Retail and Town Centres

This new Local Plan proposes policies to encourage the regeneration of our town centres and other retail areas. In particular, the Plan includes a dedicated strategy for the regeneration of Dover town centre, with the aim of creating an attractive, high quality environment encompassing a wider range of uses, and delivering better connections between the centre and other areas, including the seafront.

Draft Retail and Town Centres Policies Map

What are the key issues to consider?

From initial consultation, and the evidence we have collected so far, we have identified the following key issues in relation to retail and town centres:

The NPPF (2019) states that Local Plans should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. Furthermore, the NPPF (2019) continues that planning policies should 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, allows a suitable mix of uses (including housing) and reflects their distinctive characters.

Existing Retail Context

The District faces competition from other areas in Kent, such as Canterbury, Westwood Cross in Thanet and Bluewater in respect to retailing and leisure, and there is a need to recognise the function and role that the Districts town centres play in the retail hierarchy, and identify ways of diversifying the uses in these locations to create more sustainable centres.

Convenience and food stores serving the District are achieving an overall market share of 69.5% (with SFT), which represents a good retention rate reflecting the strength and quality of the overall food shopping offer. In contrast, the comparison goods market share (with SFT) for the main centres and stores in the District is lower achieving an overall 29.2%. A key issue is therefore to increase retention and clawback expenditure to the town centres.

The total available expenditure for food and drink in the Council area is set to increase by £47.3m (37.7%) over the period to 2037. There is no identified capacity in the short term after accounting for the A3/A4 floorspace proposed as part of the St. James scheme. The growth in expenditure results in the potential floorspace capacity in the long term of between 2,191 sqm gross and 5,438 sqm gross by 2037. The prospect for new facilities is however ultimately determined by the level of market demand and interest and should be directed to town centres to enhance the complementarity they bring.

Dover Town Centre

Dover town centre is a historic centre with strong maritime and military heritage.

It is highly accessible by train, car, bus and ferry and has a good level of parking provision. However the A20 to the south of the town centre acts as a major barrier, is often congested with lorries using the port, creates a poor quality environment, contributes to poor air quality in this area and dissects the town from the sea front. In addition to this there are also issues with the one way system around the town and east/ west links through the centre, meaning connectivity between the different areas of the town centre is also poor, and the centre is difficult to navigate around.

The town centre itself is physically long and sprawling, with no key focus. It has a diverse mix of multiple and independent operators, and a number of key anchor tenants including Marks and Spencer, Next, Boots and WH Smith. However the centre suffers from a high vacancy rate - in 2017 the Town Centre had a vacancy rate of 15.2% which was higher than the national average of 11.2% at that time.

Furthermore, there is a lack of critical mass of comparison goods retailers; a lack of food and beverage provision; and a high proportion of charity shops. The town centre also suffers from strong competition from neighbouring centres such as Canterbury; and a poor perception from residents concerning its retail offer.

The centre fails to capitalise on its tourist offer and visitors using the Port tend to by-pass the town centre in favour of other retail and tourist destinations in the surrounding area. The new cruise ship terminal at the Western docks has however created greater opportunities to grow the tourism sector in the town and the council have identified the need for mid to high end hotel accommodation to support this market.

The opening of the new St James retail development in 2018 provided the focus for the rejuvenation of the town, enhanced the retail and leisure offer, and re-positioned the town centre. There is the need to capitalise on this investment however to secure benefits to the wider town centre area.

For the town centre to work there needs to be a mix of uses that are complementary to its functioning. Empty space represents opportunities for other types of development such as residential, offices, bars and restaurants as well as other leisure uses. Hence moving forward, a more flexible strategy is required to create a more vibrant centre.

A number of development opportunities exist both within and in close proximity to the Town Centre. However in order to deliver these projects and transform the town centre a co-ordinated strategy is required.

To support these initiatives there is also the need to develop a coherent connectivity plan for the town centre to provide clear links between different areas; improve accessibility to the mainline High Speed 1 station; provide opportunities for walking and cycling; create focal points to aid navigation and increase social interaction; enhance access to the many historic and cultural assets in the town centre and beyond; and maximise access to the areas of green and blue infrastructure into the town centre to encourage greater levels of utilisation.

