One month into the public consultation on the Government's proposed retail planning guidelines and not a single observation has been received by the Department of the Environment. As retail planning affects everyone, a widespread response from the public might have been expected. However, it seems clear from a reading of the 128-page guideline document why there has been a deafening silence. The guidelines as published are just about impenetrable by non-planners.
It is not that the way they are written is difficult - for the most part the language is clear and non-technical - but it is nearly impossible to grasp what the guidelines are ultimately getting at.
From retailers' and developers' points of view, the guidelines seem so open to interpretation that they are waiting until the Minister actually decides which guidelines he intends implementing before responding in the only way that really matters - by applying for planning permission based on an interpretation of the guidelines.
One clear aim is to inhibit the introduction into the Irish market of stand-alone grocery superstores as seen elsewhere in Europe. It would seem that a good place to start coming to grips with the guidelines should be to look at the suggested size of stores. That's where things from a layperson's point of view get very complex. The draft guidelines recommend that the floor-space cap of 3,000 sq. m (32,292 sq. ft) which was introduced for supermarket development should be retained in the rest of the State outside Dublin. Within the greater Dublin area, it is recommended that the floor-space cap be increased to 3,500 sq. m (37,670 sq. ft). This would seem to suggest that a cap has been put on the physical size of supermarkets. However retail space is always broken up into net space and gross space. The 3,500 sq. m is a net retail figure. Retailers could argue that as "back of counter" space is not usually considered as net space then the space behind, for example, the deli counter or the meat counter should not be counted. Some retailers will try to suggest that the till area doesn't count as net retail space. And what about the bakery area, now a permanent feature in most supermarkets?
Even without getting into the nitty-gritty over what is net and what is gross, the workings of a supermarket demand a great deal of delivery, storage and general back-up space which are counted in terms of gross space.
A 35,000 sq. ft supermarket would require at least 10,000 sq ft. So, even if you only count the bare working essentials, then the supermarket is already up to over 45,000 sq. ft gross. When Tesco bought Quinns worth for £640 million in May, 1997, industry observers thought it would only be a matter of time before the State got its first superstore. Indeed, in October of that year, Tesco bought 12 acres of land in Malahide for a reputed £11 million, with the aim of building an 85,000 sq. ft stand-alone complex there. It also bought a site in Liffey Valley with similar intentions.
On first reading, it would seem that the guidelines prohibit such large, stand-alone complexes but to what extent will only become clear when Tesco reassesses its plans. Those planning applications will most likely be the first test of the new retail guidelines. According to Anthony Marston, senior planner at Brady Shipman & Martin, when faced with space restrictions, retailers redraw their plans in ways that directly affect consumers.
"What smaller square footages can mean," says Mr Marston, "is narrower aisles, fewer tills and a reduced choice of produce." He points out that thanks to loyalty cards, some larger retailers have a clear and accurate picture of exactly what brands their customers buy. So, if a supermarket wanted to shoehorn into a smaller space, they could opt to stock only the most favoured lines, thereby ultimately reducing choice for the consumer.
One stated objective in the guidelines is that they should not be anti-competition but they will undoubtedly put off giant foreign hyper-markets wishing to locate here.
IKEA, the Danish furniture store, is currently developing stores of 25,000 sq. m and DIY store B & Q is promoting its Depot concept of stores of 10,000 sq. m or more.
Clearly, no amount of juggling between net and gross spaces would make these hyper-markets fit into the planning guidelines. In any case, there is the bigger question as to whether there is a market for such mega-stores.
One of the objectives of the guidelines is to "seek to continue to support the continuing role of town and district centres" but how they can ultimately achieve this is difficult to see. As one observer puts it, "the guidelines seem to work from the top down but not from the bottom up". He cites the example of Aldi and Lydl, two German discount supermarkets interested in the Irish market. Their stores are typically 15,000 sq. ft and, if located out of town, could prove a very real threat to smaller Irish supermarkets, especially in regional urban areas. A provision in the guidelines is the role of the local authorities in developing their own retail guidelines.
It is a move that is widely welcome but at least in this observations stage it further hampers any concrete response to guidelines. The guidelines will undoubtedly prohibit supermarkets of the size that large retailers want. However, supermarket retailers profit most from stand-alone stores, so it looks as though the public will have to wait until the result of the first stand-alone supermarket planning application before anyone realises just what these guidelines really mean.
