BOROUGH OF BROXBOURNE COUNCIL Local Plan Evidence Base Document

Brookfield Retail & Leisure Impact Study

Retail Addendum - June 2018

www.wyg.com creative minds safe hands

Contents

1.0 Introduction ...... 1 1.1 Instruction ...... 1 1.2 Borough of Broxbourne Retail & Leisure Study 2nd Addendum ...... 1 1.3 Structure of Report ...... 4

2.0 Updated Quantitative Retail Impact Assessment ...... 5 2.1 Introduction ...... 5 2.2 Updated Quantitative Retail Impact Assessment ...... 6

3.0 Updated Impact Assessment on Existing, Committed & Planned In-Centre Investment ...... 14 3.1 Introduction ...... 14 3.2 Impact on Harlow Town Centre North Site ...... 14 3.3 Conclusions ...... 15

4.0 Updated Impact Assessment on Centre Vitality and Viability ...... 16 4.1 Introduction ...... 16 4.2 Updated Impact Assessment on Vitality and Viability of Centres within Broxbourne ...... 16 4.3 Updated Impact Assessment on Vitality and Viability of Centres outside Broxbourne ...... 19

5.0 Overall Conclusions ...... 23 5.1 Introduction ...... 23 5.2 Updated Quantitative Retail Impact Assessment ...... 23 5.3 Updated Impact Assessment on In-Centre Investment ...... 24 5.4 Updated Impact Assessment on Centre Vitality & Viability ...... 24 5.5 Overall Conclusions ...... 24

Appendices

Appendix A: Response to Neighbouring Council’s Local Plan Regulation 19 Comments

Appendix B: Statistical Retail Impact Tables

Appendix C: Statistical Retail Impact Sensitivity Testing

Appendix D: Existing/Planned/Committed In-Centre Investment Schedule – Harlow Town Centre

1.0 Introduction

1.1 Instruction

1.1.1 This statement has been prepared by WYG on behalf of the Borough of Broxbourne Council. It represents an addendum to the February 2017 Brookfield Retail and Leisure Impact Study (2017 RLIS). The addendum has been prepared in advance of the Local Plan hearing sessions which are due to take place in September this year.

1.1.2 WYG has been instructed to undertake an addendum to the February 2017 RLIS to take into account the following:

• the Borough of Broxbourne Retail Study 2 nd Retail Addendum, dated May 2018;

• health check update reviews of Waltham Cross and Hoddesdon town centres and Cheshunt Old Pond District Centre;

• any further potential investment sites identified by neighbouring LPA’s; and

• vitality and viability health check assessments and retail turnover data published since the 2017 RLIS by neighbouring local planning authorities (to support their emerging local plans).

1.1.3 WYG’s instructions are also to respond to relevant Local Plan ‘Regulation 19 Representations’ from neighbouring Council’s received by the Council between 9 th November and 21 st December 2017. Our responses are attached separately at Appendix A .

1.2 Borough of Broxbourne Retail & Leisure Study 2nd Addendum

1.2.1 The Borough of Broxbourne Retail Study 2 nd Retail Addendum provides an update on the retail capacity/quantitative need for additional convenience and comparison goods floorspace in the Borough. The addendum takes into account, inter alia , the following:

• updated population and population projection data (June 2016 ONS mid-year estimates);

• new/updated retail expenditure per capita data (based on Experian’s UK 2017 data release);

• updated retail expenditure growth projections and data (Experian Retail Planner Briefing Note 15 (December 2017);

• updated grocery sales density data (GlobalData.com);

• updated grocery floorspace data from ORC Store Point; and

Brookfield RLIS Addendum Page 1 www.wyg.com

• the current position on retail planning commitments/permissions.

1.2.2 The addendum also updates the assessment period to reflect the current plan period to 2033 and the base year for the assessment reflects the current year - 2018.

1.2.3 For ease of reference the headline convenience and comparison goods turnover and floorspace capacity findings for the plan period are set out in Figures 1.1 below.

Figure 1.1: Quantitative Need for Retail Floorspace in Borough of Broxbourne 2033 Turnover Floorspace Requirement Capacity (sq m net) (£m) Min Max Before Commitments/Planning Permissions

Convenience Goods 63.4 5,400 5,900

Comparison Goods 137.0 21,300 36,700 (Constant Market Share Scenario) Comparison Goods 234.1 36,300 62,800 (Market Share Uplift Scenario) After Commitments/Planning Permissions

Convenience Goods 57.7 4,900 5,400

Comparison Goods 124.4 19,300 33,300 (Constant Market Share Scenario) Comparison Goods 221.5 34,400 59,400 (Market Share Uplift Scenario) Source: Updated Tables 6b, 6c, 26b, 26c, 27b and 27c of 2nd Retail Study Addendum, Appendix 1 2012 Prices

1.2.4 In our July 2015 Broxbourne Retail and Leisure Study we identified that there was scope to secure an increase in the Borough’s retention of comparison goods expenditure originating in the Borough as some residents are travelling further afield to source certain types of good. The Broxbourne Retail & Leisure Study 2 nd Retail Addendum (May 2018) identifies that the Borough’s retention rate of comparison goods expenditure is just 55%. Accordingly, a significant proportion of residents living in the Borough are travelling to other centres/facilities outside the Borough for their comparison goods shopping.

1.2.5 The development of a significant quantum of comparison goods floorspace to meet identified quantitative (and qualitive) need would have the potential to increase market share and ‘clawback’ expenditure ‘leaking’ to other centres. The uplift in market share that is secured will be dependent on the scale, format and performance of the scheme that is delivered. The market share uplift scenario in the Retail Study Addendum tests an increase in Broxbourne’s study area derived market share from 25.2% to 28.9% (approximately 15% increase). Given that the level of capacity identified under this scenario (£221.5m in plan period (2033)) is estimated to be higher than the estimated turnover of the planned

Brookfield RLIS Addendum Page 2 www.wyg.com

comparison goods floorspace of Brookfield (estimated to be £187.5m at 2033 (under Scenario B – Medium sales density)) the actual market share uplift that is required to accommodate Brookfield is actually likely to be lower (between 5-10%). The uplift will depend on the amount of comparison goods floorspace that is developed at Brookfield. Proposed Policy BR1 identifies an “up to” comparison goods figures for Brookfield (28,000sq m net (30,000sq m net including the Brookfield Retail Park commitment)) and the RLIS tests this ‘worst case’ scenario.

1.2.6 As noted in the 2017 RLIS, National Planning Policy Guidance (NPPG) (paragraph 14) provides guidance on how the impact test should be used in plan making. It states:

“If the Local Plan is based on meeting the assessed need for town centre uses in accordance with the sequential approach, issues of adverse impact should not arise. The impact test may be useful in determining whether proposals in certain locations would impact on existing, committed and planned public and private investment, or on the role of centres.”

1.2.7 Turning firstly to the sequential approach, the 2015 Retail and Leisure Study sought to assess where the identified forecast additional retail and leisure capacity and growth could be located. The assessment identified:

• with the exception of the site at the northern High Street (Waltham Cross), there were no new opportunities for retail or leisure developments within or on the edge of the town centres; and

• there was very little physical capacity to accommodate all of the assessed convenience and comparison floorspace capacity over the period within the designated centres.

1.2.8 The Retail & Leisure Study concluded that, as a long-established retail destination in its own right, Brookfield (and the Greater Brookfield area) was considered the sequentially preferable location to accommodate any residual large-scale retail and leisure development within the Borough.

1.2.9 We understand from discussions with planning officers in the Council that there has been no material change in circumstances in terms of potential sequentially preferable sites in the Borough.

1.2.10 On the basis that the planned retail floorspace at Brookfield (up to 28,000sq m net comparison goods / 3,000sq m net convenience goods) is meeting the assessed identified retail need the NPPF and NPPG do not technically require an impact assessment to be undertaken. The NPPG notes that the impact test “may be useful” but it does not specifically set out a requirement to undertake one.

1.2.11 Notwithstanding the above, for robustness a detailed impact assessment has been undertaken and this addendum provides an update to the original 2017 RLIS.

1.2.12 In accordance with our instruction, taking into account the updated assessments/information at paragraph 1.1.2 and 1.1.3, the addendum updates the following sections of the 2017 RLIS:

Brookfield RLIS Addendum Page 3 www.wyg.com

• Section 4: Quantitative Retail Impact Assessment;

• Section 5: Impact on Existing, Committed & Planned In-Centre Investment; and

• Section 7: Overall Impact on Centre Vitality & Viability.

1.3 Structure of Report

1.3.1 Our report is structured as follows:

Section 2: provides an updated quantitative retail impact assessment;

Section 3: sets out an updated impacted assessment on existing, committed and planned in-centre investments;

Section 4: provides an updated assessment on the overall impact on the vitality and viability of centres the quantitative retail impact assessment;

Section 5: summarises our findings.

Brookfield RLIS Addendum Page 4 www.wyg.com

2.0 Updated Quantitative Retail Impact Assessment

2.1 Introduction

2.1.1 This section of the statement provides an updated quantitative retail impact assessment taking into account the population and retail data updates adopted in the Broxbourne Retail Study 2 nd Retail Addendum. As noted in Section 1, the update takes into account the following:

• updated population and population projection data (June 2016 ONS mid-year estimates);

• new/updated retail expenditure per capita data (based on Experian’s UK 2017 data release);

• updated retail expenditure growth projections and data (Experian Retail Planner Briefing Note 15 (December 2017);

• updated grocery sales density data (GlobalData.com);

• updated grocery floorspace data from ORC Store Point; and

• the current position on retail planning commitments/permissions.

2.1.2 Where relevant the retail turnover for centres outside the Borough have also been updated having regard to new retail studies published by neighbouring boroughs/districts since the 2017 RLIS. These retail turnovers have been converted to the same price base (2012 Prices) using Experian Retail Planner Briefing Note 15 – December 2017 (Appendix 4b).

2.1.3 The updated impact assessment also updates the base year from 2016 to 2018. In terms of the design year for testing impact, this has been updated from 2024 to 2026. Whilst the NPPF (paragraph 26) identifies that for major schemes (which Brookfield Riverside would be) impact should also be assessed up to ten years from the time the application is made, in order to be robust the impact assessment continues to adopt a design year which is 8 years from the base year.

2.1.4 The statistical retail impact tables referred to in this section are contained at Appendix B and Appendix C.

2.1.5 As per the 2017 RLIS, three trading assessment scenarios are provided testing the proposed 28,000sq m net comparison goods floorspace trading at different sales density levels. An allowance has been made for increased turnover deficiency between 2024 and 2026 as set out in Experian Retail Planner 15 (December 2017):

Brookfield RLIS Addendum Page 5 www.wyg.com

• Scenario A – Low comparison goods sales density – £4,705/sq m @ 2026 (previously £4,500/sq m @ 2024)

• Scenario B – Medium comparison goods sales density – £5,750/sq m @ 2026 (previous £5,500/sq m @ 2024)

• Scenario C – High comparison goods sales density - £6,273/sq m @ 2026 (previous £6,000/sq m @ 2024)

2.1.6 As noted at paragraph 4.1.3 of the original RLIS, having regard to: the level of planned retail floorspace; existing retail provision in Brookfield; the location of existing retail provision (notably in Harlow and Enfield); and projected turnover efficiency information provided by retail data provider Experian we consider that Scenario B represents the most likely comparison goods sales density turnover figure for the planned comparison goods floorspace at the design year.

2.2 Updated Quantitative Retail Impact Assessment

Trade Diversion to Planned Retail Floorspace at Brookfield

2.2.1 Figure 2.1 sets out the assessed potential trading effects of the planned retail (both convenience and comparison goods) floorspace at Brookfield under the three scenarios described above. As with the original 2017 RLIS two measures of retail impact are provided:

• the change in the turnover of centres in the period 2018-2026 following the development of the planned floorspace; and

• the impact of the planned floorspace on the calculated 2026 turnover of centres.

Brookfield RLIS Addendum Page 6 www.wyg.com

Figure 2.1: Potential Trading Effects of Planned Brookfield Riverside Original 2017 RLIS Updated R LIS

Change in Impact on 2024 Change in Impact on 2026 Turnover 2016- Turnover Turnover 2018- Turnover 2024 2026 SCENARIO A

Centres inside Borough Waltham Cross Town Centre +16.5% -4.1% +19.4% -3.2% Hoddesdon Town Centre +5.9% -3.1% +9.6% -2.7% Cheshunt District Centre +17.7% -2.1% +15.5% -1.7%

Centres Outside Borough Harlow Town Centre +42.4% -4.3% +24.6% -4.9% Enfield Town Centre +32.6% -4.6% +17.0% -4.2% Welwyn Garden City Town Centre +16.5% -3.4% +28.8% -2.5% Hertford Town Centre +14.2% -3.2% +18.1% -3.0% Hatfield Town Centre +26.1% -1.3% +16.7% -1.5% Stevenage Town Centre +20.2% -1.3% +16.4% -1.3% Ware Town Centre +14.1% -2.0% +14.6% -2.1%

SCENARIO B

Centres inside Borough Waltham Cross Town Centre +15.6% -4.8% +18.7% -3.8% Hoddesdon Town Centre +5.8% -3.2% +9.4% -2.8% Cheshunt District Centre +17.3% -2.3% +15.2% -2.0%

Centres Outside Borough Harlow Town Centre +41.0% -5.2% +23.2% -6.0% Enfield Town Centre +31.2% -5.6% +15.9% -5.2% Welwyn Garden City Town Centre +15.6% -4.2% +28.1% -3.1% Hertford Town Centre +13.5% -3.8% +17.4% -3.6% Hatfield Town Centre +25.7% -1.6% +16.3% -1.8% Stevenage Town Centre +19.9% -1.6% +16.0% -1.6% Ware Town Centre +13.8% -2.3% +14.3% -2.4%

SCENARIO C

Centres inside Borough Waltham Cross Town Centre +15.2% -5.2% +18.4% -4.1% Hoddesdon Town Centre +5.7% -3.3% +9.4% -2.9% Cheshunt District Centre +17.2% -2.5% +15.1% -2.1%

Centres Outside Borough Harlow Town Centre +40.3% -5.7% +22.5% -6.8% Enfield Town Centre +30.5% -6.1% +15.3% -5.6% Welwyn Garden City Town Centre +15.1% -4.6% +27.7% -3.4% Hertford Town Centre +13.1% -4.1% +17.0% -3.9% Hatfield Town Centre +25.6% -1.8% +16.1% -1.9% Stevenage Town Centre +19.7% -1.7% +15.9% -1.7% Ware Town Centre +13.7% -2.4% +14.2% -2.5%

Source: Updated Tables 13a, 13b & 13c, Appendix B and Tables 13a, 13b & 13c, Appendix C – 2017 RLIS Figures may not add due to rounding 2012 Prices

2.2.2 Figure 2.1 shows that there will continue to be an increase in the retail of turnovers of all centres within an 8-year period, even assuming the worst-case scenario (Scenario C – High Density). It is noted that whilst Waltham Cross and Hoddesdon town centres retail growth in the 8-year period is assessed to be higher (primarily as a result of lower retail turnovers being identified in their respective retail studies), both Harlow and Enfield town centres retail growth is estimated to be less than previously assessed.

