made up in more smaller, convenience stores (42%), with 14% consisting of the traditional supermarkets and 11% of the discounter stores. Leeds has a similar proportion of these stores, with a slightly greater proportion of convenience stores (43%) and traditional stores (16%) as well as wholesalers (1%) and ‘other’ stores (2%), with less of a proportion of symbol group stores (8%) and petrol forecourt stores (5%).

Another significant trend in the convenience goods sector is the emergence of online food shopping. At the start of 2015, 4% of supermarket spending was made online and slowly grew to just above 5% at the start of 2020, with specialist food shopping (including butchers and bakers) having a smaller share of roughly 2% within this time frame. Covid-19 and the introduction of national lockdown restrictions resulted in a surge of online food shopping, with the proportion of online supermarket spending reaching a peak of 12% in January 2021 and 14% for online specialist food shopping in May 2020, with both having seen significant decreases since April 2021. Online supermarket spending has seen a 1% decrease in the last year and 2% for specialist food stores, although with both remaining much higher than pre-Covid levels.

Comparison retailing

Comparison good stores are those that typically sell non-essential items for which the consumer is expected to visit a range of shops before making a choice, including clothing and footwear, furnishings and household equipment, recreation and culture, and miscellaneous goods and services, and as seen with convenience shopping, the comparison shopping sector has also changed significantly over the last twenty years.

Online shopping has made buying non-essential goods easier and more convenient, allowing comparisons to be quickly made between different online stores and websites, with better availability and a variety of convenient delivery and pick-up options, and being potentially cheaper for consumers with deals and promotions more prominent and accessible.

This was a trend that was seen emerging over the last decade, with the ONS reporting that the proportion of online sales for department (non-specialised) stores grew from just under 5% in 2008 to just over 18% in 2018, and for clothing stores growing from roughly 4% in 2008 to 17% in 2018, but has since been exacerbated by Covid-19 which saw the closure of non-essential retail stores over a series of national and local lockdowns across 2020 and 2021. 

Most retail sub-sectors follow a similar trend, although with the proportion of online spending increasing dramatically over the lockdown periods, and have remained higher than pre-Covid levels. The proportion of this online spending declined considerably between 2020 and 2022; sporting equipment and toys (-52%), electrical goods (-51%), books and stationary (-43%), furniture (-39%) and clothing (-22%), with only gardening and furniture sales increasing online in the last year.

National high street failures and vacancies

Looking at the high street stores more generally, Centre for Retail Research provides data on retail businesses that have failed (i.e. those that have entered administration) for each year since 2007, although this does not typically mean the business is no longer trading as some continue to do so or move to online. 

This shows a somewhat cyclical trend of increasing and decreasing number of retail businesses failing in the last 18 years, with fluctuations in every 3-5 years. 2023 saw the highest level of failures, reaching 61. Businesses that went into administration in 2024 include Homebase, Ted Baker, The Body Shop (although which was rescued at the end of 2024) Carpetright, Lloydspharmacy, amongst many other smaller traders.

However, despite this high number of failed businesses, this only translated into 971 stores closing (one of the lowest years) and 20,622 employees being affected in 2023. Looking at the number of stores affected each year, the impacts of the global recession in 2008-09, Covid-19 in 2020 and the emerging cost of living crisis in 2024 can be seen, highlighting the impact of these economic events on the national high street and subsequent impact on employment. For example, 2024 has seen over 7,500 U.K. stores and nearly 56,000 employees affected.

Some data is available for 2025, with January having seen 2 businesses failing affecting 124 stores and 1,533 employees.

Local Data Company has monitored national retail openings and closures between 2014 and 2023, with the number of units closing outpacing the number of new units opening for all years except for 2017. In the first half of 2023, 27,504 units were closed across Great Britain, with a net change of -4,000 units. The highest net loss of units was in 2020 followed by 2021 which saw a loss of 7,834 and 4,447 units respectively. However, despite these closures, the first halves of 2020 and 2023 saw the highest levels of openings indicating some opportunity in retail, with the Local Data Company highlighting that some occupiers are still growing their estates and identifying appealing leasing opportunities.

Local Data Company report that many of these closures over this time was from independent retail and leisure businesses, with Covid-19 associated support for businesses coming to an end in early 2022, with national chains being more resilient. Other identified impacts on the retail sector include increases to the National Minimum Wage, and rising supply and freight costs.

Breaking these retail closures down by the type of retail location, the high street saw some closures between 2019 and 2021, and with no net change in 2022 although with a further drop in 2023 driven by services and comparision retail. Retail parks have seen greater fluctuation, with considerable decreases during the pandemic, although to a lesser extent that has been seen for shopping centres, although was the only location type to have seen a net increase in those four years, likely a result of the rapid expansion of supermarket, leisure and food premises over high street locations. Shopping centre units have experienced the highest net loss, although this compares favourably to historic data, supported by rebased rents, redevelopment of department stores and an overall reduction in business failures, with the prime shopping centre market reporting strong leasing performance as occupiers focus on larger flagship stores in prime locations.

The Local Data Company also highlight national vacancy rates across all commercial properties, and broken down by retail and leisure vacancies, between 2013 and 2023. All experienced highest vacancy rates in the first half of 2021, likely a delayed impact from Covid-19, with retail having a vacancy rate of 15.8%, leisure of 11.3% and all commercial of 14.5% at this time, with lowest levels of vacancy experienced in 2016/17. 

The latest vacancy rate for retail stands at 15.3%, an increase of 3% points in the last 5 years although in the shorter term showing some signs of recovery with the vacancy rate decreasing and remaining stable across the last few periods. Leisure currently stands at 10.7% vacancy, having seen a slight increase in the last period, similarly to all commercial. Local Data Company identifies this increase in leisure being down to hospitality struggling with rising costs and restricted consumer spend, and retail proving more resilient due to cost-cutting during the pandemic and being more cautious with new openings and benefitted from a slowdown in growth in online retail.

Breaking this vacancy rate down also by retail location type, this shows that shopping centres experience a higher level of vacancy compared to the high street and retail park, with the latter experiencing the lowest levels of vacancy. Latest vacancy levels for the high street nationally was at 13.9% in 2023, similar to the overall commercial vacancy rate, with the shopping centre vacancy standing at 17.8% and retail parks more than half this at 8.1%. Despite the pandemic, high street vacancy has remained relatively stable since 2013 compared to the other location types which have seen greater fluctuation, which shows some sign of resilience although this also shows less of a recovery from the pandemic. Retail parks have seen the greatest level of recent recovery, with expansions of supermarket, lesiure and food premises.

Looking at long-term vacancy rates, properties vacant for more than three years on the high street hit a record high of 5.1% in 2023, suggesting an oversupply of units in the market. Three year vacancy for shopping centres is even greater at 6.9%, and for 3.2% for retail parks.

Comparing the vacancy rate for Yorkshire & Humber to that for Great Britain, the regional vacancy rate has been higher over the four years, although with the gap between these having narrowed recently indicating a stronger recovery regionally from Covid-19. In fact, the regional vacancy rate has returned to pre-Covid levels with nationally still remaining higher. Comparing this against the other eleven regions, Yorkshire has the sixth highest vacancy rate, although comparing similarly to Scotland, East Midlands and the North-West.

Emergence of leisure uses

In contrast to the recent contraction of retail floorspace in the UK, there has been consistent growth in the stock of ‘other’ floorspace, which the Valuations Office Agency defines as uses outside of office, industry and retail, such as assembly and leisure, education, health, hotels and accommodation, non-residential institutions, offices and retail within a specialist property, residential institutions, storage & distribution, transport, utilities and other (e.g. car parks, cemeteries, film and TV studios).

COMMERCIAL MARKET IN LEEDS

This section is to look at and analyse how the commercial market has changed in Leeds, where the commercial market currently is, and compare this against other regional and national markets (wherever possible).

Retail completions

Since 2012, the Council has monitored completions of new retail development over 500sqm, being recorded and presented within the Economic Land Availability (‘ELA’) dashboard. 