Deal Town Centre

Deal in comparison to Dover is a more compact centre. It is a traditional high street, which runs north to south through the town and forms the centre’s heart. The historic pattern of the centre lends itself to a limited scale of development for expansion, but notwithstanding this it is nonetheless well thought of by local residents. Deal also has a good level of accessibility and an attractive town centre environment.

Major retailers in the centre include Boots, WHSmith, Mountain Warehouse, Clarks and Superdrug. Additional multiple retailers include Holland and Barratt, Card Factory, M&Co, Savers, and Poundland. The majority of retailers are located along the centre and southern end of the High Street. The centre also thrives from its wide range of independent retailers which contribute significantly to the overall diversity and viability of the town centre’s offer.

Deal has a low vacancy rate when compared with the national average. The low rate of vacancy is attributable to the compact nature of the town centre and the blend of national and independent retailers that offer a diverse and attractive retail offer to shoppers.

The centre would benefit from improved connectivity with the seafront to gain additional tourist trade. The long term strategy for the centre needs to focus on proactively and continuously promoting the centre as a family leisure destination and capitalising on its historic heritage.

Sandwich Town Centre

Sandwich is renowned for its medieval street pattern and high concentration of listed buildings. The town centre serves the daily needs of its local residents and is a key tourist attraction. The centre benefits from its proximity to a renowned international golf course - The Royal St George's Golf Club which is one of the courses on The Open Championship rotation. Sandwich is also relatively well-connected in terms of road and rail links.

The retail profile of the centre is dominated by independent traders who contribute to the overall diversity, vitality and viability of the centre visit. In terms of representation by multiples this includes Boots, Costa, and the Co-op. The level of vacancy is considerably below that of the national average. The vacancy level is characteristic of a centre of this type which is constrained by the type and size of space available in a historic setting.

As the development potential is limited due to the historic layout of the town centre, the continued vitality and viability of the centre is dependent on active promotion of the centre and on capitalising on the tourism spend associated with the centre’s historic medieval heritage and golfing heritage.

Local and Village Centres

The District has a number of local and village centres which serve the day to day needs of local communities. In order to properly serve their convenience function, it is important that local and village centres retain a good range of shops. This has additional sustainability benefits, reducing the need to make avoidable trips (particularly by car) to other centres elsewhere.

Future Strategy

The Retail and Town Centre Needs Assessment (2018) identifies no need for convenience goods and a small need for comparison goods, primarily in Deal and Sandwich, towards the end of the Plan period. However there is considerable uncertainty in retail forecasting beyond ten years. Given this a review of the Retail and Town Centre Needs Assessment will be carried out post Reg 18 consultation on the draft Local Plan.

There are also concerns surrounding the increase of vacant retail premises across the District, the long term future of retailing as a sector and rapid changes in the industry on a national scale, particularly in light of COVID-19.

The recent changes by the government to the use classes order will also allow far greater flexibility to change uses within town centres without the need to obtain planning permission. The new approach aims to promote the vitality and viability of town centres by allowing more diversification in a way that can respond to rapid changes in the retail and leisure sectors. It remains to be seen however whether this approach has harmful unintended consequences for town centres.

View our Evidence Base

How could these be addressed through planning policy and what is our preferred approach?

The policy options for addressing the key issues identified are set out below:

Quantity and Location of Retail Development

The NPPF (2019) states that planning policies should allocate a range of suitable sites in town centres to meet the scale and type of development likely to be needed, looking at least ten years ahead. Meeting anticipated needs for retail, leisure, office and other main town centre uses over this period should not be compromised by limited site availability, so town centre boundaries should be kept under review where necessary.