Brookfield RLIS Addendum Page 7 www.wyg.com

2.2.3 Accordingly, the updated assessment identifies that the retail economies of the examined centres are all still assessed to continue to experience growth.

2.2.4 Turning to the impact on the 2026 retail turnover of centres/facilities. Assuming the most likely comparison goods sales density scenario (Scenario B) the updated assessment assesses:

• In terms of centres within the Borough, Waltham Cross and Hoddesdon town centres are assessed to experience impacts of 3.8% and 2.8% respectively (4.1% and 2.9% respectively under High Sales Density Scenario C). Cheshunt Old Pond District Centre is assessed to experience an impact of 2.0% (2.1% under Scenario C).

All these impacts are lower than previously assessed as part of the 2017 RLIS. The lower impacts are primarily due to the estimated increased retail turnovers of the centres resulting from the updated Experian ONS population and retail expenditure data (June 2016 ONS mid-year population estimates and UK 2017 retail data release).

• Turning to the centres outside the Borough, all centres are estimated to experience an impact of less than 6.0% (6.5% under High Sales Density Scenario C). Harlow Town Centre is estimated to experience the largest impact of 6.0% (6.8% under Scenario C), Enfield Town Centre an impact of 5.2% (5.6% under Scenario C), Welwyn Garden City Town Centre an impact of 3.1% (3.4% under Scenario C), and Hertford 3.6% (3.9% under Scenario C). Hatfield, Stevenage and Ware town centres are all assessed to experience an impact of below 2.4% (2.5% under Scenario C).

The level of impacts estimated are broadly similar to those previous assessed in the 2017 RLIS. Primarily as a result of a lower retail turnover identified in the 2017 Harlow Retail Study the impact of Brookfield is estimated to be slightly higher (+0.8%). Enfield, Welwyn Garden City and Hatfield town centres are all anticipated to experience slightly lower estimated impacts when compared to the 2017 original RLIS (-0.9% Welwyn Garden City, -0.4% Enfield, -0.2% Hatfield). Again, these differences are largely attributable to retail turnover data for these centres in updated retail and leisure studies).

2.2.5 The impact levels identified in the updated impact assessment are still considered to be low with retail turnover growth having mitigating effects on the examined impact arising from trade diversion to the planned Brookfield development.

2.2.6 We assess whether the above updated quantitative impact assessment findings result in a material change in our overall vitality and viability impact findings in Section 4 of this addendum.

Cumulative Impact with Brookfield Retail Park Extension Commitment

2.2.7 As with the 2017 RLIS, this quantitative impact assessment also takes into account the proposed 2,446sq m gross comparison goods extension retail commitment at Brookfield Retail Park (application ref:

Brookfield RLIS Addendum Page 8 www.wyg.com

07/16/0166/F). Updated Tables 13a, 13b and 13c set out separate cumulative impact figures with the retail commitment. The same assumptions have been applied to the retail commitment in terms of turnover and trade draw as that adopted in the original 2017 RLIS.

2.2.8 The assessed cumulative levels of trade diversion are partly reproduced in Figure 2.2 below.

Figure 2.2: Potential Cumulative Trading Effects of Planned Brookfield Riverside & Brookfield Retail Park Extension, 2026 Original 2017 RLIS Updated RLIS

Change in Impact on 2024 Change in Impact on 2026 Turnover 2016- Turnover Turnover 2018- Turnover 2024 2026 SCENARIO A

Centres inside Borough Waltham Cross Town Centre +16.2% -4.3% +19.2% -3.4% Hoddesdon Town Centre +5.9% -3.1% +9.5% -2.7% Cheshunt District Centre +17.6% -2.2% +15.4% -1.8%

Centres Outside Borough Harlow Town Centre +41.9% -4.6% +24.2% -5.2% Enfield Town Centre +32.2% -4.9% +16.7% -4.5% Welwyn Garden City Town Centre +16.2% -3.6% +28.6% -2.7% Hertford Town Centre +14.0% -3.3% +17.9% -3.2% Hatfield Town Centre +26.0% -1.4% +16.6% -1.6% Stevenage Town Centre +20.1% -1.4% +16.3% -1.4% Ware Town Centre +14.1% -2.0% +14.6% -2.1%

SCENARIO B

Centres inside Borough Waltham Cross Town Centre +15.3% -5.0% +18.5% -4.0% Hoddesdon Town Centre +5.7% -3.3% +9.4% -2.8% Cheshunt District Centre +17.2% -2.4% +15.2% -2.1%

Centres Outside Borough Harlow Town Centre +40.5% -5.5% +22.8% -6.3% Enfield Town Centre +30.8% -5.9% +15.6% -5.4% Welwyn Garden City Town Centre +15.3% -4.4% +27.9% -3.3% Hertford Town Centre +13.2% -4.0% +17.1% -3.8% Hatfield Town Centre +25.6% -1.7% +16.2% -1.9% Stevenage Town Centre +19.8% -1.7% +15.9% -1.6% Ware Town Centre +13.8% -2.3% +14.3% -2.4%

SCENARIO C

Centres inside Borough Waltham Cross Town Centre +14.9% -5.4% +18.2% -4.3% Hoddesdon Town Centre +5.6% -3.3% +9.3% -2.9% Cheshunt District Centre +17.1% -2.6% +15.0% -2.2%

Centres Outside Borough Harlow Town Centre +39.8% -6.0% +22.1% -6.8% Enfield Town Centre +30.1% -6.4% +15.0% -5.9% Welwyn Garden City Town Centre +14.8% -4.8% +27.5% -3.5% Hertford Town Centre +12.9% -4.3% +16.8% -4.1% Hatfield Town Centre +25.5% -1.8% +16.0% -2.0% Stevenage Town Centre +19.6% -1.8% +15.8% -1.8% Ware Town Centre +13.7% -2.4% +14.2% -2.5%

Source: Updated Tables 13a, 13b & 13c, Appendix B and Tables 13a, 13b & 13c, Appendix C – 2017 RLIS Figures may not add due to rounding 2012 Prices

Brookfield RLIS Addendum Page 9 www.wyg.com

2.2.9 The updated tables show that with the inclusion of the Brookfield Retail Park extension retail commitment in the impact assessment all defined centres are estimated to experience only a marginal increase in impact (again no more than 0.3% impact).

Quantitative Impact Sensitivity Testing

2.2.10 As noted at paragraph 4.3.1 of the 2017 RLIS, at the Council’s request the RLIS also undertook quantitative impact testing of two comparison goods scenarios. We provide an update on these scenarios below. As part of this addendum, in response to ‘Regulation 19 Representations’, we also provide an additional sensitivity impact scenario testing higher levels of trade draw from the surrounding three larger centres of Harlow, Welwyn Garden City, and Enfield.

Sensitivity Testing 1 – Retail & Leisure Study Comparison Goods Capacity Floorspace (Uplift in Market Share)

2.2.11 Given that the level of comparison goods turnover/floorspace capacity under the market share uplift scenario identified in the Retail & Leisure Study 2nd Addendum (May 2018) at 2033 (£221.5m /34,400sq m net) is now greater than the planned comparison goods floorspace at Brookfield Riverside (£187.5m at 2033 / up to 28,000sq m net) we do not consider it necessary to update this scenario.

Sensitivity Testing 2 – Previous Core Strategy Comparison Goods Floorspace (Tested in July 2011 Core Strategy Bridging Report

2.2.12 The previous Core Strategy planned for 35,000sq m net comparison goods floorspace at Brookfield. The assessed cumulative levels of trade diversion are set out in Updated Tables Gi, Gii, and Giii at Appendix C and are partly reproduced in Figure 2.3 overleaf.

2.2.13 The impact on the 2026 retail turnover of centres is, as expected, identified to be greater than the now planned comparison goods floorspace for Brookfield, with the following impacts, under Scenario B, assessed:

• Waltham Cross Town Centre – 4.8% (increase of 0.8% when compared to impact of now planned floorspace);

• Hoddesdon Town Centre – 3.0% (+0.2% increase);

• Harlow Town Centre – 7.8% (+1.5% increase);

• Enfield Town Centre – 6.7% (1.3% increase); and

• Welwyn Garden City Town Centre – 4.0% (+0.7% increase).

2.2.14 Figure 2.3 also shows that all centres are still anticipated to benefit from an increase in retail turnover in the period 2018-2026.

Brookfield RLIS Addendum Page 10 www.wyg.com

Figure 2.3: Updated Sensitivity Testing 2 (Brookfield providing 35,000sq m net comparison goods floorspace – Potential Cumulative Trading Effects, 2026 Original 2017 RLIS Updated RLIS

Change in Impact on 2024 Change in Impact on 2026 Turnover 2016- Turnover Turnover 2018- Turnover 2024 2026 SCENARIO A

Centres inside Borough Waltham Cross Town Centre +15.1% -5.3% +18.4% -4.0% Hoddesdon Town Centre +5.7% -3.3% +9.4% -2.8% Cheshunt District Centre +17.1% -2.5% +15.1% -2.1%

Centres Outside Borough Harlow Town Centre +40.1% -5.8% +22.7% -6.4% Enfield Town Centre +30.4% -6.2% +15.4% -5.5% Welwyn Garden City Town Centre +15.0% -4.6% +27.8% -3.3% Hertford Town Centre +13.0% -4.2% +17.0% -3.9% Hatfield Town Centre +25.5% -1.8% +16.2% -1.9% Stevenage Town Centre +19.7% -1.8% +15.9% -1.7% Ware Town Centre +13.8% -2.3% +14.3% -2.4%

SCENARIO B

Centres inside Borough Waltham Cross Town Centre +14.1% -6.0% +17.5% -4.8% Hoddesdon Town Centre +5.5% -3.5% +9.2% -3.0% Cheshunt District Centre +16.8% -2.8% +14.8% -2.4%

Centres Outside Borough Harlow Town Centre +38.6% -6.8% +20.9% -7.8% Enfield Town Centre +28.9% -7.3% +14.0% -6.7% Welwyn Garden City Town Centre +14.0% -5.4% +26.9% -4.0% Hertford Town Centre +12.2% -4.9% +16.1% -4.7% Hatfield Town Centre +25.2% -2.1% +15.7% -2.3% Stevenage Town Centre +19.3% -2.1% +15.5% -2.0% Ware Town Centre +13.4% -2.6% +13.9% -2.7%

SCENARIO C

Centres inside Borough Waltham Cross Town Centre +13.6% -6.5% +17.1% -5.1% Hoddesdon Town Centre +5.4% -3.6% +9.1% -3.1% Cheshunt District Centre +16.5% -3.0% +14.6% -2.5%

Centres Outside Borough Harlow Town Centre +37.7% -7.4% +20.0% -8.5% Enfield Town Centre +28.0% -7.9% +13.3% -7.3% Welwyn Garden City Town Centre +13.5% -5.9% +26.4% -4.4% Hertford Town Centre +11.7% -5.3% +15.6% -5.0% Hatfield Town Centre +24.9% -2.2% +15.5% -2.5% Stevenage Town Centre +19.1% -2.2% +15.3% -2.2% Ware Town Centre +13.2% -2.8% +13.7% -2.9%

Source: Updated Tables Gi, Gii & Giii, Appendix B and Tables Gi, Gii & Giii, Appendix C – 2017 RLIS Figures may not add due to rounding 2012 Prices

Brookfield RLIS Addendum Page 11 www.wyg.com

New Sensitivity Testing 3 – Higher Level of Comparison Goods Trade Diversion from Harlow, Enfield, and Welwyn Garden City Town Centres

2.2.15 We provide below a new sensitivity impact test in response to comments made in ‘Regulation 19 Representations’ in relation to the assessed retail trade draw patterns of the planned Brookfield development.

2.2.16 As noted earlier, the pattern of trade draw to the planned comparison goods floorspace has been assessed having regard to the trade draw patterns of existing retail facilities at Brookfield. The pattern of trade assessed from each zone has then been assessed having regard to the character of the planned development, existing shopping patterns and the location of existing retail facilities.

2.2.17 In order to respond to a number of the matters raised in ‘Regulation 19 Representations’ in relation to differing views on the assessed retail trade draw patterns of the planned Brookfield from the larger surrounding centres this new sensitivity impact scenario tests a higher level of comparison goods trade draw from Harlow (25%), Enfield (20%) and Welwyn Garden City (20%) town centres (65% trade draw overall).

2.2.18 For robustness we have not reduced the level of comparison goods trade assessed to be drawn from other centres both inside and outside the Borough. This scenario does however reduce the level of comparison goods trade estimated to be drawn from existing facilities in Brookfield and also assumes a lower level of comparison goods trade draw from outside the Survey Area.

2.2.19 The assessed cumulative levels of trade diversion for this sensitivity test are set out in Tables Hi, Hii and Hiii at Appendix C and are partly reproduced in Figure 2.4 below.

Figure 2.4: Sensitivity Testing 3 (Higher Trader Draw Assessed from Harlow, Enfield and Welwyn Garden City town centres) Cumulative Impact Cumulative Impact Cumulative Impact (Scenario A) (Scenario B) (Scenario C) Change in Impact on Change in Impact on Change in Impact on Turnover 2026 Turnover 2026 Turnover 2026 2018-2026 Turnover 2018-2026 Turnover 2018-2026 Turnover Centres Outside Borough Harlow Town Centre +21.6% -7.2% +19.6% -8.7% +18.6% -9.5% Enfield Town Centre +12.2% -8.2% +10.1% -9.9% +9.0% -10.8% Welwyn Garden City Town Centre +25.0% -5.5% +23.4% -6.7% +22.6% -7.2%

Source: Tables Hi, Hii, and Hiii, Appendix C Figures may not add due to rounding 2012 Prices

Brookfield RLIS Addendum Page 12 www.wyg.com

2.2.20 Figure 2.4 shows that even if it assumed that a higher level of trade is diverted from Harlow, Enfield and Welwyn Garden City town centres, under Scenario B, the level of impacts on their 2026 turnovers do not exceed 10% and all centres are still anticipated to benefit from an increase in retail turnover in the period 2018-2026. Given the current health of the centres (discussed later in Section 4) and our findings that no significant adverse impact arises on in-centre investment (discussed in Section 3 and Section 5 of the 2017 RLIS), we consider that such levels of quantitative retail impact is unlikely to undermine the trading position of these sub-regional centres.

