PRUPIM

PLANNING & RETAIL STATEMENT

Unit F, Springfield Retail Park, Haverfordwest

JCCxxxx vX Date

JPW0246 December2013

RPS Planning & Development

Planning & Retail Statement

QUALITY MANAGEMENT

Prepared by: KG/CT Proofread by: KG/RB Checked by: KG/RB Purpose: Final Date: 30 December 2013 Version: vA Project Number: JPW0246 Document Reference: Planning & Retail Statement

This report has been produced by RPS within the terms of the contract with the client and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

RPS Planning and Development Ltd. Registered in England No. 02947164 Centurion Court, 85 Milton Park, Abingdon, Oxfordshire, OX14 4RY. A Member of the RPS Group Plc.

RPS Planning & Development Ltd Park House Greyfriars Road Cardiff CF10 3AF T: 029 2066 8662 F: 029 2066 8622 E: [email protected] W: www.rpsgroup.com

Springfield Retail Park, Haverfordwest JPW0246: December 2013 i RPS Planning & Development Planning & Retail Statement

CONTENTS

QUALITY MANAGEMENT ...... i

CONTENTS...... ii

1 INTRODUCTION ...... 1

2 PLANNING POLICY CONTEXT ...... 7

3 ASSESSMENT OF DEVELOPMENT PROPOSALS ...... 11

4 CONCLUSIONS...... 31

APPENDICES

1 DECISION NOTICES

2 LETTER FROM JONES LANG LASALLE

3 PEMBROKESHIRE RETAIL STUDY (PRS) 2010 STUDY AREA PLAN

4 RETAIL ASSESSMENT STATISTICAL TABLES

Springfield Retail Park, Haverfordwest JPW0246: December 2013 ii RPS Planning & Development Planning & Retail Statement

1 INTRODUCTION

1.1 PREAMBLE

1.1.1 This Planning and Retail Statement has been prepared on behalf of Prudential Property Investment Managers Ltd (Prupim) in support of a s73 planning application for Unit F at Springfield Retail Park, Haverfordwest. The application seeks consent for the variation of conditions 5, 6 and 7 of planning permission 05/0316/PA (granted on the 7th April 2006) to allow Unit F to be occupied by Home Bargains and to allow an additional 140 sq m (1,500 sq ft) of floorspace through the installation of a mezzanine floor.

1.1.2 This report is intended to assist Pembrokeshire County Council in its consideration of planning and retail policy issues in its determination of the application. It has been prepared in accordance with the guidance set out in ‘Planning Policy Wales Edition 5 (November 2012)’, specifically Chapter 10 which deals with Planning for Retail and Town Centres. It seeks to evaluate the proposed development against national and local planning policies and to consider the retail justification and the implications to established trading patterns and the vitality and viability of Haverfordwest town centre.

1.1.3 This statement is not a stand alone document and should be read in conjunction with all other elements of the submission including the application forms, associated plans, design and access statement and transport statement.

1.2 SITE DESCRIPTION AND LOCATION

1.2.1 Springfield Retail Park lies on the northern edge of Haverfordwest approximately 1.5 km from the town centre and to the north of Withybush Hospital. Access to the Retail Park is gained via the A40 (Fishguard Road).

1.2.2 Current occupiers include Homebase (Unit A), Wickes (Unit B), Topps Tiles (Unit C), Carpetright (Unit C1) and Pets at Home (Unit D). There are two vacant units (Units E and F) located at the northern end of the retail park. This application relates to Unit F which provides 1,394 sq m (15,000 sq ft) of floorspace (GIA). Please refer to the Site Plan (Drawing No: JPW0080:02).

1.2.3 The retail units are arranged in a courtyard layout around a central car park of 431 spaces. There is also an area dedicated to motorcycle parking and 20 secure cycle parking spaces. The car park is divided into two sections with the access from the A40 running between the two.

1.3 PLANNING HISTORY

1.3.1 Outline permission for a bulky goods retail park (Ref: 05/0316/PA) was granted on 7th April 2006. Matters reserved for subsequent approval included design and external appearance, means of access and landscaping.

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1.3.2 The consent was granted subject to a number of conditions which include, inter alia:

• Condition 5 – the development shall not exceed a maximum net retail floorspace of 9,267 sq m and a gross floorspace of 9,754.7 sq m (incl. offices and non-retail floorspace). There shall be no provision of additional interior floorspace without the prior approval of the LPA.

• Condition 6 – The premises shall be used for the sale of Bulky goods including DIY, decorating goods and building materials, gardening goods and plants, furniture, household goods, carpets and flooring materials, motor and cycle goods, electrical items, pets and pet goods, tiles and camping and bulky outdoor leisure goods and for no other purpose in Class A1 of the Town and Country (Use Classes) Order 1987.

• Condition 7 – The premises shall not be used for the sale of food for consumption off the premises other than confectionary or for the sale of non-bulky goods unless a minor or ancillary part of any of the proposed units.

1.3.3 Reserved matters for design and external appearance were subsequently approved on 30th January 2007 (Ref: 06/0839/PA) and for landscaping and access/parking on 7th February 2007 (Ref: 06/0509/PA). Please refer to Appendix 1 for the Decision Notices.

1.3.4 In February 2007 Pembrokeshire County Council agreed to allow an increase in the gross floorspace to 10,321 sq m through the introduction of a mezzanine floor level for storage purposes in Unit A. The Council also confirmed that the requirements of the relevant conditions of the outline permission had been satisfied. Furthermore in November 2008 agreement was obtained from the local planning authority to subdivide Unit F (15,000 sq ft) into two units of 5,850 sq ft and 9,000 sq ft (Appendix 1).

1.3.5 In April 2011 an application was submitted by Prupim which sought consent to allow Units E and F to be occupied by Matalan and to allow the installation of a mezzanine floor to provide an additional 465 sq m (5,000 sq ft) of floorspace (Ref: 11/0025/PA).

1.3.6 The application was refused under delegated authority on 6th October 2011 for four reasons, namely (i) it was for the sales of non-bulky goods in an area identified for bulky goods; (ii) there was limited evidence of the quantitative need for the development; (iii) it was not shown that there were no other sites unavailable in or closer to the town centre; and (iv) it was considered that the development would have a detrimental impact on the town centre.

1.3.7 Following this refusal Prupim decided against pursuing an appeal as Matalan withdrew their interest from the property.

1.3.8 In March 2013 consent was sought to allow Unit F to be occupied by Home Bargains and an additional 140sqm of floorspace through the installation of a mezzanine floor.

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1.3.9 The application was submitted following positive discussions with a planning officer at the Council who advised informally that he didn’t envisage any issues with the Home Bargains application. This planning officer was the same officer who dealt with the Matalan application. Notwithstanding this the application (Ref: 13/0046/PA) was refused under delegated powers on the 21st June 2013 for essentially the same reasons as the Matalan application which include:

• The proposed development would result in the loss of floorspace intended for the sale of bulky goods and would increase the likelihood of other proposals being made for out of centre sites to accommodate bulky goods.

• Limited evidence has been submitted that there is a quantitative need for additional convenience goods floorspace in Haverfordwest. Similarly limited evidence has been submitted that there is a qualitative and quantitative need for additional comparison goods floorspace that cannot be met through a combination of smaller stores in and around the town centre.

• The supporting information has not adequately demonstrated that the application site is more suitable than sites in, or closer to Haverfordwest and has failed to demonstrate that the site has been selected using the sequential approach.

1.4 RATIONALE FOR THE PROPOSED DEVELOPMENT

1.4.1 Development of the Springfield Retail Park was completed in March 2008. Since this date Units E and F have remained vacant despite the fact that their availability has been widely marketed both in Wales and also nationally via Jones Lang Lasalle (previously King Sturge). The units were also marketed as pre-lets prior to the Retail Park being completed. A letter from Jones Lang Lasalle explaining their involvement in the site is attached at Appendix 2.

1.4.2 In order to try and improve the marketability of the units, planning permission was obtained in November 2008 to split Unit F into two units (please see paragraph 1.3.4 above). By doing this it was hoped to attract a wider range of tenants, however, since this date there has been little interest from potential occupiers.

1.4.3 As part of the marketing exercise all the nationwide bulky occupiers have been contacted, more than once. The availability of the units is also marketed on the PRUPIM pages of www.completelyretail.co.uk.

1.4.4 However the bulky goods sector has been very hard hit by the decline in the housing market with a number of bulky goods retailers failing and going into administration e.g. Focus DIY, Allied Caroets, Comet, MFI, Land of Leather, Furnitureland, Dreams and Klaussner. Indeed one of the tenants of Springfield Retail Park (Carpetright) was only able to take a unit as the landlord of Withybush Retail Park helped to fund the cost of their move and took a surrender of the lease of their previous unit.

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1.4.5 It is clear therefore that there is limited demand for bulky goods occupiers in Haverfordwest and the slight upturn in the economy and the strengthening housing market shows no sign at present of benefitting the bulky goods retailers to the extent that they are looking to acquire new stores again. Both units E and F at Springfield Retail Park have been very widely marketed and on very competitive terms, however, despite extensive marketing attempts over several years, there is no demand for the vacant floorspace at Springfield Retail Park with the existing trading restrictions. It appears that one of the major problems in attracting new tenants to Haverfordwest is the distance of the town from their existing portfolio of stores and the associated higher costs of servicing the stores.

1.4.6 Notwithstanding this Home Bargains has a requirement for a store in Haverfordwest and are the only occupiers to have shown any real interest in locating at the retail park since the application for Matalan was refused in October 2011. There is only one Home Bargains store in Pembrokeshire at Milford Haven (8 miles away) and the nearest other store is at Carmarthen (29 miles away).

1.4.7 Home Bargains is a discount/value retailer whose parent company, TJ Morris Ltd, was established in Liverpool over 35 years ago. It is one of the UK’s fastest growing retailers and currently has a portfolio of over 300 stores, the majority of which are spread across the north of England, as well as South Wales, London and central England. The company has plans to expand to over 700 stores by 2018. Currently the firm employs over 8,000 staff.

1.4.8 Home Bargains’ business model is to sell branded goods at heavily discounted prices, typically between 10% and 30% cheaper than elsewhere. Approximately, 70% will be regular stock and the remaining 30% one-off lines that will be constantly changing and sold on a ‘when it’s gone, it’s gone basis’. The core range of products comprise the following:

• Health and beauty products • Medicines • Baby products • Household products • Toys and games • Pet food • Home furnishings and ornaments • Seasonal products • Ancillary food and drink products • Limited clothing range

1.4.9 While the company’s offer is geared towards non-food comparison goods, their stores also sell a limited range of food and drink products as an ancillary offer to their core product range. These products generally do not make up more than 25% of the store’s sales floorspace, although given the slightly higher sales density associated with convenience goods, we estimate that a 75:25 non-food/food floorspace split would equate to a 70:30 turnover split.

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1.4.10 The complete range of non-food and food products is essential to attract customers to the store, based on a very specific business model. Every product range is essential in providing the appropriate synergy within the retail unit and provides a commercially viable store for the prospective occupier. It is not possible to disaggregate this product range to separate smaller units as it would not provide the required critical mass of products within the store. Neither is it viable to exclude any of the above goods from being sold without rendering the business model unviable.

1.4.11 Home Bargains require a store of around 16,500 sq ft which can be achieved with the construction of a 1,500 sq ft mezzanine floor. This application therefore seeks permission to allow Unit F to be occupied by Home Bargains and to allow the installation of a mezzanine floor to provide an additional 1,500 sq ft of floorspace. This application does not however cover works to the external elevations, which will be dealt with separately.

1.4.12 A typical Home Bargains store of the size proposed would be expected to generate in the region of 50 full and part time jobs. The majority of these jobs will be available to local people, and the positions will cover a range of scales and in addition to jobs within the store itself, other employment opportunities will be created. These include jobs created by the store fit out and merchandising the store, and jobs involved with the future maintenance and security of the unit.

1.4.13 Home Bargains require a high quality shop fit out which will result in an investment in the local economy of around £500,000. Therefore, the proposal will generate significant socio-economic benefits arising from the proposals if approved, and will bring a vacant unit back into beneficial use.

1.4.14 Under the terms of this planning application therefore, we suggest that conditions 5, 6 and 7 of planning permission 05/0316/PA be varied as follows:

Condition 5

1.4.15 The development hereby permitted shall not exceed a maximum gross floorspace of 10,461 sq.m (including offices and non-retail floorspace). There shall be no provision of additional interior floorspace without the prior approval in writing of the Local Planning Authority.