The Retail and Town Centre Needs Assessment 2018 makes an assessment of overall quantitative capacity for new (convenience and comparison goods) retail floorspace over the period to 2037. It is clear from this study that there is only one option the council should be considering in relation to the amount of retail development required, and the NPPF (2019) states that a town centre first approach should be taken to the location of new retail development, therefore reducing the need to consider any further options in this respect.

The council could consider allocating sites for retail development in the District's towns to deliver the retail need identified, however, given the floorspace requirements are for the end of the Plan period, and the level of uncertainty around the projections because of this, it is considered that there isn't sufficient evidence at this time to inform the need for retail allocations. Furthermore, it is considered that this need could be met through existing vacant premises in the primary shopping areas of the District's town centres and through the development opportunities identified in Dover Town Centre, set out in Strategic Policy 11.

Dover Town Centre

The Retail and Town Centre Needs Assessment 2018 identifies a number of opportunities in Dover Town Centre and an overarching strategy is required to deliver this. Options include:

  • A policy that only permits main town centre uses within the town centre boundary; or

  • A policy that takes a more flexible approach to development in the town centre, which enables the development of other uses (including residential), alongside main town centre uses, within the town centre boundary; or

  • Maintain the existing town centre boundary and primary shopping area; or

  • Define a new town centre boundary and primary shopping area.

Having considered the evidence, opportunities and policy context for Dover, the Council's preferred approach is to adopt a more flexible approach to development in Dover Town Centre, to take a more positive approach to its growth, management and adaptation over the Plan period, in line with the NPPF (2019). This will also involve redrawing the town centre boundary and primary shopping area to make them more functional.

Deal Town Centre

The Retail Town Centre Needs Assessment (2018) recommends two options for Deal Town Centre in terms of increasing the Town Centre Boundary following evidence to demonstrate town centres uses within these areas, which are currently outside of the town centre boundary.

  • Option 1 is to include High Street/Oak Street intersection up to the High Street/New Street intersection. The boundary would also encompass St George's Road. This additional area has a diversity of retail and commercial leisure provision, as well as a museum, visitor centre, St George's Church and tourism centre. These constitute town centre uses under the current NPPF (2019). It was also concluded within a Council audit that 73% of existing units in this area comprise of town centre uses as defined under the NPPF.
  • Option 2 would be to carry out the extension to the Town Centre Boundary as per option 1 and also extend the town centre boundary to include Deal Town Hall, The Landmark Centre and Union Road Car park. This will enable linkage with the retail, commercial and leisure provision in Option 1 together with safeguarding enhancing the vitality of the centre by incorporating the car park which at present also provides space for the long running market. These are classed as town centre uses under the NPPF (2019) and a council audit has shown that up to 75% of existing units in this area comprise of town centre uses.

Having considered the evidence, opportunities and policy context for Deal and in the light of the changes to planning Use Class E and the NPPF (2019) the Option 2 is the Council's preferred option to enable an increased Town Centre Boundary, to be able to provide a more focused and managed town centre context, which will also be able to provide flexibility to ensure the vitality and viability can be maintained and enhanced to provide the range of uses required to support the local residents and the visitor experience for tourists. This will allow for a level of growth as highlighted in the Retail and Town Centre Needs Assessment (2018) for retail floorspace In Deal within the plan period.

Sandwich Town Centre

The Retail and Town Centre Needs Assessment (2018) predates the Planning Use Class E changes and the NPPF (2019) and only designates a secondary shopping frontage within Sandwich town centre. In terms of the retail hierarchy and importance of Sandwich town centre, it is considered that the designation of a primary shopping area is required in order to provide appropriate policy management and protect the vitality and viability of the town centre. In order to achieve this the options are:


  • Designate a primary shopping area within the town centre at Market Street, Cattle Market, King Street and part of New Street . This will create a clearer strategy for any future change of use or development within the centre.
  • The alternative is to not designate a primary shopping frontage within Sandwich, but this would mean reliance on the NPPF only for decision making.