In this timeframe, there has been 104,000sqm of recorded completed retail floorspace, equating to an average of 8,000sqm retail floorspace each year. 2015/16, 2016/17 and 2018/19 saw the highest levels of retail completions, largely as a result of the Kirkstall Bridge Shopping Park in Kirkstall, John Lewis store in the City Centre, and The Springs retail park in Thorpe Park respectively, with very little development in recent years.

Breaking this retail down, the majority of this has been for the creation or expansion of out-of-town retail parks, including The Springs in Thorpe Park and Kirkstall Bridge Shopping Park. This represents 44% of all retail development in Leeds.

Fifteen completions have related to new supermarkets (31,400sqm), with 11 of these being for Aldi, 2 for Lidl and 2 for Asda. A further two completions (3,600sqm) relate to the rebuild or extension of existing supermarkets, one for Lidl and one for Sainsbury’s. This level of supermarket development represents 34% of all retail development monitored in Leeds.

Three completions (25,200sqm) have been recorded for the creation of new standalone retail stores, including John Lewis in the City Centre, new ground floor units as part of a mixed-use development at Thorpe Park, and a change of use in Pudsey.

28% of all retail completions 2012-24 was located within the City Centre, although with the two latest completions being in 2017/18 and 2019/20 for extensions to the Crown Point Retail Park on the edge of the City Centre. 36% of retail completions outside of the City Centre have been located within town or local centres, with the majority of this consisting of new supermarkets. Nevertheless, 69% (23,400sqm) of all supermarket development has been located out of centre.

Commercial, leisure and hospitality completions

In addition to retail completions, the Council also monitors other commercial, leisure and hospitality uses. This includes monitoring of retail, mixed commercial, food and beverage and leisure uses since 2012, and more recently, hotels, community and ‘other’ (typically sui generis uses) since 2021.

Since 2012, there has been a total of 295,000sqm of recorded completed retail, mixed commercial, food and beverage and leisure uses, equating to an average of 22,700sqm retail, commercial and hospitality floorspace each year. 2013/14 saw the completion of the First Direct Arena in the City Centre, as well as various leisure and food and beverage completions at Victoria Gate in the City Centre in 2016/17, White Rose Shopping Centre in 2017/18, and The Springs in Thorpe Park in 2018/19.

As for hotel completions, 28,500sqm has been recorded over four completions, although with consistent monitoring for this only having begun since 2021.

The amount of development which has been completed within Leeds’ Town and Local Centres across the current Plan Period has been low, with the exception of 2014-16 which saw high levels of retail completions, and with development after this being made up of low levels of leisure and food and beverage uses. A total of 37,600 sqm has been completed since 2012, making up just 13% of all of Leeds’ commercial development. This demonstrates low levels of activity reported within centres, although this would not pick up changes of use for existing premises which would likely make up the majority of development.

Commercial, leisure and hospitality pipeline (as of September 2024)

In terms of expected completions in forthcoming years, four sites are in the current supply for retail uses. Three of these have full planning permission for new Lidl stores at Horsforth (20/04077/FU) and Yeadon (22/06242/FU) and a proposed fashion store within a former church in Beeston (22/00158/FU), which have yet to start construction and which would create over 5,000sqm of new retail if and when completed. Up to 2,000sqm remains at outline stage for a new supermarket planned for the development coming forward at land to the east of Junction 45 of the M1 (15/07655/OT).

A further 21 sites are in the current supply for mixed commercial uses, equating to 50,900sqm of floorspace. 8,800sqm of this is under construction, 15,200sqm with full planning permission, 22,900sqm with outline permission and 3,900sqm remaining allocated.

Three leisure sites are also in the current supply with a combined leisure floorspace of 5,300sqm, with two having full planning permission equating to 3,900sqm if and when completed, and one completion at outline stage for 1,400sqm.

Seven hotel sites across 60,400sqm are also in the current supply, with two under construction for 8,300sqm, three with full planning permission for 11,200sqm and two at outline for 40,900sqm.

There are no sites for food and beverage in the current supply.

Commercial insights in Leeds

The ELA does not, and cannot capture, all commercial development in Leeds, as this only monitors development which requires planning permission with a threshold over 500sqm. This means a significant portion of commercial development which comes forward through Permitted Development is not captured. 

Using the data presented above, alongside anecdotal information, this sub-section aims to provide a summarised insight as to what has happened with the commercial market in Leeds and future pipeline plans to provide a more comprehensive picture.

The City Centre has seen changes since the Core Strategy was adopted. Further retail was planned as part of an expansion of Victoria Gate which was not implemented with this vacant City Centre site still remaining undeveloped, and demand for residential (particularly student accommodation) appears to be outcompeting with existing retail floorspace, with examples including retail being lost at The Core shopping centre and the former House of Fraser on Briggate being replaced by student accommodation.

In comparison, out of centre retail developments appear to be expanding much further with less constraints. This has been seen with expansion of the offering at White Rose Shopping Centre, the creation of The Springs at Thorp Park, as well as various new retail parks across the District, including St George’s Retail Park in Middleton which provided 65,000sqft of retail in 2024 and being fully let.

Health of town and local centres

A Town Centres Health Check was undertaken in 2022/23, which examined each Town and Local Centre within the District with a site visit and assessing the overall centre and a unit-by-unit analysis using various criteria, such as environmental quality (maintenance and public realm), accessibility (public and private transport), noted landmarks and anchors, reported vacancy (from a visual test), and an overall rating provided.

This Health Check reported that the Town and Local Centres are generally performing well and playing an active function for the local communities they serve, although there is variation between centres. Out of the scoring for overall ratings given for each centre, 3 centres (5%) were rated 5 (the highest score): Headingley, Chapel Allerton and Wetherby, with 30 centres rated 4 (50%) and 22 rated 3 (37%), providing a positive indication of how centres are performing with over 90% of centres scoring a relatively high score. There is no clear indication in what makes a centre score well, with the scoring varying between centres, indicating each centre has their own character and function.

No centres were scored a 1, at least indicating that every centre had at least one or two roles in functioning as a local centre.

City Centre footfall

To provide another indication on the current state of the City Centre, footfall data as measured along Briggate is available from 2018 onwards. This demonstrates a vibrant City Centre pre-Covid with nearly 14 million recorded visitors in 2018, which fell slightly in 2019, and significantly between 2020-22. However, footfall has picked up considerably in recent years, reaching nearly 13 million in 2024, with the City Centre seeing its busiest day in November 2024 with over 76,000 people walking along Briggate in one day.

Stock in retail floorspace

The Valuations Office Agency monitors and annually reports the stock of business floorspace for England and Wales, including the retail sector.

As of March 2023, the latest stock in retail floorspace in Leeds is 1,378,000sqm. This is down 0.6% from the previous year, down 2.2% from 2018, but up 5% from 2013 and up 3.5% from twenty years ago. 

Leeds has the second highest stock in retail floorspace out of all the English Core Cities, behind Birmingham which has a stock of 2,136,000sqm.

Changes in retail floorspace stock in Leeds compares similarly to recent losses seen across England, which has seen a decrease of 0.8% in the last year and a decrease of 2.0% in the last five years. Yorkshire & Humber has also seen decreases in the same time period, albeit of a lesser scale, seeing a 0.3% decrease in the last year and 1.6% in the last five years. Out of all the English Core Cities, only Birmingham has seen recent increases, with Leeds performing similarly to much better than other comparable cities.

Looking slightly longer term at the previous ten years, Leeds has performed considerably better when compared to the regional and national changes in retail floorspace, as well as against the English Core Cities. Leeds saw a 5% increase from 2013, with West Yorkshire seeing a 3% increase, Yorkshire & Humber 2.3% increase and England a 0.2% increase, with the Core Cities combined seeing a decrease of 0.4%. 