Brookfield RLIS Addendum Page 13 www.wyg.com

3.0 Updated Impact Assessment on Existing, Committed & Planned In-Centre Investment

3.1 Introduction

3.1.1 The in-centre public/private sector investment assessment undertaken in the 2017 RLIS was informed by discussions/correspondence with planning policy officers in neighbouring authorities. The discussions/correspondence resulted in the production of a number of schedules which are appended at Appendix E of 2017 RLIS. The schedules provide details of each identified investment and Section 5 of the 2017 RLIS provides an assessment.

3.1.2 In their representations to the Pre-submission Local Plan (Regulation 19 Stage) Harlow Council have identified a further potential investment site that requires consideration: ‘Harlow Town Centre North Site’.

3.1.3 No other additional/new sites have been identified by neighbouring authorities that require further consideration. This supports our own review/appraisal of the centres outside the Borough. Planning officers at the Borough of Broxbourne Council has also confirmed that there are no additional/new sites that need to be reviewed as part of this updated impact assessment.

3.1.4 The remainder of this section assesses the potential impact of the proposed Brookfield Riverside development on the ‘Harlow Town Centre North Site’. In doing so we have had regard to paragraph 17 of the NPPG which identifies that key considerations of an assessment will include:

• The policy status of the investment (i.e. whether it is outlined in the Development Plan).

• The progress made towards securing the investment (for example if contracts are established).

• The extent to which an application is likely to undermine planned development or investments based on the effect on current/forecast turnovers, operator demand and investor confidence.

3.1.5 A schedule providing details of the Harlow Town Centre North Site is attached at Appendix D.

3.2 Impact on Harlow Town Centre North Site

3.2.1 The ‘Town Centre North Site’ is identified under saved policy RTCS5 of the Adopted Replacement Harlow Local Plan as playing a key role in diversifying the town centre to develop entertainment, leisure, food, drink and residential uses to strengthen the evening economy of the town centre.

Brookfield RLIS Addendum Page 14 www.wyg.com

3.2.2 The site, which measures approximately 4.1ha, is split into three separate areas by policy RTCS5:

1. Land South of Fourth Avenue and North of Kitson Street and Post Office Road;

2. Post Office and Adams House; and

3. Market Square and Northgate.

3.2.3 The site is in active use by a mix of uses including retail and leisure, a multi-storey car park, office and a Post Office. We understand that there are currently no plans, planning application or timescales for the potential comprehensive leisure led redevelopment of this site. It is noted that planning permission was granted for the demolition of the multi-storey car park at Kitson Way for a mixed use residential led mixed-use scheme including 170 apartments and 856sq m of commercial floorspace. We understand that this planning permission has expired. Prior Approval has also recently been confirmed for the change of use of the upper floors of Market House from B1 to C3 use class.

3.2.4 Accordingly, there are currently no investment plans for commercial leisure uses (or indeed any other use) for the site to impact upon. Our conclusions are, in part, supported by those of Harlow Council’s retail planning advisors, GVA, who have advised Harlow Council as follows:

“Overall we consider that it would be unlikely that a ‘significant adverse’ impact against in-centre commercial leisure provision in Harlow would arise as a consequence of the development of the proposed facilities at Brookfield Riverside, based on the uses mix (i.e. a cinema alongside a supporting food & beverage mix) and quantum of floorspace (4,000 sq.m) identified by WYG.”

Paragraph 1.40, GVA Retail Planning Advice to Harlow Council on WYG Brookfield RLIS, November 2016

3.3 Conclusions

3.3.1 In their representations to the Pre-submission Local Plan (Regulation 19 Stage) Harlow Council identified a further potential investment site that requires consideration: ‘Harlow Town Centre North Site’.

3.3.2 The foregoing analysis of the ‘Harlow Town Centre North Site’ identifies that the planned Brookfield development will not harm this potential investment coming forward.

3.3.3 Accordingly, our conclusions in the 2017 RLIS in relation to impact on in-centre investment in Harlow Town Centre remain applicable. There is no available evidence to support that a significant adverse impact will arise on in-centre investment in Harlow or any other assessed centre.

Brookfield RLIS Addendum Page 15 www.wyg.com

4.0 Updated Impact Assessment on Centre Vitality and Viability

4.1 Introduction

4.1.1 This section of the statement provides an updated impact assessment on the vitality and viability of centres considered within the 2017 RLIS. The updated assessment has regard to: (1) our review of the health of the centres within the Borough undertaken in May 2018; and (2) any updated health check assessments of relevant centres outside the administrative area undertaken on behalf of neighbouring authorities. It also has regard to the updated quantitative impact assessment undertaken in Section 2 of this addendum.

4.1.2 As noted earlier, it is important that this addendum is read alongside the 2017 RLIS and the assessment/findings contained therein.

4.2 Updated Impact Assessment on Vitality and Viability of Centres within Broxbourne

Waltham Cross Town Centre

4.2.1 Our vitality and viability health check of Waltham Cross Town Centre undertaken in January 2015 as part of the Broxbourne Retail & Leisure Study found the centre to be generally vital and viable. Our further review of the town centre in May 2018 finds that the centre is still vital and viable. In particular:

• the centre has seen a further reduction in vacant units (from 15 to 8 between 2015-2018) with the proportion of units vacant (5%) significantly below the UK average (12%).

• the environmental quality of the centre remains mixed;

• the centre continues to be accessible to a variety of modes of transport;

• the number of units occupied by comparison goods retailers has increased (from 61 to 67 between 2015-2018) with the current proportion (46%) being significantly higher than the UK average (38%);

• high levels of footfall were monitored in the southern part of the centre with more limited draw still observed to the northern end of the High Street; and

• The number and proportion of units in retail service use has improved (from 50 (34%) to 52 (36%) between 2015-2018).

Brookfield RLIS Addendum Page 16 www.wyg.com

4.2.2 Taking into account the updated health check findings of the centre and the quantitative retail impact assessment our previous findings identified at paragraph 7.2.3 of the 2017 RLIS remain unchanged. This updated assessment in this addendum finds that:

• the town centre continues to be both vital and viable (with a reducing vacancy rate); and

• the planned Brookfield development is unlikely to harm the trading position of existing retail facilities in the centre. The updated assessment finds that the level of retail trade/turnover assessed to be diverted is assessed to still be low (-3.8% at 2026) and the retail turnover is assessed to continue to grow (+18.7% between 2018-2026).

4.2.3 Accordingly, the planned Brookfield development is unlikely to have a significant adverse impact on the vitality and viability or role of Waltham Cross Town Centre.

Hoddesdon Town Centre

4.2.4 As set out in paragraph 7.2.4 of the 2017 RLIS, Hoddesdon Town Centre was found to be vibrant in our January 2015 health check assessment. Our further review of the town centre in May 2018 supports that the centre remains vibrant and vital and its vitality and viability has further improved:

• the number of vacant units in the centre has significantly reduced since 2015 (from 14 to 6). The proportion of units vacant (4%) is now substantially below the UK average (12%);

• the environmental quality of the centre remains in good condition which is reflected in the majority of the High Street being designated as a Conservation Area and containing a number of locally and nationally Listed Buildings;

• there continues to be a good mix of both multiple and independent retailers/service operators with the larger foodstore encouraging people to link trips;

• healthy levels of footfall were monitored throughout the centre with particularly high levels monitored between both the Sainsbury’s and Morrison’s stores and the High Street; and

• the redevelopment of the site at the corner of Conduit Lane and Brewery Road has improved the environmental quality of this part of the town centre and provided new active frontages.

4.2.5 Our earlier impact findings identified at paragraph 7.2.6 of the 2017 RLIS remain unchanged. The updated assessments in this addendum finds that:

• the town centre remains vibrant (with a very low and reducing vacancy rate); and

Brookfield RLIS Addendum Page 17 www.wyg.com

• the planned Brookfield development is unlikely to materially harm the trading position of existing retail facilities in the centre. The updated assessment finds that the level of retail trade/turnover assessed to be diverted is assessed to still be low (-2.8% at 2026) and the retail turnover is assessed to continue to growth (+9.4% between 2018-2026).

4.2.6 Overall, based on the findings of the 2017 RLIS and this addendum it is assessed that the cumulative impact of the planned Brookfield development and commitments on the vitality and viability of Hoddesdon Town Centre is acceptable.

Cheshunt Old Pond District Centre

4.2.7 The 2015 Retail Study and 2017 RLIS identifies that Cheshunt Old Pond District Centre serves a more local role and has a more limited offer in terms of its retail and service provision in comparison to Waltham Cross and Hoddesdon town centres. It offers a notable local service sector and a reasonable convenience goods provision. Our further review of the centre in May 2018 finds the role and function of the district centre has not materially changed.

4.2.8 The January 2015 health check of the district centre identified that it was in good health and performing well. Our further recent review of the centre supports these findings:

• the centre continues to provide a strong service provision with a large number of restaurants, cafes, banks, estate agents and hairdressers present;

• the vacancy level (6% (5 units)) remains significantly below the UK average (12%) and has reduced since 2015 (-2%);

• there remains scope for improvement in the environmental quality of the district centre;

• the centre remains accessible by public transport albeit is still quite car-dependent; and

• whilst the centre benefits from a significant walk-in and drive-by trade the main roads continue to impede pedestrian flows.

4.2.9 Having regard to the findings of the updated health check of the centre and the low levels of impacts assessed on the centre (-1.7% at 2026) identified in the updated quantitative retail impact assessment the findings identified at paragraph 7.2.9 of the 2017 RLIS still remain applicable. The planned Brookfield development is not considered to result in any significant adverse impacts on the vitality and viability or role of the centre.

Brookfield RLIS Addendum Page 18 www.wyg.com

4.3 Updated Impact Assessment on Vitality and Viability of Centres outside Broxbourne

Harlow Town Centre

4.3.1 The updated vitality and viability assessment in the Harlow Council’s 2016 Retail and Leisure Needs Study identifies that the centre, for the most part, continues to perform well against key vitality and viability indicators:

• diversity of uses is good;

• the centre has a generally good mix of ‘mid-market’ comparison goods retailers;

• there is considerable investment in Harlow Town Centre taking place at present;

• prime Zone A rents have decreased but recent investment in the centre should hopefully assist in stabilising this;

• the town centre north area struggling for vitality and viability;

• there remains an opportunity to improve the physical appearance of the centre; and

• the presence of two foodstores, the civic offices, and a limited number of leisure uses help contribute to the vitality and viability of the centre.

4.3.2 Taking into account the updated health check findings of the centre, the updated quantitative retail impact assessment, our previous findings identified at paragraph 7.3.4 of the 2017 RLIS remain applicable. The planned Brookfield development is unlikely to have a significant adverse impact on the vitality and viability or role of Harlow Town Centre. Of particular note, the updated assessments in this addendum finds that:

• the town centre continues to perform well, for the most part, against key vitality and viability indicators;

• the planned Brookfield development would not result in any significant adverse impact on the Harlow Town Centre North site or any other potential investment site, in the town centre; and

• the trading position of existing facilities in the town centre is unlikely to be materially harmed as a result of the planned Brookfield development. The updated assessment finds that the level of retail trade/turnover assessed to be diverted is assessed to still be low (-6.3% at 2026) and the retail turnover is assessed to continue to growth (+22.8% between 2018-2026).

Brookfield RLIS Addendum Page 19 www.wyg.com

Enfield Town Centre

4.3.3 The latest published health check findings for Enfield Town Centre undertaken on behalf of Enfield Council is provided in the 2014 Enfield Retail Town Centre Study (although this document is dated 2014 it had not been approved by Enfield ‘Full Council’ at the time of the original 2017 RLIS). Like the 2007 health check for the town centre the study identifies a number of strengths and weaknesses with the centre including:

• the centre as a whole provides a good range of national and independent comparison retailers

• narrow footpaths and street clutter detract from the visual appearance of the centre;

• the centre’s vacancy rate is much lower than the UK average;

• the one-way gyratory system and traffic speeds impact on the shopping environment;

• the Palace Gardens Shopping Centres provides a good range of national comparison retailers in a pleasant pedestrianised environment;

• the evening economy could be improved; and

• there is a good selection of national multiple convenience retailers which are supported by good quality independent traders.

4.3.4 Having regard to the Council’s latest health check assessment it is considered that Enfield Town Centre continues to display goods levels of vitality and viability.

4.3.5 Taking into account the latest health check findings, the updated quantitative retail impact assessment and our previous findings at paragraph 7.3.7 of our original RLIS, it is still assessed that the planned Brookfield development is unlikely to have a significant adverse impact on the vitality and viability or role of Enfield Town Centre:

• the Council’s most recent health check assessment indicates that it displays good levels of vitality and viability; and

• the planned Brookfield development is unlikely to materially harm the trading position of existing retail facilities in the centre. The assessed impact is still considered to be low (-5.4% at 2026) and the centre is still anticipated to see an increase in turnover (+15.6%) between 2018-2026.

Brookfield RLIS Addendum Page 20 www.wyg.com

Welwyn Garden City Town Centre

4.3.6 The latest vitality and viability health check assessment of Welwyn Garden City Town Centre undertaken on behalf of Welwyn Hatfield Borough Council remains that which was undertaken as part of the 2016 Retail and Leisure Needs Assessment Update. Our original February 2017 RLIS (paragraph 7.3.8-7.3.9) has regard to this latest health check assessment. The assessment indicates that the town centre is considered to display very good levels of vitality and viability.

4.3.7 The updated quantitative retail impact assessment in this addendum identifies that the assessed level of retail impact on Welwyn Garden City Town Centre as a result of the planned Brookfield development remains low (3.5%) with the centre still anticipated to experience growth in the period 2018-2026 (+27.9%).

4.3.8 Accordingly, having regard to the updated quantitative retail impact assessment and our previous findings in paragraph 7.3.9 of the original RLIS, our previous conclusions remain applicable. It is assessed that the planned Brookfield development will not result in a significant adverse impact on the vitality and viability of Welwyn Garden City Town Centre.

Other Town Centres

4.3.9 For the town centres of Hertford, Hatfield, Stevenage and Ware, the 2017 RLIS takes into account the latest health check assessment of the centres undertaken on behalf of the relevant Councils. These are:

• Hertford Town Centre - East Herts Council Retail and Town Centre Study Update (2013);

• Hatfield Town Centre - Welwyn Hatfield Borough Council Retail and Leisure Needs Assessment Update (2016);

• Stevenage Town Centre - Stevenage Borough Council Revised Stevenage Retail Study (2014); and

• Ware Town Centre - East Herts Council Retail and Town Centre Study Update (2013).

4.3.10 A summary of the health check findings are contained at paragraphs 7.3.10, 7.3.12, 7.3.15, and 7.3.17 of the 2017 RLIS.