Condition 6

1.4.16 The premises shall be used for the sale of Bulky goods including DIY, decorating goods and building materials, gardening goods and plants, furniture, household goods, carpets and flooring materials, motor and cycle goods, electrical items, pets and pet goods, tiles and camping and bulky outdoor leisure goods and for no other purpose in Class A1 of the Town and Country (Use Classes) Order 1987 except for Unit F, as identified on Drawing No. JPW 0080:02, where a maximum of 25% of the net sales area may be used for the sale of health and beauty products, medicines, toys, arts and crafts and seasonal items.

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Condition 7

1.4.17 The premises shall not be used for the sale of food for consumption off the premises other than confectionary unless a minor or ancillary part of any of the proposed units except for Unit F, as identified on Drawing No. JPW 0080:02, where a maximum of 25% of the net sales area may be used for the sale of predominantly (90%) ambient food and drink (Class A1).

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2 PLANNING POLICY CONTEXT

2.1 INTRODUCTION

2.1.1 This section of the statement summarises the relevant national and local planning policies pertinent to the application proposal.

2.1.2 Section 70 of the Town and Country Planning Act 1990 states that in dealing with an application for planning permission the local planning authority shall have regard to the provisions of the development plan. Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that the determination must be made in accordance with the plan unless material considerations indicate otherwise. In this instance the Development Plan comprises the Pembrokeshire Local Development Plan (LDP) which was adopted on the 28th February 2013.

2.1.3 Other material considerations comprise Planning Policy Wales (PPW) (Edition 5, November 2012) and Technical Advice Note (TAN) Wales 4 ‘Retailing and Town Centres’ (November 1996).

2.2 PEMBROKESHIRE LOCAL DEVELOPMENT (LDP) 2013

2.2.1 As explained above the local planning policy context for the application site is provided by the recently adopted Pembrokeshire Local Development Plan. The application site is shown as being located within the settlement boundary (Policy SP13) on the LDP Proposals Map but is not allocated for any particular use. In the context of the proposed development the policies of the LDP, which may be considered relevant, are outlined below.

2.2.2 Policy SP4 of the LDP identifies Haverfordwest as a sub-regional centre in the retail hierarchy for Pembrokeshire and advises that all new retail and leisure development should be consistent in scale and nature with the size and character of the Centre and its role in the retail hierarchy. The supporting text to this policy notes that proposals within Haverfordwest should make a positive contribution to its role as the county town and a sub-regional town centre.

2.2.3 Policy SP12 further identifies Haverfordwest as a ‘Hub Town’ for which a range of development and land uses are likely to be accepted. Paragraph 5.66 of the LDP explains how Haverfordwest, which is the county town of Pembrokeshire, is located in the centre of the county with good road links to all areas within Pembrokeshire and strong road and rail connections to the rest of south and west Wales and beyond.

2.2.4 It further explains that it is the main administrative centre of Pembrokeshire with significant further education/higher education and healthcare provision and that the role of Haverfordwest as a sub regional Centre will develop over the plan period, with growth in population, employment opportunities and an improved retail offer.

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2.2.5 The LDP proposals map identifies the application site as being located within the settlement boundary under Policy SP13. The supporting text to this policy (para 5.63) explains that settlement boundaries define the areas that have a physical, functional and visual connection to a settlement. It goes on to explain that a settlement boundary ensures that development takes place in sustainable locations and that the natural environment is protected.

2.2.6 Policy GN.14 deals with proposals for major out-of-town development and explains that such proposals will only be permitted whether the development would not undermine the retail hierarchy and the development either by itself or in combination with other permitted or allocated retail developments would not undermine the vitality and viability of the town centres.

2.2.7 Policy GN.13 allocates a site on the edge of Haverfordwest town centre for new retail development. The site, which is occupied by the Fred Rees Skoda Dealership, covers an area of 0.31 hectares and is allocated for a mix of comparison units to meet an identified need. This site is considered in detail in the following section.

2.2.8 As part of the Evidence Base for the LDP, the Council commissioned GVA Grimley to produce a County-wide Retail Study, which was published in March 2010. The report explains that the overall aim of the study is to provide a single evidence base to inform the retailing and town centres section of the LDP, including its strategy, area-wide policies and reasoned justification. It further explains that the study is also intended to provide the Council with a robust evidence base to make development control decisions on planning applications for retail development and specific allocations of land for retail development within the town centres. The content of this study is highly relevant to the consideration of applications for further retail floorspace, and therefore an analysis of its findings and implications for the application scheme is set out in the following section.

2.3 PLANNING POLICY WALES (EDITION 5), FEBRUARY 2012

2.3.1 The fifth edition of Planning Policy Wales (PPW) was published in November 2012 and sets out the land-use planning policies of the Welsh Government. PPW is supplemented by a series of Technical Advice Notes (TAN’s). As such, PPW and TAN’s form a material consideration in the determination of this application.

2.3.2 The recently revised Chapter 7 of PPW recognises the role that retailing plays in supporting the economy of Wales and advises “For planning purposes the Welsh Government defines economic development as development of land and buildings for activities that generate wealth, jobs and incomes. Economic land uses include the traditional employment land uses (offices, research and development, industry and warehousing), as well as uses such as retail, tourism, and public services” (Para 7.1.1).

2.3.3 Paragraph 7.1.2 goes on to advise that it is essential that the planning system considers, and makes provision for, the needs of the entire economy and not just those uses defined under parts B1-B8 of the Town and Country Planning Use Classes Order.

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2.3.4 PPW further advises at para 7.1.3 that the planning system should support economic and employment growth alongside social and environmental considerations within the context of sustainable development. To this end, the planning system, including planning policies, should aim to ensure that the growth of output and employment in Wales as a whole is not constrained by a shortage of land for economic uses.

2.3.5 PPW also advises that local planning authorities should aim to steer economic development to the most appropriate locations, rather than prevent or discourage such development (paragraph 7.1.4) and that Local planning authorities should ensure that the economic benefits associated with a proposed development are understood and that these are given equal consideration with social and environmental issues in the decision- making process, recognising that there will be occasions when the economic benefits will outweigh social and environmental considerations (7.2.2).

2.3.6 PPW also notes that Local planning authorities should adopt a positive and constructive approach to applications for economic development and that in determining applications for economic land uses authorities should take account of the likely economic benefits of the development based on robust evidence (paragraph 7.6.1).

2.3.7 Chapter 10 of PPW addresses “Retailing and Town Centres”, explaining at paragraph 10.1.1 that the Welsh Government’s objectives are to:

• Secure accessible, efficient, competitive and innovative retail provision for all the communities of Wales, in both urban and rural areas; • Promote established town, district, local and village centres as the most appropriate locations for retailing, leisure and other complementary functions; • Enhance the vitality, attractiveness and viability of town, district, local and village centres; and to • Promote access to these centres by public transport, walking and cycling.

2.3.8 Local authorities are advised in paragraph 10.3.1 to consider the following issues when considering planning applications for retail proposals including redevelopment, extensions or the variations of conditions: -

• Compatibility with any community or up-to-date development plan strategy; • Need for the development/extension, unless the proposal is for a site within a defined centre or one allocated in an up-to-date development plan; • The sequential approach to site selection; • Impact on existing centres; • If redevelopment is involved whether it involves a net gain in floorspace and whether or not it is like-for-like in terms of comparison or convenience; • The rate of take-up of allocations in any adopted development plan; • Accessibility by a variety of modes of travel; • Any improvements to public transport; • The impact on overall travel patterns; and • The best use of land close to any transport hub, in terms of density and mixed use.

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2.3.9 Paragraph 10.3.3 advises that where need is a consideration, precedence should be accorded to establishing quantitative need. It will be for the decision-maker to determine and justify the weight to be given to any qualitative assessment. It goes on to advise that regeneration and additional employment benefits are not considered qualitative need factors in retail policy terms, though they may be material considerations in making a decision on a planning application.

2.3.10 PPW further explains at paragraph 10.3.4 that developers should be able to demonstrate that all potential town centre options, and then edge of centre options, have been thoroughly assessed using the sequential approach before out-of-centre sites are considered for key town centre uses.

2.3.11 Chapter 8 of PPW relates to transport issues and outlines that when determining applications for development, Local Planning Authorities should take into account a number of factors including the impacts of the proposed development on travel demand; the accessibility of the site by a different range of transport modes and the effects the development may have on the safety and convenience of other users of the transport network.

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3 ASSESSMENT OF DEVELOPMENT PROPOSALS

3.1 NEED

3.1.1 As has been noted in the previous section of this statement, current national planning policy makes it clear that a demonstration of need is a pre-requisite for any retail development unless the development is in accordance with an up-to-date development plan. Such ‘need’ may be expressed in either quantitative or qualitative terms, although Planning Policy Wales clearly states that quantitative need is the most important factor.

Quantitative Need

3.1.2 Quantitative need can be assessed via a retail capacity study, whereby the amount of available expenditure within a defined area can be compared against the turnover of existing (and committed) stores, so as to ascertain whether there is any surplus of expenditure that could potentially accommodate additional floorspace.

3.1.3 A County-wide ‘Pembrokeshire Retail Study’ was carried out by GVA on behalf of the County Council and published in March 2010 to form part of the evidence base for the Local Development Plan. Our retail assessment has therefore been based on the Pembrokeshire Retail Study (PRS) and updated where appropriate where more up-to- date information is available.

3.1.4 The PRS used a 13 zone study area based on postcode sectors, of which the urban area of Haverfordwest is situated in Zone 6 (postcode sectors SA61 1/2). A copy of the study area plan is attached at Appendix 3.

3.1.5 Our methodology follows the same steps used in the PRS assessment as well as the Retail Impact Assessment prepared by White Young Green (WYG) in support of the Sainsbury store at Slade Lane which was granted planning permission in September 2013 (Ref: 12/0829/PA). These include:

• Establish intended design year, price base and extent of the study area; • Assess present and projected population within study area and present and projected levels of per capita expenditure for comparison goods; • Multiply per capita expenditure by population to derive total available expenditure generated within study area; • Assess notional (company average) turnover of existing stores within the study area; • Deduct existing turnover from available expenditure to arrive at residual expenditure figure; • Estimate likely turnover of proposed new store and compare with residual expenditure figure.

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Study Area

3.1.6 The study area adopted is the same as the PRS. A plan extracted from the PRS that shows the study area is enclosed at Appendix 3.

Design Year and Price Base

3.1.7 The base year for the assessment is 2014 and the design year for the assessment of the proposed store is 2019. The chosen design year is considered realistic assuming planning permission is granted early to mid-2014 and store fit out is late 2014. Assessing the position five years ahead is in accordance with standard retail assessment methodology. All monetary values are expressed in 2007 prices to be consistent with the PRS (2010).

Population and Expenditure

3.1.8 Base data on population has been derived from the PRS. Population estimates are provided in Table 1 of the statistical tables that are enclosed as Appendix 4 (all tables from herein can be found there). The PRS population estimates are derived from Experian Business Strategy Reports, with adjustments made to allow for growth in each zone based on Welsh Government figures and assumptions on housing distribution. The figures for 2009, 2014 and 2021 are taken directly from the PRS.

3.1.9 Tables 2a and 2b illustrate the expenditure per capita for comparison and convenience goods, respectively, in the study area. The figures used in the PRS were based on 2009 baseline figures, but in order to provide a more robust analysis we have obtained 2011 figures for each zone from Experian. Appropriate deductions have been incorporated at each year for spending by special forms of trading (non-store purchases), utilising Experian’s forecasts of the market share of non-store retail sales detailed in their ‘Retail Planner Briefing Note 11’ (October 2013). The growth in spending 2011-2021 assumes Experian’s latest growth forecasts for convenience and comparison spending from their ‘Retail Planner Briefing Note 11.

3.1.10 Tables 3a and 3b combine the population figures in Table 1 with the expenditure per capita figures in Tables 2a and 2b to provide the total spending generated by residents in the study area on both comparison and convenience goods. It shows that at 2014 the available comparison goods expenditure within the study area will be £341m, of which £36.6m is within Zone 6 (Haverfordwest). This is estimated to rise £390.5m and £41.9m respectively at 2019. In terms of convenience goods expenditure that is estimated at to be £232m at 2014 rising to £243.8m in 2019; within just Zone 6 the available spend is £22.5m rising to £23.7m in 2019.

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3.1.11 The latest retail impact assessment considered by the Council, for the proposed Sainsbury Store at Slade Lane, also utilised the PRS study area, but included an allowance for spending by tourists, which was accepted by the Council’s consultants Applied Planning. We have therefore adopted the same methodology and figures for tourist spending as the Sainsbury assessment and these have been incorporated in our Tables 3c and 3d, which detail the total available spending within the study area, from residents and tourists. The comparison spend increases to £378.3m at 2014 and £433.7m at 2019, and the convenience to £249.4m in 2014 and £263.9m at 2019.