Retail employment forecasts

The West Yorkshire Regional Econometric Model (REM) was produced on behalf of the West Yorkshire Combined Authority by Experian in 2024, and which forecasts employment and economic scenarios for the Yorkshire & Humber region up to 2044. This uses Experian’s economic data for the Yorkshire & Humber region, including historical employment, GVA, productivity, population estimates and forecasts, and other labour market information.

This forecasts employment figures for detailed sectors, including that for retail. As of 2024, this shows that Leeds has a total 25,000 full-time equivalent employees in the retail sector. This has grown 2.8% in the last ten years, and 4.0% in the last five years. The REM forecasts that employment in the retail sector is to decrease by 1.2% in the next five years, and 2.0% in the next ten years. This contrasts to overall growth in total employment in Leeds by 2.1% in the next five years and 3.8% in the next ten years.

Similarly, the UK is set to see a decrease in retail employment of 1.3% in the next five years and 2.2% in the next ten years, with West Yorkshire seeing a drop of 1.6% in the next five years and 3.0% in the next ten years, and the wider Yorkshire & Humber region seeing a drop of 2.2% in the next five years and 3.8% in the next ten years.

Therefore, despite forecasting a net loss in employment in the retail sector over the next ten years, this compares better than the regional and national figures which all see higher losses than Leeds.

Retail Gross Value Added (GVA)

The West Yorkshire REM also forecasts changes to the Gross Value Added (GVA) for the retail sector. 

GVA measures the output of all goods and services less inputs of an industry and is identical to measuring GDP, except that it is instead measured in basic prices and do not include taxes and subsidies imposed by the Government and only includes the output and value added by that specific industry. 

As of 2024, the GVA for the Leeds retail sector was estimated to be £914 million. This has grown 1.0% in the last ten years and 27.4% in the last five years. The retail GVA is set to increase by a further 6.6% in the next five years and 12.8% in the next ten years.

The UK is set to see an increase in retail GVA of 5.5% in the next five years and 10.9% in the next ten years, with West Yorkshire seeing an increase of 5.7% in the next five years and 11.0% in the next ten years, and the Yorkshire & Humber region is to see a smaller 4.8% growth in the next five years and 9.4% in the next ten years.

CONCLUSION & NEXT STEPS

Using the data compiled above, this is to summarise how the commercial market has changed in Leeds and where the commercial market currently is, and then explore how this might look in the future to help forecast commercial needs in Leeds over the next Plan Period.

The commercial market has undoubtably seen significant change within the last decade, having experienced significant shocks from the economy, including the 2008 global recession, Brexit, Covid-19, and rising inflation, as well as changes to national planning policy including the introduction of Class E and associated changes to Permitted Development. 

This has had significant impacts on the way we shop (with a prolonged move to more online shopping for convenience and comparison goods as well as increased trips to out of centre retail developments), how much we spend (with a general trend with reduced spending on certain goods, coupled with costs of goods increasing with inflation), and what we spend this on (with an increase in discounter stores for food shopping). 

This has significantly impacted the role of the high street and our local centres, which now play a greater role beyond just retail and have adapted with flexible leisure and food uses, as demonstrated in the increased levels of reported completions for these uses compared to former A1 retail.

There are also some positive signs for the commercial market in Leeds, with the stock in retail floorspace having increased significantly over the last ten years (although noting recent losses as a likely result of Covid-19), and this comparing favourably when benchmarked against regionally, nationally and against the Core Cities which have seen greater losses in the last ten years. There has also been considerable growth in the stock of ‘other’ floorspace as measured by the Valuations Office Agency, which includes leisure, education and hospitality uses (amongst others). 

Footfall within the City Centre has increased year-on-year in the last three years nearly reaching pre-Covid levels, and with initial health checks of local centres reporting generally good performance.

The West Yorkshire Regional Econometric Model (REM) also forecasts 6.6% growth in the retail sector in the next five years and 12.8% in the next ten years, reaching over £1bn by 20235 in GVA. This growth compares favourably against the regional and national forecasted growth, seeing 9.4% and 10.9% growth respectively in the next ten years.

Significant uncertainty still however surrounds the commercial market in Leeds and is highly susceptible to economic and policy impacts which cannot be impacted nor avoided within the Local Plan, with Leeds not immune from the impacts of national retail failures, nor can consumer habits and spending patterns be accurately predicted to inform policy direction. The Local Plan shall therefore need to offer a flexible and pragmatic approach in responding to any challenges.

Subject to public consultation at the Regulation 18 (Issues & Options) stage, the Local Plan could seek to introduce a retail need figure, as done in the past, to help allocate new sites necessary for new retail development. Such need figure could be calculated by:

• using past take-up from past completions (which has been discounted as this does not pick up all retail development), 
• past trends established by retail floorspace stock from the Valuations Office Agency (which has been discounted as this does not precisely demonstrate the scale of new development coming forward), or 
• by using forecasts within the REM (which forecasts declines in employment but growth in GVA). 

However, establishing and setting a retail need figure has been discounted at this stage of the Plan preparation process due to the significant uncertainty within the commercial market, the strength shown in the retail market in Leeds particularly when compared to other regions and cities, changes to national policy which means retail uses require less planning permission and offers much more flexibility than just retail meaning this is hard to allocate specifically for and monitor, and the availability of retail opportunities currently present within the existing supply. 

There is an opportunity for the Plan to be more prescriptive in when and where commercial development should be provided, particularly within the City Centre and opportunity areas identified within the Local Plan (such as the proposed expanded City Centre and growth corridors) to provide active ground floor frontages as part of mixed-use developments to create vibrant, mixed-use neighbourhoods, as well as within large residential schemes across the District to complete, compact and connected places by ensuring for necessary local amenities. This may be considered sufficient in meeting the need for retail and commercial uses in Leeds in a more proactive way, rather than relying on specific allocations with great uncertainty on delivery, whilst still allowing for flexibility in the market.

Paper C – Hot Food Takeaways Supporting Paper

INTRODUCTION

This supporting paper seeks to provide evidence, supporting information and justification for the preferred Hot Food Takeaway (HFT) planning policy approach in Leeds Local Plan 2042 (LLP2042).   

This paper sets out existing national and local policy and guidance which supports the Council’s approach, whilst highlighting relevant evidence datasets linked to health and deprivation which proposed policies seek to address. 

WHY IS IT NEEDED?

Planning plays a vital role in providing safe and healthy places for all of society. Lack of access to healthy food, a proliferation of unhealthy food choices and the ever-evolving nature of food delivery takeaways can help create unsafe and unhealthy built environments for everybody. Nationally and locally, the negative impacts of child and adult obesity have only become worse and planning for healthy food environments can form part of a holistic approach to combatting that. It has long been acknowledged that the quality of the built environment can have significant impact on people’s health and wellbeing. 

Planning can help positively influence people’s local food and built environment by restricting uses that can be seen to be harmful in certain locations and concentrations. A hot food takeaway is a place where hot food is sold for consumption off the premises. HFTs (planning use Sui Generis) are often seen as an example of such uses that can cause harm, due to the unhealthy food they often serve and the negative impacts on local amenity due to pollution (noise/smell/littering) and highways (pedestrian and vehicles). The Council currently has and adopted HFT Supplementary Planning Document (SPD) that contains supplementary planning guidance on HFTs. The SPD has had some success in controlling the locations of HFTs in Leeds since its adoption in 2019. However, since adoption of the SPD, both national guidance and policy has been updated which allows Local Authorities to adopt stricter planning controls on HFTs where justified. The new Leeds Local Plan is therefore seen as the appropriate planning mechanism to explore and introduce new planning controls on HFTs. 

POLICY OPTIONS

The Council’s current preferred approach is to build upon the existing HFT SPD guidance, which currently focusses on the clustering in centres, controls around secondary schools and impact on local amenity of HFTs. This can be done through using local health indices (number of HFTs/obesity rates) to assist in decision making. Emerging policy can strengthen existing controls whilst addressing new issues relating to highways, delivery and dark kitchens. This is in line with the new National Planning Policy Framework (NPPF) and planning guidance and it is important that any new HFT policy clarifies upon some of the definitions within NPPF paragraph 97 (such as concentration, walking distance etc). This will ensure that HFT planning applications can be dealt with consistently and efficiently without the need for debate over those definitions. 

