Retail Statement

On behalf of:

In respect of: “Outline mixed use proposal for retail (Use Class A1) with associated petrol filling station and car parking (providing space for mobile library), food and drink (Use Classes A3, A4 and A5) / day nursery (Use Class D1) and residential (Use Class C3) alongside the provision of a community and sports facility (Use Classes D1 and D2), public open space (including formal playing pitch provision), and other associated infrastructure (inclusive of linkage to consented Langarth/Stadium sites). [Means of access to be determined only]” Date:

August 2014

Reference:

GH/MO/R0001

Cardiff Sophia House, 28 Cathedral Road, Cardiff CF11 9LJ Tel: 029 20660265

Executive Summary

This application proposal will deliver the Western District Centre, residential units, community facilities and will enable the Stadium for Cornwall to be built.

The application proposals meet the identified retail need and provide residents with a choice of retail offer. It meets this need at a site which is a natural extension to the approved Langarth mixed-use scheme and one which provides strong links to the Stadium for Cornwall and the wider development of the surrounding area, thereby meeting the requirements of the sequential test.

The application proposal will principally compete with similar developments both within and outside of Truro. Whilst the city centre will experience some trade diversion, the over trading of existing shops and the annual growth in retail expenditure means that the impact will not be significantly adverse and the turnover of the city centre will still increase even with the proposals.

Crucially, the application proposals will deliver economic, social and environmental benefits to the local community. The enabling of the construction of the Stadium of Cornwall will also deliver a once- in-a-lifetime opportunity for Cornish professional sport and community groups.

The proposals represent a high quality comprehensive development generating hundreds of jobs and drawing people to the area. Crucially, the proposals do this without significant adverse impact on Truro City centre. As such, the proposals meet a number of long held objectives of the Council and have significant community support. The planning balance is clearly in favour of approving the proposals.

Contents

1.0 Introduction 3 2.0 The Proposal 4 3.0 Planning Policy Context 11 4.0 The Retail Context 15 5.0 The Sequential Test 20 6.0 The Impact of the Proposal 34 7.0 Summary and Conclusions 51

Appendices

A Retail Impact Tables 56

Table 1 Population Estimates Table 2A Convenience Goods Per Capita Expenditure Estimate Table 2B Comparison Goods Per Capita Expenditure Estimate Table 3A Total Convenience Goods Expenditure Table 3B Total Comparison Goods Expenditure Table 4A Turnover of Foodstore Element of Proposal Table 4B Turnover of Non-Food Element of Proposal Table 5A Turnover of Existing Convenience Goods Stores and Centres 2014 Table 5B Turnover of Existing Convenience Goods Stores and Centres 2019 Table 5C Turnover of Existing Comparison Goods Stores and Centres 2014 Table 5D Turnover of Existing Comparison Goods Stores and Centres 2019 Table 6 Solus Convenience Goods Trade Diversion to Proposal Table 7 Convenience Goods Turnover in 2019 with Solus Impact Table 8 Solus Convenience Goods Impact Summary Table 9 Cumulative Convenience Goods Trade Diversion to Proposal Table 10 Cumulative Convenience Goods Turnover 2019 and Impact Table 11 Solus Comparison Goods Trade Diversion to Proposal Table 12 Comparison Goods Turnover in 2019 with Solus Impact Table 13 Solus Convenience Goods Impact Summary Table 14 Cumulative Comparison Goods Trade Diversion to Proposal Table 15 Cumulative Comparison Goods Turnover 2019 and Impact Table 16 Total Solus and Cumulative Impact on Truro City Centre

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1.0 Introduction

1.1 This retail statement has been prepared on behalf of Inox Group and Henry Boot Developments Limited in support of an outline planning application at West Langarth for:

“Outline mixed use proposal for retail (Use Class A1) with associated petrol filling station and car parking (providing space for mobile library), food and drink (Use Classes A3, A4 and A5) / day nursery (Use Class D1) and residential (Use Class C3) alongside the provision of a community and sports facility (Use Classes D1 and D2), public open space (including formal playing pitch provision), and other associated infrastructure (inclusive of linkage to consented Langarth/Stadium sites). [Means of access to be determined only]”

1.2 Section 2 of this assessment sets out details of the site and the application proposals. Section 3 sets out the planning policy context. Section 4 sets out the retail context for the proposals. Section 5 considers the proposal against the sequential test and Section 6 assesses the application proposals against the policies relating to retail impact. Section 7 provides a summary and conclusions.

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2.0 The Proposal

2.1 The application is submitted in outline with all matters except access reserved for future consideration. The proposal comprises the following elements:

• 1 no. Class A1 Foodstore (5,574 sq m gross); • 1 no. Petrol Filling Station (12 pumps); • Class A1 Comparison Goods Units (4,645 sq m gross); • Class A3, A4, A5, D1 Use (929 sq m gross); • Associated car parking with an area suitable to accommodate the mobile library; • Up to 130 Residential Units (Use Class C3); • 1 no. Community/Sports Building (Use Class D1/D2) (500 sq.m gross); and • 3 no. sports pitches and areas of public open spaces.

2.2 Whilst expressions of interest have been lodged, at this stage, there are no confirmed operators for any of the proposed A1/A3/A4/A5/D1 units. As such, the application is made in outline in order to agree the principle of development. Details of the exact nature, design and location of the units will be considered at the reserved matters stage.

2.3 As set out in detail in the Design and Access Statement which accompanies the planning application, the proposal creates direct physical link with the adjacent Langarth scheme and beyond to the approved Stadium for Cornwall and the existing park and ride facility. The commercial element of the application proposal has been designed to act a as ‘dumb-bell’ to the approved stadium and the local centre approved as part of the Langarth scheme. The provision of strong vehicular/public transport links and a ‘green’ route for pedestrians and cyclists will draw people east to west within the site. This linkage reflects that this application proposal should be read as one with the approved Langarth and stadium schemes.

2.4 The linkage between the existing approved stadium and Langarth schemes means that the proposals will benefit from linked trips between the different attractions. In addition, the proposals will encourage linked trips to the city centre, particularly those people who are drawn to the stadium for matches who might otherwise not visit Truro.

2.5 In light of the above, it is necessary when considering the proposals to also consider not only the elements specifically applied for as part of this application the approved Langarth scheme and the Stadium for Cornwall proposal, which is enabled by the application.

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Deliverability of the Proposal

2.6 As outlined above, at this stage, there are no operators contractually tied to the application proposal. We contend that this does not weaken the case in support of the application, not least because the applicants have confirmed interest from two supermarket operators are interested occupying a store in this part of Threemilestone/Truro. Given that there are four current opportunities for supermarkets in close proximity to one another, it is inevitable that the supermarket retailers will wait to see which scheme is approved before committing. Equally, whilst Asda are a named operator on the Willow Green application, this will almost certainly be a subject to planning contract, meaning that if planning permission is not secured, Asda will be able to ‘jump-ship’ to the successful site.

2.7 In terms of the non-food floorspace and A3/A4/A5/D1 units, the applicant has identified a number of operators with live requirements for floorspace in Truro, who have confirmed that subject to the granting of planning permission, they would take space at the development. These operators are those typically found at similar sites to that proposed rather than in city centre locations. Moreover, where operators who occupy city centre locations have expressed potential interest, they see the application site as complementary to the city centre offer, rather than instead of it.

2.8 On the basis of an outline planning application and in the absence of a named operator, the ability of the applicant to deliver the proposals could be a concern for the LPA. Clearly, in a competitive ‘either-or scenario’ such as that present in Threemilestone, the LPA need confidence that the approved scheme can and will be delivered. This need for certainty of delivery is why Inox Group entered into a joint venture with Henry Boot Developments Limited (HBDL); a leading force in the UK property development market, and are vastly experienced in delivering schemes like this.

2.9 HBDL have delivered mixed-use schemes throughout the UK. They are not reliant on external funding to deliver schemes meaning that they are not as exposed as other developers to the difficulties in securing finance to deliver projects. In addition, their track record of delivering development schemes since 1886 means that they have exceptionally good links with retailers and commercial occupiers. As such, we contend that HBDL’s involvement in this project means that if planning permission is granted, occupiers will be confirmed and the scheme will be delivered without delay.

2.10 In light of the absence of any named operators, in order to assess the impact of the retail elements of the proposal a number of assumptions have been made. These are set out

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below:

The Proposed Food Store

2.11 The proposed foodstore will meet the need identified in the Cornwall Retail Study and will fulfil the long held aspiration of Cornwall Council for the provision of a new district centre to the west of Truro, serving existing residents and the planned residential growth of the city around Threemilestone.

2.12 The following assumptions have been applied when assessing the impact of the proposed foodtstore:

2.13 Net Floorspace – As the food store operators all have different net to gross ratios, we have adopted a high net to gross ratio in order to ensure that the proposed store meets the needs of all potential occupiers. As such, we have adopted the net to gross ratio of 65%. This gives a net floorspace figure of 3,623 sq.m. (38,998 sq.ft.).

2.14 Floorspace Split – Each of the supermarket operators has a different convenience/comparison goods split. As such, in the absence of a named operator, we have opted for a 70/30 convenience/comparison floorspace split. This results in a convenience goods floorspace of 2,536 sq.m. (27,297 sq.ft) and a comparison goods floorspace of 1,087 sq.m. (11,700 sq.ft).

2.15 Sales Density - As there is no operator currently associated with the proposal, we have adopted an average of the convenience goods benchmark density of the four main foodstore operators according to Verdict 2014 (expressed at 2007 Prices). This gives a convenience goods sales density of £9,308 per sq.m.

2.16 For comparison goods, in the same way as we have for convenience goods, we have adopted an average of the comparison goods benchmark density of the four main foodstore operators according to Verdict 2014 (expressed at 2007 Prices). This gives a comparison goods sales density of £9,340, per sq.m.

2.17 The table below sets out the respective benchmark sales densities of the ‘big four’ supermarket operators (Source: Verdict 2014):

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Food Non-Food

2007 Price Base (£ per sq.m) (£ per sq.m)

Tesco 8,072 12,431

Sainsbury’s 10,009 6,244

Asda 9,949 8,344

Morrison’s 9,202 10,342

Average 9,308 9,340

2.7 Turnover - Based on the above assumptions the proposal is assessed on the following basis:

Net Floorspace Benchmark Sales Density Turnover (£M) (sq.m.) (£ per sq.m.)

Convenience Goods 2,536 9,308 23.61

Comparison Goods 1,087 9,340 10.15

TOTAL 3,623 - 33.76

The Non-food Retail Units

2.18 The proposed non-food retail units will meet the need for additional floorspace identified in the Cornwall Retail Study. The proposed units will serve Truro and the surrounding area, reducing the overtrading currently experienced by existing comparison goods stores in the city. Recent planning consents outside of Truro will claw back trade from the city and, to a lesser extent, divert it from Truro. As such, the application proposals will also claw back expenditure which would otherwise be lost to the recently approved schemes elsewhere.