4.3.11 The updated quantitative retail impact assessment undertaken as part of this addendum updates the quantitative retail impact assessment undertaken as part of the original 2017 RLIS. Section 2 of the addendum finds that the level of trade diversions from all four town centres to the planned Brookfield development remains low (between -1.6%-3.8% at 2026); the retail turnover of each town centre is assessed to continue to grow (between 14.3%-17.1% - 2018-2026); and as a result, the trading position of existing retail facilities in the centres will not be materially harmed.

Brookfield RLIS Addendum Page 21 www.wyg.com

4.3.12 Accordingly, having regard to the updated quantitative retail impact assessment undertaken as part of this addendum our conclusions for each of the four town centres set out in Section 7 of the 2017 RLIS remain unchanged. Brookfield is unlikely to result in a significant adverse impact on the vitality and viability or role of Hertford, Hatfield, Stevenage or Ware town centres.

Brookfield RLIS Addendum Page 22 www.wyg.com

5.0 Overall Conclusions

5.1 Introduction

5.1.1 This statement represents an addendum to the February 2017 Brookfield Retail and Leisure Impact Study. The addendum has been prepared in advance of the Local Plan hearing sessions which are due to take place in September this year.

5.1.2 The addendum takes into account the following:

• the Borough of Broxbourne Retail Study 2 nd Retail Addendum, dated May 2018;

• health check update reviews of Waltham Cross and Hoddesdon town centres and Cheshunt Old Pond District Centre;

• any further potential investment sites identified by neighbouring LPA’s; and

• vitality and viability health check assessments and retail turnover data published since the February 2017 Retail Impact by neighbouring local planning authorities (to support their emerging local plans).

5.2 Updated Quantitative Retail Impact Assessment

5.2.1 The level of quantitative impacts estimated in this updated RLIS are broadly similar to those previous assessed in the 2017 RLIS. Primarily as a result of a lower retail turnover identified in the 2017 Harlow Retail Study the impact of Brookfield is estimated to be slightly higher (+0.8%). Enfield, Welwyn Garden City and Hatfield town centres are all anticipated to experience broadly similar levels of estimated impacts when compared to the 2017 RLIS (-0.9% Welwyn Garden City, -0.4% Enfield, +0.2% Hatfield).

5.2.2 The impact levels identified in the updated impact assessment are still considered to be low with retail turnover growth having mitigating effects on the examined impact arising from trade diversion to the planned Brookfield development.

5.2.3 In response to comments made in ‘Regulation 19 Representations’ this addendum has also provided an additional sensitivity impact scenario testing a higher level of comparison goods trade diversion from Harlow, Enfield and Welwyn Garden City town centres to the planned Brookfield development. Given the current health of the centres and our findings that no significant adverse impact arises on in-centre investment we consider that even with the levels of quantitative retail impact the trading position of these sub-regional centres is unlikely to be undermined.

Brookfield RLIS Addendum Page 23 www.wyg.com

5.3 Updated Impact Assessment on In-Centre Investment

5.3.1 Harlow Council have identified a further potential investment site that requires consideration as part of the assessment of impact of the planned Brookfield development. No other additional/new sites have been identified by neighbouring authorities that require further consideration which supports our own review/appraisal of the centres outside the Borough.

5.3.2 The impact assessment on the identified ‘Harlow Town Centre North Site’ identifies that the 4.1ha site is identified as playing a key role in diversifying the town centre to develop entertainment, leisure, food, drink and residential uses to strengthen the evening economy of the town centre. The analysis in this addendum identifies that the planned Brookfield development will not harm potential investment coming forward on this site.

5.3.3 Our conclusions in our 2017 RLIS in relation to impact on-in centre investment remain applicable. There is no available evidence to support that a significant adverse impact will arise on in-centre investment in Harlow or any other assessed centre.

5.4 Updated Impact Assessment on Centre Vitality & Viability

Centres within Borough

5.4.1 Having due regard to the updated health checks findings for Hoddesdon and Waltham Cross town centres and Cheshunt Old Pond District Centre and the updated quantitative retail impact assessment our conclusions with regard to impact of the planned Brookfield development on centre vitality and viability remain applicable. We consider it unlikely that the Brookfield development would result in a significant adverse impact on the vitality and viability of any defined centres within the Borough.

Centres outside Borough

5.4.2 The updated impact assessment on the vitality and viability of centres outside the Borough considers updated health check assessment undertaken on behalf of neighbouring Council’s published since the original 2017 RLIS. It also has regard to the updated quantitative retail impact assessment findings and updated impact assessment on in-centre investment. Our updated assessment finds that no significant adverse impacts on the vitality and viability of any assessed centres outside the Borough arise.

5.5 Overall Conclusions

5.5.1 Having regard to the impact assessment update contained in this addendum together with analysis contained in the 2017 RLIS we remain of the view that no significant adverse impact will arise on in- centre investment or the vitality and viability of any of the assessed defined centres within or outside the Borough.

Brookfield RLIS Addendum Page 24 www.wyg.com

Brookfield RLIS Addendum Page 25 www.wyg.com

Appendix A Response to Neighbouring Council’s Local Plan Regulation 19 Comments

Brookfield RLIS Addendum Page 26 www.wyg.com BORUGH OF BROXBOURNE COUNCIL BROOKFIELD RETAIL & LEISURE IMPACT STUDY (BRLIS) PRE-SUBMISSION LOCAL PLAN (REGULATION 19 STAGE) NEIGHBOURING COUNCIL REPRESENTATIONS AND WYG RESPONSE ______

No. Name Comments WYG Response/Comments

1. Harlow Proposed Comparison Goods Floorspace Proposed Comparison Goods Floorspace Council 1. The planned comparison goods floorspace (28,000sq m net) 1. Paragraph 23 of the NPPF identifies the importance for LPA’s, exceeds the identified comparison goods need for assessed in drawing up Local Plans, to allocate sites to meet the needs impact period as tested in the Broxbourne Retail Study 2016 for retail and other town centres uses in full. In accordance Addendum. Therefore, there is no justification for the higher with paragraph 23, the planned comparison goods floorspace level of comparison goods floorspace. in Brookfield is intended to meet the identified comparison goods needs assuming a small uplift in Broxbourne’s market share. Trade Draw & Comparison Goods Impact Trade Draw & Comparison Goods Impact 2. The emerging [now adopted (January 2017)] Harlow Retail & 2. The HRLNS was not published at the time of the drafting of the Leisure Needs Study (HRLNS) identifies that a greater amount Brookfield RLIS. The HRLNS survey zones are not directly of comparison goods expenditure is being drawn to Brookfield comparable to those adopted in the Broxbourne Retail & from Harlow. With the addition of potential new retailers at Leisure Study (BRLS). We however note that both studies Brookfield the influence on shopping patterns in Harlow will identify that Brookfield has limited influence on shopping increase. patterns in the urban area of Harlow (HRLNS - £3.3m of 3. The BRLIS understates the potential quantitative impact on £195.2m (Zones 1,2 and 5) BRLS - £2.0m of £171.8m (Zone Harlow Town Centre. The BRLIS should test a higher level of 13)). comparison goods trade diversion from Harlow Town Centre. 3. Having regard to, inter alia, the existing shopping patterns and the strength and provision of comparison goods facilities in Harlow Town Centre and at out-of-centre locations, and the existing trade draw patterns of existing retail facilities in Brookfield, the assessed levels of trade diversion are considered to be appropriate. Notwithstanding, and without prejudice to this view, an additional quantitative retail impact sensitivity scenario is provided in the BRLIS Addendum testing higher level of comparison goods trade diversion from Harlow Town Centre.

______A096754 –Reg19 Stage Neighbouring LPA Reps Page 1 of 3 May 2018 BORUGH OF BROXBOURNE COUNCIL BROOKFIELD RETAIL & LEISURE IMPACT STUDY (BRLIS) PRE-SUBMISSION LOCAL PLAN (REGULATION 19 STAGE) NEIGHBOURING COUNCIL REPRESENTATIONS AND WYG RESPONSE ______

No. Name Comments WYG Response/Comments

Impact on Town Centre Investment Impact on Town Centre Investment 4. A qualitative assessment of the implications of Brookfield 4. Harlow Town Centre North allocation was not identified by Riverside on the Harlow Town Centre North allocation should be Harlow Council as necessary for consideration at the time of undertaken. drafting the BRLIS. The BRLIS Addendum now reviews whether Brookfield Riverside is likely to result in a significant adverse impact on the Harlow Town Centre North allocation.

Commercial Leisure Qualitative Impact Commercial Leisure Qualitative Impact 5. Brookfield Riverside is unlikely to have a significant adverse 5. Noted impact on in-centre commercial leisure provision in Harlow. Overall Impact on Harlow TC Vitality & Viability Overall Impact on Harlow TC Vitality & Viability 6. The vitality and viability health check of Harlow Town Centre 6. The RLIS adopted, at that time, Harlow Council’s most recently used in the BRLIS is out-of-date. published health check assessment of Harlow Town Centre. 7. Whilst Harlow Town Centre could be considered to be (mostly) The January 2017 HRLNS now provides a more recent health performing well that does not mean it would not be vulnerable check of Harlow Town Centre. The BRLIS Addendum has when faced with strengthened competition from Brookfield. regard to the Council’s more recent health check assessment. No concerns are raised with the proposed convenience or 7. Noted – WYG agrees that Harlow Town Centre is performing commercial leisure floorspace. well. Given its current vitality and viability, strength, catchment, retail provision and other town centre uses WYG is not aware of any evidence that suggests that Harlow Town Centre is vulnerable. 2. London 1. Concerned with soundness of strategy in particular quantum of 1. A review of town centres within the Borough of Broxbourne to Borough retail floorspace and need to justify sequential approach test. assess whether there was any sequentially preferable site of Enfield 2. The vitality and viability health check assessment of Enfield suitable to meet the identified need was undertaken as part of Town Centre in BRLIS is not indicative of the current position. the July 2015 Retail & Leisure Study. WYG is not aware of any 3. The RIA does not consider smaller centres both within and material change of circumstances since the 2015 Retail & outside Broxbourne. Leisure Study.

______A096754 –Reg19 Stage Neighbouring LPA Reps Page 2 of 3 May 2018 BORUGH OF BROXBOURNE COUNCIL BROOKFIELD RETAIL & LEISURE IMPACT STUDY (BRLIS) PRE-SUBMISSION LOCAL PLAN (REGULATION 19 STAGE) NEIGHBOURING COUNCIL REPRESENTATIONS AND WYG RESPONSE ______

No. Name Comments WYG Response/Comments

2. The RIA adopted, at that time, the London Borough of Enfield’s most recently published health check assessment of Enfield Town Centre. London Borough of Enfield has now made available their most recent health check assessment which is provided in the Enfield Retail and Town Centre Study (November 2014). The RIA Addendum has regard to the Council’s more recent health check assessment. 3. The RIA has regard to widely accepted principle that ‘like competes with like’ (paragraph 16 of the NPPG). Having regard to the role and function of Brookfield and the service/local role of smaller district and local centres both within and outside Broxbourne there is considered to be limited trading overlap between Brookfield and these smaller centres. Any impact on these smaller centres, particularly those located outside the Borough of Broxbourne, will be immaterial. 3. Welwyn 1. WHBC raise no objection to the identification of Brookfield as 1. Broxbourne Borough Council accept that Brookfield is currently Hatfield an appropriate location for additional retail growth where this designated as out-of-centre in retail policy terms. The review Borough cannot be accommodated in its existing centres. However, of town centres within the Borough of Broxbourne identifies Council WHBC considers that the proposal to designate Brookfield as a that there are no sequentially preferable sites suitable to meet (WHBC) town centre is not justified by the evidence as it does not the identified need. As a long-established retail destination in currently function as a town centre. its own right, Brookfield has been considered by the Council 2. There are potential impacts from the scale of growth the sequentially preferable location to accommodate large envisaged at Brookfield on Welwyn Garden City, which could scale retail and leisure need within the Borough. impact on vitality and viability. 2. Comment noted - the potential impacts have been assessed in 3. Because a specific scheme has not been assessed qualitative the submitted RIA and RIA addendum. impacts have not been taken into account. If one, or both, of 3. The two department stores referred to in the representation the department stores in Welwyn Garden City were to relocate from Welwyn Garden City are assumed to be Debenhams and the impact of Brookfield would be more significant. John Lewis. We understand that neither of these retailers are currently being considered by the Councils as prospective tenants for the Brookfield development.

______A096754 –Reg19 Stage Neighbouring LPA Reps Page 3 of 3 May 2018 Appendix B Statistical Retail Impact Tables

Brookfield RLIS Addendum Page 27 www.wyg.com BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 1: Total Survey Derived Comparison Goods Market Share, 2018 (%) - No New Development

Total Study Zone Destination Area 1 2 3 4 5 6 7 8 9 10 11 12 13 (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%)

Brookfield 13 17 30 30 32 3 9 12 6 14 5 10 14 1 Waltham Cross Town Centre 7 1 11 9 21 3 13 7 6 13 3 1 2 Hoddesdon Town Centre 3 24 8 2 4 0 1 0 0 1 4 Cheshunt Old Pond District Centre 2 3 5 10 4 3 3 5 4 2 2 0 Other within Broxbourne 1 0 3 2 1 1 1 1 0 0 0

Sub Total Borough of Broxbourne 25 46 57 52 62 10 25 21 12 32 12 14 23 2

Harlow Town Centre 15 21 19 6 5 61 6 2 2 6 15 18 56 Harlow Retail Parks/Foodstores 6 11 4 4 1 19 3 0 4 6 8 21 Enfield Town Centre 13 2 2 5 8 0 4 42 40 4 5 0 8 1 Enfield Retail Parks/Foodstores 7 1 6 5 4 5 23 20 1 0 0 0 Welwyn Garden City Town Centre 6 6 2 7 3 2 2 3 33 33 11 7 Hertford Town Centre 3 2 1 1 1 0 0 13 15 8 Hertford Retail Parks/Foodstores 0 0 1 4 1 Hatfield Town Centre 1 2 1 1 0 0 4 2 2 1 2 Hatfield Retail Parks/Foodstores 0 0 0 1 0 2 Stevenage Town Centre 2 1 0 0 0 1 1 2 11 5 Stevenage Retail Parks/Foodstores 2 1 1 4 2 12 0 1 2 2 Ware Town Centre 1 0 0 0 9 2 Lakeside Shopping Centre 2 3 2 0 2 2 3 1 1 5 8 Bluewater Shopping Centre 1 1 0 0 2 2 0 Other (including Central London) 15 4 7 12 11 5 39 10 21 23 19 9 12 10

Total 100 100 100 100 100 100 100 100 100 100 100 100 100 100

Notes: Derived from Updated Table 25 of Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 2: Total Survey Derived Convenience Goods Market Share, 2018 (%) - No New Development

Total Study Zone Destination Area 1 2 3 4 5 6 7 8 9 10 11 12 13 (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%) (%)