The policy could also consider:

• Also include a food desert policy, which considers the healthy food options in a location where a HFT is proposed. 
• Also include a dark kitchen specific policy. 

The alternative policy approach is to not have a specific local policy and rely upon NPPF paragraph 97 and existing SPD guidance. However, the SPD is arguably out of date and the NPPF without clarification over the definitions within it, would only lead to inefficient determination of HFT applications. 

WHAT IS IT SEEKING TO ACHIEVE?

Any proposed policy option is seeking to improve the health of Leeds’ residents by reducing obesity (children and adult) whilst improving Leeds healthy food environment. LLP2042 has 35 objectives, of which objectives 31 and 34 are relevant to HFTs:

IS IT JUSTIFIED BY THE EVIDENCE? 

HFTs have been identified to (directly and indirectly) create harm in the following ways:

• Increase in obesity levels (especially in areas of high deprivation)
• Widen health inequalities and contribute to poor health 
• Create noise and sound pollution
• Highways impacts from deliveries and collections
• Produce refuse and litter

Further background reading and information regarding the impact of HFT uses can be found within sections 5 and 6 of the HFT SPD[1].

National Planning Policy Guidance (NPPG) states that when local authorities seek to control uses such as HFTs, then “evidence and guidance produced by local public health colleagues and Health and Wellbeing Boards may be relevant.” The following evidence base is sourced from the Council’s health colleagues and reports:

LOCAL EVIDENCE: LEEDS HEALTH PROFILE

A key document that details the current and future health needs for Leeds is the Leeds Joint Strategic Assessment (JSA). The JSA 2024[2] assesses current and future health and social care needs in Leeds to inform the Health and Wellbeing Strategy, specifically to shape priorities, inform commissioners and guide the use of resources as part of commissioning strategies and plans for the city. The evidence within the document includes data on obesity (children and adults), diabetes and health inequality. The following datasets and analysis have been taken from the JSA to justify the proposed HFT policy approach:

CHILD OBESITY

The overall Leeds trend has been flat, with a prevalence rate of 9.4% in 2022/23, compared to 9.5% in 2013/14 amongst reception-aged children (age 4-5). By the time a child in Leeds has reached year 6 (age 10-11), the chances of living with obesity rise to 23.3%, exceeding pre-Covid levels of 20.8%. Across both cohorts, Leeds has a slightly higher rate of obesity than the national average but is below Yorkshire and The Humber. Changing the perspective slightly, Indices of Multiple Deprivation (IMD) are used to illustrate the difference in outcomes for those living in areas recognised as quintile one (20% most deprived areas of Leeds), and quintile five (20% least deprived areas of Leeds). Amongst reception-aged children, those living in quintile one areas are over twice as likely to live with obesity than those in quintile five areas, at 11.8% and 5.3%, respectively. This picture worsens as a child grows up, with roughly a third of year 6 children (29.6%) in quintile one living with obesity, compared to 11.9% in quintile five.

ADULT OBESITY

Levels of obesity defined by those adults with a BMI of above 30 measured 24.6% at the end of 2023/24. Compared to pre-Covid, this has been a significant increase from 23.6% in 2019/2020. This pattern has been consistent across communities in Leeds regardless of socio-economic factors while maintaining the existing inequality gap, measuring 28.3% and 18.9% in IMD 1 and IMD 10 respectively.

DIABETES

The overall trend in incidences of type 1 and type 2 diabetes is showing a slight increase, totalling 178.8 per 100,000 between 2020-2022. For people living in the most deprived areas the rate was 9,817 and 4,280 for in the least deprived.

FOOD RETAIL AND TAKEAWAY DATA

The Food Environment Assessment Tool (FEAT)[3]

The Centre for Diet and Activity Research (CEDAR) and the University of Cambridge developed the FEAT tool to provide data on the locations of HFTs in England, Scotland and Wales. It has been designed to aid planners is both decision making and policy writing for HFT applications and is updated on a monthly basis, allowing decisions to be made with the most up to date evidence and the ability to monitor changes over time.

The FEAT tool shows that in March 2025, Leeds has 0.95 takeaways per 1k population, compared to 0.74 in Harrogate and 0.7 in Harrogate (now both part of North Yorkshire Combined Authority), 1.44 in Wakefield, 1.34 in Bradford and 1.4 in Kirklees. As of March 2025, Leeds has 753 identified HFTs compared to 834 in June 2023 (earliest data available through the FEAT tool). 

However, as the evidence suggest that areas with higher levels of deprivation are often found to have worse health outcomes, it is important the FEAT tool also allows the mapping of takeaway at more local levels (Ward, MSOA and LSOA). The following map shows the density of HFTs per 1000 people at a ward level across Leeds:

The ward level data shows that the following wards have the highest density of HFTs in Leeds:

• Little London and Woodhouse (2.67 per 1k)
• Hunslet and Riverside ( 1.67 per 1k)
• Beeston and Holbeck (1.34 per 1k)
• Kirkstall (1.26 per 1k)
• Morley South ( 1.24 per 1k)
• Armley and Bramley and Stanningley (1.19 per 1k)

 LEEDS CITY COUNCIL HEALTH DATA MATRIX/FOOD ENVIRONMENT TOOL

The Council is currently developing a data matrix tool/food environmental tool that will seek to understand and map Leeds food environment. The tool has been designed to provide access to diet related disease data and an overview of the food environment across Leeds, including the locations of HFTs. The tool may be able to help identify areas of high HFT concentrations and the impacts of them. The tool may consider data such as:

• Takeaway Counts
• Deprivation Score
• Noise/litter complaints
• Obesity Rates 

The above is not an exhaustive list, however further details will be published in subsequent consultations when the tool is complete. 

ENVIRONMENTAL HEALTH COMPLAINTS

The Council’s Environmental Health team records complaints made against property types that include takeaways. The following tables display all complaints made against takeaways, catering premises (pubs/restaurants etc.) and retailers/shops (supermarkets etc.) since records began. Complaints are logged against premises rather than locations/addresses and therefore an address can have multiple premises located on site over time. It should also be noted that complaints information does not necessarily mean action was taken to address the perceived issue, just that a complaint was logged against the premises. 

 The complaints data suggests that takeaway premises are subject to more perceived waste issues (14.2 per premises compared to 6.5 for caterers and 4.7 for retailers) whilst also receiving 3.2 noise complaints per premises. Ultimately, the data suggest that HFT premises are subject to a significant amount of waste complaints compared to other premises. This evidence supports NPPG guidance which suggests that extra litter management measures should be installed to control litter associated with HFTs. 

DEVELOPMENT CONTROL PRACTICE (DCP) THE PLANNING DIET: HOW LOCAL AUTHORITIES ARE SHAPING A SLIMMER BRITAIN REPORT

The DCP published[4] a report on how local planning authorities are using planning controls to address health inequalities, and this included a review of hot food takeaway policies and guidance. Conclusions from the review included:

• Of the ways to reduce obesity, policies and guidance controlling HFTs were the second most effective way of curbing obesity.
• that if averagely performing takeaway policies were to be applied nationally there could be 54,000 fewer people living with obesity by 2029/30 than if current trends continued based on Office for National Statistics and Office for Health Improvement & Disparities figures.
• Guidance and restrictions of HFTs around schools could result in a 2.37% reduction in childhood obesity if applied across all of England.
• By the end of the study period in 2022/23, obesity was less prevalent in areas with a takeaway policy (not guidance) than those that had not introduced one, by 1.1 percentage points 
• the rate of growth in obesity levels were also lower in areas with a takeaway policy than those without one – 3.4% increase compared with 4.2%.

HOW WILL IT HELP DELIVER THE COUNCIL'S CORPORATE STRATEGY?

