From the Rural Shops Alliance
IMMEDIATE RELEASE: 5th August 2015
The “done deal” tone of the consultation does rather contravene the government’s own guidance on consultations, “Engagement should begin early in policy development when the policy is still under consideration and views can genuinely be taken into account.”
The evidence base cited in the consultation to measure the benefits of the proposed change is really threadbare. The government’s own research paper (from the then DTI) is based on ten year old data, having been published in May 2006. In retail terms, that is positively prehistoric. It is before the rise of on-line shopping, coffee shops taking over the world, the development of click and collect, the relative decline of the traditional high streets and price inflation running at a few percent per year. It was a different world.
The other main paper cited is from the London School of Economics, which attempts to make international comparisons, analysing the effects of Sunday trading restrictions in different countries. As the recent Greek crisis has shown (and yes, Greece is one of the economies on which their research is based), countries do really behave in very different ways. The paper also makes the point that changes can take effect over a very long time period, way beyond the researched timeframe. The authors do not sound very confident in their conclusions, which is not surprising.
In fact, the best evidence available, is from the period around the 2012 London Olympics when Sunday trading laws were relaxed temporarily. This is real data. It showed that the public had little appetite for longer Sunday trading hours – although of course this was only a limited and atypical period. Despite its limitations, that’s the data this consultation should be quoting.
Government guidance suggests that “Every effort should be made to make available the Government’s evidence base at an early stage to enable contestability and challenge.” Actually, there is no good evidence base for the main topic of the consultation, namely allowing local authorities to set their own rules for Sunday trading. A postcode lottery could see shops on one side of a street open, those on the other side in a different district closed. There may be a good argument for longer trading hours for tourists in central London, but elsewhere in the country it is hard to think of a good justification for local differences. How is it expected to work in practice? How will the massive increase in the wage bill that retailers will face with the introduction of the National Living Wage from April 2016 onwards affect their decisions? Will existing weekend takings merely spread over longer trading hours? How much market share will multiples take from smaller retailers? Will any jobs created by big chains compensate for the loss of employment in smaller retailers – will transferring sales just transfer the jobs that go with them? Nobody, however expert in UK retailing, knows how it would work in 2015 trading conditions. It is impossible to see a local district council or elected mayor having any real knowledge or expertise to answer such difficult questions. So we are going to make them responsible for the decision?
It is a good principle that if you really do not know what the outcome of a proposed policy will be and the existing policy is working OK and has broad public support, leave well alone. Until the government can provide a better steer than relying on figures from 2006, that is exactly what they should be doing.
The consultation can be found at: Consultation on devolving Sunday trading rules
The 2006 DTI research can be found at: The economic costs and benefits of easing Sunday shopping restrictions on large stores in England and Wales
Notes for editors:
The Rural Shops Alliance (RSA) is the national voice for about 7,500 rural retailers. The RSA campaigns on behalf of rural retailers and also help these shops to become more competitive with practical advice and support, to the benefit of thousands of rural communities. Many ‘blue chip’ suppliers and county councils sponsor and partner the work of the RSA. Our direct contact with rural shops and with these organisations means that we keep in close touch with emerging issues and concerns in our fast changing business sector.
Kenneth Parsons – Tel 01761 462371 Mobile 07980 673675
Post will be moved to the press release archive on Saturday August 6th, 2016