Brookfield 14 13 41 57 49 3 2 5 1 28 5 13 2 Waltham Cross Town Centre 4 0 9 14 5 14 1 0 4 1 Hoddesdon Town Centre 13 74 45 5 10 18 1 11 3 11 15 25 Cheshunt Old Pond District Centre 2 1 4 10 13 0 1 Other within Borough 2 4 5 8 6 1 1 4 0

Sub Total Borough of Broxbourne 34 92 96 89 91 22 9 30 3 35 17 32 27 2

Harlow Town Centre 4 1 21 1 1 2 18 Other Harlow 12 1 1 51 1 2 0 72 Enfield Town Centre 3 1 19 Other Enfield 16 0 5 2 1 3 40 64 6 Welwyn Garden City Town Centre 0 1 Other Welwyn Garden City 0 0 2 2 2 1 Hertford Town Centre 1 1 1 0 0 9 5 6 Other Hertford 8 1 0 1 57 34 46 Hatfield Town Centre 0 0 1 0 1 Other Hatfield 0 4 3 Stevenage Town Centre 1 0 4 1 Ware Town Centre 3 1 23 15 Other 18 1 1 3 6 4 86 29 13 51 11 1 4 8

Total 100 100 100 100 100 100 100 100 100 100 100 100 100 100

Notes: Derived from Updated Table 4 of Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 3: Comparison Goods Expenditure, 2018 - No New Development (£m Spend)

Zone Total Study Trade from Beyond Total Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area Turnover (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 13.6 19.9 25.6 37.9 1.5 12.5 16.6 14.1 9.9 2.2 13.8 13.2 2.0 182.9 9.1 192.1 Waltham Cross Town Centre 0.9 7.4 7.4 25.1 1.6 17.3 8.7 13.9 9.0 1.4 0.9 2.1 95.7 4.4 100.1 Hoddesdon Town Centre 19.5 5.5 1.5 4.8 0.2 1.1 0.0 0.1 1.2 3.7 37.7 1.3 39.1 Cheshunt Old Pond District Centre 2.3 3.2 8.5 4.4 1.5 3.5 3.9 1.6 2.9 1.8 0.7 34.4 3.4 37.9 Other within Broxbourne 0.1 1.8 1.8 1.0 0.4 1.9 1.7 0.1 0.2 0.2 9.2 - 9.2

Sub Total Borough of Broxbourne 36.4 37.8 44.8 73.3 5.3 33.3 28.2 29.7 23.0 5.6 18.8 21.0 2.7 359.9 18.3 378.3

Harlow Town Centre 16.5 12.6 4.9 6.1 31.7 7.8 2.1 1.5 2.9 21.0 16.9 95.7 219.6 101.3 321.0 Harlow Retail Parks/Foodstores 8.8 2.7 3.8 1.2 10.1 3.7 0.5 1.8 8.5 7.6 36.0 84.5 157.5 242.0 Enfield Town Centre 2.0 1.3 4.3 9.5 0.1 5.5 56.5 97.2 2.8 2.1 0.5 7.8 2.2 191.6 51.5 243.1 Enfield Retail Parks/Foodstores 0.9 3.8 4.5 5.2 6.9 30.2 47.3 0.7 0.1 0.4 0.1 100.0 62.0 162.0 Welwyn Garden City Town Centre 4.6 1.5 6.1 3.9 1.1 2.5 8.2 23.9 15.0 14.8 6.7 88.2 244.6 332.9 Hertford Town Centre 1.9 0.4 1.3 0.6 0.6 0.2 5.8 21.1 7.4 39.2 5.9 45.2 Hertford Retail Parks/Foodstores 0.3 0.4 4.9 1.3 6.8 6.8 Hatfield Town Centre 1.5 0.4 1.3 0.2 1.2 2.8 0.8 2.9 0.6 2.8 14.4 51.4 65.7 Hatfield Retail Parks/Foodstores 0.1 0.1 0.6 0.2 2.3 3.3 61.2 64.5 Stevenage Town Centre 1.1 0.2 0.2 0.2 1.9 0.4 1.0 15.3 4.3 24.6 95.4 120.0 Stevenage Retail Parks/Foodstores 0.7 0.5 3.6 2.0 16.3 0.2 0.5 2.3 1.8 27.9 27.9 Ware Town Centre 0.0 0.1 0.1 12.4 1.4 14.0 7.6 21.6 Lakeside Shopping Centre 2.3 1.0 0.2 1.8 0.9 3.4 1.7 0.3 4.7 14.5 30.9 30.9 Bluewater Shopping Centre 0.5 0.4 0.2 2.4 5.3 0.1 9.0 9.0 Other (including Central London) 2.9 4.5 10.3 13.2 2.7 52.4 13.9 50.3 16.3 8.6 12.9 10.7 17.9 216.6 216.6

Total 79.7 66.6 86.1 117.6 52.0 134.6 133.5 241.3 72.0 45.3 138.0 92.1 171.8 1,431

Notes: 1483 Turnover of Existing Centres/Facilities derived from Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018). Town centre trade drawn from beyond study area derived from latest Retail Studies for the relevant neighbouring boroughs/districts (survey area turnover deducted from identified total comparison goods turnover figure) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 4: Convenience Goods Expenditure, 2018 - No New Development (£m Spend)

Zone Total Study Trade from Beyond Total Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area Turnover (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 6.2 15.9 28.1 35.9 1.0 1.4 4.3 1.8 10.9 1.3 10.1 2.7 119.5 3.6 123.1 Waltham Cross Town Centre 0.1 4.3 10.2 3.9 13.3 1.8 0.1 3.3 0.8 37.8 - 37.8 Hoddesdon Town Centre 35.3 17.4 2.5 7.4 5.6 1.0 10.6 1.3 2.7 12.3 13.0 109.2 - 109.2 Cheshunt Old Pond District Centre 0.5 1.4 4.7 9.6 0.1 0.7 17.1 - 17.1 Other within Borough 2.0 2.0 4.2 4.1 0.2 0.4 1.5 0.1 14.5 - 14.5

Sub Total Borough of Broxbourne 44.1 36.7 43.8 67.2 6.9 7.4 28.3 3.6 13.8 4.2 25.8 13.8 2.7 298.1 3.6 301.7

Harlow Town Centre 0.7 6.5 0.7 1.7 0.9 21.9 32.3 14.4 46.7 Other Harlow 0.6 0.3 15.8 1.0 0.7 0.2 87.3 105.8 35.2 141.1 Enfield Town Centre 1.1 27.1 28.2 4.3 32.6 Other Enfield 0.1 2.2 1.7 0.3 2.2 38.1 91.1 2.3 138.0 138.0 Welwyn Garden City Town Centre 0.2 0.2 42.4 42.5 Other Welwyn Garden City 0.2 0.8 0.7 0.6 0.6 2.9 39.7 42.5 Hertford Town Centre 0.3 0.4 0.2 0.3 2.4 4.0 3.2 10.8 55.9 66.7 Other Hertford 0.7 0.1 0.4 14.5 27.7 23.6 67.0 67.0 Hatfield Town Centre 0.2 0.2 0.1 0.4 0.8 43.9 44.7 Other Hatfield 1.5 0.7 2.2 79.3 81.5 Stevenage Town Centre 0.2 3.4 0.8 4.4 62.8 67.2 Ware Town Centre 0.7 18.7 7.7 27.0 21.0 48.0 Other 0.4 0.5 1.4 4.5 1.3 67.3 27.2 18.0 20.4 2.7 0.6 1.9 9.6 155.8 155.8

Total 47.7 38.3 48.9 73.5 31.1 78.5 94.8 141.7 39.6 25.4 81.1 51.8 121.6 874.1

Notes: Turnover of Existing Centres/Facilities derived from Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018). Town centre trade drawn from beyond study area derived from latest Retail Studies for the relevant neighbouring boroughs/districts (survey area turnover deducted from identified total convenience goods turnover figure) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 5: Comparison Goods Expenditure, 2026 - No New Development (£m Spend)

Zone Total Study Trade from Beyond Total Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area Turnover (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 17.7 25.8 32.9 48.6 2.0 16.2 22.1 18.5 12.8 3.0 18.1 17.4 2.6 237.5 11.9 249.3 Waltham Cross Town Centre 1.1 9.5 9.4 32.2 2.1 22.4 11.6 18.3 11.6 1.9 1.2 2.8 124.1 5.7 129.9 Hoddesdon Town Centre 25.4 7.2 1.9 6.2 0.3 1.4 0.0 0.2 1.5 4.8 49.0 1.7 50.7 Cheshunt Old Pond District Centre 3.0 4.1 11.0 5.7 2.0 4.6 5.0 2.2 3.8 2.3 0.9 44.5 2.2 46.7 Other within Broxbourne 0.1 2.3 2.4 1.3 0.5 2.5 2.2 0.2 0.2 0.2 12.0 - 12.0

Sub Total Borough of Broxbourne 47.3 48.9 57.5 93.9 6.9 43.1 37.7 39.1 29.6 7.4 24.6 27.6 3.5 467.1 21.6 488.6

Harlow Town Centre 21.4 16.2 6.3 7.8 41.0 10.2 2.9 1.9 3.8 27.5 22.2 123.5 284.7 146.0 430.6 Harlow Retail Parks/Foodstores 11.4 3.5 4.8 1.5 13.1 4.7 0.7 2.4 11.2 10.0 46.4 109.6 215.0 324.7 Enfield Town Centre 2.5 1.7 5.6 12.2 0.1 7.1 75.3 127.8 3.5 2.8 0.6 10.3 2.8 252.2 49.9 302.1 Enfield Retail Parks/Foodstores 1.1 4.9 5.8 6.7 8.9 40.3 62.1 0.8 0.2 0.5 0.1 131.6 69.9 201.4 Welwyn Garden City Town Centre 5.9 1.9 7.8 5.0 1.4 3.2 10.8 30.7 19.9 19.4 8.8 114.9 335.2 450.1 Hertford Town Centre 2.4 0.5 1.6 0.8 0.7 0.3 7.7 27.6 9.8 51.4 8.8 60.2 Hertford Retail Parks/Foodstores 0.4 0.5 6.4 1.7 8.9 8.9 Hatfield Town Centre 1.9 0.5 1.6 0.3 1.6 3.6 1.0 3.9 0.8 3.6 18.6 63.8 82.4 Hatfield Retail Parks/Foodstores 0.1 0.1 0.8 0.3 3.0 4.3 82.7 87.0 Stevenage Town Centre 1.4 0.2 0.3 0.3 2.5 0.5 1.3 20.0 5.7 32.3 110.2 142.4 Stevenage Retail Parks/Foodstores 0.9 0.7 4.7 2.6 21.1 0.2 0.7 3.0 2.4 36.2 36.2 Ware Town Centre 0.1 0.2 0.2 16.2 1.8 18.4 8.4 26.8 Lakeside Shopping Centre 3.0 1.3 0.3 2.4 1.2 4.4 2.3 0.4 6.2 18.7 40.0 40.0 Bluewater Shopping Centre 0.7 0.6 0.2 3.1 7.0 0.2 11.7 11.7 Other (including Central London) 3.8 5.9 13.2 17.0 3.5 67.9 18.5 66.1 20.9 11.3 16.9 14.0 23.1 282.2 282.2

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 164.5 119.4 221.6 1846 Notes: 1483 Turnover of Existing Centres/Facilities derived from Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018). Town centre trade drawn from beyond study area derived from latest Retail Studies for the relevant neighbouring boroughs/districts (survey area turnover deducted from identified total comparison goods turnover figure) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 6: Convenience Goods Expenditure, 2026 - No New Development (£m Spend)

Zone Total Study Trade from Beyond Total Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area Turnover (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 6.6 16.7 29.4 37.4 1.0 1.5 4.7 1.9 11.5 1.5 10.8 2.8 125.9 3.8 129.6 Waltham Cross Town Centre 0.1 4.5 10.7 4.1 14.5 1.9 0.1 3.6 0.8 40.3 - 40.3 Hoddesdon Town Centre 37.2 18.3 2.7 7.7 5.9 1.1 11.6 1.4 3.1 13.2 14.0 116.2 - 116.2 Cheshunt Old Pond District Centre 0.6 1.5 4.9 10.0 0.1 0.7 17.9 - 17.9 Other within Borough 2.1 2.1 4.4 4.3 0.2 0.5 1.6 0.1 15.2 - 15.2

Sub Total Borough of Broxbourne 46.5 38.8 45.8 70.1 7.3 7.8 30.9 3.8 14.5 4.9 27.6 14.8 2.8 315.5 3.8 319.2

Harlow Town Centre 0.7 6.9 0.7 1.8 1.0 23.0 34.1 17.2 51.4 Other Harlow 0.6 0.3 16.7 1.0 0.8 0.2 91.9 111.5 45.2 156.7 Enfield Town Centre 1.2 29.2 30.4 4.3 34.6 Other Enfield 0.1 2.3 1.7 0.4 2.3 41.6 98.0 2.5 148.7 52.7 201.4 Welwyn Garden City Town Centre 0.2 0.2 46.0 46.1 Other Welwyn Garden City 0.2 0.8 0.8 0.7 0.6 3.1 43.1 46.1 Hertford Town Centre 0.3 0.5 0.2 0.3 2.7 4.3 3.5 11.8 64.3 76.1 Other Hertford 0.7 0.1 0.5 16.7 29.6 25.4 73.0 73.0 Hatfield Town Centre 0.2 0.2 0.1 0.4 0.9 47.5 48.4 Other Hatfield 1.6 0.8 2.4 85.9 88.3 Stevenage Town Centre 0.2 3.6 0.8 4.7 73.5 78.2 Ware Town Centre 0.7 20.0 8.2 28.9 25.8 54.7 Other 0.4 0.5 1.5 4.6 1.4 71.1 29.7 19.4 21.4 3.1 0.7 2.0 10.2 166.0 166.0

Total 50.3 40.4 51.2 76.8 32.9 82.9 103.3 152.1 41.6 29.3 86.6 55.8 127.9 931.2

Notes: Turnover of Existing Centres/Facilities derived from Borough of Broxbourne Retail & Leisure Study - Retail Addendum Note (May 2018). Town centre trade drawn from beyond study area derived from latest Retail Studies for the relevant neighbouring boroughs/districts (survey area turnover deducted from identified total convenience goods turnover figure) Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 7: Planned Comparison Goods Floorspace - Brookfield, 2026

Net Floorspace Average Sales Density Turnover (sq m) (£/sq m) (£m) [1] [2] [3] a - Low sales density 4,705 131.7 b - Medium sales density 28,000 5,750 161.0 c - High sales density 6,273 175.6

Updated Table 8: Planned Convenience Goods Floorspace - Brookfield, 2026

Net Floorspace Average Sales Density Turnover (sq m) (£/sq m) (£m) [1] [2] [3]