BEST COUNCIL AMBITION

Leeds City Council has the ambition to be the best City in the UK, and this recognised through the 3 pillars of our Best City Ambition. One of those 3 key pillars is Health and Wellbeing which aims to ensure Leeds will be “a healthy and caring city for everyone: where those who are most likely to experience poverty improve their mental and physical health the fastest, with health and care inequalities reducing, and people being supported to thrive from early years to later life.” As part of this pillar, the Council will focus on “ensuring children have the best start in life and enjoy a healthy, happy childhood.” As part of the net zero ambition, another focus is “promoting a vibrant and resilient food economy for Leeds so everyone can access and enjoy a healthy diet, where more produce is grown locally, and less food is wasted”. A HFT related planning policy will help the Council meet those ambitions through controlling a potentially unhealthy use, promoting healthy food environments and discouraging food waste through adequate waste management. 

CHILDREN AND YOUNG PEOPLES PLAN

One of the fourteen key priorities of the Council’s Children and Young People Plan is to “promote and enable physical activity and healthy eating”, which a proposed HFT policy will help to deliver.

HEALTH AND WELLBEING STRATEGY 2023 - 2030

In order for the Council to be meet its Health and Wellbeing Strategy objective that Leeds will be “a healthy and caring city for all ages, where people who are the poorest improve their health the fastest”, a priority is to “work across sectors to support people around healthy food and reduce diet- related ill health”. Any proposed HFT policy will have the input of multiple Council services (Environmental Health/Public Health/Planning/Licensing) and aim to support the above the priority. 

LEEDS FOOD STRATEGY

The Leeds Food Strategy visions is to ensure that “Leeds to have a vibrant food economy where everyone can access local, healthy, and affordable food that is produced in ways that improve our natural environment and embrace new techniques and technologies”.  HFT planning policies can help achieve this visions by controlling the locations of unhealth food options served by HFTs. 

HEALTHY WEIGHT DECLARATION 

Health and wellbeing are one of Leeds City Council’s three main corporate ambitions as shown by the Council’s adoption of the Healthy Weight Declaration in 2018, and planning for healthy food environments can help achieve those aims. 

HOW IS IT CONSISTENT WITH THE NPPF?

The proposed approach is a consequence of updated national guidance and policy since adoption of the SPD. In December 2024, the National Planning Policy Framework (NPPF) was updated to include the following paragraph:

97. Local planning authorities should refuse applications for hot food takeaways and fast food outlets:

a) within walking distance of schools and other places where children and young people congregate, unless the location is within a designated town centre; or

b) in locations where there is evidence that a concentration of such uses is having an adverse impact on local health, pollution or anti-social-behaviour.

Any proposed policy would also help the objectives of NPPF paragraph 96:

96. Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:

c) enable and support healthy lives, through both promoting good health and preventing ill-health, especially where this would address identified local health and well-being needs and reduce health inequalities between the most and least deprived communities – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling. 

Further direction on how to implement and promote healthy and safe communities through planning policy can be found through national planning policy guidance[5] (NPPG). It states that:

Planning can influence the built environment to improve health and reduce obesity and excess weight in local communities. Local planning authorities can have a role by supporting opportunities for communities to access a wide range of healthier food production and consumption choices. Planning policies and supplementary planning documents can, where justified, seek to limit the proliferation of particular uses where evidence demonstrates this is appropriate (and where such uses require planning permission). In doing so, evidence and guidance produced by local public health colleagues and Health and Wellbeing Boards may be relevant. Planning policies and proposals may need to have particular regard to the following issues:

• proximity to locations where children and young people congregate such as schools, community centres and playgrounds
• evidence indicating high levels of obesity, deprivation, health inequalities and general poor health in specific locations
• over-concentration of certain uses within a specified area
• odours and noise impact
• traffic impact
• refuse and litter

With regards to HFTs, and policy controls that can be implemented by Local Authority, the above allows a policy to consider proximity to locations where young people congregate, use obesity and health inequality data, consider the over-concentration of such uses, regard traffic and highways impacts and consider the impact on refuse and litter. With regards to litter, the NPPG provides further guidance:

Local Planning Authorities should consider seeking details from applicants, setting out what measures will be put in place to reduce the litter associated with a proposed development, to ensure there is no unacceptable impact from litter on the amenity of the area. Details can include proposals to install litter bins, commitments to undertake litter picking and advisory signage. Litter generated from such premises may be deposited away from the immediate vicinity of the premises. Councils can consider the wider effect this has on local amenity – such as by asking for premises to undertake litter picking to collect litter (generated from off-sales from that premises) which has been deposited further away from the immediate vicinity. It will, subject to meeting the relevant tests of conditions, often be appropriate to impose conditions to require ongoing compliance with any measures proposed.

If the policy to option to rely on national policy and guidance is explored by the Council, planning applications for HFTs will still be assessed against the above NPPF and NPPG, however a Local Plan policy will provide clarity on its implementation and use local evidence to help in decision making. 

HOW ARE WE GOING TO MEASURE THE IMPACT?

Measuring the direct impact of a HFT policy is difficult due to a policy being part of a wider Council holistic campaign to reduce obesity. Therefore whilst obesity rates can be monitored annually, the direct impact of the policy would be hard to ascertain. Monitoring can also consider the amount of HFT planning application received annually, their location and how the planning decision. 

HOW WILL IT BE IMPLEMENTED?

Any proposed policy, and/or the existing NPPF, will be used to determine planning applications related to a HFT (Sui generis use). The Council will use any proposed policy to define and clarify what it determines to be a HFT (including dark kitchens) and what factors it will consider (number of seats etc.) when doing so. 

EQUALITY, DIVERSITY, COHESION AND INTEGRATION

Areas with higher levels of deprivation are often those with the higher levels of HFTs, which can result in higher obesity levels. By adopting policies that aim to deliver healthy food environments, they can form part of a holistic Council effort to reduce obesity in these areas and help reduce health inequalities. However, the policy should also be aware of how different cultures and demographics interact and use HFTs, and how they may provide an important food option to certain demographics.

Paper D – Land-Based Gambling Supporting Paper

What is land-based Gambling 

The 2005 Gambling Act sets out how gambling in Great Britain is regulated. In the act, gambling is defined as “playing a game of chance for a prize, betting and participating in a lottery”.  Land-based gambling is the physical buildings and spaces used for the following: 

• casinos;
• arcades, comprising adult gaming centres (AGCs) and family entertainment centres (FECs);
• betting; and
• bingo.

The above uses are permitted where operators hold the appropriate licences issued by the Gambling Commission and their local licensing authority. Licences are also required by manufacturers and suppliers of gambling machines, which can be installed in the above types of premises as well as premises holding an alcohol premises licence or gaming machine permit.

The Licensing Act and the Gambling Act requires the Licensing Authority (Leeds) to prepare a statement of principles that they propose when making decisions around licences and enforcement of the legislation. Leeds published a revised Statement of Licensing Policy in accordance with Section 349 of the Gambling Act 2005 on 1 January 2025. This lasts until 2028 (unless reviewed sooner as required). 

The purpose of the Leeds Statement of Licensing Policy is to set out the principles that the Council propose to apply when determining licences, permits and registrations under the Gambling Act 2005. Any decision taken by the Council regarding determination of licences, permits and registrations should aim to permit the use of premises for gambling in so far as it is reasonably consistent with the licensing objectives.

What are the risk factors and categories of vulnerability to gambling harm? 

In 2018 the Local Government Association (LGA) and Public Health England published a document to provide an overview of harmful gambling and how councils can try to help local residents who are impacted by it

The report sets out that there is increasing awareness about the harms that can be caused by gambling and its impact on families and local communities, as well as the individuals directly affected by it. The prevalence of high street gambling premises; the significant increase in gambling advertising since the introduction of the Gambling Act in 2005; and the rise in online gambling have all contributed to societal concern about gambling in the UK and the harm that can be associated with it.  