Turnover of Existing Floorspace

3.1.12 Table 4 details Haverfordwest’s market share of the available convenience goods spending within the study area. It can be seen that in relation its ‘home zone’ (Zone 6), Haverfordwest is retaining 98.9% of local spending. Table 5 applies the market shares in Table 4 to the available spending in Table 3d to show the actual convenience goods turnovers of existing stores in Haverfordwest. In total the existing stores are turning over £76.7m, which is forecast to rise (assuming a constant market share) to £81m in 2019.

3.1.13 Table 6 then sets out Haverfordwest’s market share of available comparison goods spending and shows that 81% of local spending is being retained. Post 2014 we have incorporated minor amendments to the share of spending that out-of-centre stores capture from Zones 4, 5 & 6. The adjustments mirror those adopted by WYG in the analysis they undertook for the proposed Sainsbury Store: we believe they are reasonable and necessary given the additional retail floorspace already committed in Haverfordwest, which will increase the attractiveness of the town as a retail destination. Table 7 then applies those market shares to the available spending (from Table 3c) to show the comparison turnover of stores in Haverfordwest: at 2014 this totals £181.1m at 2014 rising to £211.5m at 2019.

3.1.14 Table 8 then sets out the benchmark comparison goods turnovers of existing and committed floorspace in Haverfordwest. The floorspace and sales densities are taken from the PRS, with allowance for growth in floorspace efficiency as per Experian Retail Planner Briefing Note 11. We have also incorporated changes that have taken place since the PRS was produced: these include Topps Tiles entering Springfield Retail park; Boots and Debenhams at Withybush Retail Park and Allied Carpets closing at Bridge Meadow. In relation to Debenhams, adopting the company’s latest company average sales density from Retail Rankings 2013, that new store turns over £4.5m. However it should be noted that the store replaces an MFI that previously occupied this unit, which had an estimated turnover of £2.7m. Allowing for this previous turnover, the new Debenhams therefore provides a net uplift of £1.8m. That is less than the uplift assumed by WYG in their impact assessment for the proposed Sainsbury Store. WYG applied a sales density of £2787/sq m for Debenhams and the latest Retail rankings 2013 shows the correct company average is actually £2249/sq m (in 2007 prices). WYG therefore assumed the uplift from Debenhams taking the former MFI unit was in the region of £2.9m, when in fact it is only £1.8m.

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3.1.15 Table 8 also details the turnover of committed comparison floorspace, which comprises the recently approved Sainsbury Store and the proposed development in the town centre at Ebeneezer Row: this latter development has not yet been given planning permission and therefore should not really count as a commitment, however we have included it in our analysis for the sake of robustness. The Sainsbury store is expected to turnover £12.7m from comparison goods, which is 80% of its company average level: WYG’s retail assessment in support of the planning application made clear that Sainsbury expect the store to trade at 80% of its benchmark level, in part due to the lack of convenience goods expenditure capacity in Haverfordwest.

3.1.16 The proposed development at Ebeneezer Row is expected to turnover £6.7m at 2014: that assumes the 1981sq m of gross floorspace being proposed has a net to gross ratio of 70% (1387sq m net sales) and trades at the same sales density as that assumed for other shops in the town centre. It should be noted that in the WYG impact assessment produced for the recently permitted Sainsbury store, WYG (who are also the consultants for the Ebeneezer Row application) assumed a turnover of £8.9m for Ebeneezer Row, or £9m when converted to our 2007 price base. That is £2.3m more than our estimated turnover (£6.7m) for the development. The principal reason for this is an error in WYG’s impact tables where they have assumed the net sales area of the Ebeneezer Row development will be 1981sq m, when the drawings submitted with the application, and the description of development in the impact assessment, both explicitly say that 1981sq m is the gross internal area. In applying their assumed sales density to the gross floorspace WYG therefore over-estimate the turnover of the development.

3.1.17 It is important to note that the Council have granted planning permission for the proposed Sainsbury store, in part on the basis of the capacity and impact assessment undertaken by WYG. As highlighted above that analysis assumed a turnover for the Ebeneezer Row scheme of £8.9m and a net uplift from the new Debenhams at Withybush of £2.9m i.e. a total quantum of £11.8m. In fact, correcting errors in the calculations and using the latest sales density for Debenhams, the actual total quantum of these two schemes is £8.5m. That is £3.3m less than allowed for in the Sainsbury report that the Council subsequently granted permission. The comparison turnover of the proposed Home Bargains, which is only £2.2m, could therefore be approved and the final capacity position would still be better than the Council understood would be the case when they granted permission for the Sainsbury store.

3.1.18 The changes that have occurred since the PRS was produced include allowance for the closure of Allied Carpets, with the vacant unit assumed to have a turnover of £2,695 per sq m, nearly double that of Allied Carpets. Unit 2 at Withybush Retail Park is now occupied by Boots so allowance for a benchmark turnover of £5,390 per sq m has been allowed for rather than £2,558 sq m. Allowance has also been made for the occupation of Unit D at Springfield Retail Park by Topps Tiles, with a sales density of £1,655 per sq m rather than the £2,558 per sq m assumed by the PRS when the unit was vacant.

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3.1.19 It should be noted that allowance has already been made in the PRS (2010) for the application site at Springfield Retail Park (Unit F). An assumed sales density for the unit of £2,695 per sq m has been applied, resulting in a turnover of £1.9m. This is material in that this allowance must be discounted from the turnover of the proposed Home Bargains store in order to avoid double counting which would lead to an underestimation of quantitative need.

3.1.20 In overall terms, the benchmark comparison goods turnover of Haverfordwest stores is estimated to be £159m at 2014, which contrasts to the £151.2M at 2009 assumed in the PRS. We therefore consider the benchmark estimate to be robust.

3.1.21 Table 9 estimates the benchmark turnover of existing convenience goods floorspace in Haverfordwest, based on Table 13 of the PRS (2010). The sales densities assumed in the PRS (2010) have been retained, but with an allowance for changes in floorspace efficiencies 2010-2014. The current 2014 convenience goods turnover of Haverfordwest stores is estimated to be £82.7m.

Turnover of the Proposed Home Bargains Store

3.1.22 Table 10 provides an estimate of the likely turnover of the proposed Home Bargains store. The gross floor area extends to 1,533 sqm with the operator estimating a net sales area of 1,380 sq m. Home Bargains is large format mixed goods retailer who sell predominantly non-food branded household goods. Up to 25% of a stores sales floorspace, however, may be given over to convenience goods, and the estimated annual turnover of the store is expected to be £3.1m. This is based on a sales density of £2,250 per sq m, which is considered reasonable for the discount sector populated by home Bargains/ B&M Bargains / Family Bargains. Having regard to the higher sales per sq m generated by food compared to non-food, it is expected that around 30% (£0.9m) of the store’s turnover will be generated from food and drink goods and 70% (£2.2m) from non-food goods.

3.1.23 A proportion of the turnover of the proposed development will originate from residents beyond the PCA (Zone 6). However given that the proposed store is likely to be heavily orientated towards serving the immediate local area, in the interests of robustness we have assumed the entire turnover is derived from within the study area for capacity assessment purposes

Retail Capacity

3.1.24 Table 11 demonstrates the estimated comparison goods expenditure capacity above and beyond existing and committed provision. The expenditure available to Haverfordwest is taken from Table 7, while the benchmark turnover of existing and committed floorspace is derived from Table 10. Subtracting the benchmark turnovers from the total expenditure currently being captured by Haverfordwest, provides a residual expenditure capacity of £15.4m at 2019. Allowing for the £2.4m turnover of the proposed

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Home Bargains store (£2.2m at 2014 with an allowance for growth in floorspace efficiency 2014-2019), there will still be a residual surplus of £13m at the design year. This demonstrates a quantitative need for the proposed store.

3.1.25 Table 12 undertakes the same analysis for convenience goods, and shows a deficit in convenience expenditure capacity, equivalent to -£38.4m at 2014. This deficit of spending was also identified and acknowledged by WYG in their impact assessment submitted with the Sainsbury application. Notwithstanding this identified lack of quantitative need (for convenience goods), the Council nevertheless resolved to grant permission for the Sainsbury. In this respect, we believe a similar stance should be taken with the Home Bargains application, especially given that, unlike the Sainsbury, the convenience goods offer in Home Bargains is only a small element ancillary to the wider non-food offer. At only £0.9m the proposed store’s convenience turnover will be equivalent to less than 3% of the approved Sainsbury store. The modest turnover of £0.9m does not make the negative capacity position materially worse, and will not lead to any harmful outcome. In these circumstances we do not consider that an absence of quantitative need for the convenience goods element of the propsoed development can be credibly defended as a reason for refusal.

Qualitative Need

3.1.26 As previously stated, the Welsh Government has confirmed that quantitative need is the most important consideration; however, qualitative need is also material.

3.1.27 In terms of qualitative need, the proposed store will reduce the need to travel to comparable stores further afield, and it will generate job opportunities within the local area. These jobs will comprise both full and part time positions and will be available to local people. Such job opportunities have the potential for major local benefits and represent an increase in the number of employment positions.

3.1.28 This application therefore represents a valuable opportunity to secure a tenant for the unit, which has been vacant since it was built which in turn will provide a new and exciting employment opportunity for the local community.

3.1.29 Furthermore, the presence of a key national retailer, such as Home Bargains will maximise the opportunity for linked shopping trips with other retail premises within the retail park and within the surrounding area and improve choice for local residents.

3.2 SEQUENTIAL APPROACH

3.2.1 Having demonstrated a need for the proposed development, the next step required by national planning guidance is to demonstrate that a sequential approach to site selection has been followed.

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3.2.2 The approach mandated in Planning Policy Wales is to first select sites within a town centre. If none can be identified that are available, suitable and viable, then edge-of- centre sites may be considered. These are defined in TAN4 as “a location within easy walking distance of the centre normally not more than 200-300 metres from existing town centre shops, providing parking facilities that serve the centre as well as the store, thus enabling one trip to serve several purposes”. Where no edge-of-centre sites can be identified then out-of-centre locations may be considered where they are accessible by a choice of means of transport.

3.2.3 The application site lies approximately 1.5km to the north of the town centre and is therefore out-of-centre in policy terms. Under the sequential approach the requirement must be to identify sites either within or closer to the defined town centre. Therefore we have undertaken a number of site visits to try and identify any land or vacant units which have the potential to accommodate the proposed development. We have also taken account of the recently adopted LDP, which has identified the Fred Rees Skoda Garage site as being suitable for a mix of comparison units under Policy GN.13.

3.2.4 In applying the sequential approach PPW requires flexibility from retailers and developers. However, at the same time for any site to be credible it must be capable of meeting the identified need. The approach also requires ‘flexibility and realism’ from LPA’s. It should not in our opinion, be used to seek the arbitrary disaggregation of a well established business model operated by a retailer nationwide, which has been subject to detailed scrutiny by numerous local planning authorities, Inspectors and Ministers.

3.2.5 Notwithstanding the above, PPW provides limited guidance on the criteria to be adopted in the selection of sequential sites, other than they must be suitable, available and viable to meet the need and should “take into account of such factors as floorspace, quality, convenience, attractiveness and traffic.” (Para 10.2.12). While this issue is raised in PPW in the context of development control, this must be considered in the light of case law. In particular, reference must be made to the Supreme Court Judgment of Tesco Stores Limited (Appellants) v Dundee City Council (Respondents) (Scotland) [2012] UKSC 13. At para 37 of the judgement, Lord Hope stated:

“It is the proposal for which the developer seeks permission that has to be considered when the question is asked whether no suitable site is available within or on the edge of the town centre.”

3.2.6 He added at paragraph 38 of the judgement (ibid):

“These [sequential test] criteria are designed for use in the real world in which developers wish to operate, not some artificial world in which they have no interest doing so.”

3.2.7 It is clear from Lord Hope’s judgment that the sequential test should centre on the nature of the development proposed and not on a hypothetical scenario of disaggregated floorspace for which there is no identified interest.

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3.2.8 Home Bargains has a portfolio of around 300 stores nationwide. The smallest store operated is one of Home Bargains’ pilot stores which is notably small comprising only 500 sq m GIA. In contrast Home Bargains’ largest store has in excess of 2,780 sq m GIA. It is within this range which the retail operator demonstrates its scope for flexibility. However, it must be noted that the retail sector is dynamic, and Home Bargains continue to refine their business model based on their trading experiences at other stores.

3.2.9 As part of this learning process, both product offer and store layout has evolved towards larger units and the sale of bulkier products. In some of the more recently opened stores garden centres have also been included – an example of the evolution of the business model. Viability considerations also apply in terms of the provision of a certain floor plate to enable sufficient sales to be generated to cover operating costs such as initial store fit out, rent / rates, staff costs etc.