Foodstore 3,000 12,000 36.0

Notes: [3] = [1] x [2] /1000000

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 9: Brookfield Comparison Goods Assessed Trade Draw, 2026

Zone Total Beyond Study Total 1 2 3 4 5 6 7 8 9 10 11 12 13 Zones 1-13 Area

[1] Brookfield's Existing Market Share (%) 17 30 30 32 3 9 12 6 14 5 10 14 1 13 - - [2] Existing Retail Facilities - Brookfield Turnover (£m), 2026 17.7 25.8 32.9 48.6 2.0 16.2 22.1 18.5 12.8 3.0 18.1 17.4 2.6 237.5 11.9 249.3 [3] Brookfield's Existing Trade Draw by Zone (%) 7 10 13 19 1 6 9 7 5 1 7 7 1 95 5 100

[4] New Scheme Trade Draw by Zones (%), 2026 7 10 13 19 1 6 9 7 5 1 7 7 1 95 5 100

[5a] New Scheme Trade Draw by Zones (£m), 2026 - (a) Low Sales Density 9.3 13.6 17.4 25.7 1.0 8.5 11.7 9.8 6.8 1.6 9.6 9.2 1.4 125.5 6.3 131.7 [5b] New Scheme Trade Draw by Zones (£m), 2026 - (b) Medium Sales Density 11.4 16.6 21.2 31.4 1.3 10.4 14.3 12.0 8.3 1.9 11.7 11.2 1.7 153.3 7.7 161.0 [5c] New Scheme Trade Draw by Zones (£m), 2026 - (C) High Sales Density 12.5 18.1 23.1 34.2 1.4 11.4 15.6 13.0 9.0 2.1 12.7 12.3 1.8 167.3 8.4 175.6

Notes: [1] Taken from Updated Table 1 [2] Taken from Updated Table 5 [3] Derived from [2] [4] Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Table 9) [5] Total turnover figures derived from Updated Table 7 Figures may not add due to rounding

2012 Prices

Updated Table 10: Brookfield Convenience Goods Assessed Trade Draw, 2026

Zone Total Beyond Study Total 1 2 3 4 5 6 7 8 9 10 11 12 13 Zones 1-13 Area

[1] Brookfield's Existing Market Share (%) 13 41 57 49 3 2 5 1 28 5 13 2 14 - - [2] Existing Retail Facilities - Brookfield Turnover (£m), 2026 6.6 16.7 29.4 37.4 1.0 1.5 4.7 1.9 11.5 1.5 10.8 2.8 125.9 3.8 129.6 [3] Brookfield's Existing Trade Draw by Zone (%) 5 13 23 29 1 1 4 1 9 1 8 2 97 3 100

[4] New Scheme Trade Draw by Zones (%), 2026 5 13 23 29 1 1 4 1 9 1 8 2 97 3 100 [5] New Scheme Trade Draw by Zones (£m), 2026 1.8 4.7 8.2 10.4 0.3 0.4 1.3 0.5 3.2 0.4 3.0 0.8 35.0 1.0 36.0

Notes: [1] Taken from Updated Table 1 [2] Taken from Updated Table 6 [3] Derived from [2] [4] Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Table 9) [5] Total turnover figure derived from Updated Table 8 Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 11a: Comparison Goods Expenditure, 2026 - With Brookfield Development (Low Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 25.7 35.3 44.3 67.1 3.0 23.0 32.6 27.3 18.6 4.5 27.2 25.9 3.9 338.2 17.5 355.8 Waltham Cross Town Centre 1.0 8.7 9.2 30.2 2.1 22.1 11.3 18.0 11.3 1.8 1.2 2.8 119.8 5.7 125.5 Hoddesdon Town Centre 24.9 7.0 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.7 48.1 1.7 49.8 Cheshunt Old Pond District Centre 3.0 4.0 10.7 5.5 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.8 2.2 46.0 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.8 11.8

Sub Total Borough of Broxbourne 54.7 57.1 68.5 110.2 7.9 49.6 47.8 47.6 35.1 8.9 33.7 35.9 4.8 561.7 21.0 582.6

Harlow Town Centre 17.9 11.3 4.7 4.4 40.3 8.9 1.7 1.5 3.7 25.9 19.3 122.6 262.3 145.0 407.3 Harlow Retail Parks/Foodstores 10.3 2.8 4.0 1.0 12.8 4.5 0.6 2.3 10.2 9.2 46.1 103.7 214.7 318.4 Enfield Town Centre 2.4 1.4 4.5 9.3 0.1 6.7 71.2 124.9 3.0 2.7 0.6 9.5 2.8 239.1 49.0 288.1 Enfield Retail Parks/Foodstores 1.0 4.3 5.0 4.2 8.4 38.0 60.2 0.8 0.2 0.4 0.1 122.5 69.6 192.1 Welwyn Garden City Town Centre 5.2 1.6 5.4 2.6 1.4 3.1 10.1 28.1 19.3 18.1 8.1 102.9 334.6 437.5 Hertford Town Centre 2.3 0.3 1.5 0.8 0.7 0.3 7.4 26.0 8.6 48.0 8.4 56.4 Hertford Retail Parks/Foodstores 0.3 0.5 6.0 1.7 8.4 -0.2 8.2 Hatfield Town Centre 1.7 0.4 1.4 0.3 1.4 3.0 1.0 3.7 0.8 3.5 17.2 63.4 80.7 Hatfield Retail Parks/Foodstores 0.1 0.1 0.8 0.3 2.9 4.0 82.5 86.5 Stevenage Town Centre 1.0 0.2 0.1 0.2 2.3 0.5 1.3 18.8 5.5 29.9 109.8 139.7 Stevenage Retail Parks/Foodstores 0.9 0.5 4.0 2.4 20.2 0.2 0.7 2.7 2.3 33.8 33.8 Ware Town Centre 0.2 0.2 15.5 1.8 17.6 8.2 25.8 Lakeside Shopping Centre 2.6 0.9 0.3 1.8 1.1 4.1 1.7 0.4 5.5 18.6 37.2 -0.2 37.0 Bluewater Shopping Centre 0.4 0.4 0.2 2.8 6.4 0.2 10.5 -0.2 10.3 Other (including Central London) 3.4 5.2 10.6 13.1 3.5 65.3 16.6 64.2 19.9 11.1 16.3 13.2 23.0 265.3 -0.6 264.7

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.2 119.5 221.6 1864 131.7 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1846 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 11b: Comparison Goods Expenditure, 2026 - With Brookfield Development (Medium Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 27.4 37.4 46.9 71.2 3.2 24.5 34.9 29.3 19.8 4.8 29.2 27.8 4.2 360.6 17.4 378.0 Waltham Cross Town Centre 1.0 8.5 9.1 29.8 2.1 22.0 11.2 18.0 11.3 1.8 1.2 2.8 118.8 5.7 124.5 Hoddesdon Town Centre 24.8 6.9 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.6 47.9 1.7 49.6 Cheshunt Old Pond District Centre 2.9 4.0 10.6 5.5 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.7 2.2 45.9 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.8 11.8

Sub Total Borough of Broxbourne 56.3 58.9 70.9 113.8 8.1 51.1 50.1 49.5 36.3 9.2 35.7 37.7 5.1 582.7 20.8 603.5

Harlow Town Centre 17.1 10.2 4.3 3.7 40.2 8.6 1.4 1.4 3.6 25.6 18.6 122.5 257.4 144.7 402.1 Harlow Retail Parks/Foodstores 10.0 2.6 3.8 0.8 12.7 4.4 0.5 2.3 10.0 9.1 46.0 102.3 214.7 317.0 Enfield Town Centre 2.3 1.3 4.3 8.7 0.1 6.7 70.3 124.2 2.9 2.7 0.5 9.4 2.8 236.2 48.8 285.0 Enfield Retail Parks/Foodstores 1.0 4.1 4.8 3.7 8.3 37.4 59.7 0.8 0.2 0.4 0.1 120.5 69.5 190.0 Welwyn Garden City Town Centre 5.0 1.5 4.9 2.1 1.4 3.0 9.9 27.5 19.1 17.8 7.9 100.3 334.5 434.7 Hertford Town Centre 2.3 0.3 1.4 0.8 0.7 0.3 7.4 25.7 8.3 47.2 8.4 55.6 Hertford Retail Parks/Foodstores 0.2 0.5 5.9 1.6 8.3 -0.2 8.0 Hatfield Town Centre 1.7 0.4 1.4 0.3 1.3 2.9 1.0 3.6 0.8 3.5 16.9 63.4 80.3 Hatfield Retail Parks/Foodstores 0.1 0.1 0.7 0.3 2.8 4.0 82.5 86.4

Stevenage Town Centre 0.9 0.2 0.1 0.1 2.3 0.4 1.3 18.5 5.4 29.3 109.8 139.1 Stevenage Retail Parks/Foodstores 0.9 0.5 3.8 2.3 20.0 0.2 0.7 2.6 2.2 33.3 33.3 Ware Town Centre 0.2 0.2 15.3 1.8 17.4 8.2 25.6

Lakeside Shopping Centre 2.5 0.8 0.3 1.7 1.1 4.1 1.5 0.4 5.4 18.6 36.5 -0.2 36.3 Bluewater Shopping Centre 0.4 0.4 0.2 2.8 6.3 0.2 10.3 -0.2 10.0 Other (including Central London) 3.3 5.0 10.0 12.3 3.5 64.7 16.2 63.7 19.7 11.1 16.1 13.0 23.0 261.5 -0.7 260.8

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.3 119.5 221.6 1864 161.0 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1847 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 11c: Comparison Goods Expenditure, 2026 - With Brookfield Development (High Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 28.3 38.5 48.1 73.2 3.3 25.3 36.0 30.3 20.5 4.9 30.2 28.7 4.4 371.8 17.4 389.1 Waltham Cross Town Centre 1.0 8.4 9.1 29.6 2.1 22.0 11.2 18.0 11.3 1.8 1.2 2.8 118.3 5.7 124.0 Hoddesdon Town Centre 24.7 6.9 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.6 47.7 1.7 49.5 Cheshunt Old Pond District Centre 2.9 4.0 10.6 5.5 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.6 2.2 45.8 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.8 11.8

Sub Total Borough of Broxbourne 57.1 59.9 72.1 115.6 8.2 51.8 51.2 50.4 36.9 9.4 36.7 38.6 5.3 593.2 20.8 614.0

Harlow Town Centre 16.7 9.7 4.2 3.3 40.1 8.4 1.3 1.4 3.6 25.4 18.3 122.4 254.9 144.6 399.5 Harlow Retail Parks/Foodstores 9.9 2.6 3.7 0.8 12.7 4.4 0.5 2.3 9.9 9.0 45.9 101.7 214.6 316.3 Enfield Town Centre 2.3 1.3 4.2 8.4 0.1 6.6 69.9 123.9 2.8 2.7 0.5 9.3 2.8 234.8 48.7 283.4 Enfield Retail Parks/Foodstores 1.0 4.0 4.7 3.4 8.2 37.2 59.5 0.8 0.2 0.4 0.1 119.5 69.5 188.9 Welwyn Garden City Town Centre 4.9 1.5 4.6 1.9 1.4 3.0 9.8 27.2 19.1 17.7 7.9 98.9 334.4 433.3 Hertford Town Centre 2.3 0.3 1.4 0.8 0.7 0.3 7.3 25.5 8.2 46.8 8.3 55.2 Hertford Retail Parks/Foodstores 0.2 0.5 5.9 1.6 8.2 8.2 Hatfield Town Centre 1.7 0.4 1.4 0.3 1.3 2.9 1.0 3.6 0.8 3.5 16.7 63.3 80.1 Hatfield Retail Parks/Foodstores 0.1 0.1 0.7 0.3 2.8 3.9 82.4 86.4 Stevenage Town Centre 0.9 0.2 0.1 0.1 2.3 0.4 1.3 18.4 5.4 29.0 109.7 138.8 Stevenage Retail Parks/Foodstores 0.9 0.5 3.7 2.3 20.0 0.2 0.7 2.6 2.2 33.0 33.0 Ware Town Centre 0.2 0.2 15.3 1.8 17.4 8.2 25.5 Lakeside Shopping Centre 2.5 0.8 0.3 1.7 1.1 4.1 1.5 0.4 5.3 18.6 36.2 36.2 Bluewater Shopping Centre 0.4 0.4 0.2 2.7 6.3 0.2 10.1 -0.3 9.9 Other (including Central London) 3.2 5.0 9.7 11.8 3.5 64.5 16.0 63.5 19.6 11.0 16.0 12.9 23.0 259.6 -0.8 258.8

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.4 119.5 221.6 1864 175.6 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1847 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 12: Convenience Goods Expenditure, 2026 - With Brookfield Development

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 7.8 18.5 31.4 40.2 1.3 1.8 5.9 2.4 13.4 1.9 13.1 3.6 176.3 4.7 181.0 Waltham Cross Town Centre 0.1 4.1 9.9 4.1 14.5 1.9 0.1 3.5 0.8 39.2 39.2 Hoddesdon Town Centre 36.1 16.9 2.3 7.3 5.9 1.1 11.6 1.3 3.1 13.0 14.0 112.7 112.7 Cheshunt Old Pond District Centre 0.6 1.5 4.8 9.8 0.1 0.7 17.4 17.4 Other within Borough 2.1 2.1 4.3 4.2 0.2 0.5 1.6 0.1 14.9 14.9

Sub Total Borough of Broxbourne 46.6 39.1 46.9 71.4 7.5 8.1 31.9 4.3 16.3 5.3 29.7 14.8 3.6 360.5 3.7 365.3

Harlow Town Centre 0.7 6.8 0.7 1.8 1.0 22.9 33.8 17.2 51.0 Other Harlow 0.6 0.3 16.5 1.0 0.7 0.2 91.3 110.6 45.1 155.7 Enfield Town Centre 1.2 29.1 30.2 4.2 34.4 Other Enfield 0.0 2.0 1.1 0.4 2.3 40.9 97.7 2.3 146.7 52.5 199.2 Welwyn Garden City Town Centre 0.2 0.2 46.0 46.1 Other Welwyn Garden City 0.1 0.6 0.7 0.7 0.6 2.7 43.0 45.7 Hertford Town Centre 0.3 0.4 0.1 0.2 2.7 4.2 3.5 11.4 64.3 75.7 Other Hertford 0.7 0.0 0.4 16.4 28.6 25.4 71.5 71.5 Hatfield Town Centre 0.1 0.2 0.1 0.4 0.8 47.4 48.2 Other Hatfield 1.6 0.8 2.3 85.9 88.3 Stevenage Town Centre 0.2 3.6 0.8 4.6 73.5 78.1 Ware Town Centre 0.7 19.2 8.2 28.2 25.8 53.9 Other 0.4 0.5 1.1 4.0 1.4 70.8 29.3 19.3 19.8 3.1 0.6 2.0 10.2 162.5 -1.9 160.6