Gambling related harms are now widely recognised as a public health issue which require a broad response. Harmful gambling is a complex problem with many different but often interlinked factors - no single measure is likely to be effective on its own in addressing it. 

In recent years, concern about the harms associated with gambling has been increasing and in March 2018, the Public Health England (PHE) remit letter confirming PHE’s priorities for 2018 to 2019 included the request for PHE to ‘inform and support action on gambling-related harm as part of the follow up to the Department for Digital, Culture, Media and Sport-led review of gaming machines and social responsibility’.

In May 2018, the Department for Digital, Culture, Media and Sport published its response to a consultation on proposals for changes to gaming machines and social responsibility measures. In it they announced that ‘PHE will conduct an evidence review of the health aspects of gambling-related harm to inform action on prevention and treatment’. This was published in January 2023.

It identifies, alongside previous research that harms associated with gambling are wide-ranging. These include not only harms to the individual gambler but their families, close associates and wider society. The evidence review amongst other things seeks to set out what the determinants (risk factors) of gambling and harmful gambling are as well as the harms to individuals, families, communities, and wider societal harms associated with harmful gambling.

The research review identified 45 possible risk factors with three-quarters of these (33 factors) being individual (personal) level risk factors. The remaining related to families or other social influences (5 factors), community-level influences (4 factors) and societal influences (3 factors).

Categories of harm can be categorised into:

• financial
• relationship disruption, conflict or breakdown
• mental and physical health
• cultural
• employment and education
• criminal activity

Leeds Gambling harms vulnerability matrix evidence for indicators

Introduction

In January 2024 Leeds City Council Public Health, Licensing, Financial Inclusion, and Planning colleagues began a joint project to develop a Gambling Harms Vulnerability Matrix which would provide data to inform Licensing and Planning application decisions in Leeds. 

Leeds selected a number of indicators to use in our Gambling Harms Vulnerability Matrix. The evidence for indicators was informed by the Office for Health Improvement and Disparities (OHID) Risk factors for gambling and harmful gambling: an umbrella review: A review of systematic reviews and meta-analyses (Public Health England or PHE). 

We now have a working model of the Leeds Gambling Harms Vulnerability Matrix which will be tested in real world decisions and iterated accordingly.

Methods: how indicators were selected

Leeds chose to use only high and moderate confidence evidence in our Leeds Gambling Harms Vulnerability Matrix. OHID/PHE umbrella review identified a large number of potential risk factors associated with gambling or harmful gambling, but not all research was high enough quality for us to have confidence in the evidence for the risk of causing or exacerbating gambling harms. 

We matched the OHID/PHE evidence to equivalent Leeds data sets. For example, we used Leeds data on not achieving a strong pass in English and Maths as a proxy measure for OHID/PHE “poor academic performance”. This is a “good enough” proxy measure for poor academic performance amongst children and young people in Leeds. 

We then applied weighting based on the strength of the evidence and the size and quality of the data set, for example gambling treatment is specific evidence of gambling harms but is a small data set so this was weighted lower so as not to skew the model. Age and biological sex is a larger data set and male sex in young people is a risk factor in which there is high confidence so we felt confidence in applying stronger weighting for this indicator.

In selecting indicators, we applied a cautious approach and as more high-quality evidence emerges we will revisit the indicators and include more risk factors. We have taken this cautious approach to defend our robust decisions from challenge in Licensing and Planning decisions.

OHID/PHE Gambling-related Harms Evidence Review High and Moderate confidence

The Office for Health Improvement and Disparities Gambling-related Harms evidence review summary (OHID, 2023) Gambling-related harms evidence review: summary - GOV.UK (www.gov.uk) gives a high level overview of the risk factors for gambling-related harms for children and young people which have high and moderate confidence. This is the predominant source for the indicators we have included and as previously stated, only high and moderate confidence risk factors have been included.

“We had a high degree of confidence in the evidence that risk factors for subsequent harmful gambling among children and young people include:

• impulsivity (a cognitive trait)
• substance use (alcohol, tobacco, cannabis and other illegal drugs)
• being male
• experiencing depression

We had moderate confidence that risk factors for subsequent harmful gambling among children and young people include:

• participating in a higher number of gambling activities
• already experiencing problem gambling
• anti-social behaviour
• violent behaviour
• poor academic performance
• peer influence (having peers who gamble)”

Leeds Gambling Harms Vulnerability Matrix Indicators linked to the OHID/PHE Evidence

Educational attainment, Income and Employment 

We included measures on educational attainment based on high and moderate quality evidence from OHID/PHE. The evidence for adults is generally less strong than for children but there are links between income and employment and gambling harms. These indicators have been given a lower weighting to reflect the strength of the evidence.

Measure: Attainment % DIDN’T achieve E&M strong pass

Measure: Not in Education, Employment or Training (NEET)

Measure: Adult Universal Credit

Evidence: “Poor academic performance” is an individual level influence. PHE state: “From the small amount of high-quality longitudinal review-level evidence, it appears poor academic performance may be a risk factor for harmful gambling in children and young people”. There is no relevant evidence for adults.

OHID (2023) state: “We had moderate confidence that risk factors for subsequent harmful gambling among children and young people include: poor academic performance”

There are links between income and employment and gambling in young people, older adults, and migrant communities, including harmful gambling in older adults, and income as a risk factor for harmful gambling in older adults but there is a lack of high-quality review evidence or longitudinal data.

Age and biological (male) sex

We included age and male biological sex and gave this a high weighting to reflect the strength of the evidence of this as a risk factor for gambling harm alongside the size and quality of the data set.

Measure: Age band / gender modelled activity from national rates

Evidence: PHE state: “The evidence suggests that male gender is a risk factor for harmful gambling for children and young people and, to a lower degree, for adults”.

OHID (2023) state: “We had a high degree of confidence in the evidence that risk factors for subsequent harmful gambling among children and young people include: being male”

Age on its own is not a risk factor for harmful gambling among children and young people.

Special educational needs and disabilities (SEND)

We included SEND but gave this a lower weighting to reflect the confidence in the risk factor and the size and quality of the data set. 

Measure: Educational and Health Care Plan (EHCP) May 2024 Rates per 100,000

Evidence: PHE evidence covers impulsivity, emotional regulation, attention deficit hyperactivity disorder (ADHD). 

On Impulsivity PHE states: “In summary, the large body of evidence suggests that impulsivity (including under-controlled temperament and sensation seeking) is associated with both gambling and harmful gambling for adults. There is also evidence it is a risk factor for harmful gambling for children and young people. Evidence suggests that sensation seeking is not associated with harmful gambling in adults. But as there are no longitudinal studies it is not possible to tell if impulsivity is a cause of gambling in all age groups, or of harmful gambling in adulthood”.

On impulsivity, OHID (2023) state: “We had a high degree of confidence in the evidence that risk factors for subsequent harmful gambling among children and young people include: impulsivity (a cognitive trait)”

On emotional regulation, PHE states: “In summary, we did not find any evidence of a relationship between a person’s ability to regulate emotion and gambling. The small amount of review-level evidence shows emotional regulation (including alexithymia) may be associated with problem gambling in adults, but dispositional attention is not associated with problem gambling in young people. Further high-quality longitudinal evidence is needed to confirm that emotional regulation is a risk factor for all age groups”.

On ADHD, PHE states: “In summary, there was a lack of high-quality review level evidence or longitudinal data for ADHD as an influence on gambling. Overall, the evidence suggests that ADHD may be associated with harmful gambling in children and young people, and in adults. However, further high-quality longitudinal evidence is needed to confirm that ADHD is a risk factor for harmful gambling among all ages”.

Depression

We included depression as an indicator and gave this a higher weighting based on the strength of the evidence of the risk factor and the size and quality of the Leeds data set from GP data.