3.2.10 It is important to note that Home Bargains operate in town centres as well as out-of- centre. A large number of Home Bargains stores are located on the high street. These are however generally much smaller units (c. 5-7,500 square feet) offering a truncated and much softer retail offer focused on basket shoppers. This type of format has proven far less viable in recent years and partly in response to the economic downturn Home Bargains has broadened its retail offer in terms of the number of products and depth of range, meaning that much larger stores are required in which customers shop in bulk using trolleys. This format requires immediately adjacent, demised customer parking and single floorplates, as we will come on to discuss.

3.2.11 From extensive research and experience, the retail model has evolved with the majority of pipeline stores having a floorspace of between 1,115 sq m and 2,323 sq m GIA. The lower end of the range effects the minimum quantum of floorspace required in order for the operator to sell their full product range without unduly compromising their retail offer. The proposed 1,533 sq m GIA store falls within the lower range of the modern store format being brought forward by Home Bargains. The need for a size of the store proposed in Haverfordwest is dictated by a number of variables that are used to forecast what critical mass is required to be able to create a viable trading proposition. A smaller store would simply not be viable.

3.2.12 The product range also contains some bulky goods (home and garden furniture, gardening goods, car accessories etc), which further underscores the limitations posed by multiple floors. Home Bargains is not a department store that can split its product line over multiple levels with separate checkout areas.

3.2.13 It is clearly not the intention of national guidance, nor compliant with the Dundee judgement to require the arbitrary sub-division of proposals and require single retailers to split into separate sites where flexibility in the business model and scope for disaggregation has been demonstrated. It is salient that national guidance requires flexibility and realism from local planning authorities as well as developers and retailers.

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3.2.14 It is therefore necessary to identify whether there are any distinct ‘elements’ of the Home Bargains business model that could be separated from the whole, and consequently, whether it could be provided on one or more sequentially preferable sites. A Home Bargains store includes the following fundamental components:

• The ability to sell the full range of goods including both bulky and non-bulky non- food goods as well as ancillary food and drink products; • A demised customer car park of an appropriate size directly adjacent to the retail unit (with trolley bays) to allow the safe and direct transfer of goods from store to customer vehicle; • Simple, safe and efficient servicing arrangements allowing HGV’s to arrive, unload and leave the site without any disruption, conflict with the wider highway network or any negative impact on residential amenity; and • A customer base that is able to make purchases from various ranges, for example someone buying home furnishings may also want to purchase the other related household items and so on - the core element of the retail offer is the complementary nature of many of the products and the synergy that exists between the product ranges. • The stores need a single level trading floorplate.

3.2.15 Without each of these components of Home Bargains’ business model, the retail model is unacceptably compromised and the retailer will not proceed with a new store.

3.2.16 It is important for the local planning authority to understand that the product lines and floorspace given over to each does not form a separate defined element independent to the rest of the store. The sale of the different elements of the scheme such as the bulky and non-bulky comparison goods as well as the ancillary food element does not take place from distinct parts of the unit. Furthermore, there are no separate tills, access or egress points; no distinct parking and no individual opening or servicing hours which would be expected with a self-sufficient sales retail offer. The sales area as a whole is an integral and fundamental part of the business model. A visit to the Milford Haven store will confirm the above.

3.2.17 In terms of the inability to viably trade on multiple-levels, a number of factors are relevant. Firstly, trolleys are not conducive to multi-level retailing for obvious reasons. Those reasons are why DIY stores and other large format retailers do not normally trade from multi-levels stores.

3.2.18 Secondly, research has shown that customers are far less likely to show on a second floor, being put off by lifts and elevators. This is best evidenced by supermarkets and discount retailers most of whom sell from single level floorplates with very limited exceptions.

3.2.19 Thirdly, the likelihood for shrinkage or theft is significantly increased on multi-level retailing. Elevators and escalators provide blind spots where the propensity for shoplifting is heightened. With a retailer already trading from limited margins this shrinkage poses a threat to the viability of the retail model.

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3.2.20 Finally, Home Bargains have a huge turnover of product receiving 60 to 80 cages per day. Distribution of this stock from a small back of house area to the shop floor would be impossible over two levels without compromising the trading performance of the store.

3.2.21 Therefore, unlike some retailers, the Home Bargains business model and retail offer does not contain distinct elements which could, through disaggregation be located to a sequentially preferable site. To do so would compromise the retail model and viability of the store, and an unintended consequence could be to result in shoppers having to make multiple trips to purchase all of their required goods – potentially in different parts of the town, which would clearly be contrary to national policy.

3.2.22 The importance of a single retailer being able to sell their full range of goods has been recognised by an Inspector and Secretary of State (albeit in an English decision, but the principles are clearly applicable in Wales). In respect of an M&S store at Ellesmere Port (ref: APP/A0665/V/09/2098680) in October 2009. In respect of disaggregation the Inspector concluded (paragraph 178):-

“Marks and Spencer’s requirement is to be able to conduct their business as a whole and that is one of the reasons for the size of the store proposed. To my mind, in order to allow the proposed scheme to be a success, boost the economy of Ellesmere Port and diversify the economy, it would be unreasonable to expect the Applicants to disaggregate various parts of the scheme. I suggest it may well deter and discourage the necessary investment in Ellesmere Port”.

3.2.23 The principles considered above are no different to Home Bargains’ requirement in Haverfordwest. They need to be able to enter the market and compete with other retailers, sell their full range of products and be a viable commercial proposition.

3.2.24 An element of Home Bargains’ offer is comprised of bulky comparison goods such as DIY, garden products and furniture. The nature of this goods coupled with they fact that customers usually buy ‘in bulk’ means that a large proportion of customers will use a shopping trolley. This trading characteristic means that there is an operational requirement for immediately adjacent and demised customer car park to enable goods to be transferred to customer’s vehicles.

3.2.25 Given that there are no distinct elements of the proposed Home Bargains store that can be viably provided on an alternative site(s), it is appropriate to consider potentially sequentially preferable sites which could accommodate the entirety of the required floorspace (1,533 sq m), albeit allowing for flexibility. As such we have undertaken a sequential assessment based on sites which could accommodate a store of at least 1,115 sq m GIA on a single-floor plate would be required to meet the Home Bargains current basic business model outline above. This demonstrates flexibility given this figure is some 27% less than that proposed in Unit F, Springfield Retail Park.

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TOWN CENTRE SITES

Former Ocky White Department Store, Bridge Street

3.2.26 The former Ocky White Department Store closed in summer 2013, after over 100 years of trading. The retail unit is a multi-level department store premises located within the pedestrianised area of Haverfordwest Town Centre.

3.2.27 The unit fronts onto Bridge Street, with the River Cleddau to the rear. The site is serviced at the rear from the Swan Square roundabout with access through a narrow archway through to the rear of the unit.

3.2.28 It is set on three floors and provides a total of 956sqm of retail floor space, storage areas and cafe. Parking is provided but for only 6 vehicles.

3.2.29 The site is currently being marketed and so is clearly available. The unit is however considered to be unsuitable and unviable for the following reasons:

• It does not provide the minimum quantum of floorspace necessary for the retailer to implement its full business model. • The floorspace is not provided on a single floorpate, and for the reasons detailed earlier, a multi-level format is not viable for the business model. • It does not provide a demised, immediately adjacent customer car park, which is another fundamental requirement of the retailer’s business model. • The site is wholly unsuitable for to be serviced by the operators HGVs

3.2.30 It is therefore concluded that the site cannot be considered a sequentially preferable location to accommodate the proposed Home Bargains store.

Fred Rees Garages and Car Sales / Ebenezer Row, Swan Square

3.2.31 The 0.31 hectare site lies at the northern end of the town centre boundary and is allocated within the adopted LDP under Policy GN.13 for retail uses and in particular for ‘comparison units’. No reference, however, is made to the quantum or nature of the retail provision envisaged on the site.

3.2.32 The LDP’s Supplementary Planning Guidance (SPG) on Development Sites (adopted October 2013) provides site specific information on all sites allocated for development in the LDP. The PRS (2010) also provides a detailed analysis of the Fred Rees site.

3.2.33 The PRS (2010) and draft SPG both identify flooding as a constraint to developing the ‘Fred Rees’ site. The LDP draft SPG states that “more than 10% of the site area is considered at ‘intermediate’ susceptibility to surface water flooding” and the PRS (Appendix E) advises of the need to consider the site’s location adjacent to the fluvial floodplain. Whilst this is not considered to be fundamental to a retail scheme it stands to reason that the developable area is likely to be impacted, and there will be costs associated with remediation measures.

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3.2.34 Whilst the adopted LDP allocation refers to a 0.31 ha site, it is in reality two small sites divided by an access road leading to the Wilkinson store car park. The PRS (Appendix E) acknowledges that the need to accommodate the existing access through the site to the car park is a constraint to development. It further advises that access to the site is unlikely to be acceptable off Churnworks roundabout or Old Bridge Relief Road.

3.2.35 The main developable area is the section of the site currently occupied by the Skoda dealership which extends to approximately 0.17ha, with a smaller area of around 0.1ha on the other side of the access road. The requirement to preserve access to the Wilkinsons car park means that it is unlikely a single larger unit such as that proposed could be developed without disaggregated car parking provision. This is highly unlikely to be acceptable to retailers.

3.2.36 In response to the constraints identified above, it is recognised that an outline planning application (ref: 12/0828/PA) for the site was submitted in December 2012 for a mixed- use development comprising a combination of retail, residential and office uses. To date, the application remains undetermined.

3.2.37 The indicative site layout shows that the proposed development would comprise two distinct buildings situated either side of the existing access road, with the northern block containing a mix of retail and office space. The retail space (circa 898sqm GIA) would be on the ground floor with offices above. The proposed southern block, which is the larger of the two, would consist of retail (circa 1,083sqm GIA) on the ground floor with residential on the first and second floors. The site includes basement parking for 26 vehicles to serve the residential units only. There is no dedicated parking for the retail units, with the nearby Perrotts Road Car Park being the nearest car park.

3.2.38 In terms of the retail element, the proposal consists of four separate, but interconnected units on the ground floor of the development. These units would vary in size but amount to 1,981 sq. m (GIA) across the site. It is proposed that all vehicular activity associated with the office and retail elements of the development would be encompassed within the existing town centre public car-parks.

3.2.39 Indeed, we do not consider that it would be physically possible to accommodate a store capable of accommodating Home Bargains business model on the site taking into account the need for appropriate servicing, access and car parking arrangements. The submitted development proposals confirm this view.

3.2.40 Furthermore the PRS (Appendix E) itself acknowledges that the site is a ‘medium term’ opportunity. Home Bargains have immediate requirement for floorspace in Haverfordwest and there is no evidence to suggest that the allocated site will be available within a reasonable timescale to meet this, particularly as there is a requirement to secure an alternative relocation site for the existing business. The site is therefore considered to be unavailable within a reasonable timescale.

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3.2.41 Home Bargains have specifically considered this site and they have commented that the site would not be able to accommodate their business model requirements, even on a flexible basis and the site is not suitable or viable for the following reasons:

• It does not provide the minimum quantum of floorspace necessary for the retailer to implement its full business model. • It does not provide a demised, immediately adjacent customer car park, which is another fundamental requirement of the retailer’s business model. • It is unclear how servicing will be undertaken, and whether the site is suitable for HGVs deliveries.

3.2.42 It is therefore concluded that the site cannot be considered a sequentially preferable location to accommodate the proposed Home Bargains store. Furthermore Home Bargains have confirmed that they would not progress with this site in the event that permission was not granted for the application site.

Other Town Centre Sites

3.2.43 Elsewhere in the town centre, the scope for new development sites is severely limited by the fact that the majority of the centre is already densely developed and the majority of the town centre is covered by a conservation area designation. There are also a substantial number of Listed Buildings scattered throughout the town centre. In any event there are few large units in the town centre (such as the Wilkinson’s store on Old Bridge) but those that are there are all currently occupied.

3.2.44 As a consequence of the above, there are no sites, which could be considered to be available, suitable and viable to meet the identified need within the town centre.

EDGE-OF-CENTRE

3.2.45 Given that there are no sites which could be considered to be available, suitable and viable to accommodate the identified need within the town centre, we have then considered the potential of edge-of-centre sites within 300 metres of the existing town centre shops.

3.2.46 Having undertaken a search of potential sites it is evident that there are very few genuine potential sites to accommodate new development as a consequence of numerous constraints including the river, the topography of the town centre, the dense pattern of existing development and the fact that the town centre Conservation Area extends well beyond the town centre as defined in retail policy terms and there are numerous Listed Buildings.