2.19 The following assumptions have been applied when assessing the impact of the proposed foodstore:

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2.20 Net Floorspace – As there is no end occupier for the non-food units at present, we have had to assume the net to gross floorspace ratio. As such, we have used a conservative 80% ratio, giving a total net floorspace for the three non-food retail units of 3,716 sq.m. (39,999 sq.ft.).

2.21 Floorspace Split – In the absence of named operators, we have assumed that the proposed floorspace will be restricted to the sale of comparison goods. We have also assumed that the floorspace will not be restricted to the sale of bulky-goods. We have also assumed that the minimum floorspace of any unit would be 929 sq.m (10,000 sq.ft).

2.22 Sales Density – The location and nature of the proposed development means that the proposed comparison goods units are most likely to be occupied by typical out-of-centre retailers. This view is supported by the commercial agent’s findings on retailer interest for the site. However, as there are no named operators for the proposed development and at this time, we are not suggesting any restrictive conditions on the operation of the units, we have tested an impact scenario whereby the development could be occupied by retailers who also operate town centre stores.

2.23 The tables below sets out the benchmark sales densities of the types of retailers who generally occupy out-of-centre proposals according to Verdict 2014 (expressed at 2007 Prices). This gives an average comparison goods sales density of £2,697 per sq.m:

Retail Type £ per sq.m Stationery 1,377 Carpet Retailers 806 Clothing/General Household 2,305 Electrical 6,304 Furniture 3,118 Homeware Retailers 1,632 Miscellaneous 2,927 Sports, Camping and Leisure Goods 5,811 Toy Retailers 1,983 DIY Retailers - Main Multiples 1,521 DIY Retailers - Other Traders (10 or less outlets) 1,278 Garden Centres 3,297 OVERALL AVERAGE 2,697

2.24 However, for robustness and to assess the potential impact of the proposed comparison goods units being occupied by retailers who are also found on the high street, we have taken into account the higher potential turnover as set out in the table below derived from Verdict

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2014 (2007 Prices):

Retail Type £ per sq.m Book sellers and Stationers 2,826 Clothing Retailers 4,172 Department Stores 4,630 Other Department Stores 2,620 Electrical Retailers 9,491 Mobile Phone Retailers 16,130 Footwear Retailers 7,735 Furniture Retailers (Main) 2,254 Furniture Retailers (Other) 2,759 Health and Beauty 10,549 Homeware 2,398 Jewellers 13,427 Mixed-Goods Retailers 5,793 Music and Video Games Retailers 3,463 Sports, Camping and Leisure Goods 4,612 Toy Retailers 1,983 OVERALL AVERAGE 5,928

2.25 Given the nature of the development proposed, there is no prospect of the units being occupied by jewellers or mobile phone retailers. As such, it is legitimate for these retailers, who have a higher benchmark sales density due to their smaller footprints, to be excluded from the average benchmark sales density used to assess the proposals. On this basis, the average town centre retailer benchmark sales density is £4,352 per sq.m.

2.26 Based on the above, we have assumed that the turnover of the proposed comparison goods units is an average of the typical out-of-town retailers benchmark (£2,697) and the typical town centre retailer (excluding jewellers and mobile phone retailers) (£4,352 per sq.m.), which gives an average of £3,525 per sq.m. This figure is considered higher than the actual turnover is likely to be, but tests the ‘worst case’ impact scenario, demonstrating the robustness of the assessment.

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2.27 Turnover - Based on the above assumptions the non-food retail units are assessed on the following basis :

Net Floorspace Benchmark Sales Density Turnover (£M) (sq.m.) (£ per sq.m.) Comparison Goods 3,716 3,525 13.10

2.28 As set out above, the use of a combined typical ‘out-of-centre’ and ‘town centre’ sales densities means that the above turnover figure is highly likely to be an over-estimate of the turnover of proposed comparison goods units. As such, in assessing the resultant trade diversion and ‘impact’ we consider the assessment to be extremely robust.

Total Turnover of the Proposed Development

2.29 Based on the above assumptions, the turnover of the proposals will be as follows:

Net Sales Sales Density Turnover (Sq.m) (£ per Sq.m) (£M)

Foodstore Convenience 2,536 9,308 23.61 Foodstore Comparison 1,087 9,340 10.15 Comparison Goods Units 3,716 3,525 13.10 Total 7,339 - 48.86

2.30 Use of benchmark sales densities and the ‘composite’ out-of-town/town centre benchmark used to calculate the turnover of the comparison goods units, means that the turnover set out below is likely to represent an overestimate of the actual turnover generated by the store. This is due to a combination of the competitive retail environment in which the development will be entering and, for the comparison goods element, a robust assumption about the nature of the retailers who might occupy the development. As such, in assessing the trade diversion associated with the above turnover, it should be considered a worst-case scenario.

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3.0 Planning Policy Context

3.1 This section sets out the planning policy context of the proposed development.

National Planning Policy

3.2 National planning policy is set out in the National Planning Policy Framework (“NPPF”) published in March 2012.

3.3 The NPPF states that the Government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future.

3.4 The NPPF goes on to state that the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. It highlights that planning should operate to encourage and not act as an impediment to sustainable growth. It concludes that, significant weight should be placed on the need to support economic growth through the planning system.

3.5 In the context of the above statements, the NPPF states that where the development plan is absent, silent or relevant policies are out ‑of ‑date, planning permission should be granted unless:

• any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or

• specific policies in this Framework indicate development should be restricted.

3.6 Crucially, the NPPF states that local planning authorities should look for solutions rather than problems, and decision-takers at every level should seek to approve applications for sustainable development where possible. It goes on to state that local planning authorities should work proactively with applicants to secure developments that improve the economic, social and environmental conditions of the area.

3.7 When assessing applications for retail, leisure and office development outside of town centres, which are not in accordance with an up-to-date Local Plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold (if there is no locally set threshold, the default threshold is 2,500 sq m).This should include assessment of:

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• the impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and

• the impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made. For major schemes where the full impact will not be realised in five years, the impact should also be assessed up to ten years from the time the application is made.

3.8 The NPPF states that local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. It states that LPA’s should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered.

3.9 The NPPF states that when considering proposals not within a town centre, preference should be given to accessible sites that are well connected to the town centre. The NPPF highlights that the requirement for flexibility of format and scale is on local planning authorities as well as applicants.

Development Plan Policy

3.10 Further to the revocation of the Regional Strategy for the South West and the Cornwall Structure Plan, the extant development plan for the site comprises the saved policies of the Carrick District Local Plan (adopted April 1998). However, it is important to note that these Policies are now over 15 years old and, therefore, in accordance with the advice at paragraph 215 of the NPPF, the NPPF is plainly a material consideration.

Local Plan

3.11 Policy 7A identifies that retail developments within Truro will be consolidated within or adjoining the central shopping areas identified on the Proposals Map. Proposals for significant development outside of these areas will be required to show that the needs of the area cannot be adequately provided for within or adjoining the Central Shopping Area having regard for the need for flexibility in respect of the format, design and scale of development (including the amount of car parking) and that it would have no significant adverse impact upon the long term viability and vitality of the centre as a whole. Within Truro, no further retail uses will be allowed to front onto the Inner Circuit Road or Morlaix Avenue in the interest of road safety and accessibility.

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3.12 Policy 7G states that proposals for supermarkets and superstores located outside of the town centres (including Truro) will only be permitted where the needs of the area cannot be accommodated within or adjoining the central shopping areas identified in Policy 7A and where a series of criteria are complied with (no conflict with environmental or built environment policies; no significant adverse impact upon the vitality and viability of the centre as a whole when considered on its own or together with other relevant proposals in the locality; adequate parking; no loss of industrial premises; acceptable access and no adverse impact on surrounding highway network; satisfactory landscaping; scale and design compatible with surrounding land uses; no issues with the provision of essential services). Where any future changes to the retail character of such developments would threaten the vitality and viability of a town centre shopping area, the district planning authority will seek an obligation under section 106 of the Town and Country Planning Act 1990 to limit the range of goods sold and to restrict future sub-divisions.

Emerging Local Plan

3.13 The policies detailed in the emerging Cornwall Local Plan are not yet part of the development plan in advance of formal adoption. Discussions with a member of the local authority’s Planning Policy team confirmed that following a further round of consultation on the submission version, it is expected that the Plan will be submitted towards the end of 2014. Therefore, at this stage the relevant retail policy (Policy 4) may only be afforded very limited weight in the decision making process.

Neighbourhood Plan for Truro and Kenwyn

3.14 Whilst there has been Panel discussion on the emerging Neighbourhood Plan, it has yet to be subject of a formal referendum and therefore carries minimal weight in planning decisions.

Land North of the A390 Development Brief

3.15 It is the opinion of Christopher Lockhart-Mummery QC, whose opinion accompanies the planning application that the Land North of the A390 Development Brief “is not, and cannot be, a planning policy document.”. This view is supported by James Findlay QC on behalf of the LPA:

“The Brief should not be treated like a development plan document but it can justifiably be had regard to”.

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3.16 James Findlay QC has also set out his view on the purpose of the Development Brief, stating:

“What the DB has done is gather the relevant principles, goals and objectives and has undertaken consideration of these against the specific circumstances of the location. The DB sets out at least one view as to what might constitute good planning of the area and to that extent is entitled to weight”.

3.17 James Findlay’s view supports our own that the brief was no more than a response to schemes put to the council at the time of drafting the document in 2012. It is not underpinned by any technical survey work and does not even appear directly related to the advice on the provision of a district centre contained in the Cornwall Retail Study (“CRS”).

3.18 The boundary adopted by the Brief is contiguous with the boundaries of those schemes and, therefore, we contend, that had West Langarth been put to the Council at that time it is highly likely that the area of the Brief would have included it. Thus, in our view the boundaries of the brief have little credence.

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4.0 The Retail Context

4.1 The Cornwall Retail Study produced by GVA (“the CRS”) on behalf of Cornwall Council and published in 2010 sets the context for retail development within the County.

4.2 The CRS examines the current shopping patterns in Cornwall and sets out recommendations for accommodating further retail provision. To inform its recommendations, the CRS examines the availability of expenditure within Cornwall and the current performance of existing stores. We set out below conclusions drawn from the CRS in the context of the subject proposal.

Convenience Goods

4.3 The household shopping survey undertaken to inform the CRS demonstrated that Zone 10 (Truro) retains the vast majority of it’s convenience goods expenditure (84%). For Zones 9, 11 and 12 which abut Truro, the expenditure accounted for in Truro was less at 21%, 69% and 74%, but remained high, reflective of the retail hierarchy in this part of Cornwall.