Total 50.3 40.4 51.2 76.8 32.9 82.9 103.3 152.1 41.6 29.3 86.6 55.8 127.9

Notes: 50.3 40.4 51.2 76.8 32.9 82.9 103.3 152.1 41.6 29.3 86.6 55.8 127.9 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 10) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 13a: Potential Trading Effects of Planned Brookfield, 2026 (Low Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 164.6 19.4 -3.2 164.4 19.2 -3.4 Hoddesdon Town Centre 148.3 166.9 162.5 9.6 -2.7 162.4 9.5 -2.7 Cheshunt Old Pond District Centre 54.9 64.6 63.5 15.5 -1.7 63.4 15.4 -1.8

Centres Outside Borough Harlow Town Centre 367.7 482.0 458.3 24.6 -4.9 456.8 24.2 -5.2 Enfield Town Centre 275.6 336.8 322.5 17.0 -4.2 321.6 16.7 -4.5 Welwyn Garden City Town Centre 375.4 496.2 483.7 28.8 -2.5 482.9 28.6 -2.7 Hertford Town Centre 111.9 136.3 132.1 18.1 -3.0 131.9 17.9 -3.2 Hatfield Town Centre 110.5 130.8 128.9 16.7 -1.5 128.8 16.6 -1.6 Stevenage Town Centre 187.2 220.7 217.8 16.4 -1.3 217.7 16.3 -1.4 Ware Town Centre 69.6 81.5 79.8 14.6 -2.1 79.8 14.6 -2.1

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables 11a and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 13b: Potential Trading Effects of Planned Brookfield, 2026 (Medium Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) 2018-2026 (%) Commitment, 2026 (£m) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 163.7 18.7 -3.8 163.4 18.5 -4.0 Hoddesdon Town Centre 148.3 166.9 162.3 9.4 -2.8 162.2 9.4 -2.8 Cheshunt Old Pond District Centre 54.9 64.6 63.3 15.2 -2.0 63.3 15.2 -2.1

Centres Outside Borough Harlow Town Centre 367.7 482.0 453.1 23.2 -6.0 451.6 22.8 -6.3 Enfield Town Centre 275.6 336.8 319.4 15.9 -5.2 318.5 15.6 -5.4 Welwyn Garden City Town Centre 375.4 496.2 480.9 28.1 -3.1 480.1 27.9 -3.3 Hertford Town Centre 111.9 136.3 131.3 17.4 -3.6 131.1 17.1 -3.8 Hatfield Town Centre 110.5 130.8 128.5 16.3 -1.8 128.4 16.2 -1.9 Stevenage Town Centre 187.2 220.7 217.2 16.0 -1.6 217.1 15.9 -1.6 Ware Town Centre 69.6 81.5 79.6 14.3 -2.4 79.6 14.3 -2.4

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables 11b and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

Updated Table 13c: Potential Trading Effects of Planned Brookfield, 2026 (High Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) 2018-2026 (%) Commitment, 2026 (£m) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 163.2 18.4 -4.1 162.9 18.2 -4.3 Hoddesdon Town Centre 148.3 166.9 162.2 9.4 -2.9 162.1 9.3 -2.9 Cheshunt Old Pond District Centre 54.9 64.6 63.2 15.1 -2.1 63.2 15.0 -2.2

Centres Outside Borough Harlow Town Centre 367.7 482.0 450.5 22.5 -6.5 449.0 22.1 -6.8 Enfield Town Centre 275.6 336.8 317.8 15.3 -5.6 316.9 15.0 -5.9 Welwyn Garden City Town Centre 375.4 496.2 479.5 27.7 -3.4 478.7 27.5 -3.5 Hertford Town Centre 111.9 136.3 130.9 17.0 -3.9 130.6 16.8 -4.1 Hatfield Town Centre 110.5 130.8 128.3 16.1 -1.9 128.2 16.0 -2.0 Stevenage Town Centre 187.2 220.7 216.9 15.9 -1.7 216.7 15.8 -1.8 Ware Town Centre 69.6 81.5 79.5 14.2 -2.5 79.5 14.2 -2.5

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables 11c and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices

Appendix C Statistical Retail Impact Sensitivity Testing

Brookfield RLIS Addendum Page 28 www.wyg.com BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING

Updated Table A: Proposed Comparison Goods Floorspace - Brookfield, 2026

Net Floorspace Average Sales Density Turnover (sq m) (£/sq m) (£m) Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report) a - Low sales density 4,705 164.7 b - Medium sales density 35,000 5,750 201.3 c - High sales density 6,273 219.6

Table B: Proposed Convenience Goods Floorspace - Brookfield, 2024

Net Floorspace Average Sales Density Turnover (sq m) (£/sq m) (£m) [1] [2] [3]

Foodstore 3,000 12,000 36.0

Notes: [3] = [1] x [2] /1000000

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING

Updated Table C: Brookfield Comparison Goods Assessed Trade Draw, 2026

Zone Total Beyond Study Total 1 2 3 4 5 6 7 8 9 10 11 12 13 Zones 1-13 Area

[1] Brookfield's Existing Market Share (%) 17 30 30 32 3 9 12 6 14 5 10 14 1 13 - - [2] Existing Retail Facilities - Brookfield Turnover (£m), 2026 17.7 25.8 32.9 48.6 2.0 16.2 22.1 18.5 12.8 3.0 18.1 17.4 2.6 237.5 11.9 249.3 [3] Brookfield's Existing Trade Draw by Zone (%) 7 10 13 19 1 6 9 7 5 1 7 7 1 95 5 100

Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

[4] New Scheme Trade Draw by Zones (%), 2026 7 10 13 19 1 6 9 7 5 1 7 7 1 95 5 100

[5a] New Scheme Trade Draw by Zones (£m), 2026 - (a) Low Sales Density 11.7 17.0 21.7 32.1 1.3 10.7 14.6 12.2 8.4 2.0 11.9 11.5 1.7 156.8 7.8 164.7 [5b] New Scheme Trade Draw by Zones (£m), 2026 - (b) Medium Sales Density 14.3 20.8 26.5 39.2 1.6 13.0 17.8 15.0 10.3 2.4 14.6 14.1 2.1 191.7 9.6 201.3 [5c] New Scheme Trade Draw by Zones (£m), 2026 - (C) High Sales Density 15.6 22.7 28.9 42.8 1.7 14.2 19.5 16.3 11.3 2.6 15.9 15.3 2.3 209.1 10.5 219.6

Notes: [1] Taken from Updated Table 1 [2] Taken from Updated Table 5 [3] Derived from [2] [4] Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Table 9) [5] Total turnover figures derived from Updated Table A Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table Fi: Comparison Goods Expenditure, 2026 - With Brookfield Development (Low Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 27.7 37.7 47.2 71.7 3.3 24.7 35.2 29.5 20.0 4.8 29.4 28.0 4.3 363.4 17.4 380.8 Waltham Cross Town Centre 1.0 8.4 9.1 29.8 2.1 22.0 11.2 18.0 11.3 1.8 1.2 2.8 118.7 5.7 124.4 Hoddesdon Town Centre 24.8 6.9 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.6 47.8 1.7 49.6 Cheshunt Old Pond District Centre 2.9 4.0 10.6 5.5 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.6 2.2 45.9 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.8 11.8

Sub Total Borough of Broxbourne 56.5 59.2 71.2 114.3 8.1 51.3 50.4 49.7 36.4 9.2 35.9 37.9 5.2 585.3 20.8 606.1

Harlow Town Centre 17.0 10.1 4.3 3.6 40.2 8.5 1.4 1.4 3.6 25.6 18.5 122.4 256.7 144.7 401.5 Harlow Retail Parks/Foodstores 10.0 2.6 3.7 0.8 12.7 4.4 0.5 2.3 10.0 9.0 46.0 102.2 214.7 316.8 Enfield Town Centre 2.3 1.3 4.3 8.6 0.1 6.6 70.2 124.1 2.9 2.7 0.5 9.4 2.8 235.9 48.7 284.6 Enfield Retail Parks/Foodstores 1.0 4.1 4.7 3.6 8.3 37.4 59.7 0.8 0.2 0.4 0.1 120.2 69.5 189.7 Welwyn Garden City Town Centre 5.0 1.5 4.8 2.1 1.4 3.0 9.9 27.4 19.1 17.8 7.9 99.9 334.4 434.4 Hertford Town Centre 2.3 0.3 1.4 0.8 0.7 0.3 7.4 25.7 8.3 47.1 8.4 55.5 Hertford Retail Parks/Foodstores 0.2 0.5 5.9 1.6 8.3 -0.2 8.0 Hatfield Town Centre 1.7 0.4 1.4 0.3 1.3 2.9 1.0 3.6 0.8 3.5 16.9 63.4 80.2 Hatfield Retail Parks/Foodstores 0.1 0.1 0.7 0.3 2.8 4.0 82.4 86.4 Stevenage Town Centre 0.9 0.2 0.1 0.1 2.3 0.4 1.3 18.5 5.4 29.2 109.8 139.0 Stevenage Retail Parks/Foodstores 0.9 0.5 3.8 2.3 20.0 0.2 0.7 2.6 2.2 33.2 33.2 Ware Town Centre 0.2 0.2 15.3 1.8 17.4 8.2 25.6 Lakeside Shopping Centre 2.5 0.8 0.3 1.7 1.1 4.1 1.5 0.4 5.4 18.6 36.5 -0.2 36.2 Bluewater Shopping Centre 0.4 0.4 0.2 2.7 6.3 0.2 10.2 -0.2 10.0 Other (including Central London) 3.2 5.0 9.9 12.2 3.5 64.7 16.1 63.7 19.7 11.1 16.1 12.9 23.0 261.0 -0.7 260.3

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.4 119.5 221.6 1864 164.7 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1847 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table Fii: Comparison Goods Expenditure, 2026 - With Brookfield Development (Medium Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 29.9 40.3 50.4 76.8 3.5 26.6 38.1 32.0 21.6 5.2 32.0 30.3 4.6 391.4 17.2 408.6 Waltham Cross Town Centre 1.0 8.2 9.0 29.2 2.0 21.9 11.1 17.9 11.2 1.8 1.2 2.7 117.5 5.7 123.2 Hoddesdon Town Centre 24.7 6.8 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.6 47.6 1.7 49.3 Cheshunt Old Pond District Centre 2.9 3.9 10.6 5.5 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.4 2.2 45.7 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.7 11.7

Sub Total Borough of Broxbourne 58.6 61.5 74.2 118.8 8.4 53.1 53.2 52.1 37.9 9.6 38.4 40.2 5.5 611.6 20.7 632.2

Harlow Town Centre 16.0 8.8 3.8 2.7 40.0 8.2 1.1 1.3 3.6 25.1 17.7 122.2 250.5 144.4 395.0 Harlow Retail Parks/Foodstores 9.7 2.4 3.5 0.7 12.7 4.3 0.5 2.2 9.7 8.8 45.9 100.5 214.6 315.1 Enfield Town Centre 2.3 1.2 4.0 7.8 0.1 6.6 69.1 123.3 2.7 2.7 0.5 9.2 2.8 232.2 48.5 280.7 Enfield Retail Parks/Foodstores 0.9 3.9 4.5 3.0 8.1 36.7 59.1 0.7 0.2 0.4 0.1 117.7 69.4 187.1 Welwyn Garden City Town Centre 4.8 1.5 4.1 1.4 1.4 3.0 9.7 26.7 18.9 17.5 7.7 96.6 334.3 430.9 Hertford Town Centre 2.2 0.2 1.4 0.8 0.7 0.3 7.3 25.2 8.0 46.1 8.3 54.4 Hertford Retail Parks/Foodstores 0.2 0.5 5.8 1.6 8.1 -0.3 7.8 Hatfield Town Centre 1.6 0.4 1.4 0.3 1.3 2.7 0.9 3.6 0.8 3.5 16.5 63.3 79.8 Hatfield Retail Parks/Foodstores 0.1 0.1 0.7 0.3 2.8 3.9 82.4 86.3 Stevenage Town Centre 0.8 0.2 0.0 0.1 2.2 0.4 1.3 18.1 5.4 28.6 109.7 138.3 Stevenage Retail Parks/Foodstores 0.9 0.4 3.6 2.2 19.8 0.1 0.7 2.5 2.2 32.5 32.5 Ware Town Centre 0.2 0.2 15.1 1.8 17.2 8.1 25.3 Lakeside Shopping Centre 2.4 0.7 0.3 1.6 1.1 4.0 1.4 0.4 5.2 18.6 35.7 -0.3 35.4 Bluewater Shopping Centre 0.3 0.4 0.2 2.7 6.2 0.2 9.9 -0.3 9.6 Other (including Central London) 3.1 4.8 9.2 11.1 3.5 64.0 15.6 63.1 19.4 11.0 15.9 12.7 23.0 256.3 -0.9 255.4

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.5 119.5 221.6 1864 201.3 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1847 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table FIii: Comparison Goods Expenditure, 2026 - With Brookfield Development (High Sales Density Scenario)

Zone Total Study Trade from Beyond Total Turnover Destination 1 2 3 4 5 6 7 8 9 10 11 12 13 Area Study Area (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m) (£m)

Brookfield 31.0 41.6 52.0 79.4 3.7 27.5 39.5 33.2 22.4 5.4 33.2 31.5 4.8 405.4 17.2 422.5 Waltham Cross Town Centre 1.0 8.1 9.0 28.9 2.0 21.8 11.1 17.9 11.2 1.8 1.2 2.7 116.8 5.7 122.6 Hoddesdon Town Centre 24.6 6.8 1.9 6.0 0.3 1.4 0.0 0.2 1.5 4.6 47.4 1.7 49.2 Cheshunt Old Pond District Centre 2.9 3.9 10.5 5.4 2.0 4.6 4.9 2.2 3.7 2.3 0.9 43.3 2.2 45.6 Other within Broxbourne 0.1 2.2 2.3 1.3 0.5 2.5 2.2 0.2 0.2 0.2 11.7 11.7

Sub Total Borough of Broxbourne 59.6 62.6 75.7 121.0 8.6 54.0 54.6 53.3 38.7 9.8 39.7 41.4 5.7 624.7 20.6 645.3