Measure: depression, common mental health problems, severe mental health problems

Evidence: PHE evidence covers individual level influences of “Mental health problems and neurological disorders treatment”

On depression, PHE states: ”There is longitudinal evidence that symptoms of depression are a risk factor for harmful gambling in young people, but anxiety, psychological distress, suicidal thoughts and negative affect are not. The lack of high-quality longitudinal evidence makes it difficult to state whether mental health problems are risk factors for harmful gambling in adulthood. The relationship appears to be bi-directional”.

OHID (2023) state: “We had a high degree of confidence in the evidence that risk factors for subsequent harmful gambling among children and young people include: experiencing depression”

Substance use

We included substance use (alcohol) and gave this a higher weighting based on the strength of the evidence and the size and quality of the Leeds data set from GP and Forward Leeds data.

Measure: alcohol treatment, Audit score 16 or more

Measure: alcohol treatment episodes

Evidence: Substance use

PHE state: “In summary, the evidence suggests that substance use is a risk factor for harmful gambling among children and young people. Substance use may be associated with gambling in children and young people, and harmful gambling in adults, but, because of the lack of longitudinal data, we cannot come to any definite conclusions”.

OHID (2023) state: “We had a high degree of confidence in the evidence that risk factors for subsequent harmful gambling among children and young people include: substance use (alcohol, tobacco, cannabis and other illegal drugs)”

Gambling treatment

We included gambling treatment as this is specific evidence of Leeds residents experiencing gambling-related harms but as this is a smaller data set with moderate confidence from OHID as a risk factor we gave this a lower weighting.

Measure: Gambling treatment – LYPFT

Measure: Gamcare (awaiting data – not yet included)

Evidence: This data is for numbers of people experiencing gambling related harms who have started treatment in Leeds. This is likely to be much lower than those experiencing gambling harms.

OHID (2023) evidence states: “We had moderate confidence that risk factors for subsequent harmful gambling among children and young people include: already experiencing problem gambling”

Gambling opportunities (offline)

We included proximity to gambling premises and gambling machines in on license premises and gave this a higher weighting due to the size and quality of the Leeds data set for this moderate confidence risk factor.

Measure: ACORN offline gambling and On Licence prems May 2023 + Gambling premises

Evidence: Proximity to gambling opportunities (PHE)

PHE state: “In summary, the available evidence suggests that proximity to gambling may be a risk factor for gambling and harmful gambling, but more high-quality evidence is needed to confirm this.”

OHID (2023) evidence states: “We had moderate confidence that risk factors for subsequent harmful gambling among children and young people include: participating in a higher number of gambling activities”

Deprivation

We included deprivation but gave this a relatively low weighting to avoid skewing the data with this large Leeds data set. The weighting reflects the lower confidence overall in deprivation as a “Place” factor for gambling harms vulnerability although PHE/OHID suggests that at a “Person” level the evidence is stronger, particularly for those at higher levels of harm.

Measure: IMD

Evidence: Personal relative deprivation

PHE states: “In summary, evidence suggests there may be an association between personal relative deprivation and gambling, which is stronger at higher levels of problem gambling severity across age groups.”

Antisocial Behaviour (ASB)

Alcohol-related ASB was included as an indicator but given a lower weighting due to this being a moderate confidence risk factor and a smaller size data set.

Measure: Alcohol related antisocial behaviour

Evidence: Anti-social behaviours, violence and aggression

PHE states: “In summary, from the limited high-quality longitudinal review-level evidence, it appears that anti-social behaviour and violence may be risk factors for harmful gambling in children and young people, but aggression is not. No evidence was available to reach any conclusions for a relationship between these risk factors and harmful gambling in adults or gambling for any age group”.

OHID (2023) state: “We had moderate confidence that risk factors for subsequent harmful gambling among children and young people include: anti-social behaviour.”

Care experienced children and young people

Looked after children or children under child protection “at risk” arrangements is the only indicator we included that was not informed by the OHID/PHE review. This was given a lower weighting due to this not being an OHID/PHE high/moderate confidence risk factor and being a smaller data set. However, we felt it was important to include as the high prevalence in Looked After Children/child protection ”at risk”children of depression, SEND and educational attainment which are also high and moderate confidence risk factors for gambling-related harms suggest that we should apply a “precautionary principle” and avoid further potential risk to these vulnerable children and young people.

Measure: CLA July 2020 plus July 2021

Evidence: There is not yet any specific evidence for Local Authority care or child protection “at risk” arrangements as a risk factor for gambling-related harms. This is absence of evidence, rather than evidence of absence as this is an under-researched population with only a few small sample studies conducted in the UK (Fleming et al., 2021).  However, those studies which do exist demonstrate the vulnerability of this cohort who have “poorer mental and physical health, increased behavioural problems, and increased self-harm and mortality compared to peers” (Fleming et al., 2021).

Ball et al. (2024)[6] in their study of mental health usage found that that children on child protection registers due to being at risk of serious harm have up to five times (5 x) the rate of mental health service use.. Fleming et al. (2021)[7] found that looked after children were a vulnerable cohort with worse educational and health outcomes compared to peers, more likely to miss school, be excluded from school and have poor educational attainment and unemployment, more likely to have special educational needs and disabilities including ADHD, depression, and several neurodevelopmental conditions.

Paper E –   Drive-Thru’s Supporting Paper

Drive Thru’s - Why is the policy needed? 

In considering minimising carbon emissions from new development in Leeds, this topic area has explored the opportunity to introduce a new policy that restricts new drive thru development, tightening the existing Leeds Core Strategy approach which places a preference for retail and commercial within and on the edge of town and local centres and also to help address air quality and emission levels by seeking to avoid reliance on the private car and create a compact, accessible and connected city.  

The Leeds Transport Strategy, 2021[8] recognises that road transport is by far the largest source of air pollutants that are the most harmful to health – nitrogen dioxide (NO2) and particulate matter. Air pollution affects everyone but has a disproportionate impact on the most vulnerable in society: young people, older people and people with existing ill health. The annual cost to society of the health impacts of particulate air pollution alone in the UK is estimated to be around £16 billion. Polluted air is the biggest environmental risk to our health in the UK. It is estimated that up to 36,000 people die early every year as a result of long-term exposure to air pollution. (Source: Public Health England, 2019) In recent years, Leeds City Council has taken action to improve air quality across the city through initiatives to modernise fleets, especially with bus, taxi and private hire operators. These measures have been successful in bringing air quality in Leeds below the targets set by government.  

The idea of “bans” on drive-thru’s has been under the microscope before with cities in America banning the building of drive thru’s (Minneapolis, California, Missouri, and New Jersey). Closer to home, Glasgow earlier this year announced they are proposing a similar introduction of restriction but not an outright ban^[9].  

Evidence indicates that idling engines contribute to emissions and increased fuel consumption, with scientists suggesting idling for more than 10 seconds uses more fuel and produces more emissions than restarting your car’s engine.  Drive-thru users stay in their vehicle and have the engine running instead of walking into the restaurant to place an order for food or beverage. Although the drive-thru’s are convenient, and they save time for customers, they may have negative impacts on air quality. Idling vehicles waiting in lines at drive-thru facilities waste petrol, harm air quality, and increase greenhouse gas emissions.  

A report by the Royal College of Physicians “every breath we take: the lifelong impact of air pollution”^[10] starkly sets out the dangerous impact air pollution is currently having on our nation’s health. Each year in the UK, around 40,000 deaths are attributable to exposure to outdoor air pollution which plays a role in many of the major health challenges of our day. It has been linked to cancer, asthma, stroke and heart disease, diabetes, obesity, and changes linked to dementia. The health problems resulting from exposure to air pollution have a high cost to people who suffer from illness and premature death, to our health services and to business. In the UK, these costs add up to more than £20 billion every year. 

What is the policy seeking to achieve? 

As set out in the Connecting Leeds Transport Strategy October 2021 this policy seeks to address the objectives set out against ‘tackling climate change’ and ‘improving health and well-being’ through ‘helping to reduce the need for travel by car’ and ‘reducing the negative effects of transport on our local communities by improving air quality and reducing C02 emissions’.  

