Should a shopfront design guide be used to determine the quality of design and materials for new or changed shopfronts as well as signage?
PROPOSED POLICY WORDING
HS6. SHOPFRONT DESIGN GUIDE
All proposals that would involve the alteration, replacement or creation of a shopfront within the town centre boundary shown on the Proposals Map will be expected to comply with the advice found in the Hoylake Vision Shopfront Design Guide.
On the basis of public feedback from the original 2011 “What’s Your Vision” we identified a need for an approach to shopfront design that is transformative and proactive rather than reactive; local rather than regional.
So, in the 2015-2020 NDP we proposed that a Shopfront Design Guide would help support improvements in the High Street, in particular making it more attractive for local people and visitors, boosting footfall and improving civic pride.
However in April 2016, during the pre-referendum examination process, the independent examiner found there was insufficient evidence to support our proposal. Here is the relevant extract from the Examiner’s recommendations:
6.103 Policy HS4 (Shopfront Design) requires proposals for the alteration, replacement or creation of shopfronts within the Town Centre to comply with advice set out in the Shopfront Design Guide produced by Hoylake Village Life.
6.104 In the absence of a relevant and up to date Supplementary Planning Document prepared and adopted by the Local Authority I understand the reasons for preparing a design guide. However no evidence or explanation is provided to justify the policy and the desirability of ensuring a high standard of shopfront design is not referred to in the commentary on the ‘Improving the Town Centre’ theme.
6.105 Neither does the Shopfront Design Guide which is published in draft form on the Hoylake Village Life website appear to have been subject to any form of public consultation with key stakeholders and members of the public. As the Guide was published in 2011 elements of the document could become out of date. There is also no mechanism for ensuring that it is kept up to date and that the Plan is future proofed in that respect.
6.106 I therefore conclude that in view of the impracticability of using the Hoylake Village Life Shopfront Design Guide to inform the consideration of planning applications Policy HS4 does not add anything to extant WUDP Policy SH8 (Criteria for Shop Fronts) and should be deleted.
6.107 Proposals for new shop fronts will continue to be considered on the basis of WUDP Policy SH8 (Criteria for Shop Fronts) until replaced by new Local Plan policies and accompanying guidance. In this respect I note that Wirral Council are producing an SPD on Town Centre Uses alongside the CSLP which will include guidance, inter alia, on design, materials, shop fronts and architectural detailing, to support the implementation of the CSLP.
In order to get the original Policy HS4 (now HS6) into the next iteration of the NDP in 2020 we will need to address the examiner’s concerns by:
- Providing evidence and an explanation of the desirability of ensuring a high standard of shopfront design. This may come in the form of, for example, data on how shopfront design quality impacts positively on footfall and tourism, with examples of similar towns that have benefitted. A retail professional from the community may be able to advise and support this process.
- Hoylake Vision need to formally adopt the draft design guide from Hoylake Village Life and subsequently update and finalise the content. Through an emerging process of public consultation we need to demonstrate public support for the ideas within it. We know from responses to the initial survey that such a policy would have support but we need specific responses to the finished document, with particular reference to the issue of shopfront security.
- We believe the council’s UDP Policy SH8 does not go in to sufficient detail and that a ‘one size fits all’ approach to a shopfront design guide does not meet the needs of the unique requirements of individual town centres. We need to explain why Hoylake needs a unique design guide and demonstrate why the council’s policy SH8 does not suffice locally. For example, WMBCs policy SH8 states: “company colours, logos, and advertising should be designed and applied with reference to the character of the area, the building concerned and its neighbours”, yet does not provide any examples of what that might mean in a particular location, leaving it wide open to subjective interpretation. The phrase “and its neighbours” also leaves the policy open to adjacent poor quality precedent being cited by applicants when challenged.
- Further, we know from experience that the council has insufficient resources to enforce some of its own policies, including, notably, policy SH8. We know that this leads to an unacceptable situation where unauthorised use of shutters and signage takes place. At best there are occasional retrospective planning applications that are difficult for the council to refuse given the poor quality precedent examples that exist. We argue that, since policy SH8 has clearly not been consistently enforced; then a local policy (NDP policy HS6) is needed in order to to reverse the situation and remove that negative precedent over time.
- In collaboration with WMBC we need to develop a mechanism for monitoring and reporting policy breaches, especially unauthorised use, dimensions or position of shutters or signage, in order to improve and maintain the required standards overall.