4.4 The CRS examined the need for further convenience goods floorspace in Truro. It examined the extent of additional floorspace required to meet needs based on four population scenarios ranging from high growth based on the National Housing and Planning Advice Unit, through to a zero new residential development across Cornwall. The need for additional convenience goods floorspace (sq.m.) for each growth scenario for the years 2009-2031 are set out in the extract from the Study below:

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4.5 The extract above shows that assuming a constant marketshare, there would sufficient available expenditure to support the convenience goods element of the application proposal by 2021 under two of the four population scenarios tested.

Comparison Goods

4.6 The household shopping survey undertaken in support of the CRS demonstrates that Truro acts a regional centre for comparison goods shopping. The household survey results show that Truro accounts for 20% of the comparison goods expenditure from the CRS Study Area, which encompasses the whole of Cornwall and western Devon. Applying a primary catchment to the household survey, encompassing zones 1-17 and 22, which excludes the most easterly zones which fall in Devon, Truro’s market share of comparison goods expenditure increases to 41% of total available expenditure. The second largest market- share is accounted for by St Austell (11%), closely followed by Penzance (10%). As such, it is clear that Truro is the dominant comparison goods retail centre in Cornwall.

4.7 Based on the CRS, the turnover of existing comparison goods stores in Truro from Zones 1-17 and Zone 22 equates to £581.63M per annum at 2014, which by 2019, will increase to £673.92M per annum. In assessing the current planning applications for retail floorspace in Truro, GVA have assumed that 80% of this expenditure is accounted for by the city centre, the remainder comprising out-of-centre retail stores and centres. As such, the city centre turnover is assumed to be £539.14M at 2019.

4.8 GVA examine the need for further floorspace in Truro in the CRS. They examine the ‘need’ for additional floorspase based on four population scenarios, ranging from high growth based on the National Housing and Planning Advice Unit, through to a zero new residential development across Cornwall. The need for additional comparison goods floorspace (sq.m.) for each growth scenario for the years 2009-2031 are set out in the extract from the Study below:

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4.9 The above demonstrates that for all scenarios, there is a need for considerable additional comparison goods floorspace. We contend that the most robust population scenario is the trend based growth which, according to GVA, results in a need for an additional 34,144 sq.m of comparison goods floorspace by 2021.

4.10 Whilst there has been comparison goods floorspace approved as part of a number of planning permissions across Cornwall since the CRS was prepared, the vast majority of these are outside of Truro. As such, whilst GVA highlight in their latest advice to the LPA that the need for additional comparison goods floorspace in Truro has been reduced by schemes such as the Trevithick Manor and Treloggan Road sites in Newquay clawing back expenditure from Truro, this has had the effect of reducing the need for additional floorspace in Truro rather than removing the need altogether.

Overtrading of Existing Stores

4.11 The table below is derived from the Study and sets out the floorspace composition of Truro city centre in 2008 and 2009:

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4.12 Based on the above and the average benchmark sales densities for typical town centre operators derived from Verdict (2014), it is possible to calculate a broad benchmark sales density of the comparison and convenience goods floorspace in Truro city centre. The table below summarises our estimates of these:

Floorspace (based on Benchmark Sales Benchmark 2009 derived from Density (£ per sq.m.) Turnover (£M) Study) (2007 Prices)

Convenience Goods 9,792 £1,750 £17.1

Comparison Goods 47,464 £5,928 £281.37

Total 57,256 N/A £298.5

4.13 Whilst the above is very crude as it is based on dated floorspace figures and our estimate of a realistic convenience goods benchmark sales density, it provides a useful barometer to assess the current performance of the city centre and the likely impact of the proposed development on it.

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4.14 As set out above, the market share in the CRS indicates that at 2014, the turnover of Truro City Centre is £474.25M. As can be seen from the above table, very crudely the comparison goods turnover of the city centre equates to approximately 133% the benchmark turnover estimate. Whilst this is a very crude estimate, it is clear that even with sensitivity applied to the level of floorspace present in the city centre or the benchmark sales density assumed, the city centre is performing well above ‘benchmark’ and can be said to be ‘over-trading’.

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5.0 The Sequential Test

5.1 The NPPF requires the assessment of proposals against the sequential test to site selection.

5.2 The NPPF requires applicants for all retail proposals outside of an existing centre to demonstrate that there are no sequentially preferable sites that are available, suitable and viable that could accommodate the application proposal. Suitable sites or buildings within existing centres should be considered first, then edge of centre locations and finally out of centre sites. In applying the sequential test, the decision taker has to have regard to accessibility and connectivity to the relevant town/city centre.

5.3 Before considering the proposals against the sequential test, it is important to consider the implications of the application proposals being directed to an alternative site. As set out in the Enabling Development Statement which accompanies the planning application, profit from the proposed development will fund the development of the approved stadium. As such, in applying the sequential test, any requirement for the application to be accommodated on an alternative site would, by virtue of the need to purchase it, reduce the profit from the proposed development. This is because any site which was identified as being sequentially preferable to the application site would attract a premium value compared to the application site. In such circumstances, the ability of the application proposal to enable the construction of the approved stadium would be severely compromised.

5.4 In light of the above, we contend that the enabling development benefit of the proposal should be a factor in the consideration of the application of the sequential test. This is best assessed against the viability criteria in the test, as the economic case in support of the proposed development needs not only to support the proposed development, but also the construction of the stadium.

5.5 Before considering the proposals against the sequential test, it is important to assess the relative merits of the application site and the need it is meeting. It is also crucial to be clear on the requirements of alternative sites to be able to accommodate the application proposals.

The Application Site

5.6 Prior to considering whether there are sequentially preferable sites to accommodate the application proposals, it is important to consider the relative ‘sequential’ merits of the application site.

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5.7 The application proposal is located to act as the ‘western district centre’, the need for which is identified in the GVA Cornwall Retail Study and is carried through into the Land North of the A390 Truro/Threemilestone Development Brief (“the Brief”), although as set out earlier in this assessment, the weight afforded to that document is limited.

5.8 Whilst the application site falls outside, but adjacent to the site boundary of the Brief, the proposals are fully integrated with the adjacent Langarth approved scheme. The application proposal is in effect an extension of the Brief area, increasing the level of residential development provided to meet the need beyond that identified in the Brief, but also making provision for public open space to facilitate the delivery of the Langarth approved scheme and the stadium proposal. As such, we contend that the proposal should be viewed as delivering the vision of the Brief. In this sense, we contend that the retail element of the application proposals meet the identified need and are in line with the spirit of the Brief, if not the specified boundary.

5.9 The Brief should not be treated as a development plan document, but rather an indication of what the LPA, at the time of preparing it in early 2012, considered to be ‘good planning of the area’. As set out earlier, the Brief directly reflected the planning applications submitted at that moment in time. As such, had the West Langarth proposal been submitted at that time, it is highly likely that it too would have been included within the boundary.

5.10 Since the Brief was prepared there have been a number of material changes in circumstances including the approval of the Langarth and stadium applications, and, crucially, the shortfall in funding for the delivery of stadium, which forms an integral part of the Brief. As such, we believe that in considering this application, the boundary of the Brief should be considered as being expanded to take account of the need for further development beyond that envisaged at the time of its preparation.

5.11 In terms of the application of the sequential test, the Brief does not specify the location of the anticipated district centre. As such, it can be said that any site within the Brief boundary is meeting the identified need for the western district centre. It is reasonable, therefore, to conclude that in applying the sequential approach within the area, all sites should be considered as being ‘equal’. Applying this principle to the assertion that the application proposal represents an evolution of the brief to reflect a material change in circumstances since it was prepared, means that the application site fulfils the requirements of the Western district centre and, therefore, satisfies the sequential approach.

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5.12 Our contention that the application site is meeting the need for the Western district centre is supported by an assessment of the application proposals against the criteria that GVA set out in the Cornwall Retail Study for the assessment of suitable sites to meet this need. GVA’s criteria are set out below:

“In order to ensure that any new centre is located where it can provide easily accessible facilities for the resident population, we consider that the decision on should be informed by geographical and accessibility factors. Given its importance, it is likely that convenience retail provision will form the basis for any new provision, supplemented by other day-to-day shopping and service facilities. We set out below (not in any order of importance) a basket of factors which we feel may be appropriate for the Council to take into account when considering the scale and location of a new defined centre:

(i). Geographical distribution of retail floorspace. This can identify which areas are best/worst served by retail provision.

(ii). Dominant shopping facilities, by area. Using shopping survey data, the analysis can identify which facilities are attractive to the residents and can establish the distances which local residents currently travel for convenience and comparison shopping.

(iii). Walk-in catchments. It is vital that new residential development in Truro/Threemilestone has easy and convenient access to retail facilities, especially convenience retail provision. Walking distances of 500 metres to 1km can be modelled to show areas which have good/poor accessibility on foot.

(iv). Drive-time catchments. Given the dominance of car-borne journeys, particularly for bulk/main-food shopping trips, it will be important to model 5 minute drive time catchments from existing stores and centres.

(v). Public transport accessibility. The walk-in and drivetime catchments should also be accompanied by an analysis of public transport routes which can establish the proximity of residential areas to public transport routes which serve retail provision.

The outputs from the above can then be mapped to show potential suitable locations for a new centre. Where such areas are identified, then the Council can consider other factors which cannot be mapped but may nevertheless be important factors. Such factors are likely to be individual to local area and the

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areas/developments concerned, although may include: impact on existing local businesses, accessibility, contribution to community vitality, contribution to local economy, visibility to passing trade and deliverability.”

5.13 In assessing the application proposals against GVA’s criteria, we conclude the following:

• The application is located such that will serve the existing and proposed community in Threemilestone in the same way that the alternative sites will;

• In terms of distance from the city centre, we contend as an expansion of Langarth, the site is equal to the alternative sites; and

• The CRS shows that there is a currently leakage of convenience goods expenditure from Truro to shops and centres further afield. This is largely to do with the limited choice of convenience goods provision and the over-trading of existing stores making them unattractive shopping destinations. This qualitative deficiency is particularly relevant to Threemilestone. Whilst comparison goods expenditure is largely retained by Truro and the city draws expenditure from a wide catchment, there remains a need for further floorspace, which we contend, cannot be accommodated within the city centre;

5.14 The application proposal is embedded within the approved Langarth residential scheme and the wider Threemilstone Development Brief area. The application has been designed to maximise linkage between the retail units and the surrounding residential areas, with a particular emphasis on creating a ‘boulevard’ style link and a ‘green’ pedestrian/cycle to the heart of the Langarth and beyond to the approved stadium proposal. As such, whilst it is to the west of Threemilestone, the attraction of the mix of uses and the physical linkages mean that the application site is delivering the vision set out in the development brief.