Harlow Town Centre 15.5 8.1 3.6 2.2 39.9 8.0 0.9 1.2 3.6 24.9 17.3 122.1 247.4 144.3 391.7 Harlow Retail Parks/Foodstores 9.5 2.3 3.4 0.6 12.6 4.3 0.5 2.2 9.6 8.7 45.8 99.7 214.5 314.2 Enfield Town Centre 2.2 1.2 3.8 7.5 0.1 6.5 68.5 122.9 2.6 2.6 0.5 9.1 2.8 230.4 48.3 278.7 Enfield Retail Parks/Foodstores 0.9 3.8 4.4 2.6 8.1 36.4 58.9 0.7 0.2 0.4 0.1 116.5 69.4 185.8 Welwyn Garden City Town Centre 4.7 1.4 3.8 1.1 1.4 3.0 9.6 26.3 18.8 17.3 7.6 95.0 334.2 429.1 Hertford Town Centre 2.2 0.2 1.3 0.8 0.7 0.3 7.3 25.0 7.8 45.7 8.2 53.9 Hertford Retail Parks/Foodstores 0.2 0.5 5.7 1.6 8.0 -0.3 7.7 Hatfield Town Centre 1.6 0.3 1.3 0.3 1.2 2.7 0.9 3.5 0.8 3.5 16.3 63.2 79.5 Hatfield Retail Parks/Foodstores 0.1 0.1 0.7 0.3 2.7 3.9 82.4 86.2 Stevenage Town Centre 0.8 0.2 0.0 0.1 2.2 0.4 1.3 17.9 5.3 28.2 109.6 137.9 Stevenage Retail Parks/Foodstores 0.9 0.4 3.5 2.2 19.7 0.1 0.7 2.5 2.2 32.2 32.2 Ware Town Centre 0.2 0.2 15.0 1.8 17.1 8.1 25.2 Lakeside Shopping Centre 2.4 0.7 0.3 1.5 1.1 4.0 1.3 0.4 5.1 18.6 35.3 -0.3 35.0 Bluewater Shopping Centre 0.3 0.3 0.2 2.6 6.1 0.2 9.7 -0.3 9.4 Other (including Central London) 3.0 4.7 8.9 10.5 3.5 63.6 15.4 62.8 19.2 11.0 15.8 12.6 23.0 254.0 -1.0 253.0

Total 103.6 86.1 110.6 150.8 67.4 174.4 178.0 317.0 92.8 59.8 180.7 121.3 221.6 1,864

Notes: 103.6 86.1 110.4 150.8 67.4 174.4 177.9 317.0 92.8 59.8 165.6 119.5 221.6 1864 219.6 Assessed new Brookfield scheme would have same zonal trade draw patterns as existing retail facilities within Brookfield (see Updated Table 9) Trade draw within each zone has been assessed having regard to the existing shopping patterns and location of existing retail facilities Figures may not add due to rounding 1847 2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table Gi: Potential Trading Effects of Planned Brookfield, 2026 (Low Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 163.5 18.6 -3.9 163.3 18.4 -4.0 Hoddesdon Town Centre 148.3 166.9 162.2 9.4 -2.8 162.2 9.4 -2.8 Cheshunt Old Pond District Centre 54.9 64.6 63.3 15.2 -2.0 63.3 15.1 -2.1

Centres Outside Borough Harlow Town Centre 367.7 482.0 452.5 23.1 -6.1 451.0 22.7 -6.4 Enfield Town Centre 275.6 336.8 319.0 15.7 -5.3 318.1 15.4 -5.5 Welwyn Garden City Town Centre 375.4 496.2 480.5 28.0 -3.2 479.7 27.8 -3.3 Hertford Town Centre 111.9 136.3 131.2 17.3 -3.7 131.0 17.0 -3.9 Hatfield Town Centre 110.5 130.8 128.4 16.3 -1.8 128.3 16.2 -1.9 Stevenage Town Centre 187.2 220.7 217.1 16.0 -1.6 217.0 15.9 -1.7 Ware Town Centre 69.6 81.5 79.6 14.3 -2.4 79.6 14.3 -2.4

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables Fi and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table Gii: Potential Trading Effects of Planned Brookfield, 2026 (Medium Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 162.3 17.7 -4.6 162.1 17.5 -4.8 Hoddesdon Town Centre 148.3 166.9 162.0 9.2 -3.0 161.9 9.2 -3.0 Cheshunt Old Pond District Centre 54.9 64.6 63.1 14.8 -2.3 63.1 14.8 -2.4

Centres Outside Borough Harlow Town Centre 367.7 482.0 446.0 21.3 -7.5 444.5 20.9 -7.8 Enfield Town Centre 275.6 336.8 315.1 14.3 -6.4 314.2 14.0 -6.7 Welwyn Garden City Town Centre 375.4 496.2 477.0 27.1 -3.9 476.2 26.9 -4.0 Hertford Town Centre 111.9 136.3 130.2 16.3 -4.5 129.9 16.1 -4.7 Hatfield Town Centre 110.5 130.8 128.0 15.8 -2.2 127.8 15.7 -2.3 Stevenage Town Centre 187.2 220.7 216.4 15.6 -1.9 216.2 15.5 -2.0 Ware Town Centre 69.6 81.5 79.3 13.9 -2.7 79.3 13.9 -2.7

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables Fi and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 2: Previous Core Strategy Floorspace (Tested in July 2010 Core Strategy Bridging Report)

Updated Table Giii: Potential Trading Effects of Planned Brookfield, 2026 (High Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 161.7 17.3 -5.0 161.4 17.1 -5.1 Hoddesdon Town Centre 148.3 166.9 161.9 9.2 -3.0 161.8 9.1 -3.1 Cheshunt Old Pond District Centre 54.9 64.6 63.0 14.7 -2.5 63.0 14.6 -2.5

Centres Outside Borough Harlow Town Centre 367.7 482.0 442.8 20.4 -8.1 441.3 20.0 -8.5 Enfield Town Centre 275.6 336.8 313.2 13.6 -7.0 312.3 13.3 -7.3 Welwyn Garden City Town Centre 375.4 496.2 475.3 26.6 -4.2 474.5 26.4 -4.4 Hertford Town Centre 111.9 136.3 129.6 15.9 -4.9 129.4 15.6 -5.0 Hatfield Town Centre 110.5 130.8 127.7 15.6 -2.4 127.6 15.5 -2.5 Stevenage Town Centre 187.2 220.7 216.0 15.4 -2.1 215.8 15.3 -2.2 Ware Town Centre 69.6 81.5 79.2 13.7 -2.9 79.2 13.7 -2.9

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Tables Fi and 12 [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 3: Higher Level of Comparison Goods Trade Draw from Harlow, Enfield and Welwyn Garden City Town Centres

Table Hi: Potential Trading Effects of Planned Brookfield, 2026 (Low Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 164.6 19.4 -3.2 164.4 19.2 -3.4 Hoddesdon Town Centre 148.3 166.9 162.5 9.6 -2.7 162.4 9.5 -2.7 Cheshunt Old Pond District Centre 54.9 64.6 63.5 15.5 -1.7 63.4 15.4 -1.8

Centres Outside Borough Harlow Town Centre 367.7 482.0 448.7 22.0 -6.9 447.2 21.6 -7.2 Enfield Town Centre 275.6 336.8 310.2 12.6 -7.9 309.3 12.2 -8.2 Welwyn Garden City Town Centre 375.4 496.2 469.9 25.2 -5.3 469.1 25.0 -5.5 Hertford Town Centre 111.9 136.3 132.1 18.1 -3.0 131.9 17.9 -3.2 Hatfield Town Centre 110.5 130.8 128.9 16.7 -1.5 128.8 16.6 -1.6 Stevenage Town Centre 187.2 220.7 217.8 16.4 -1.3 217.7 16.3 -1.4 Ware Town Centre 69.6 81.5 79.8 14.6 -2.1 79.8 14.6 -2.1

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Table 12. For comparison goods trade diversion refer to paragraph 2.2.17 and 2.2.18 of the RLIS Addendum [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 3: Higher Level of Comparison Goods Trade Draw from Harlow, Enfield and Welwyn Garden City Town Centres

Table Hii: Potential Trading Effects of Planned Brookfield, 2026 (Medium Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 163.7 18.7 -3.8 163.4 18.5 -4.0 Hoddesdon Town Centre 148.3 166.9 162.3 9.4 -2.8 162.2 9.4 -2.8 Cheshunt Old Pond District Centre 54.9 64.6 63.3 15.2 -2.0 63.3 15.2 -2.1

Centres Outside Borough Harlow Town Centre 367.7 482.0 441.4 20.0 -8.4 439.9 19.6 -8.7 Enfield Town Centre 275.6 336.8 304.4 10.4 -9.6 303.5 10.1 -9.9 Welwyn Garden City Town Centre 375.4 496.2 464.0 23.6 -6.5 463.2 23.4 -6.7 Hertford Town Centre 111.9 136.3 131.3 17.4 -3.6 131.1 17.1 -3.8 Hatfield Town Centre 110.5 130.8 128.5 16.3 -1.8 128.4 16.2 -1.9 Stevenage Town Centre 187.2 220.7 217.2 16.0 -1.6 217.1 15.9 -1.6 Ware Town Centre 69.6 81.5 79.6 14.3 -2.4 79.6 14.3 -2.4

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Table 12. For comparison goods trade diversion refer to paragraph 2.2.17 and 2.2.18 of the RLIS Addendum [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices BROXBOURNE BOROUGH COUNCIL PLANNED RETAIL AND LEISURE FLOORSPACE - BROOKFIELD QUANTITATIVE RETAIL IMPACT ASSESSMENT

COMPARISON GOODS FLOORSPACE SCENARIO IMPACT TESTING Scenario Impact Test 3: Higher Level of Comparison Goods Trade Draw from Harlow, Enfield and Welwyn Garden City Town Centres

Table Hiii: Potential Trading Effects of Planned Brookfield, 2026 (High Comparison Goods Sales Density Scenario)

Total Combined Retail Turnover Residual Combined Total Impact of New Floorspace Residual Combined Total Cumulative Impact Turnover after Planned Turnover after Planned Destination 2018 2026 Change in Impact on 2026 Change in Impact on 2026 Brookfield, 2026 Brookfield & Retail Park (£m) (£m) Turnover Turnover (%) Turnover Turnover (%) (£m) Commitment, 2026 (£m) 2018-2026 (%) 2018-2026 (%) [1] [2] [3] [4] [5] [6] [7] [8]

Centres Inside Borough Waltham Cross Town Centre 137.9 170.2 163.2 18.4 -4.1 162.9 18.2 -4.3 Hoddesdon Town Centre 148.3 166.9 162.2 9.4 -2.9 162.1 9.3 -2.9 Cheshunt Old Pond District Centre 54.9 64.6 63.2 15.1 -2.1 63.2 15.0 -2.2

Centres Outside Borough Harlow Town Centre 367.7 482.0 437.8 19.1 -9.2 436.3 18.6 -9.5 Enfield Town Centre 275.6 336.8 301.4 9.4 -10.5 300.5 9.0 -10.8 Welwyn Garden City Town Centre 375.4 496.2 461.1 22.8 -7.1 460.3 22.6 -7.2 Hertford Town Centre 111.9 136.3 130.9 17.0 -3.9 130.6 16.8 -4.1 Hatfield Town Centre 110.5 130.8 128.3 16.1 -1.9 128.2 16.0 -2.0 Stevenage Town Centre 187.2 220.7 216.9 15.9 -1.7 216.7 15.8 -1.8 Ware Town Centre 69.6 81.5 79.5 14.2 -2.5 79.5 14.2 -2.5

Notes: [1] & [2] Combined Retail Turnovers derived from Updated Tables 3, 4, 5 & 6 [3] Derived from Updated Table 12. For comparison goods trade diversion refer to paragraph 2.2.17 and 2.2.18 of the RLIS Addendum [4] = ([3]-[1])/[1]% [5] = ([3]-[2])/[2]% [6] Comparison goods turnover of extension asssessed to be £8.4m (retail warehouse sales density of £4,300/sq m applied to 1,957sq m net floorspace (assuming 80/20 gross/net split)). Assumed same trade diversion patterns as comparison goods floorspace of new Proposed Brookfield scheme [7] = ([6]-[1])/[1]% [8] = ([6]-[2])/[2]% Figures may not add due to rounding

2012 Prices

Appendix D Existing/Planned/Committed In-Centre Investment Schedule – Harlow Town Centre

Brookfield RLIS Addendum Page 29 www.wyg.com BOROUGH OF BROXBOURNE COUNCIL LOCAL PLAN RETAIL EVIDENCE BASE DOCUMENT BROOKFIELD RETAIL/ LEISURE IMPACT STUDY ADDENDUM EXISTING, PLANNED AND COMMITED IN-CENTRE INVESTMENT HARLOW TOWN CENTRE NORTH SITE

Site Name/ Site Location Current Use Potential Use Assessment Description Area (ha) Policy Status of Investment Progress on Investment Town Centre 4.09 Site is located Mix of retail and Planning permission (ref. HW/PL/10/00347) was North – land partly within service units and granted in 2012 for demolition of the multi-storey Saved Local Plan Policy RTCS5 identifies that the site We understand that there is currently no plans, south of Fourth SSF and within multi-storey car car park at Kitson Way to create a mixed-use is to play a key role in diversifying the town centre to planning application or timescales for the Avenue and the Town park. scheme comprising 170 apartments and 856sq m of develop entertainment, leisure, food, drink and comprehensive redevelopment of this site for a north of Kitson Centre commercial floorspace (uses A1-A5, B1(a), D1 and residential uses to strengthen the evening economy. leisure led scheme. Way and Post Boundary. D2) and a new public realm. Office Road RTCS6/1 - The location on the corner of Fourth Having regard to the recent planning application (RTCS6/1) Avenue and Velizy Avenue would be activity on parts of the site and the existing active Town Centre Mix of retail and Planning permission (ref. HW/FUL/16/00127) for preferred for a hotel and conference centre. uses within the site it is unclear if and when the site North – Post leisure service change of use of first floor of Market House from could come forward for comprehensive Office and units, with office B1 to C3 was granted in July 2016. In May 2018, RTCS6/2 - The post office is considered to be a key redevelopment. Adams House above, alongside permission (ref. HW/REMVAR/18/00122) was town centre facility which would need to be East (RTCS6/2) Post Office. granted to alter the number of flats from 12 to 10. incorporated into a scheme or would require relocation to an appropriate town centre site. Two applications (refs. HW/COUOR/17/00574 and HW/COUOR/17/00575) for change of use of second RTCS6/3 - The market is considered to be a key town and third floors of Market House from B1 to C3, centre facility which would need to be incorporated were confirmed by the Council in March 2018 that into a scheme or would require relocation to an prior approval is not required for the proposed appropriate town centre site. development.

Town Centre Mix of retail and A planning application (reference. North – Market service units HW/LDCP/17/00313) was submitted in July 2017 Square and for removal of the existing children’s play area and Northgate refurbishment and replacement of the paving and (RTCS6/3) installation of new street furniture at Market Square. The proposal was considered by the Council to be lawful use/development in August 2017.

Notes: PSF = Primary Shopping Frontage SSF = Secondary Shopping Frontage (as defined in the Adopted Local Plan)