Blands Garage, Perrot’s Road

3.2.47 The 0.45 hectare site is located to the east of the northern end of the town centre boundary on the opposite side of the roundabout from the former Fred Rees Garage and adjacent to an existing Lidl Store. The site is currently vacant and for sale and is therefore available.

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3.2.48 The existing building provides 1,190sqm of floorspace with car parking arranged around the building on all four sides. The site currently has two access points, one from Perrot’s Road and the other from Thomas Parry Road.

3.2.49 The site is considered too small to provide a unit sufficient to meet the needs of Home Bargains business model, with sufficient car parking and HGV access.

3.2.50 HGV servicing would be likely to be taken from the existing access on Thomas Parry Way, but due to site constraints it is unlikely a turning area within a service yard could be accommodated without severely limiting the potential to accommodate the store building and to provide demised car parking. It is likely therefore that the site could only be serviced through the potential customer car parking area, HGVs either manoeuvring to leave Thomas Parry Way in forward gear or alternatively from Perrot’s Road. Such an arrangement would be unacceptable to Home Bargains due to constraints on when deliveries could arrive to the site.

3.2.51 The site is considered to be unsuitable for the following reasons:

• The site would not facilitate a store of the minimum quantum of floorspace necessary for the retailer to implement its full business model, without impacting on the ability to provide adequate servicing and demised car parking. • The site is unlikely to provide adequate demised car parking spaces. • Notwithstanding the above, due to the constrained site, servicing the unit by HGVs, even if acceptable to the Highways Authority and Highways Agency would lead to conflict with the safe operation of the car parking area and require out-of-hours deliveries which would not be acceptable in the context of the business model.

3.2.52 It is therefore concluded that the site cannot be considered a sequentially preferable location to accommodate the proposed Home Bargains store. Furthermore Home Bargains have confirmed that they would not progress with this site in the event that permission was not granted for the application site.

OUT-OF-CENTRE

3.2.53 Given that there are no available, suitable and viable sites in, or on the edge of the town centre, national planning guidance supports the development of proposals in out-of- centre locations where they are accessible by a choice of means of transport. There are two other vacant retail warehouse units in Haverfordwest which have been considered as potential alternatives to the application site.

Withybush Retail Park

3.2.54 At Withybush Retail Park there are currently two vacant units: Unit 5 which is 7,700 sq.ft (715 sq.m) gross and Unit 6 which is 10,000 sq.ft (929 sq.m), however, both of these units are under offer with contracts expected to be signed in early 2014.

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3.2.55 Notwithstanding the above the planning consent for Withybush Retail Park (Consent Ref: 07/0722/PA granted on 31st October 2007) limits the floorspace for the sale of food or other edible goods to 1,692 sq.m. This limitation relates to the total amount of food retail floorspace on the site. The Marks and Spencer store (Unit 1) absorbs all of this allowance and therefore no additional food retail floorspace is permitted which would prevent Home Bargains from occupying either or both of these units. There is also a covenant in place which prevents any of the units being occupied by a discount retailer.

3.2.56 In any case it should be noted that Withybush Retail Park is also an out-of-centre site with similar accessibility characteristics to the application site given the position of both retail parks just off Fishguard Road, and it is therefore cannot be deemed to sequentially preferable in light of PPW.

Springfield Retail Park

3.2.57 Springfield Retail Park is already a committed retail site and the principle of non-food retail use is established, and there can be no issues regarding the nature of the proposed use: it is a predominantly bulky goods retail use. The food element that we propose is ancillary to the bulky goods and is essential to the Home Bargains business model. It will not become a food retail destination in its own right.

3.2.58 The site is accessible by foot, cycle, public transport and car. There is clearly a strong likelihood of linked trips being made to other units on the retail park and also to the nearby Withybush Retail Park. In conclusion the application site is available, suitable and viable to accommodate the identified need, and would not result in an increase in out-of-centre floorspace other than for the modest mezzanine floor proposed.

3.2.59 There are no other out-of-centre sites that can provide the required floorspace and also offer potential for linked trips to other retail stores and the same degree of accessibility by a choice of means of transport. The application site is therefore considered to be the most appropriate location for the identified need in Haverfordwest, and we consider the proposal satisfies the sequential test. As previously stated Home Bargains is the proposed occupier of Unit F at Springfield Retail Park– a new entrant into the town. Home Bargain’s have confirmed that there are no other sites in the town which meet their requirement, and the refusal of this planning application will not divert their requirement to another unit in the town. This is demonstrated by the commitment of the retailer to the site in spite of the refusal of the previous planning application in June 2013.

3.2.60 To refuse the application would simply mean that the retailer will not invest in the town to the detriment of competition, consumer choice, and job creation and would result in a continued leakage of expenditure out of the town and county. To frustrate the retailer from occupying the premises and constructing a modest mezzanine floor necessary to implement their business model at the retail park allocated by the Council for such uses would make no sense and would in our view conflict with the objectives and spirit of national policy particularly the new guidance within Section 7 of Planning Policy Wales. It would also send negative signals to potential investors in Haverfordwest and Pembrokeshire.

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3.3 IMPACT

Haverfordwest Town Centre

3.3.1 In assessing the impact of the proposal on existing centres, it is firstly critical to establish which centres should be considered. The primary catchment area of the proposed store is considered to the urban area and rural hinterland of Haverfordwest, and it is therefore only appropriate to consider this defined centre. Our analysis of the potential impact of diversion on the town centre is informed by the PRS (2010), the Pembrokeshire Town Centre Performance and Economic Consequences of Car Parking Charges (2011) and RPS surveys undertaken in October 2012.

3.3.2 The PRS (2010) provides a comprehensive evaluation of the health of Haverfordwest Town Centre based on a number of key indicators (where data is available). Haverfordwest is located in the geographical centre of Pembrokeshire and is the County’s main administrative and retail centre. It is the largest retail centre in Pembrokeshire County and is able to attract the highest proportion of convenience and comparison goods shopping trips. The town has a good qualitative range of convenience shopping provision which is split between edge of centre, out of centre and a small amount in the town centre.

3.3.3 Throughout the day time the town centre is consistently vibrant and more so at night time, especially at weekends, with several pubs and newly established restaurants located in the heart of Haverfordwest.

3.3.4 The PRS (2010) states that Haverfordwest is the highest ranked centre in Pembrokeshire under the VenueScore rankings of UK shopping centres. The ranking has declined since 2005. The mix of uses within Haverfordwest Town Centre including a comparison to national average levels is set out in Table 5.1 below. These figures were compiled by Pembrokeshire County Council in their own Retail Study (2010).

Table 5.1:Mix of Town Centre Uses, June 2009 Sector County Wide Retail Study (June 2009) UK Average No. % % Convenience 11 5.58 9 Comparison 88 44.67 46 Service 67 34.01 33 Vacant 30 15.23 11 Misc 1 0.51 1 TOTAL 197 100 100

3.3.5 A new Retail Survey was undertaken by RPS in October 2012. The results, which include a comparison to the national average, are set out in Table 5.2 on the next page.

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Table 5.2: Mix of Town Centre Uses, October 2012 Sector RPS Survey 2011 UK Average No % % Convenience 10 5.07 8.5 Comparison 106 53.81 41.4 Services 45 22.84 35.4 Vacant 16 8.12 13.6 Miscellaneous 20 10.15 2.3 TOTAL 197 100 100

3.3.6 The proportion of convenience units is lower than national average, this is not unexpected due to the fact that this is a relatively small centre and most of the large convenience stores are located out of town. The town centre mainly consists of small newsagents that provide the mere basics for nearby residents; however a small Iceland is situated at the bottom of High Street.

3.3.7 The proportion of comparison units is above the national average, which is not a surprise given that Haverfordwest is one of the largest centres within the County and serves the adjacent areas alongside Tenby and closely followed by Pembroke. The comparison goods retailer offer includes a range of goods selling clothes, gifts, crafts, stationary, toiletries etc. There are some multiples in the service sector such as banks and local government buildings.

3.3.8 The proportion of service units has decreased substantially from the June 2009 survey to October 2012, where it has decreased by 22 units. However there has been a still increase in comparison units where a number of services may have been changed into A Class units. There has also been an increase in the number of ‘miscellaneous’ units, where many units may have been redeveloped into dwellings.

3.3.9 An update of the survey results identified that the health of the town centre showed a significant improvement where the number of vacant units decreased from 30 to 18 units. The vacant units that have become available are small units that are more suited to small local businesses rather than multiple retailers. The former Boots unit (145 sq m ground floor sales), which was the largest vacant unit within the town centre for some time, is now occupied by Poundland along Riverside Quay. The majority of vacant units at present are located on the more peripheral frontage of High Street on the western edge of the town centre.

3.3.10 The town centre is reasonably well served by national multiple retailers. This includes Argos, Dorothy Perkins, WH Smith, Evans, Wilkinsons, Superdrug, Iceland and Specsavers. It is important to note that the application proposal concerns Home Bargains, a national retailer currently not represented in the town, nor are any of their direct large format household discount competitors such as B&M Bargains and Family Bargains.

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3.3.11 In undertaking our retail survey of Haverfordwest we have updated the Councils Goad map that they produced in June 2009. The update covers the same area of Haverfordwest Town Centre and shows units that are occupied at ground floor A class, occupied commercial non A class use and vacant units. By covering the same area and using the same indicators we can compare and contrast the situation of the retail pattern in Haverfordwest Town Centre.

3.3.12 The pattern emerging from both maps shows that there is no significant change in the distribution of occupied and vacant units. The most viable and vibrant areas of Haverfordwest for retail development remain along Bridge Street, Riverside Quay and Quay Street.

3.3.13 Haverfordwest is a reasonably healthy and vibrant town centre that serves local residents. The above analysis highlights that Haverfordwest is one of the dominant centres performing relatively well in its role in broad terms and offering a mix of retail uses. Within the town centre it is clear the most commercially vibrant areas are situated on either side of the River Cleddau.

3.3.14 In terms of economic indicators, the PRS (2010) notes that the commercial yield for the town centre has fallen (improved) in recent years, and the town performs reasonably well in terms of investor confidence in comparison to other competing towns such as Cardigan.

3.3.15 Rental levels for Zone A floorspace were around £50 per sq ft in 2007 which was slightly below the levels experienced in Llanelli and Aberystwyth and well below Carmarthen. However, the centre is considered to be likely to achieve higher rents than other centres in Pembrokeshire given its position in the retail hierarchy.

3.3.16 The town centre is reasonably well served by car parking with a mixture of on and off street facilities. The largest car park is located along Cartlett Road which is situated north west of the town centre. Pedestrian accessibility is achieved successfully from the car park and around the town centre where the majority of the streets including the main shopping street, Bridge Street are pedestrianised where vehicles can only access this road for delivery. The town is well served by local bus services to all other areas in the County including the principal towns of Milford Haven, Tenby, Pembroke and Fishguard.

3.3.17 The environmental quality of the town centre is reasonably high, with a conservation area designation covering the vast majority of the town centre, and numerous Listed Buildings scattered throughout.

3.3.18 The above has demonstrated that Haverfordwest town centre is a reasonably vital and vibrant centre and is not showing signs of being particularly vulnerable. Indeed the significant fall in the number of vacant units is encouraging in comparison to national trends. Notwithstanding this, it is necessary to assess the likely impact of the proposed development on the town centre, and to assess whether this will be materially harmful to suggest that the application should be refused.

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Trade Diversion Estimates

3.3.19 Table 13 details the expected trade draw pattern of the proposed development, for both convenience and comparison goods – the table is essentially the same format as used by WYG in their impact assessment for the Sainsbury at Slade Lane. It details the turnover of existing stores at 2014 and 2019, and then subtracts the trade assumed to be diverted to the proposed development at Ebeneezer Row; the approved Sainsbury store and the uplift to the new Debenhams; and finally to the proposed Home Bargains. The cumulative impact from all four developments is detailed, as well as a solus impact of just the Home Bargains.

3.3.20 The table shows that the larger part of the Home Bargains turnover is expected to be derived from stores outside the town centre (85% or £2.6m): only 15% or £0.5m is expected to be taken from shops in the town centre. It can be seen while the cumulative impact on the Iceland, Lidl and other small convenience shops in the centre are substantial, that is not as a result of the Home Bargains.