5.15 The application proposal is located within easy driving distance of a large proportion of the residents of Truro, but also, by virtue of its location directly adjacent to the A390, to people living to the west of Truro who are currently underserved by convenience and comparison goods floorspace. Of the ‘alternative sites’, the application site being situated to the west of the growth area means that it arguably best serves this element of the population.

5.16 The application proposal incorporates significant improvements to public transport provision which will serve the retail development but also the wider residential and leisure provision at the site. As such, we contend that the site is very well catered for by public transport links.

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5.17 In reality, it is evident that there is very little, if any, difference between the alternative sites when assessed against the above criteria. However, GVA also set out a number of other factors which might influence the choice of the location of the district centre. In considering these, the application proposal offers something above and beyond the alternative district centre proposals.

5.18 Firstly, the application is a mixed-use proposal, anchored by a supermarket, but also comprising non-food retail units, a public house/restaurant, a petrol filling station and a community sports facility. As such, the proposals make a significant contribution to community vitality and the local economy. In addition, as set out in the accompanying Enabling Development Statement, the application proposals will fund the delivery of the approved stadium proposal at the heart of the Brief site. As such, we assert that the wider benefit for the local community and economy resulting from this application is far greater than any of the alternative proposals.

5.19 In light of the above, the application proposal fulfils the western district centre role outlined in the brief. We assert that the proposals reflect the evolution of the growth of Threemilestone since the brief was prepared and that the difference between the alternative sites is so little that the brief area is not a particularly important consideration. Crucially, the brief also did not identify a specific location for the foodstore.

5.20 In light of the lack of weight afforded to the brief, the location of the foodstore should have more regard to the wider locational issues that GVA suggest should be taken into account when assessing the location of the district centre. Assessing the proposal against these criteria, we contend that the proposal comes out better than the alternative sites, particularly when the enabling development argument for the stadium, which is at the heart of the vision for the area, is taken into account.

5.21 In summary, we conclude that as the western district centre, the application meets the aspirations of the LPA and satisfies the requirements of the sequential test. Notwithstanding this view, for completeness, we have undertaken an assessment of the application proposals against the sequential approach.

The Search Area

5.22 In applying the sequential approach, it is important to consider the appropriateness of the area of search for alternative sites. The NPPF is silent on this matter, however, it is evident that the requirement for the site to be ‘suitable’ to accommodate the application proposals means that it must be suitable to meet the identified need.

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5.23 In this case, the proposed development fulfils the stated objective of the LPA to provide a district centre to meet the retail need identified in the Land North of the A390 Truro/Threemilestone Development Brief. This states that there is a need for the provision of “ new retail floorspace to meet the needs of existing and future residents in a form and of a size consistent with the findings of the Study of Retail provision in Cornwall carried out for the Council by consultants GVA Grimley in 2010 and to include a single medium sized new Foodstore. ” The Brief goes on to highlight that the 2010 GVA retail study indicates the need for a store “ probably not less than 2,500 sq.m. net but principally on the basis of geography, walking etc to serve fully the convenience needs of development on the whole of the area covered by the Brief and reduce need to travel to other stores. ”

5.24 The CRS confirms that there are “ likely to be opportunities for improved quality of provision both within the city centre and possibly to serve new large residential communities which are created by the extension of the Truro/Threemilestone urban area. ” It goes on to confirm that “The current successful trading performance, and potential overtrading of the main supermarkets in Truro, also contributes to the need for qualitative improvements in provision in the city. ”

5.25 In light of the above, it is clear that there is an acceptance by the LPA and their retail advisors, GVA, that the identified retail need can only be met by a site located in Truro, and more specifically in the Threemilestone area. As such, in considering the sequential approach, our search has been restricted to this area. To do otherwise would result in unsuitable sites being considered.

5.26 Having considered the search area, alternative sites are assessed against three criteria: availability, suitability and viability. These are considered in more detail below:

Availability

5.27 In relation to the availability of alternative sites, the NPPF requires the consideration of any edge or town centre sites which might be ‘available’. It does not seek to suggest that sites should be available during the remainder of the plan period or over a period of any specified number of years. Given the ethos of the NPPF, which is to “look for solutions rather than problems” and to facilitate and not frustrate economic growth, we contend that it is entirely reasonable to suggest that in the absence of any specific requirement to predict future availability, any alternative sites must be available to meet the identified need now.

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Suitability

5.28 Suitability, relates to whether the proposals can reasonably and successfully be located at a particular site. In considering the Dundee case, the Supreme Court ruled that ‘suitable’ means ‘suitable for the development proposed by the applicant’. Moreover, the principle that an applicant should alter or reduce the proposal so as to fit onto an alternative site has been explicitly rejected. These principles were explored in the recent Rushden Lakes call-in decision, where the Inspector stated:

“The policy concerning the sequential approach as set out in the NPPF, and (to the extent that it is still relevant) the non-policy PG that accompanied PPS4, must be applied in a manner which complies with the legally binding case law on the meaning of the sequential approach.”

5.29 The Rushden Lakes call-in decision provides a very clear statement on the balance between suitability and flexibility. It States:

“if a site is not suitable for the commercial requirements of the developer in question then it is not a suitable site for the purposes of the sequential approach; and [b] that in terms of the size of the alternative site, provided that the Applicant has demonstrated flexibility with regards to format and scale, the question is whether the alternative site is suitable for the proposed development not whether the proposed development could be altered or reduced so that it can be made to for the alternative site.”

5.30 The Rushden decision also provides clear guidance on the principle of flexibility and, in particular, disaggregation of proposals when considering the suitability of alternative sites. The Inspector stated (para 8.47):

“A related submission concerns the differences between national policy as now stated in the NPPF and as previously stated in PPS4. The last sentence of NPPF states that: “Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale.” This contrast strikingly with what was said previously in PPS4 in policy EC15.1 at (d) (iv) and 15.2 which contained an explicit requirement for disaggregation. There is no longer any such requirement stated in the NPPF. It is no answer to this to refer to the words “such as” in the last sentence of NPPF. These words cannot be read so as to imply that a major, and extremely controversial, part of previously stated national policy lives on by implication in the NPPF. Had the Government intended to retain disaggregation as a requirement it

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would and should have explicitly stated this in the NPPF. If it had been intended to carry on with the requirement then all that would have been required is the addition of the word “disaggregation” at the end of NPPF.”

5.31 The Rushden decision is clear, “ There is no requirement to disaggregate ” (para 8.51). In relation to what constitutes ‘flexibility’, the Rushden decision (para 8.49) highlights the absence of any clarification within the NPPF, but suggest guidance be drawn from the Guidance which accompanied PPS4:

“The NPPF requires developers to demonstrate flexibility on issues such as format and scale. No indication as to what degree of flexibility is required is contained in the NPPF. Such a requirement was previously contained in PPS4 and so any relevant PG advice continues to be material. PPS4 PG is of assistance: flexibility in a business model, use of multi level stores, flexible car parking requirements or arrangements, innovative servicing solutions and a willingness to depart from standard formats.”

Viability

5.32 Finally, in assessing sites ability to accommodate the application proposals, they should not present any obvious economic obstacles. As set out above, the application proposal will fund the construction of the approved stadium on the adjacent site. As such, in this instance, as it forms the premise of the application proposal, we contend that in assessing the financial viability of an alternative site, the need for the scheme to result in a profit which would fund the stadium should be a consideration.

Assessment parameters

5.33 For the purposes of the sequential test, sites have been which will be able to accommodate the below floorspace as proposed:

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Site Area 17.64 hectares – 4.65 hectares to accommodate 11,648 sq.m. (gross) of A1/A3/A4/A5/D1/D2 floorspace parking and servicing.

Parking Provision Up to 650 spaces

Operational Requirements Located within the Threemilestone area in order to meet the identified qualitative and quantitative need of existing and future residents of the western part of the city.

5.34 In line with the requirements of the NPPF, the applicant has adopted a flexible approach to above requirements. In considering the scale of development, the applicant has demonstrated flexibility by virtue of the fact that the applicant could have provided far greater retail floorspace than the site than is proposed. This is demonstrated by the fact that a large part of the site is taken up by public open space provision. In addition, whilst the application proposal does not currently propose any mezzanine floorspace, in assessing alternative sites, this option has been considered in order to reduce the footprint on the proposed development, maximising flexibility.

5.35 In relation to demonstrating flexibility through a reduction in the level of commercial development proposed, it is important to have regard to the enabling case being presented by the application proposal. As outlined in the Enabling Development Statement, which accompanies the application, profit from the proposed commercial development will be used to fund the development of the approved stadium on the adjacent. As such, reducing the size of the development proposed would reduce the profit generated from the scheme, which in turn would mean that there would be a shortfall in the funding required to develop the stadium. Accordingly, we contend that in this instance, there is good reason for the overall floorspace of the proposed development not being reduced in order that it might be accommodated on an alternative site.

5.36 In addition to examining the potential to reduce the overall floorspace of the proposed development, the applicant has also considered reducing the car parking requirement for the site. The applicant has also examined whether the introduction of different servicing arrangements to those proposed would enable the proposed development to be

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accommodated on alternative sites.

Conclusions Drawn from Other Applications

5.37 Prior to assessing the potential of other sites to accommodate the proposals, it is useful to consider the conclusions reached on sequentially preferable sites in respect of the three current planning applications in Threemilestone and, prior to them, the Taste of Cornwall/Waitrose application.

5.38 Whilst the conclusions reached on these applications are specific to the respective proposals, which differ from this application, their nature is identical; all being supermarket anchored schemes. Moreover, similar to the application proposal, the three current planning applications are all centred around Threemilestone. The only difference between the applications is the inclusion of additional non-food units. However, on the basis of the above assessment of the requirements of a site to be ‘suitable’, and the clear statement that proposals are no longer required to be disaggregated, we contend that comparison with the previously reached conclusions on the sequential test are valid, not least because even adopting a flexible approach, the size of the proposed development is considerably larger than any of the other proposals assessed.

5.39 In assessing the other retail applications in Truro, the Council’s retail consultants, GVA, and the Council have made a series of conclusions on the sequential test, which are relevant to this application. Crucially, the following sites were not considered suitable, available or viable alternatives to the Taste of Cornwall/Waitrose application:

• Pydar Street;

• Moorfield car park/former Sommerfield unit;

• Pannier Market;

• Old Bridge Street Car Park;

• Fairmantle Street Car Park;

• Halfords;

• High Cross Car Park;

• Garras Wharf; and

• TA Hall

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5.40 In considering the current retail proposals at Threemilestone, GVA reconfirmed that the above conclusions remain relevant, but they have also dismissed the following out-of-centre sites:

• Old County Hall

• Richard Lander School site;

• Newquay Road Retail Park; and

• Truro City FC

5.41 In light of the above, GVA have concluded that the only debate on sequentially preferable sites relates to the relative merits of the alternative application sites. We concur with this view.