The RAC recently published an article^[11] on Clean Air Day (16th June 2022) and includes links to “engine Idling – why it’s so harmful and what’s being done’ and “11 ways in which to reduce your driving emissions”. The strongest message in this being that: 

“a car left at home is emitting nothing”.

Is the policy justified by the evidence?  

Evidence indicates that idling engines contribute to emissions and increased fuel consumption, with scientists suggesting idling for more than 10 seconds uses more fuel and produces more emissions than restarting your car’s engine. 

Research from Coventry University alongside BBC1 Inside Out^[12] undertook an evaluation of outdoor air pollution in drive-thru locations in February 2020. The study used AQMesh combo monitors mounted onto the back of vans and parked near the drive-thru outlets of 10 locations (Birmingham, Milton Keynes, Erith, Taunton, Liverpool, Hartlepool, Nottinghamshire, Hull, Newport and Glasgow).

Pollution levels were constantly monitored for 2 weeks and recorded at intervals of 15 minutes. The study found levels of nitrogen dioxide and particulate matter peaking at many times the standard limit (40µg/m3)[13] with the drive thru at Erith having the highest percentage of exceedances over the standard limits at 61% and Taunton and Hull showing exceedances of 33% and 27%.
 
The total number of exceedances of the pollution were calculated against the standard pollution levels. The data was analysed to highlight the number of times when the pollution exceeded UK/EU standard levels. There were persistent levels above the standard limit that would likely result in typical health effects, both short and long-term, as a consequence of high concentrations of air pollutants. Whilst Leeds was not included in the study the likelihood is that similar patterns of exceedance at drive thru locations would be the result.  
 
Although there are permissible standards set by the government no studies can assertively claim that there is an allowable level of air pollution as the impact on health can affect different groups of people differently. Vulnerable groups of people with underlying health effects can be impacted even at low levels of exposures.
 
The overall aim of the project was to measure the levels of pollutants to raise awareness among employees and users of drive thru’s of the dangers of the deleterious effects of pollution; to highlight that employers have the duty to protect the drive thru employees from the harmful effects of pollution and employ proper precautionary measures to minimise exposure and hence mitigate any possible damage to health and well-being.  

Air pollution has a significant impact on the health and well-being of populations. Vehicle emissions represent the main source of atmospheric pollutants, and both short- and long-term exposure to traffic pollution have been associated with adverse health effects. Poor air quality is the greatest environmental risk to public health in the UK. It is known to exacerbate the impact of pre-existing health conditions, such as respiratory and cardio-vascular illnesses, especially for the elderly and infants. Nitrogen dioxide is of particular concern because there is widespread exceedance of limit values for this pollutant in the UK. Nitrogen dioxide is associated with adverse effects on human health. Estimating its long-term impacts is difficult, because of the challenge of separating its effects from those of other traffic-related pollutants. Particulate matter is also of concern, although the UK has been compliant with EU limit values in recent years. As vehicular pollution produces the highest levels of nitrogen dioxide and particulate matter that is considered very harmful to health, it becomes imperative to understand how this affects the drive thru employees who are subject to inhaling this pollution over short-term periods or even long-term. 

As set out in the Leeds Local Plan Authority Monitoring Report 2018-2019 under Indicator 41: “Air quality in Leeds” Leeds currently meets EU Air Quality Directive Standards for particulate matter. Both PM2.5 and PM10 targets are comfortably achieved, with Leeds also coming close to achieving its aspiration of meeting the PM2.5 annual mean target of 10 μg/m3 set by the World Health Organisation. There are two objectives to be achieved for Nitrogen Dioxide (NO2) specified in the UK Air Quality Regulations: an annual mean not to be exceeded of 40 μg/m3, and an hourly mean of 200 μg/m3 not to be exceeded on more than 18 occasions per year.  

Leeds continues to meet the regulatory limits for the hourly average, however NO2 concentrations at some specific locations across Leeds are exceeding the annual average limit of 40 μg/m3, making Leeds non-compliant with the UK and EU objectives. 

The recent study undertaken by Coventry University, whilst it didn’t include Leeds, does point to comparable drive thru’s with persistent NO2 levels above the standard limit that are considered to likely result in health effects as a consequence of high concentrations of air pollutants.  Therefore by placing greater restriction on where drive thru’s are located in Leeds   (focusing them within town and local centres/or edge of centre, where there is greater opportunity to  access services by means other than the car) not only helps with minimising car journeys, but should also help to reduce localised impacts on air quality. 

How will the policy help deliver the Council’s corporate strategy? 

This planning policy directly supports the zero carbon and inclusive growth pillars of the Leeds Best City Ambition^[14]. The Best City Ambition recognises that as part of the zero carbon pillar there is a need to focus on “Delivering a low-carbon and affordable transport network which encourages people to be physically active and reduces reliance on the private car, helping people to get around the city easily and safely”.  Safe and easy walking and cycling and access to public Transport and shared mobility alternatives offer an important (and lower carbon) alternative to the private car. Similarly, in relation to the ‘Inclusive Growth’ pillar, it is acknowledged that “place matters and positive identity, culture, heritage and pride in our communities are vital assets in a sustainable future for the City and its local centres”. In seeking to ensure that new drive thru development is located within town and local centres this helps to provide inclusive and welcoming neighbourhoods across the City. 

How is the policy consistent with the NPPF? 

The NPPF specifically sets out that planning policies and decisions should aim to achieve healthy, inclusive, and safe places which promote social interaction, safe and accessible spaces and promote healthy lifestyles. It also acknowledges that planning policies and decisions play a key role in the provision of social, recreational and cultural services that meet community needs and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community. 

The NPPF makes a number of references to the role that the planning system has in relation to sustainable places. Of particular relevance to this proposed policy is Section 9: (promoting sustainable transport), this includes: 

NPPF paragraph 105 which states that “the planning system should actively manage patterns of growth in support to these objectives…” (objectives set out in Paragraph 104, including opportunities to promote walking, cycling and public transport (c); avoiding and mitigating and adverse effects on environmental impacts (d); and patterns of movement (e).   

NPPF Paragraph 112 states that “… applications for development should: 

a) give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas; and second – so far as possible – to facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use;

 b) address the needs of people with disabilities and reduced mobility in relation to all modes of transport; 

c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards. 

d) allow for the efficient delivery of goods, and access by service and emergency vehicles; and 

e) be designed to enable charging of plug-in and other ultra-low emission vehicles in safe, accessible and convenient locations.” 

A clear policy approach to the restriction of new drive thru development outside of town and local centres supports the principles of aiming to achieve healthy, inclusive and safe place as set out in Section 8 (promoting healthy and safe communities).  

How are we going to measure the impact of the policy? 

Air Quality is currently monitored in the Leeds Local Plan Authority Monitoring Report under Indicator 41. This policy will be monitored against the number of applications approved in out of centre locations from the base date of policy adoption.  

How will it be implemented? 

The policy will be implemented through the Development Management process and used in the determination of planning applications affecting relevant development across Leeds. 

Equality, diversity, cohesion and integration 

When developing detailed proposals that seeks to restrict a particular land use to places within or on the edge of town and local centres the issue of accessibility is highlighted when considering equality.  Getting around is a key aspect for all but the equality and inclusion issues are most highlighted for those on low incomes or with no or limited access to a car. 

By locating drive thru development in locations that does not rely on private car and promoting easier access via active travel and public transport it is likely to have positive outcome from an equality perspective.   

Further References:

https://airqualitynews.com/2020/10/19/drive-throughs-are-hotspots-for-air-pollution/

https://www.inverse.com/science/uk-drive-through

Time for the UK to say goodbye to drive-throughs: for the sake of our environment, our health – and our culture - Connecting Research (reading.ac.uk)

https://www.gov.uk/government/publications/health-matters-air-pollution/health-matters-air-pollution

http://www.euro.who.int/__data/assets/pdf_file/0006/74715/E86650.pdf

New research reveals high levels of air pollution which could harm health of drive thru staff and customers | Coventry University