3.3.21 The significant impact on Iceland is despite Home Bargains taking no trade from that store. In relation to the Lidl, of the -29.6% cumulative impact shown on that store’s convenience turnover only -0.3% arises from the Home Bargains – deleting the trade draw to Home Bargains results in a cumulative impact from the remaining developments of -29.3%. In relation to the store’s comparison turnover, the cumulative impact is - 28.6%, of which only 7% is from the Home Bargains. In respect of the convenience turnover of other shops in the town centre, the total cumulative impact is -19.1%, of which only -0.6% is from the Home Bargains. As a consequence it is evident that the small turnover of the Home Bargains unit contributes very little to the total cumulative impact on existing stores in the town centre. Granting the development planning permission would therefore not result in any significant increase in the impacts on existing shops.

3.3.22 The minimal affect the proposed development will have is more clearly shown in the solus impact column, which shows that the only impact of any note is -7% on the Lidl’s comparison offer. As a deep discounter whose primary offer is food this minimal impact on the Lidl’s ancillary non-food offer cannot be considered to be significant.

3.3.23 The majority of the proposed Home Bargains turnover will be derived from out-of-centre stores, where impact is not material, but rather valid commercial competition. Notwithstanding that, the solus impact of the proposed store can be seen to be minimal.

3.3.24 In considering the likely impact of the Home Bargains proposal, it is relevant to note that the Council previously considered an application at Unit A1 at Havens Head Retail Park and accepted for Home Bargains to occupy the unit. Planning permission was granted in May 2012 for the variation of condition 1 of planning permission 96/0389/PA to allow for the scale of food goods (ref: 11/1229/PA). In terms of the proposed turnover of the scheme it was estimated of the £0.98m expenditure only £0.05m (5%) would be drawn from the existing retail units within the town centre, at a worst case scenario. Having regard to the estimated trade draw the case officer affirms:

Springfield Retail Park, Haverfordwest JPW0246: December 2013 29 RPS Planning & Development Planning & Retail Statement

“Having regard to the nature of proposed food goods (namely ambient goods with long shelf-life) and trading patterns in the town centre and retail park, it is likely that the level of trade diversion would be significantly less than this.”

3.3.25 He continues by stating:

“…for example, should the level of trade diversion be 1% rather than 5% then only some £0.01m would be drawn from the town centre. Such a level of trade diversion would have a negligible impact on the performance of the town centre.”

3.3.26 In light of the above the following comparisons can be made between the applications of Haverfordwest and Milford Haven:

• Haverfordwest is a larger town than Milford Haven and has a lower vacancy, currently sitting at 8% which is much lower than the national average and much lower than the 28% in Milford Haven at the time the application was determined. • The Home Bargains proposed at Springfield Retail Park our estimated to have a similar level of convenience goods trade diversion from the town centre at £0.03m, which is comparable to the Milford Haven town centre draw of £0.01m – £0.05m.

• Given the case officer’s acknowledgement that a similar trade draw figure from Milford Haven town centre would have a ‘negligible impact’, it would be wholly inconsistent to take a different view to the Haverfordwest proposal, particularly given Haverfordwest is a larger centre.

3.3.27 Given the above health check assessment and estimated pattern of trade diversion, it is considered that there are no grounds for concern that the application to enable Home Bargains to occupy the Unit F at Springfield Retail Park will materially harm Haverfordwest Town Centre and as such it is considered that the application is not contrary to Policy GN.14 of the LDP.

3.3.28 Furthermore, given the Council’s decisions to grant permission to permit a Home Bargains store in Milford Haven and a Sainsbury’s store in Haverfordwest, the refusal of the application on impact grounds would be wholly inconsistent.

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4 CONCLUSIONS

4.1 This Planning and Retail Statement is submitted in support of a s73 planning application for Unit F at Springfield Retail Park, Haverfordwest. The application seeks consent for the variation of conditions 5, 6 and 7 of planning permission 05/0316/PA to allow the unit to be occupied by Home Bargains and to allow the installation of a mezzanine floor to provide an additional 140 sq m (1,500 sq ft) of floorspace.

4.2 Springfield Retail Park lies on the northern edge of Haverfordwest approximately 1.5km from the town centre and current occupiers include Homebase, Wickes, Topps Tiles, Carpetright and Pets and Home. The vacant unit to which this application relates (Unit F) provides 15,000 sq ft of floorspace.

4.3 Outline planning consent for the Retail Park was granted on 7th April 2006 subject to a number of conditions. These include a condition, which limits the net retail floorspace and prevents the provision of additional internal floorspace (condition 5) and conditions, which restrict the types of goods that can be sold at the Retail Park to Bulky Goods (Conditions 6 and 7).

4.4 The availability of Units E and F has been widely marketed both in Wales and also nationally. Nevertheless both units remain vacant. Home Bargains has a long-standing requirement for a store of around 16,500 sq ft in Haverfordwest which can be achieved with the construction of a 1,500 sq ft mezzanine floor in Unit F.

4.5 This report has been prepared in accordance with the guidance set out in Planning Policy Wales (Edition 5) and has sought to evaluate the proposals against national and local planning policy and to consider the retail justification and the implications of the proposals on Haverfordwest town centre.

4.6 The pertinent points arising from the planning application are summarised as follows:

• There is a quantitative need for further comparison goods floorspace provision in Haverfordwest. The proposed Home Bargains unit will have a turnover fractionally above the allowance already made in the Pembrokeshire Retail Study (2010) for the currently vacant unit. The convenience element is an ancillary but essential element.

• Home Bargains have a requirement in Haverfordwest for a 16,500 sq ft store, and operate a business model which cannot be viably disaggregated into smaller components.

• There are no units or sites capable of meeting this need in or on the edge of Haverfordwest town centre. The application site is an established retail destination with appropriate infrastructure to maximise the potential for travel by a variety of modes and promote linked trips.

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• The Haverfordwest store will divert the majority of its trade from nearby out-of- centre stores, with only a very modest impact on the town centre. It will also encourage residents to shop in the local area rather than travelling to Home Bargains stores further afield e.g. Carmarthen/Milford Haven.

• The proposal will introduce a new retailer to the town, and will not result in an existing retailer reoccupying.

• Despite extensive marketing attempts over several years, there is no demand for the vacant floorspace at Springfield Retail Park with the existing trading restrictions.

• The proposal will create around 50 new jobs and bring a vacant unit into beneficial use which is fully in accordance with the new guidance contained within Chapter 7 of Planning Policy Wales.

4.7 Having regard to the above conclusions, it can be seen that the proposed development would conform to both national and local planning policies while at the same time providing a distinct improvement in local shopping provision and accordingly should be approved.

Springfield Retail Park, Haverfordwest JPW0246: December 2013 32 RPS Planning & Development

Appendix 1

Appendix 2

Appendix 3 Pembrokeshire Household Survey Area Map

0 mi 5 10 15 20 © 1988–2009 Microsoft Corporation and/or its suppliers. All rights reserved. http://www.microsoft.com/uk/mappoint/ © 1984-2009 Tele Atlas. All rights reserved. Data Source © 2009 Tele Atlas N.V. This product includes mapping data licenced from Ordnance Survey® with the permission of the Controller of Her Majesty’s Stationery Office. © Crown copyright and/or database right 2008. All rights reserved. Licence number 100025324. ©2009 NAVTEQ. All rights reserved. NAVTEQ ON BOARD is a registered trademark of NAVTEQ.

Appendix 4 Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 1: Population of Study Area by Survey Zone (2009-2021)

Zone Postcode Sectors 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 - Tenby SA70 7/8 10035 10297 10381 10467 10552 10639 10726 10814 10903 2 - Pembroke SA71 4/5 10255 10469 10538 10608 10679 10750 10821 10893 10965 3 - Pembroke Dock SA72 4/6 10222 10460 10537 10614 10692 10771 10850 10930 11010 4 - Saundersfoot SA68 0; SA69 9 7900 8090 8152 8214 8276 8339 8403 8467 8531 5 - Miford Haven SA73 1/2/3 20376 20780 20911 21043 21176 21310 21444 21580 21716 6 - Haverfordwest SA61 1/2 14562 14847 14940 15033 15127 15221 15316 15412 15508 7 - St Davids SA62 3/6 10634 10824 10886 10948 11011 11074 11137 11201 11265 8 - Haverfordwest East SA62 4; SA63 4 4766 4837 4860 4884 4907 4931 4954 4978 5002 9 - Fishguard SA62 5; SA64 0; SA65 9 12070 12332 12417 12502 12588 12675 12762 12850 12938 10 - Narberth SA67 7/8; SA66 7 9820 9962 10009 10055 10103 10150 10197 10245 10293 11 - Newport SA41 3; SA42 0 4403 4522 4560 4599 4638 4677 4717 4757 4797 12 - Cardigan & Newcastle Emlyn SA35 0; SA36 0; SA37 0; SA38 9; SA43 1/2/3 20819 21090 21200 21311 21423 21535 21648 21761 21875 13 - Whitland SA33 4; SA34 0 10249 10275 10290 10305 10320 10335 10350 10365 10380 TOTAL 146111 148785 149681 150613 106915 107581 76368 76843 155183

Notes Derived from Table 1 of Pembrokeshire Retail Study (PRS) 2010 Growth for Zones 1-11 based on global popuation growth figures from WG along with assumptions made on housing distribution as detailed in PRS (2010) Table 1 footnotes Figures for 2009, 2014 and 2021 have been taken directly from the PRS (2010).

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 2a: Total Comparison Goods Expenditure Per Capita (exc SFT)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 2234 2380 2428 2481 2531 2586 2645 2712 2784 2 2130 2269 2314 2365 2413 2465 2522 2585 2654 3 2109 2248 2292 2342 2390 2442 2498 2560 2629 4 2141 2281 2326 2377 2426 2478 2535 2598 2667 5 2199 2343 2390 2442 2492 2546 2604 2669 2740 6 2312 2463 2512 2567 2620 2676 2737 2806 2881 7 2173 2316 2362 2413 2463 2516 2574 2638 2708 8 2449 2610 2661 2719 2775 2835 2900 2973 3052 9 2063 2198 2242 2290 2337 2388 2442 2504 2570 10 2213 2358 2405 2457 2508 2562 2620 2686 2757 11 1833 1953 1992 2035 2077 2122 2170 2225 2284 12 2002 2134 2176 2223 2269 2318 2371 2430 2495 13 2139 2279 2324 2375 2424 2476 2532 2596 2665

Notes: Expenditure per capita for each zone at 2011 is derived from Experian. Growth rates applied fare taken from the most up to date Experian Retail Planner Briefing Note 11 (October 2013) Figures 1a and 1b. Growth rates: 2012 +3.1%; 2013 +3.2%; 2014 +2.3%; 2015 +2.8%; 2016-2020 +3%pa and 2021 +2.9%. Deductions have been made at each year for expenditure by special forms of trading (non-store purchases), in accordance with forecasts in Experian's Retail Planner Briefing Note 11. 2007 Prices

Table 2b: Total Convenience Goods Expenditure Per Capita (exc SFT)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 1655 1617 1613 1623 1631 1639 1649 1658 1665 2 1544 1508 1505 1514 1521 1529 1538 1547 1553 3 1473 1439 1436 1445 1452 1459 1467 1476 1482 4 1696 1658 1654 1664 1672 1680 1690 1700 1707 5 1495 1461 1458 1466 1473 1480 1489 1498 1504 6 1550 1514 1511 1520 1528 1535 1544 1553 1559 7 1689 1651 1647 1657 1665 1673 1683 1693 1699 8 1687 1648 1645 1655 1663 1671 1681 1691 1697 9 1617 1580 1577 1586 1594 1601 1611 1620 1627 10 1648 1611 1607 1617 1625 1633 1642 1652 1658 11 1580 1544 1540 1550 1557 1565 1574 1583 1589 12 1605 1568 1565 1574 1582 1590 1599 1609 1615 13 1681 1642 1639 1648 1657 1665 1674 1684 1691

Notes: Expenditure per capita in each zone at 2011 derived from Experian Growth rates applied fare taken from the most up to date Experian Retail Planner Briefing Note 11 (October 2013) Figures 1a and 1b. Growth rates: 2012 -0.6%; 2013 -0.6%; 2014 -0.3%; 2015 +0.1%; 2016-2021 +0.8%pa. Deductions have been made at each year for expenditure by special forms of trading (non-store purchases), in accordance with forecasts in Experian's Retail Planner Briefing Note 11. 2007 Prices