5.42 Given the similarity in nature and location of the proposed development to the alternative application sites, and the establishment that disaggregation is no longer a requirement of the sequential approach, we contend that the above conclusions on the sequential approach apply equally to the application proposal. As such, the only sites considered relevant to the assessment of the application against the sequential approach are the current application sites, which are considered in detail below:

Alternative Application Sites

5.43 Firstly, in terms of the relative merits of the location of the three current planning applications, they are located on adjoining sites and GVA have confirmed that in relation to the respective distances and physical connection of the Willow Green, Langarth Farm, Maiden Green and Hendra sites with the city centre, “we do not consider it reasonable to single out one of these sites above the other” .

5.44 In considering the physical relationship of the respective current applications to the park and ride facility, GVA conclude that the neither the Willow Green or Hendra schemes are not afforded sequential advantage over the other because of proximity to the park and ride facility because of the close proximity of bus stops. This view is supported by James Findlay QC, representing the LPA, when he states that the “impact of the proximity of the Park and Ride is a matter of planning judgement and not of legal opinion” .

5.45 Finally, GVA have confirmed that Threemilestone is not considered a defined centre and, therefore, perceived connectivity from potential development sites to this area is not a

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matter for the “ proper application of the sequential approach ”.

5.46 In respect to the issue of ‘proximity’ to Truro city centre, James Findlay QC, representing the LPA confirms that it is “ relevant to the question of town centre linkage but it may not be determinative ”.

5.47 Finally in terms of the application of the sequential approach, James Findlay QC confirms that it is entirely legitimate for a Council to conclude that competing sites are equal.

5.48 In respect of the status of the Development Brief, James Findlay QC confirms that the Brief is “a material consideration and weight is a matter for the decision maker .” He goes on to confirm the view shared by Ian Dove QC, that the Brief does not allocate or specify any particular site for a foodstore.

5.49 James Findlay QC also sets out his view on the purpose of the Development Brief, stating:

“What the DB has done is gather the relevant principles, goals and objectives and has undertaken consideration of these against the specific circumstances of the location. The DB sets out at least one view as to what might constitute good planning of the area and to that extent is entitled to weight”.

5.50 In summarising the weight afforded to the Brief, James Findlay QC states:

“The Brief should not be treated like a development plan document but it can justifiably be had regard to”.

5.51 Crucially, in considering the relative merits of the three current application sites against the requirements of the sequential approach, GVA conclude that no single application was sequentially superior.

5.52 The above can be summarised as follows:

• Whilst the Development Brief is a material consideration, it merely sets out what ‘might’ constitute good planning in meeting the identified needs of the area;

• The respective distances and physical connection of the Willow Green, Langarth Farm, Maiden Green and Hendra sites with the city centre are considered equal;

• Threemilestone is not considered a defined centre and, therefore, perceived connectivity from potential development sites to this area is not a matter for the sequential approach; and

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• The three current applications are considered equal in terms of the sequential approach and that this a legitimate position for the LPA to adopt.

Summary and Conclusion

5.53 In light of the above, we contend that given that the application site forms an extension of the Langarth scheme, which is included within the boundary of the Brief, the application site should be considered on the same terms as the three current planning applications.

5.54 It is a competing scheme to accommodate the western district centre, the exact location of which is not fixed by the development plan or the Brief. Moreover, whilst a material consideration in applying the sequential approach, the weight afforded to the Brief is down to the decision maker. In this instance, we contend that the application proposal meets the needs of the Brief at a location which is no less connected or accessible then the three current applications. The Brief, which is now more than two years old, no longer reflects the scale of development required at Threemilestone to deliver the vision it contains.

5.55 In conclusion, we contend that the application site is entirely appropriate to meet the need the CRS identifies; it just does so in a location which falls outside of the Brief. However, the Brief cannot be treated as a development plan document and is afforded little weight. As such, assessed against the criteria set out in the CRS and in terms of the associated benefits of the application site, we contend that the application proposals meet the requirements of the sequential approach.

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6.0 The Impact of the Proposal

6.1 National planning policy guidance for retail development is set out in the National Planning Policy Framework (NPPF). Supporting guidance is provided in the Practice Guidance which accompanied PPS4. The NPPF states that retail proposals outside of town centre and not in accordance with an up-to-date development plan should assess:

• The impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and

• The impact of the proposal on town centre vitality and viability including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made.

6.2 In light of the above, we have undertaken an assessment of the likely impact of the proposals.

The Impact on Existing Stores and Centres

6.3 To assess the impact on existing stores and centres, we have undertaken an assessment of the likely trade diversion associated with the proposals. This assessment is based on the following:

6.4 Evidence Base - In order to maintain consistency with the authority’s retail strategy, the assessment is based on the GVA Cornwall Retail Study (“the CRS”). We have also taken into account the retail assessments undertaken in support of the three current planning applications in Truro which include elements of retail floorspace.

6.5 Study Area - For consistency the same Study Area adopted by Quod in the retail assessment in support of the Willow Green application has been adopted. This follows the Study Area set out in the CRS but excludes the most westerly zones which fall beyond what is considered to the catchment of the application proposals. The Study Area equates to zones 1-17 and 22 of the CRS. These zones represent where the application proposal will derive all of its turnover, however, some shops and centres, such as Truro city centre, will draw some of their trade from beyond this area. As such, in assessing the impact of the proposals, the turnover of existing shops and centres is considered an underestimate as it is based on turnover derived solely from the Study Area. Indeed, the CRS indicates that a further £19M would be attracted to Truro in 2014 from Zones 18-26 (excluding Zone 22).

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6.6 Population Projections - In light of the acceptance by the Council’s retail advisors, GVA, of the Experian based population projections used by Quod in their 28 th January 2014 revised assessment in support of the Willow Green application in Truro, and to provide a consistency for assessing the proposals, we have adopted the same population projections.

6.7 It should be noted, however, that Experian derived population projections are derived from the latest census information with growth applied in line with recent trends. As such, they do not necessarily reflect the future planned growth of the Study Area, not least the growth in and around the application site, which alone will add an additional 2,500 dwellings. As a consequence, we consider the population projection to 2019 to be an underestimate.

6.8 The population estimates for the respective Zones within the Study Area are set out in Table 1.

6.9 Price Base - For consistency with the Study, a price base of 2007 has been adopted.

6.10 Base Year - A base year of 2014 has been selected to reflect the year that the assessment is being undertaken.

6.11 Design Year - A design year of 2018 has been adopted. This reflects the five years projection that is widely accepted for the purposes of assessing impact.

6.12 Expenditure Per Capita Projections - In light of the acceptance by the Council’s retail advisors, GVA, of the per capita expenditure forecasts used by Quod in their 28 th January 2014 revised assessment in support of the Willow Green application in Truro, and to provide a consistency for assessing the proposals, we have adopted these per capita expenditure forecasts. These per capita estimates make an allowance for Special Forms of Trading. Expenditure Per Capita Estimates are set out in Tables 2A and 2B

6.13 Total Available Expenditure - The total available convenience expenditure per zone is set out in Table 3A . The total comparison expenditure estimates per zone are set out in Table 3B .

6.14 In light of the acceptance by the Council’s retail advisors, GVA, of the total available expenditure forecasts used by Quod in their 28 th January 2014 revised assessment in support of the Willow Green application in Truro, and to provide a consistency for assessing the proposals, we have adopted the same 10% inflow of convenience and comparison goods expenditure to each zone generated by ‘visitors’. These will principally be tourists, but will also include people from beyond the Study Area who undertake their shopping at shops and centres located within it.

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6.15 Turnover of Application Proposals - As set out in Section 2, based on the assumptions about the nature of the proposed development, the convenience and comparison goods turnover will be as set out below and outlined in Table 4 :

Net Sales Sales Density Turnover

(Sq.m) (£ per Sq.m) (£M)

Foodstore Convenience 2,536 9,308 23.61

Foodstore Comparison 1,087 9,340 10.15

Comparison Goods Units 3,716 3,525 13.10

Total 7,339 - 48.86

6.16 Existing Turnover of Stores and Centres - For consistency, we have adopted the market share estimates of existing stores and centres as set out in the CRS. This is based on the NEMS household survey undertaken in 2008. We have then applied the total available expenditure estimates to calculate the turnover of existing stores and centres at 2014 and 2019, assuming constant market share.

6.17 As the CRS does not differentiate between city centre and out of centre expenditure in Truro, following consultation with GVA, it has been assumed that 80% of the comparison goods turnover of Truro is derived from the city centre. This assumption has been applied by GVA in their assessment of the other current retail proposals in Truro and based on our own assessment of the balance between in centre and out of centre floorspace, appears robust.

6.18 As the CRS is based on a 2008 household survey, it allocates expenditure to the Somerfield store in Truro city centre which is now closed. As such, it is necessary to re-allocate this expenditure. For robustness, we have re-distributed this across the Study Area in accordance with the marketshare of each respective zone. Whilst this is the most robust way of dealing with this issue, it does, in our view, underplay that the majority of the turnover of the Somerfield store would be redirected to similar city centre stores. As such, by following the marketshare approach, the turnover of the remaining convenience goods stores in the city centre is understated.

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6.19 Finally, as we do not have access to the raw survey data and have relied on the published CRS, the marketshare of some zones dis not equate to 100%. Where this occurred, over or under representation was balanced across each zone in accordance with respective marketshare.

6.20 Table 5A sets out the convenience goods turnover of shops and centres at 2014. Table 5B sets out the convenience goods turnover of shops and centres at 2019 assuming constant market share.

6.21 Table 5C sets out the comparison goods turnover of shops and centre at 2014. Table 5D sets out the comparison goods turnover of shops and centres at 2019 assuming constant market share.

Solus Impact on Existing Convenience Stores

6.22 Table 6 sets out the solus trade diversion to the application proposal from existing stores, centres. Table 7 sets out the resultant impact of this diversion on the turnover of existing shops and centres and Table 8 sets out a summary of the solus impact.

6.23 Table 6 shows that we anticipate that a total of 17 stores would experience trade diversion following the introduction of the application proposal. Stores in a total of six towns will experience trade diversion to the proposal, although the majority of the diversion (74%) will be experienced by stores in Truro.

6.24 The greatest level of convenience goods diversion will be experienced by the two large supermarkets in Truro, Sainsbury’s (£8.5M) and Tesco (£7.55M). The third largest diversion is anticipated the Asda store in Penryn (£1.89M).

6.25 It is anticipated that Truro City Centre (including M&S, Iceland and the Co-Op) will experience a trade collective diversion of just £0.6M. This small level of diversion reflects the nature of the convenience goods shopping undertaken in the City Centre, which is principally top-up basket shopping rather than main-food, and the well-established principle that ‘like- effects-like’. As such, we contend that the majority of people predisposed to shopping in the city centre, who are already served by two large supermarkets, will not divert to the application proposal.