Having considered the evidence, opportunities and policy context for Sandwich, the Council's preferred approach is to designate a primary shopping area within the town centre highlighted on the policies map, which includes units within Market Street, Cattle Market, King Street, and New Street. This will create a more proactive and flexible guided approach to decision making within the town centre in line with the NPPF (2019). The aim is to ensure the continued vitality and viability of the centre with a range of uses available to meet the needs of the local population and capitalise on the tourism spend associated with the centre's historic and medieval heritage and golfing heritage. The option of not designating a primary shopping area will mean the policy context for Sandwich is not up to date and would not provide sufficient guidance for decision making within the town centre.

Retail and Town Centres

With the changes to the NPPF (Feb 2019) requiring a designated primary shopping area compared with the previous method of designating primary and secondary retail frontages, the policy needs to identify the uses which are considered to be acceptable within the primary shopping areas.

Options include:

  • A policy which allows only retail uses within the primary shopping area.
  • A more flexible policy which allows a wider range of commercial uses subject to specified criteria that ensure the proposals contribute to the overall vitality and viability of town centres.
  • To not allow residential uses within the ground floor of the primary shopping areas to protect the retail and commercial uses.

Given the changing nature and role of town centres, and the importance of a wider range of uses being provided within town centre, to ensure their future vitality and viability, the flexible approach is considered to be the preferred option. In addition, changes resulting from the new use Class E and potential impacts associated within the COVID-19 pandemic mean a more flexible approach is the most appropriate. The provision of residential uses within town centres is considered important to increase footfall and activity in town centres, however the provision of residential on the ground floor within the primary shopping areas is likely to have a negative effect on the commercial function of the area. The option to restrict residential on the ground floor is therefore considered to be justified.

The Sequential and Impact Test

The NPPF requires that a sequential test is carried out for main town centres uses not within a main centre nor in accordance with an up to date plan. The NPPF also sets out the requirement for an impact assessment for retail proposals greater than 2,500 sqm, or where a local threshold applies.

Options include:

  • A policy which sets out the NPPF requirements.
  • A more localised policy setting out the expected requirements supported by the threshold evidenced in the Retail and Town Centre Needs Assessment (July 2018) .

A more localised policy is the preferred approach utilising the impact assessment threshold of 350sqm as set out in the evidence base, to ensure that the impact of proposals for retail development outside of town centres can be fully considered and ensure no harmful impact upon the town centres from out of town proposals.

Local Centres

Local Centres perform an important role in the retail hierarchy catering for basket and top up shopping, located in sustainable locations often walkable from residential areas. It is important the such facilities continue to be provided in order to support local communities and to reduce the need to travel (particularly by private car). Options to protect the smaller convenience shops within the district are:

  • To have a policy which protects the loss of local convenience shops, by requiring evidence to support the loss of any unit in the form of active marketing for at least 12 months consistent with other similar policies which seek to protect specified uses and ensuring any new convenience stores would be a maximum floorspace of 280sqm consistent with the NPPF (2019).
  • No policy to protect the loss of local convenience stores, or limit on the size of convenience stores in the context of the overall retail hierarchy.

The preferred option is to have a specific policy which provides clarity and guidance for the loss of convenience stores and the size limits of local stores. Without this, there is risk that local facilities could be lost where there is a need for the facility. The limit on size of new facilities would ensure that the existing retail hierarchy is supported and protected, and that larger facilities are directed to town centres in accordance with national policy.

Shop Fronts

There is a need to create town centres and retail units which are flexible and can adapt to change, but there is also need to protect the overall character and historic environment of our town centres. The majority of the primary shopping areas within Dover, Deal and Sandwich fall within Conservation areas and alterations or development therefore need to be carefully managed.

Options include:

  • A shopfront policy which guides development in order to ensure alterations continue to positively contribute to the overall character of retail and commercial frontages within the town centres.
  • No policy to guide shopfront alterations or development, reliance on NPPF (2019) only for decision making.

The preferred policy approach for shopfronts is to have a policy which can guide alterations and development in order to ensure the vitality and viability of town centres can be maintained. The reliance on the NPPF for decision making does not provide sufficient local detail to be considered in decision making.

View the Draft Local Plan on our Consultation Portal