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Table 3a: Residents Comparison Goods Expenditure (£m)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 22.4 24.5 25.2 26.0 26.7 27.5 28.4 29.3 30.4 2 21.8 23.8 24.4 25.1 25.8 26.5 27.3 28.2 29.1 3 21.6 23.5 24.2 24.9 25.6 26.3 27.1 28.0 28.9 4 16.9 18.5 19.0 19.5 20.1 20.7 21.3 22.0 22.8 5 44.8 48.7 50.0 51.4 52.8 54.3 55.8 57.6 59.5 6 33.7 36.6 37.5 38.6 39.6 40.7 41.9 43.2 44.7 7 23.1 25.1 25.7 26.4 27.1 27.9 28.7 29.6 30.5 8 11.7 12.6 12.9 13.3 13.6 14.0 14.4 14.8 15.3 9 24.9 27.1 27.8 28.6 29.4 30.3 31.2 32.2 33.3 10 21.7 23.5 24.1 24.7 25.3 26.0 26.7 27.5 28.4 11 8.1 8.8 9.1 9.4 9.6 9.9 10.2 10.6 11.0 12 41.7 45.0 46.1 47.4 48.6 49.9 51.3 52.9 54.6 13 21.9 23.4 23.9 24.5 25.0 25.6 26.2 26.9 27.7 TOTAL 314.3 341.0 349.9 359.7 369.3 379.5 390.5 402.7 415.9

Notes: Total population (Table 1) multipled by expenditure per capita (Table 2a) 2007 Prices

Table 3b: Residents Convenience Goods Expenditure (£m)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 16.6 16.6 16.7 17.0 17.2 17.4 17.7 17.9 18.1 2 15.8 15.8 15.9 16.1 16.2 16.4 16.6 16.9 17.0 3 15.1 15.1 15.1 15.3 15.5 15.7 15.9 16.1 16.3 4 13.4 13.4 13.5 13.7 13.8 14.0 14.2 14.4 14.6 5 30.5 30.4 30.5 30.9 31.2 31.5 31.9 32.3 32.7 6 22.6 22.5 22.6 22.9 23.1 23.4 23.7 23.9 24.2 7 18.0 17.9 17.9 18.1 18.3 18.5 18.7 19.0 19.1 8 8.0 8.0 8.0 8.1 8.2 8.2 8.3 8.4 8.5 9 19.5 19.5 19.6 19.8 20.1 20.3 20.6 20.8 21.0 10 16.2 16.0 16.1 16.3 16.4 16.6 16.7 16.9 17.1 11 7.0 7.0 7.0 7.1 7.2 7.3 7.4 7.5 7.6 12 33.4 33.1 33.2 33.6 33.9 34.2 34.6 35.0 35.3 13 17.2 16.9 16.9 17.0 17.1 17.2 17.3 17.5 17.5 TOTAL 233.2 232.0 232.9 235.7 238.3 240.9 243.8 246.7 249.1

Notes: Total population (Table 1) multipled by expenditure per capita (Table 2b) 2007 Prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 3c: Total Comparison Goods Expenditure (£m)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 34.1 37.3 38.3 39.5 40.6 41.9 43.1 44.5 46.0 2 22.8 24.8 25.4 26.1 26.9 27.6 28.4 29.3 30.3 3 25.7 28.1 28.8 29.7 30.5 31.4 32.4 33.4 34.5 4 16.9 18.5 19.0 19.5 20.1 20.7 21.3 22.0 22.8 5 46.2 50.2 51.6 53.0 54.5 56.0 57.6 59.5 61.4 6 48.6 52.9 54.3 55.9 57.4 59.1 60.8 62.7 64.7 7 23.1 25.1 25.7 26.4 27.1 27.9 28.7 29.6 30.5 8 11.7 12.6 12.9 13.3 13.6 14.0 14.4 14.8 15.3 9 25.9 28.2 29.0 29.8 30.6 31.5 32.5 33.5 34.6 10 21.7 23.5 24.1 24.7 25.3 26.0 26.7 27.5 28.4 11 8.1 8.8 9.1 9.4 9.6 9.9 10.2 10.6 11.0 12 41.7 45.0 46.1 47.4 48.6 49.9 51.3 52.9 54.6 13 21.9 23.4 23.9 24.5 25.0 25.6 26.2 26.9 27.7 TOTAL 348.4 378.3 388.2 399.2 409.9 421.4 433.7 447.2 461.7

Notes: Residents expenditure from Table 3a with allowance added for spending by tourists. Tourist spend per zone at 2011 is as taken from WYG retail assessment for permitted Sainsbury at Slade Lane (data derived from Pembrokeshire STEAM 2010 report). Growth in tourism spend is assumed to be 3%pa (The Economic Contribution of the Visitor Economy: UK and the Nations, June 2010). 2007 Prices

Table 3d: Total Convenience Goods Expenditure (£m)

Zone 2011 2014 2015 2016 2017 2018 2019 2020 2021 1 25.0 25.9 26.2 26.8 27.3 27.8 28.4 28.9 29.5 2 16.2 16.2 16.3 16.5 16.7 16.9 17.1 17.4 17.6 3 16.5 16.6 16.8 17.0 17.2 17.5 17.8 18.0 18.3 4 13.4 13.4 13.5 13.7 13.8 14.0 14.2 14.4 14.6 5 31.8 31.8 32.0 32.4 32.8 33.2 33.7 34.1 34.5 6 25.6 25.8 26.0 26.4 26.8 27.1 27.5 27.9 28.3 7 18.0 17.9 17.9 18.1 18.3 18.5 18.7 19.0 19.1 8 8.0 8.0 8.0 8.1 8.2 8.2 8.3 8.4 8.5 9 20.7 20.8 20.9 21.2 21.5 21.8 22.1 22.4 22.7 10 16.2 16.0 16.1 16.3 16.4 16.6 16.7 16.9 17.1 11 7.0 7.0 7.0 7.1 7.2 7.3 7.4 7.5 7.6 12 33.4 33.1 33.2 33.6 33.9 34.2 34.6 35.0 35.3 13 17.2 16.9 16.9 17.0 17.1 17.2 17.3 17.5 17.5 TOTAL 249.1 249.4 250.8 254.2 257.3 260.4 263.9 267.4 270.5

Notes: Residents expenditure from Table 3b with allowance added for spending by tourists. Tourist spend per zone at 2011 is as taken from WYG retail assessment for permitted Sainsbury at Slade Lane (data derived from Pembrokeshire STEAM 2010 report). Growth in tourism spend is assumed to be 3%pa (The Economic Contribution of the Visitor Economy: UK and the Nations, June 2010). 2007 Prices

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Table 4: Haverfordwest Convenience Goods Market Share

Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) Tesco Extra 1.5 1.4 0.6 3.9 13.0 50.8 39.2 36.3 17.8 26.0 7.8 2.5 3.6 Morrison 0.0 0.6 1.7 3.5 10.4 28.1 21.0 41.1 20.3 15.0 6.9 2.5 0.7 Lidl 0.0 0.0 0.0 0.7 0.8 6.5 3.6 2.3 0.3 1.4 0.7 0.0 0.0 Aldi 0.2 0.0 0.0 0.0 1.1 1.9 2.9 0.3 2.5 2.5 0.7 0.0 0.0 Iceland 0.0 0.0 0.0 0.7 1.1 1.7 0.8 0.4 0.3 0.3 0.0 0.0 0.0 Other stores Haverfordwest TC 0.2 0.0 0.0 0.0 0.6 4.8 4.0 4.8 1.1 0.3 0.0 0.4 0.0 Wilkinsons 0.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 Local stores, Portfield 0.0 0.0 0.0 0.0 0.0 0.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Other stores in Haverfordwest 0.0 0.3 0.3 0.0 0.0 4.4 0.8 1.2 0.9 0.3 0.0 0.0 0.0 Total 2.0 2.3 2.5 8.8 27.1 98.9 73.6 86.4 43.3 45.9 16.1 5.4 4.3

Notes Derived from Pembrokeshire Retail Study 2010.

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 5: Convenience Goods Turnover of Haverfordwest Stores

2014 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) Tesco Extra 0.4 0.2 0.1 0.5 4.2 13.1 7.0 2.9 3.7 4.2 0.5 0.8 0.6 38.3 Morrison 0.0 0.1 0.3 0.5 3.3 7.3 3.8 3.3 4.2 2.4 0.5 0.8 0.1 26.5 Lidl 0.0 0.0 0.0 0.1 0.3 1.7 0.7 0.2 0.1 0.2 0.0 0.0 0.0 3.2 Aldi 0.1 0.0 0.0 0.0 0.4 0.5 0.5 0.0 0.5 0.4 0.0 0.0 0.0 2.4 Iceland 0.0 0.0 0.0 0.1 0.4 0.4 0.2 0.0 0.1 0.0 0.0 0.0 0.0 1.2 Other stores Haverfordwest TC 0.1 0.0 0.0 0.0 0.2 1.2 0.7 0.4 0.2 0.1 0.0 0.1 0.0 3.0 Wilkinsons 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Local stores, Portfield 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Other stores in Haverfordwest 0.0 0.0 0.0 0.0 0.0 1.1 0.2 0.1 0.2 0.1 0.0 0.0 0.0 1.7 Total 0.5 0.4 0.4 1.2 8.6 25.5 13.1 6.9 9.0 7.4 1.1 1.8 0.7 76.7

2019 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) Tesco Extra 0.4 0.2 0.1 0.6 4.4 14.0 7.4 3.0 3.9 4.4 0.6 0.9 0.6 40.4 Morrison 0.0 0.1 0.3 0.5 3.5 7.7 3.9 3.4 4.5 2.5 0.5 0.9 0.1 28.0 Lidl 0.0 0.0 0.0 0.1 0.3 1.8 0.7 0.2 0.1 0.2 0.1 0.0 0.0 3.4 Aldi 0.1 0.0 0.0 0.0 0.4 0.5 0.5 0.0 0.6 0.4 0.1 0.0 0.0 2.6 Iceland 0.0 0.0 0.0 0.1 0.4 0.5 0.2 0.0 0.1 0.1 0.0 0.0 0.0 1.2 Other stores Haverfordwest TC 0.1 0.0 0.0 0.0 0.2 1.3 0.8 0.4 0.3 0.1 0.0 0.1 0.0 3.2 Wilkinsons 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Local stores, Portfield 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Other stores in Haverfordwest 0.0 0.1 0.1 0.0 0.0 1.2 0.2 0.1 0.2 0.1 0.0 0.0 0.0 1.8 Total 0.6 0.4 0.4 1.2 9.1 27.2 13.8 7.2 9.6 7.7 1.2 1.9 0.7 81.0

2021 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) Tesco Extra 0.4 0.2 0.1 0.6 4.5 14.4 7.5 3.1 4.0 4.4 0.6 0.9 0.6 41.4 Morrison 0.0 0.1 0.3 0.5 3.6 7.9 4.0 3.5 4.6 2.6 0.5 0.9 0.1 28.7 Lidl 0.0 0.0 0.0 0.1 0.3 1.8 0.7 0.2 0.1 0.2 0.1 0.0 0.0 3.5 Aldi 0.1 0.0 0.0 0.0 0.4 0.5 0.6 0.0 0.6 0.4 0.1 0.0 0.0 2.6 Iceland 0.0 0.0 0.0 0.1 0.4 0.5 0.2 0.0 0.1 0.1 0.0 0.0 0.0 1.3 Other stores Haverfordwest TC 0.1 0.0 0.0 0.0 0.2 1.4 0.8 0.4 0.3 0.1 0.0 0.1 0.0 3.3 Wilkinsons 0.0 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Local stores, Portfield 0.0 0.0 0.0 0.0 0.0 0.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.2 Other stores in Haverfordwest 0.0 0.1 0.1 0.0 0.0 1.2 0.2 0.1 0.2 0.1 0.0 0.0 0.0 1.9 Total 0.6 0.4 0.5 1.3 9.3 28.0 14.1 7.3 9.8 7.8 1.2 1.9 0.8 83.0

Notes: Derived from market shares in Table 4 and available spending in Table 3d.

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 6: Haverfordwest Comparison Goods Market Shares

2014 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%)

Haverfordwest TC 17.2 35.2 31.9 22.4 50.5 60.1 67.9 57.9 58.9 45.0 32.8 5.7 3.0 Haverfordwest out-of-centre 5.1 8.1 6.4 7.8 13.5 20.4 14.2 21.4 13.2 6.9 5.2 2.3 1.3 Total 22.3 43.3 38.3 30.2 64.0 80.5 82.1 79.3 72.1 51.9 38.0 8.0 4.3

Notes: Derived from Pembrokeshire Retail Study 2010

2019 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) Haverfordwest TC 17.2 35.2 31.9 22.4 50.5 60.1 67.9 57.9 58.9 45.0 32.8 5.7 3.0 Haverfordwest out-of-centre 5.1 8.1 6.4 8.8 14.5 25.0 14.2 21.4 13.2 6.9 5.2 2.3 1.3 Total 22.3 43.3 38.3 31.2 65.0 85.1 82.1 79.3 72.1 51.9 38.0 8.0 4.3

Notes: Market shares amended (as per retail assessment for permitted Sainsbury at Slade Lane) to take account of improvements to the town's retail offer provided by committed developments.