6.26 Table 7 indicates that the diffuse nature of the trade diversion and the over-trading of a number of stores, most notably the Tesco and Sainsbury’s stores in Truro, means that no single store will not experience a significant detrimental impact.

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6.27 Whilst Table 8 the Sainsbury’s, Tesco and Aldi stores in Truro will experience 26%, 17% and 17% solus impacts, the current performance of these stores means that they will all continue to trade at levels which will not threaten their on-going trading. Crucially, none of these stores are located in-centre and, therefore, are not afforded planning policy protection. This view that no store will close as a result of the impact of the proposals reflects the findings of GVA in their assessment of the other current retail applications in Truro.

Cumulative Impact on Existing Convenience Stores

6.28 For robustness, we have adjusted the current market share of shops and centres within the Study Area to take account of diversion of expenditure to the following commitments:

• Waitrose/Taste of Cornwall, Truro – New Store;

• Sainsbury’s, Falmouth – Redeveloped Store;

• Asda, Hayle – New Store;

• Tesco, St Austell – Extension;

• Morrisons, St Austell – New Store;

• Duchy Foodstore, Newquay – New Store;

• Trevithick Manor Mixed Use Scheme – Food Hall and Non-Food Units;

• Trellogan Road, Newquay – Non-Food Units; and

• St Columb Foodstore – New Store;

6.29 It should be noted that whilst the above represent schemes with live planning consents, a number of the schemes look highly unlikely to proceed within the next five years. As such, whilst these stores have been factored into the current market shares of the Study Area, it is considered that this is an unrealistic position and overestimates the cumulative impact resulting from the application proposals.

6.30 Table 9 sets out the trade diversion to the application proposal taking into account the presence of commitments. This shows that the introduction of the commitments and the resultant diversion from them means that the trade diversion from existing stores and centres is reduced. Reflective of the pattern of diversion to the commitments, the greatest reduction to the application proposal is experienced by the large supermarkets, most notably

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the Sainsbury’s and Tesco stores in Truro. However, the general pattern of trade diversion remains the same post introduction of the commitments.

6.31 Table 9 sets out the trade diversion from the committed development to the application proposal. This indicates that all of the committed development except the proposed extension to the Tesco store in St Austell will experience a trade diversion to the application proposal. The greatest level of diversion from commitments will be from the Waitrose store in Truro, which will experience a £1.95M trade diversion.

6.32 Table 10 sets out the diversion to the commitments and then the resultant cumulative impact of these and the application proposals on the turnover of existing stores and centres.

6.33 Firstly, Table 10 indicates that based on retail assessments which accompanied the respective applications, a total of £102M will be diverted from existing stores and centres to committed proposals within the Study Area.

6.34 The inclusion of committed development means that the trade diversion associated with the proposed development will be even more diffuse. The effect of this is to reduce the trade diversion from a number of stores to reflect that they will have lost an element of their trade to some of the commitments.

6.35 Table 10 indicates that greatest cumulative impact of the application proposal and the committed development, will be experienced by the Morrisons store in Newquay. This will experience a total trade diversion of £28.17M, equivalent to an 80% impact. The application proposal contributes just £0.47M of this cumulative impact and, therefore, will make no significant difference to the vitality and viability of the store.

6.36 In terms of Truro, which, as set out above, accounts for 74% of the solus diversion, the greatest cumulative impact would be experienced by the Sainsbury’s store, with a total diversion of £14.09M, equivalent to a 44% impact. The Tesco store will experience the second largest cumulative impact, with a £13.85M diversion, equivalent to a 31% impact.

6.37 In terms of the city centre, the nature of the committed development and the application proposals means that the cumulative impact remains low, with a total diversion of £1.15M from Co-Op, M&S and Iceland. This equates to a cumulative impact of just 12%. The application proposal contributes just £0.55M of this. As such, the level of cumulative trade diversion is not considered significant and cannot be said to have such an impact on centre as a whole that it would result in significant harm to its vitality and viability.

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6.38 The above conclusions reflect the advice from GVA on Waitrose/Taste of Cornwall proposal and the current planning applications in Truro, all of which have a higher convenience goods turnover than the application proposal. In respect of the Willow Green proposal, GVA estimate that the City Centre would experience a 7% solus impact and a 16% cumulative impact. However, they go on to concluded that:

“In deciding how these impacts will affect the health of Truro city centre we have taken into account the fact that the city centre is in a good state of health and is not reliant on convenience goods expenditure to maintaining its role and status, albeit that convenience goods expenditure does contribute to an important mix of uses in the centre. We have also taken into account the potential trading overlap, particularly in relation to comparison goods shopping, not least due to the size of the store.”

6.39 Crucially, GVA confirm that:

“it unlikely that one new supermarket (beyond Waitrose/Taste of Cornwall) would lead to the closure of the Co-Op and Marks and Spencer stores in the city centre.”

6.40 As such, in reaching a conclusion on the estimated convenience goods diversion from the Willow Green proposal of £1M, GVA state:

“it is our conclusion that the retail element of the Willow Green Farm proposal will have an adverse impact on the health of Truro city centre but it is contribution to the wider cumulative impact on the centre is unlikely to be significantly adverse.”

6.41 Given that we estimate that the convenience goods diversion to the application proposal from the city centre would be just £0.55M, we contend that the above statement from GVA is even more relevant.

Solus Impact on Existing Comparison Stores

6.42 Table 11 sets out the trade diversion from existing stores and centres to the application proposal. Table 12 sets out the resultant turnover of existing stores and centres following the diversion to the application proposals. Finally, Table 13 sets out a summary of the solus impact of the comparison goods element of the application proposals.

6.43 Before considering the impact of the application proposals on individual stores and centres, it is important to note that the growth in comparison goods expenditure in the Study Area between 2014 and 2019 will be £222M. To put this in context, the application proposal

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equates to just 10% of the anticipated growth in expenditure between 2014 and 2019. As such, in reality, rather than diverting existing turnover from shops and centres, the application proposal will absorb some of the growth in expenditure which, in theory, would otherwise lead to an increase in the turnover of existing stores and centres. This theoretical absorbing of expenditure relies on existing stores and centres continuing to develop and expand their offer in order to attract this new custom. The reality is that whilst some stores will achieve this, others will not, meaning that the additional expenditure per annum will be directed to new stores, or in their absence, shops and centres further afield.

6.44 The consequences of the above are that not all of the growth in expenditure will be taken up by existing stores and centres, meaning that it is available for new stores, such as the application proposal. As a result, the impact of the application proposals should not be viewed as a true impact; it is an impact on the theoretical future turnover of existing stores and centres. This difference between the likely actual impact and the theoretical impact based on constant market share is particularly important for a centre such as Truro, as the overtrading of the city centre means that the ability of existing stores to continue to absorb the growth in expenditure is limited

6.45 Notwithstanding the above commentary on the reality of trade diversion to the application proposals, we have, for completeness, assessed the impact of the proposals based on a constant market share.

6.46 In assessing the trade diversion to the application proposal, we have separated the comparison goods element of the foodstore and the non-food units. This is because the two respective elements will draw trade in very different ways. The comparison goods element of the foodstore will principally impact on similar foodstores whereas the non-food units will draw from out-of-centre store and will have a greater impact on the city centre as the type of retailers will be more similar than the offer of the foodstore.

6.47 As with convenience goods, the nature and location of the proposal means that the impact of the proposals will be diffuse, with a total of nineteen stores/centres experiencing trade diversions. Whilst centres as far away as Hayle will experience some diversion, the majority (78%) will be derived from stores located in Truro.

6.48 Out of centre stores in Truro will experience the greatest level of trade diversion from the application proposals, with a collective £9.24M being diverted. This reflects that the majority of the trade diversion associated with the comparison goods element of the proposed

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foodstore being from similar foodstores, most notably the Sainsbury’s and Tesco stores in Truro.

6.49 A considerable element of the trade diversion from the proposed comparison goods units will also be from foodstores, but existing retail parks will also be impacted upon. Whilst in isolation this level of diversion looks significant, when put into the context of the total turnover of these stores, it is equivalent to an impact of less than 7%. Moreover, even post- impact, the turnover of out-of-centre stores will be £9.22M higher in 2019 than in 2014.

6.50 The city centre will experience the second largest trade diversion, with a total of £8.96M expected to be diverted. However, this is equivalent to less than 2% of the total turnover of the city centre at 2019 meaning that the impact cannot be said to be significant. Moreover, the turnover of the city centre will be 12% higher in 2019 than in 2014 even with the application proposal coming forward.

6.51 As set out above, the reality of the anticipated trade diversion is that is it simply re-allocating a small element of the projected £27M growth in expenditure between 2014 and 2019 from a city centre which is already currently over-trading. The result is that, without exception, every store in the Study Area will increase their turnover between 2014 and 2019 despite the application proposal coming forward.

6.52 As with the convenience goods floorspace, in assessing the current planning applications for new retail floorspace in Truro, GVA have assessed the likely consequences of the trade diversion on the overall health of the city centre. GVA conclude that the Maiden Green proposals, which include a foodstore with 978 sq.m. of comparison goods floorspace and a further 1,995 sq.m of comparison goods units, would have a total comparison goods turnover of £18.8M. GVA estimate the impact of this proposal on the city centre is 3%. This compares to this application proposal, which we estimate would have a combined comparison goods turnover of £23.3M, just £4.5M higher than the Maiden Green proposal. In terms of impact on the city centre, as set out above, we estimate this to be 2%, so less than the impact expected from the Maiden Green proposal. As such, GVA’s conclusion that such an impact is “not seen as a significant adverse impact in its own right” must equally apply to this proposal.

Cumulative Impact on Existing Comparison Stores

6.53 Table 14 sets out the cumulative trade diversion from existing stores and centres and commitments. Table 15 sets out the trade diversion from existing stores and centres to the

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commitments and the cumulative impact of the proposals.

6.54 Table 14 sets out that committed development will divert a total of £44.5M from existing stores and centres. The vast majority of this (£24.7M) will be diverted from Truro City Centre, with a further £13.5M being diverted from Newquay town centre, the majority of which is accounted for by the Trevithick Manor proposal on the outskirts of Newquay.

6.55 Table 14 indicates that the greatest cumulative diversion will be experienced by Truro city centre. We estimate that post committed development, the diversion from the city centre to the application proposal will be £8.83M, and the resultant cumulative impact will equate to £33.53M. This is equivalent to an impact of 6.3%, but of more significance is that it equates to just 15% of the growth in comparison goods expenditure in the Study Area between 2014 and 2019.

6.56 As with the convenience goods cumulative trade diversion, the effect of the application proposal is to divert a small element of the growth in expenditure which would otherwise be directed to existing stores in the city centre, which are already overtrading. Crucially, even taking account of the cumulative impact of the application proposals and committed development, every centre, without exception, will increase their turnover between 2014 and 2019. As such, the application proposals can be accommodated without prejudicing the continued growth of existing stores and centres.