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 7: Haverfordwest Comparison Goods Turnover

2014 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Haverfordwest TC 6.4 8.7 8.9 4.1 25.4 31.8 17.0 7.3 16.6 10.6 2.9 2.6 0.7 143.0 Haverfordwest out-of-centre 1.9 2.0 1.8 1.4 6.8 10.8 3.6 2.7 3.7 1.6 0.5 1.0 0.3 38.1 Total 8.3 10.7 10.7 5.6 32.2 42.6 20.6 10.0 20.3 12.2 3.4 3.6 1.0 181.1

2019 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) Haverfordwest TC 7.4 10.0 10.3 4.8 29.1 36.5 19.5 8.3 19.1 12.0 3.4 2.9 0.8 164.2 Haverfordwest out-of-centre 2.2 2.3 2.1 1.9 8.4 15.2 4.1 3.1 4.3 1.8 0.5 1.2 0.3 47.3 Total 9.6 12.3 12.4 6.6 37.5 51.7 23.5 11.4 23.4 13.9 3.9 4.1 1.1 211.5

2021 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Zone 7 Zone 8 Zone 9 Zone 10 Zone 11 Zone 12 Zone 13 Total (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) Haverfordwest TC 7.9 10.7 11.0 5.1 31.0 38.9 20.7 8.8 20.4 12.8 3.6 3.1 0.8 174.9 Haverfordwest out-of-centre 2.3 2.5 2.2 2.0 8.9 16.2 4.3 3.3 4.6 2.0 0.6 1.3 0.4 50.4 Total 10.3 13.1 13.2 7.1 39.9 55.1 25.0 12.1 25.0 14.7 4.2 4.4 1.2 225.3

Notes: Derived from market shares in Table 6 and available spending in Table 3c.

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 8: Comparison Goods Floorspace within Haverfordwest

Benchmark Net Comparison Sales Density Total Benchmark Store Centre Gross Floorspace Floorspace 2014 Turnover 2014 (sq m net) (sq m net) (£/sq m) (£m)

HAVERFORDWEST Town Centre 16456 9874 4836 47.8

Out-of-Centre Tesco 6115 2715 9804 26.6 Morrisons 2787 418 8624 3.6 Aldi 760 152 4693 0.7 Lidl 929 186 3436 0.6

Bridge Meadow Halfords 740 518 1078 0.6 Currys 1367 957 7567 7.2 Vacant (former Allied Carpets) 740 518 2695 1.4

Withybush Retail Park M&S 2300 1840 8153 15.0 Boots 927 649 5390 3.5 Next 1234 864 6135 5.3 Laura Ashley 610 427 3708 1.6 Unit 5 Vacant 634 444 2695 1.2 Former Comet Vacant 933 653 2695 1.8 Debenhams 2002 2249 4.5 Sports World 981 687 2414 1.7

Springfield Retail Park Homebase 3606 2524 1432 3.6 Wickes 1911 1338 2590 3.5 Carpetright 620 434 1446 0.6 Topps Tiles 617 432 1655 0.7 Pets at Home 747 523 1617 0.8 Vacant Unit F 994 696 2695 1.9 Vacant Unit G 1463 1024 2695 2.8

Other stores in Haverfordwest 11700 8190 2695 22.1 TOTAL EXISTING - 38065 159.0

Committed development at Ebeneezer Row 1981 1387 4836 6.7 Committed Sainsbury, Slade Lane 2230 5695 12.7 TOTAL COMMITTED 3617 19.4

Notes: Sales densities taken from Table 14 PRS (2010), except for Boots which replaces a vacant unit at Withybush Retail Park with £5,000 per sq m assumed rather than £2,500 per sq m at 2009. Topps Tiles introduced at Springfield Retail with £1,535 per sq m rather than £2,500 per sq m at 2009 assumed for vacant unit (Retail Rankings). The Bridge Meadow Allied Carpets has closed and is vacant and so allowance is made for a sales density of £2,500 per sq m rather than £1,353 per sq m at 2009. Debenhams in former MFI unit assumed to trade at company average level (from RR2013), which means a turnover of £4.5m or an uplift of £1.8m compared to the turnover of the previous occupier MFI (£2.7m) Floorspace Efficiency growth rates taken from Table 4b of Experian Retail Planner 9 (September 2011), 10.1 (September 2012) and 11 9October 2013 in order to convert 2009 sales densities to 2014 Gross floorspace of proposed development at Ebeneezer Row is taken from planning application 1981sq m gia). We have assumed net to gross ratio of 70%. Notional sales density is that assumed for town centre space. Comparison floorspace and turnover of permitted Sainbury store is taken from applicants RIA and assumes store will trade at 80% of company average (as detailed by Sainsbury). 2007 prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 9: Convenience Goods Floorspace within Haverfordwest

Convenience Convenience Total Goods Sales Goods Density Benchmark Store Centre Net Floorspace Area 2014 Turnover (sq m net) (sq m net) (£/sq m) 2014(£m)

HAVERFORDWEST Town Centre 915 824 3742 3.1

Out-of-Centre Tesco Extra 6115 3400 11892 40.4 Morrisons 2787 2369 10298 24.4 Aldi 760 608 4072 2.5 Lidl 929 743 2981 2.2 Iceland 539 485 5357 2.6

M&S 696 9355 6.5

Other stores in Haverfordwest 300 270 3825 1.0 TOTAL - 9395 82.7

Committed Sainsbury, Slade Lane 3344 9659 32.3

Notes: Sales densities taken from Table 13 PRS (2010) Floorspace Efficiency rates taken from Table 4b of Experian Retail Planner 9 (September 2011), 10.1 (September 2012) and 11 (October 2013) in order to convert 2009 sales densities to 2014. Convenience floorspace and turnover of permitted Sainbury store is taken from applicants RIA and assumes store will trade at 80% of company average. 2007 prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 10 - Turnover of the Proposed Development at 2014

Gross Floorspace (sq m) 1533 Net Sales Area (sq m) 1380

Estimated Total Turnover (£m) 3.1

Comparison Goods Turnover (%) 70 (£m) 2.2

Convenience Goods Turnover (%) 30 (£m) 0.9

Notes: Net sales estimated to be 90% of Gross (which includes proposed 139 sqm mezzanine) Sales density of £2,250 utilised as reasonable sales density for Home Bargains / B&M Bargains / Family Bargains in the absence of published sales densities. Expressed in 2007 prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 11: Comparison Goods Capacity in Haverfordwest

2014 2019 2021

Available comparison exp in Haverfordwest (£m) 181.1 211.5 225.3

Benchmark turnover of existing floorspace (£m) 157.1 174.5 181.7

Benchmark turnover of committed floorspace (£m) 19.4 21.6 22.4

Expenditure capacity (£m) 4.6 15.4 21.1 Turnover proposed Home Bargains (£m) 2.2 2.4 2.5 Residual capacity (£m) 2.4 13.0 18.6

Notes: Available comparison goods expenditure captured by Haverfordwest taken from Table 7.

Benchmark turnover of existing and committed floorspace taken from Table 8. Turnover assumed for vacant Unit F at Springfield has been omitted as that is the unit that will be occupied by the proposed Home Bargains Growth in floorspace efficiency 2014-2021, of existing and committed stores and the proposed Home Bargains, assumes Experian's forecast growth in comparison sales densities from Fig 4b in Retail Planner Briefing Note 11. 2007 prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 12: Convenience Goods Capacity in Haverfordwest

2014 2019 2021

Available convenience exp in Haverfordwest (£m) 76.7 81.0 83.0

Benchmark turnover of existing floorspace (£m) 82.7 82.2 82.3

Benchmark turnover of committed floorspace (£m) 32.3 32.1 32.1

Expenditure capacity (£m) -38.4 -33.2 -31.4 Turnover proposed Home Bargains (£m) 0.9 0.9 0.9 Residual capacity (£m) -39.3 -34.2 -32.3

Notes: Available comparison goods expenditure captured by Haverfordwest taken from Table 7. Benchmark turnover of existing and committed floorspace taken from Table 8. Growth in floorspace efficiency 2014-2021, of existing and committed stores and the proposed Home Bargains, assumes Experian's forecast growth in comparison sales densities from Fig 4b in Retail Planner Briefing Note 11. 2007 prices

JPW0246 December 2013 (c) RPS Group Plc Proposed Home Bargains at Springfield Retail Park, Haverfordwest Retail Assessment

Table 13 Retail Impact

Turnover Turnover Trade Draw Resultant Trade Draw to Resultant Trade Draw to Resultant Cumulative Impact HB Solus 2014 2019 to Ebeneezer Row T/O 2019 Sainsbury & Debenhams T/O 2019 Home Bargains T/O 2019 Impact (£m) (£m) (%) (£m) (£m) (%) (£m) (£m) (%) (£m) (£m) (%) (%) Iceland, Haverfordwest Convenience 1.2 1.2 0 0.0 0.7 1 0.3 0.4 0 0 0.4 -71.5 0 Comparison 0.0 0.0 0 0.0 0.0 0 0.0 0.0 0 0 0.0 0.0 0

Lidl, Haverfordwest Convenience 3.2 3.4 0 0.0 3.4 2 1.0 2.4 0 0.01 2.4 -29.6 -0.3 Comparison 0.6 0.7 0 0.0 0.7 0 0.2 0.5 2 0.05 0.5 -30.5 -7.0

Haverfordwest Town Centre Convenience 3.2 3.4 0 0.0 3.4 1 0.6 2.8 1 0.02 2.8 -19.1 -0.6 Comparison 47.8 53.0 15 1.0 58.7 3 1.6 57.2 12 0.38 56.8 7.1 -0.7 Sub-total Haverfordwest Town Centre 56.0 61.8 15.0 1.0 66.9 7.8 3.7 63.2 15.0 0.5 62.8 1.6 -0.7 Tesco, Haverfordwest Convenience 38.3 40.4 0 0.0 40.4 33 15.5 24.9 5 0.15 24.8 -38.7 -0.4 Comparison 26.6 29.6 5 0.3 29.2 11 5.2 24.0 7 0.2 23.8 -19.4 -0.7 Morrison, Haverfordwest Convenience 26.5 28.0 0 0.0 28.0 21 10.0 18.0 13 0.39 17.6 -37.1 -1.4 Comparison 3.6 4.0 2 0.1 3.9 3 1.3 2.6 5 0.15 2.4 -39.9 -3.7 Aldi, Haverfordwest Convenience 2.4 2.6 0 0.0 2.6 2 1.0 1.6 0 0.01 1.6 -39.2 -0.4 Comparison 0.7 0.8 0 0.0 0.8 0 0.2 0.6 2 0.05 0.6 -27.3 -6.3 Retail Parks, Haverfordwest Convenience 3.9 3.8 0 0.0 3.8 0 0.0 3.8 3 0.1 3.7 -2.6 -2.6 Comparison 57.6 64.0 53 3.6 60.4 9 4.4 56.0 33 1.0 55.0 -14.0 -1.6 Other Haverfordwest Convenience 1.9 2.0 0 0.0 2.0 1 0.6 1.4 0 0 1.4 -28.8 0.0 Comparison 22.1 24.5 15 1.0 23.5 3 1.5 22.0 0 0 22.0 -10.2 0.0

New Sainsbury, Slade Lane Convenience ------32.3 8 0.25 32.1 Comparison ------12.7 10 0.3 12.4

Sub-total Haverfordwest Out-of-Centre 183.5 199.6 75.0 5.0 194.6 314.1 39.6 200.0 85.0 2.6 197.4 -1.1 -1.3 Total Haverfordwest 239.5 261.4 90.0 6.0 261.5 322.0 43.3 263.2 100.0 3.1 260.1 -0.5 -1.2 Outside Haverfordwest Convenience - - 7 3.4 0 0 Comparison - - 10 0.7 1 0.3 0 0 TOTAL 100.0 6.7 329.8 47.0 100.0 3.1

Notes:

Turnover of existing stores derived from Tables 5 & 8, with allowanace made for M&S at Withybush (assumes company average sales density 2013 projected forward at Experian's forecast growth rates in Retail Planner Briefing Note 11.

Trade draw patterns of proposed development at Ebeneezer Row and permitted Sainsbury at Slade Lane is as per WYG retail assessments submitted with each application. Cumulative impact shows overall affect of Ebeneezer Row, new Debenhams, Sainsbury at Slade lane and the proposed Home Bargains. Solus impact shows impact of just the impact of the Home Bargains on each stores pre-impact 2019 turnover. 2007 prices

JPW0246 December 2013 (c) RPS Group Plc