6.57 In assessing the consequences of the Maiden Green scheme, GVA conclude that the proposal would have a 3% solus impact on the city centre and a 8% cumulative impact. In so doing, GVA repeat the same conclusions as they did in respect of the Willow Green proposal that:

“On its own, an impact of 2%-3% from Willow Green Farm may not be seen as a significant adverse impact in its own right. However, it is part of a growing impact on Truro caused by the approval of retail schemes in surrounding settlements. The approval of schemes such as the Kingsley and Treloggan Road proposals in Newquay is seen by the Council as benefitting Newquay residents as it will enable shorter shopping trips and reduce leakage of retail expenditure to Truro. This obviously has a negative impact on the successful performance of Truro city centre, which is then further compounded by the impact of new out of centre floorspace in Truro such as Willow Green Farm. This situation requires a balancing exercise from the Council, balancing the perceived benefits to other settlements against the impact on Truro, leading to a reduction in its market share. Whilst a cumulative impact of 8% does not lead us to the conclusion that there is a significant cause for concern, large

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comparison goods areas in out of centre supermarkets in Truro do pose direct competition for the city centre.”

6.58 In light of this statement, GVA conclude:

“The retail element of the MGF proposal will have an adverse impact upon the health of Truro city centre but its contribution to the wider cumulative impact on the centre is unlikely to be significantly adverse.”

6.59 Given the small uplift in comparison goods turnover of the application proposal compared to the Willow Green proposal, and the fact the overall impact of the proposal is lower, we contend that the conclusions reached by GVA on the significance of the cumulative impact on the city centre apply even more so to this application than the others. As such, we cannot see how GVA can reach a different view on this application than they have on the others.

Total Impact on Truro City Centre

6.60 The NPPF does not differentiate between convenience and comparison goods sectors, referring instead to impact on the ‘centre’. As such, whilst the above assessment is important in terms of consumer choice, the real impact test is on the centre as a whole.

6.61 Table 16 sets out the solus and cumulative impact of the application proposals on Truro city centre as a whole. This sets out that the total solus impact of the application proposals on the city centre will be £9.67M, equivalent to an impact of just 1.75%.

6.62 Taking account of commitments, which as highlighted above are not all certain to be built- out, the cumulative impact on the city centre is £36.18M, equivalent to an impact of 6.56%. Crucially, in 2019 the turnover of the City Centre will be £38.14M higher than in 2014 even if all of the commitments and the application proposals are implemented. This means than existing stores and centres will increase their turnover or further new floorspace can be accommodated to meet this growth.

6.63 Crucially, the total growth in retail expenditure in the Study Area between 2014 and 2019 is £249.59M. The total turnover of committed development and the application proposal is £193.75M, leaving £55.84M to support growth in existing shops and centres across Cornwall or through the introduction of further new developments.

6.64 Whilst the application proposals will impact on the city centre, in light of the very small solus impact and the modest scale of the cumulative impact, and that the cumulative turnover of

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committed development and the application proposals can be accommodated through the growth in expenditure, it cannot be said that the application proposals would have a “significant adverse impact” on Truro City Centre.

Linked Trips

6.65 The location of the application site is commensurate with the principle of a twin Centre approach, linking the proposed District Centre functions with the Local Centre and Stadium hub located within the Langarth development. This combined attraction and the strong physical links between the respective ‘attractions’ will result in the prospect of linked trips both within the wider site, but also to the city centre.

6.66 The location of the application site, towards the western extents of Truro, will intercept vehicular trips to other stores or centres closer to the city centre. As such, the proposal will result in “trip chaining” whereby the application site becomes a waypoint for existing journeys to other retail centres, and particularly the City Centre. This breaking up of the journey to the City Centre will encourage people to stay for longer once there.

6.67 Allied to this, the Local Centre and Stadium hub uses are located adjoining the Park & Ride, and given this relationship, it is considered that the propensity to complete the last leg of the journey to the City Centre by Park & Ride bus service would be increased. Indeed, the ability to enter the Park & Ride from a rear access from the Northern Access Road, as foreseen within the Langarth development, would further increase this potential. In this respect, the application site would reinforce linkage with the City Centre by sustainable non-car travel modes.

6.68 As set out above, we believe that there will be degree of linkage between the proposal and the city centre which would benefit the existing retailers. In terms of the financial benefit associated with linked trips, our assessment of impact has made no allowance for linked trips to the proposed development and the city centre. However, it will occur and this will have the effect of reducing the level of impact on the city centre set out in the assessment.

6.69 Moreover, we have not made any allowance for the anticipated £0.8M per annum which would be spent in the city centre as a direct result of the Stadium for Cornwall being facilitated by this application. The effect of this would be to offset some of the trade diversion to the development. Finally, we have also not made any allowance for any element of the turnover of the proposed development being derived from people visiting the stadium. This would have the effect of reducing the trade draw from other stores, most

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notably those in the city centre.

The Impact on Planned Investment

6.70 In addition to the need to examine the impact in quantitative terms on the turnover of existing stores and centres, national guidance requires applications for retail development to consider the effect on planned investment within the study area.

6.71 The preceding analysis of the trade diversion associated with the application proposal indicates that the vast majority of the turnover of the proposed development (86% of convenience goods turnover and 65% of comparison goods turnover) will be derived from Zones 9-12. As such, in considering the impact on planned investment, we consider it appropriate to focus on these zones. Considering these zone, Truro City Centre is the focus of planned investment.

6.72 In relation to the first criteria, the Practice Guidance states that the key factors which will determine whether a proposal is likely to undermine committed or planned investment will include the effects on current/forecast turnovers, operator demand and investor confidence. The Practice Guidance sets out a checklist for measuring the effects on planned investment.

6.73 There are a number of sites which have been promoted through various forums over the past few years. The most significant ‘investment plan’ in recent years was the Truro and Threemilestone Area Action Plan (“AAP”) which was published in 2008. The AAP reached the preferred options stage, highlighting a number of potential sites for retail development, principally intended to meet the level of residential growth anticipated through the Regional Spatial Strategy for the South West. Following the revoking of the RSS and the resultant change in the level of residential growth and therein retail growth, the AAP was abandoned in 2009 after a period of public consultation.

6.74 Whilst the AAP was subject to a period of public consultation, it has not been progressed for several years. As such, we contend that the AAP is a draft document which did not progress beyond the early stages of development and which should, therefore, be afforded very limited weight.

6.75 One site which the AAP examined and which was saved under Policy 7Db of the Carrick Local Plan, is the former Council offices at Pydar Street/St Clement Street. Policy 7Db allocates the site for a mixed-use redevelopment to include retail uses alongside offices and residential. This allocation formed the basis of the site being considered in the AAP, which identified it as a “major opportunity for redevelopment for mixed-use development ”.

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6.76 In 2011 developers Stanhope purchased part of the Pydar Street site and made public their intention to work in partnership with the council to develop a £70 million 300,000sq ft retail scheme of 30 shops and restaurants. At the point of purchasing the site, Alistair Shaw, retail development director at Stanhope, stated that they intended to submit a planning application for within 12 months, with a start on site in 2013 and completion in 2015.

6.77 We understand that since 2011, Stanhope have held discussions with neighbouring land owners about the potential purchase of additional land.

6.78 Whether there is sufficient need - Since the abolition of PPS4, the demonstration of 'need' is no longer a policy requirement. As such, whilst we have not examined ‘need’, our assessment of impact identifies that Truro city centre and out-of-centre stores are currently overtrading to a significant degree. This indicates that there is a quantitative and qualitative need for additional floorspace. Whilst committed development will reduce this overtrading, it will not eradicate it and increasingly expenditure, particularly on comparison goods, means that the need for additional floorspace will remain. As a result, we contend that there is sufficient need to support the application proposal and any development at Pydar Street.

6.79 Whether the proposals are competing for the same market opportunity – Pydar street is a city centre opportunity, which, it is anticipated, will provide a wide range of retail and non- retail opportunities. The application proposal is a district centre location which will provide a large foodstore and a limited number of larger non-food units. The location of the application proposal at the western extreme of the city means that it will not provide an alternative to the city centre. Whilst it is anticipated that the type of retailer who would occupy the proposed development would not typically be found in city centre locations, any retailers who did so, would see the application proposal as complementary to their main city centre store. As such, the proposal is not competing with Pydar Street.

6.80 Evidence of retailer/investor/developer concern - The agents acting for Stanhope, the owners of part of the Pydar Street site have objected to the three current planning applications in Truro which include elements of retail floorspace. They contend that the proposed developments will ‘impact on the viability’ of the Pydar Street scheme. However, they present no evidence to substantiate this claim. Crucially, they also do not provide any evidence to confirm the progress which has been made since 2011 on the bringing forward of development at the site. As such, we conclude that the concerns raised

6.81 The cumulative impact of the proposals - As outlined above, at just 6.56%, the cumulative impact of the proposals is not considered to be significant. In terms of the turnover of the

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convenience goods floorspace, the overtrading of existing stores means that the proposals and the planned investment are effectively stripping out the overtrading in existing stores. This reflects the views of GVA in their assessment of the current retail schemes in Truro. Moreover, the cumulative impact should be seen in the context of the growth in available expenditure between 2014 and 2019, of which the cumulative turnover is equivalent to just 77%.

6.82 In light of the above, we conclude that the application proposals poses no threat to the delivery of further floorspace in Truro city centre.

Positive Benefits

6.83 The Practice Guidance which accompanied PPS4 made it clear that any adverse impacts should be balanced against the positive effects of the proposals in terms of; investment; employment generation, social inclusion; and physical and economic regeneration. This principle is also now present in the NPPF.

6.84 The proposals represent a multi-million pound investment and delivers the long-held council aspiration for the Western District Centre. The proposals a meet the quantitative and qualitative need identified in the CRS for additional floorspace in this part of Truro.

6.85 Based on the Drivers Jonas Deliotte Employment Densities Guide (2010), the proposals will generate 287 full time equivalent jobs. In addition to the direct employment associated with the proposal, there will be additional indirect jobs created through the construction phase and then in servicing the development once completed. The Stadium for Cornwall, enabled by the application proposal, will also generate between 114 and 448 full time equivalent direct and indirect jobs. As such, the total job creation will be close to 750. Of these, a large number will be derived locally and it is possible that the applicant could enter into a local labour agreement to ensure that a percentage of the jobs created are ring-fenced for the long-term unemployed.

6.86 Based on the above, the jobs created by the proposal will alone generate approximately £4M per annum in salaries. If the stadium proposal enabled by the application is added to this, the net economic benefit to the local economy will be in excess of £7M per annum.

6.87 The application proposal includes high quality sports pitches and a community/sports building that will be available to local people and groups. The proposals also make provision to accommodate the needs of the mobile library facility on site. As such, the proposals will deliver facilities which will promote social inclusion.

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6.88 The application enables the Stadium for Cornwall to be built. The Enabling Development Statement which accompanies the application sets out the benefits associated with the stadium, but it represents a once-in-a-lifetime opportunity to create a sporting arena capable of delivering a step-change in the performance of Cornwall’s professional sporting teams. The stadium makes provision for community use as well, creating a facility for local people and groups to benefit from. In considering the planning application for the stadium, the officer’s report to committee concluded that:

“..the scheme will have a positive economic impact representing a significant investment in sporting and leisure facilities for the locality, Truro and the County. It will also bring considerable job creation and training opportunities. It will provide a high quality all year round facility which will improve the attraction of the area ”.

6.89 In terms of the financial benefit of the Stadium to the area, the committee report relating to the scheme referred to an ‘annual gross direct effects’ of between £2.8M and £5.4M per annum. However, the report also highlighted that the Exeter Chief’s had ‘put £10M into the local economy between May 2010 and November 2011.

6.90 Whilst a great deal of the expenditure generated by the stadium proposal will be spent in and around the stadium itself, the economic assessment of the stadium proposal estimated that £0.8M per annum would be spent in the city centre as a result of the stadium being constructed. Moreover, this estimate was based on very conservative attendance figures, which the Cornish Pirates have confirmed they are confident can be exceeded.

Impact on Truro City Centre

6.91 The quantitative impact of the application proposals is considered above; the conclusion being that the solus and cumulative diversion is so small that it cannot be considered to be significantly adverse. Moreover, the above assessment concluded that the growth in comparison goods expenditure was more than sufficient to accommodate the application proposals and still leave surplus expenditure to support further growth across Cornwall. However, in addition to the quantitative impact on the city centre, it is necessary to assess the qualitative impact.

Diversity of uses

6.92 The table below sets out the findings of the 2012 GOAD survey of the City Centre:

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GOAD 2012

Number of Units Percentage Convenience 23 5.2% Comparison 200 45.5% Food and Drink 164 37.2% Vacant 53 12.1% Total 440 -

6.93 The above table demonstrates that convenience goods account for 5.2% overall retail provision. This is below the GOAD national average of 8%. At 2012 comparison goods equated to 45.5%, well above the GOAD national average of 33%. Food and drink units accounted for 37.2% compared to the GOAD national average of 47%. In 2012, vacant units accounted for 12%, which was in-line with the GOAD national average. It is highly significant, however, that a DPP survey undertaken in August 2014 only identified 14 vacant units within the city centre. This equates to just 3% of the total number of units, some 9% below the GOAD national average.

6.94 The above supports the view that Truro city centre is acting as the dominant regional shopping centre. It has a large number of comparison goods shops, many of which are occupied by national multiple retailers. The convenience goods offer is lower than the national average, but this reflects that a large proportion of this people shopping in the city centre are travelling from further afield to undertaken comparison goods shopping, whereas convenience goods shopping, by its nature, would be undertaken closer to home.

6.95 The extremely low number of vacant units supports the view that the city centre is vibrant and performing very well. This view is supported by a qualitative assessment of the city centre, which indicates that it is popular with local people and tourists. The centre combines a number of national multiple retailers such as Marks & Spencer’s, Next and Debenhams with very successful local retailers. The retail offer is also complimented by a wide range of food & drink units, which again combine national multiples such as Costa Coffee, Pizza Express, Starbucks and ASK with high quality local businesses such as 108 Coffee House, Bustophers, Lavenders Delicatessen and Grounded Coffee.

6.96 The City Centre provides an ideal mix of national multiples and independent businesses in a picturesque setting which creates a pleasant environment in which to shop and enjoy the many other attractions as well as taking in the many food & drink outlets. It is clear from spending time in Truro that is a vital and viable centre, which is performing very well and which could be a role model for the rest of the UK in creating a centre which is a unique

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‘destination’ rather than a characterless shopping centre.

6.97 In light of the above, it is clear that the ‘overtrading’ of the city centre as indicated by the household shopping survey results, is correct. The city centre is vital and viable and meets the shopping, leisure and food & drink needs of the residents of Truro and surrounding area. The offer of the city centre is very different to the application proposal, which whilst offering some of the uses present in the city centre, will be a very different destination due to the limited number of occupiers present, the location and nature of the environment, will create a complimentary rather than directly competing offer.

6.98 Whilst the application proposal will divert some expenditure from the city centre, the majority will be from shops and centres further afield. This, combined with the current overtrading of the city centre and the annual growth in available expenditure to support further floorspace, means that the city centre will continue to perform very well and no single store will be impacted upon to such an extent that closure will result.

6.99 Finally, as highlighted earlier in this assessment, and as outlined in more detail in the Enabling Development Statement which accompanies the planning application, the stadium development enabled by the application proposal will have a positive economic impact on the city centre. The work undertaken in support of the stadium proposal indicates that the gross direct financial benefit would be between £2.8M and £5.4M per annum. Of this, it was concluded that the city centre would benefit financially through supporters visiting the stadium be that ‘day-trippers’ or ‘staying supporters’, spending money in shops, restaurants, bars or hotels.

6.100 Based on a conservative average attendance, is anticipated that the stadium would result in a financial boost to the city centre of £0.8M per annum. It is of note that this figure is based on an attendance which the Cornish Pirates feel they can exceed. Moreover, this figure does not take account of those coming to Truro as a result of matches but not attending the game, such as other family members, the geographical location of Truro meaning that people are more likely to “make a weekend of it” than might be the case for games elsewhere.

6.101 Crucially, the majority of the income from rugby and football matches will be outside of the peak holiday season, providing a boost to the city centre at a quieter period for visitors. Finally, the above financial benefit to the city centre does not take account of other events which would be held at the stadium, which would draw people to Truro from across the county. Linked trips to the city centre whether utilising the park and ride facility or not, would result in a financial benefit to the city centre which it currently does not experience.

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6.102 The positive impact on the city centre associated with the stadium enabled by the application proposal will offset some of the trade diversion to the application proposal. Moreover, linked trips will occur between the application proposal, the stadium and the city centre. As such, by drawing people to the application site and/or the stadium, the proposals are making it more likely that people will then extend their trip to the city centre. As a result, we contend that whilst trade diversion will occur, the application proposals and the stadium they enable, will have an overall positive qualitative and quantitative impact on the overall vitality and viability of the city centre compared to the current position.

Summary

6.103 In summary, the above assessment of the impact of the proposals has shown the following:

• The convenience goods floorspace can be accommodated solely through the growth in expenditure in the Study Area between 2014 and 2019;

• The solus convenience goods impact of the application proposal will principally be from similar foodstores in Truro and beyond. The impact on the city centre of £0.6M cannot be considered significant;

• The cumulative convenience goods impact of the proposal on the city centre is just £1.15M, equivalent to a 12% impact, which is not considered significant;

• The application proposal is equivalent to just 10% of the growth in comparison goods expenditure between 2014 and 2019. As such, as with the convenience goods floorspace, the proposal could be accommodated solely through the growth in expenditure;

• The solus comparison goods diversion from the city centre of £8.96 is equivalent to an impact of just 2%;

• Even after the application proposal comes forward, the comparison goods turnover of the city centre is still 12% higher in 2019 than in 2014;

• The cumulative impact of the proposal and committed development on comparison goods stores in the city centre is equivalent to just 6.3% of 2019 turnover.

• The total impact of the application proposals on the city centre is just £9.87M, equivalent to a 1.75% impact on the 2019 turnover. Adding committed development to the trade draw means that the cumulative impact on the city centre

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is £36.18M, equivalent to a 6.56% impact;

• Taking account of committed development and the application proposals, the turnover of the city centre in 2019 will still be £38.17M higher than it is in 2014;

• The total turnover of commitments and the application proposals is the equivalent of just 77% of the growth in total expenditure in the Study Area between 2014 and 2019. As such, even taking account of the committed development and the application proposals, there remains £55.83M to support growth in existing stores and centres or the provision of further new floorspace without impacting on the current turnover of any store in the city centre;

• The application proposals will create opportunities for linked trips within Langarth and the Stadium for Cornwall but also to the city centre;

• The application proposals pose no threat to the delivery of further floorspace in Truro city centre;

• The application proposals will result in many positive benefits for the local area including the delivery of a much needed district centre; the creation of 287 jobs; the provision of sports and community facilities; the enabling of the Stadium for Cornwall and an economic benefit to the local area of £7M per annum; and

• Finally, Truro City Centre is vital and viable and is currently over-trading. As such, it is very well placed to continue to trade virtually unaffected by the application proposals.

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7.0 Summary and Conclusions

7.1 The application proposals will deliver the Western District Centre together with other community benefits, not least the Stadium for Cornwall. The integration of the proposals with West Langarth creates a twin-centre attraction ensuring accessibility from within Langarth and Threemilstone and maximising linked-trips.

7.2 This assessment has shown that the trade diversion associated with the proposals will have a minimal impact on the city centre, the majority of turnover being derived from supermarkets and out of centre stores. The assessment shows that the city centre is currently over- performing. Whilst this will be reduced if the committed development elsewhere in the Study Area is constructed, the growth in available expenditure means that there is still a need for additional floorspace in Truro. Moreover, it has been shown that the turnover of the application proposals can be met solely through the growth in expenditure between 2014 and 2019.

7.3 This assessment is based on the application proposals meeting the Council’s long-held aspiration for the development of the Western District Centre. We contend that is does this as an extension of the consented Langarth scheme and fulfils more of the Council’s requirements for the District Centre than any of the alternative sites.

7.4 The application proposals will divert some of the growth in available expenditure from the city centre, but even with the proposals it will increase it’s turnover compared to today. Moreover, the stadium enabled by the application proposals will also generate income for the city centre, which will offset the diversion to the proposed floorspace.

7.5 The proposals will create 287 FTE direct jobs and many more indirect opportunities. At least a further 144 FTE jobs will be created by the stadium proposal. The wages from alone will result in a significant boost to the local economy. We estimate that the economic benefit to the local area will be at least £7M per annum.

7.6 Finally, when read in conjunction with the Enabling Development Statement, which also accompanies the planning application, we contend that the positive benefits which the NPPF refers to as being a material consideration, far outweigh the limited number of dis-benefits, especially when considered against the alternative retail schemes.

7.7 In summary, the application proposals meet the long-held council aspiration for the Western District Centre. They meet an identified retail need the resultant trade diversion on the city centre is not considered to be significant. Moreover, the proposals will deliver significant

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economic, social and environmental benefits for the local community, in addition to which is the enabling of the Stadium for Cornwall, a once-in-a-lifetime opportunity to boost sporting excellence in the county. As such, the planning balance is clearly in favour of the proposals and planning permission should be forthcoming.

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Appendices

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