CONTENTS

1 INTRODUCTION This Statement is prepared on behalf of Pets Corner UK Ltd in support of a planning application for the change of use of Unit 1, Spindle Way, Three Bridges, Crawley (‘the Site’). It is proposed that the change of use will provide for a mix of uses to include Class A1 (retail) together with Class B1(a)(office) and sui generis use at the Site. At the fundamental level, the applicant, Pets Corner UK Ltd, seek to occupy a new site that can better provide for the expanded HQ adminstrative and training needs of the company alongside retail space, and a complementary dog care business (sui generis use) that provides flexible accommodation for dogs whilst their owners are at work or out. Given the nature of this proposal, this Retail and Economic Statement demonstrates that the proposed change of use for a range of economic development uses, is consistent with national and local retail planning policy, and will support new investment, job creation and skills training, at a currently vacant employment unit in Crawley that has been actively marketed. The Statement further demonstrates that the mix of uses outlined at Section 3 represent ancillary and complementary uses that both address the operational requirements of the applicant, and which provide a mix of specialist uses for local residents, at a sustainable location in close proximity to Crawley town centre. In preparing this change of use proposal, full regard has been had to the adopted Crawley Borough Local Plan (2015), and national policy guidance and associated documents.

Page 2 Furthermore, this statement should be read in conjunction with the suite of supporting application documentation, including the Planning Statement prepared by Gregory Gray Associates. The statement provides an overview of the existing site at Section 2, whilst Section 3 sets out the current proposal. Section 4 provides an overview of the relevant national and local planning policy framework whilst Section 5 and 6 address employment land and retail policy merits of the proposal respectively, with regard to the requirements of relevant Local Plan policy and the National Planning Policy Framework (NPPF). Section 8 provides a conclusion.

Page 3 2 THE SITE AND SURROUNDING CONTEXT

The Site and Surrounds

2.1 The application site is located at the Three Bridges Industrial Estate, which is located approximately 0.3 mile (0.5 km), to the east of Crawley town centre.

2.2 The site comprises a steel portal frame unit providing a mix of warehouse and office floorspace with further office accommodation at first floor level. Designated parking exists to the front (south) and side (east) of the unit.

2.3 The unit is currently vacant and has been actively marketed by Stiles Harrold Williams. The agents marketing details identify a total floorspace of 555 sq. m (5,974 sq. m).

2.4 The application site forms part of a detached unit, split into two units, located on a corner plot to the south of the industrial estate. The subject site comprises the eastern unit whilst to the west, the unit is occupied by a safety equipment supplier (JP supplies). Further to the west, adjoining employment units include a tyre services and building merchants.

2.5 Immediately to the east, the site adjoins Spindle Way, beyond which are a mix of office and light industrial/warehousing facilities with parking to the front of premises and on street, and car rental premises. To the north, aligned along Spindle Way, a range of mixed use occupiers exist, including a leisure use (Lazer World), nursery (Busy Bees), carpet centre (Sussex Carpet Centre), plumbing merchants (HPS Crawley), electrical distributors (Medlock Electrical), salon services (Sally Salon). To the south, occupiers include Brewers Decorators Centre and auto motors (Sawyers).

2.6 Elsewhere within the wider Three Bridge industrial estate, the mixed range of quasi retail and trade counter uses is evident at the Denvale Trade Park, together with standalone retail uses including Bathstore and Wickes.

2.7 Road access to the application site is direct from Spindle Way, which links to the north with Haslett Avenue East (A2220), which provides excellent accessibility to public transport, cyclists and pedestrians. The site is approximately 2 miles from junction 10, M23. Previous Use 2.8 The subject unit was previously occupied by Complete Tyre Services (new and part worn tyres). This previous use was sui generis as a recycling and storage facility for used and waste tyres, which employed approximately 9 people. 2.9 The unit has been vacant since January 2016 and has been actively marketed by commercial agents (Stiles Harrold Williams). 2.10 Further details of the relevant planning history are provided at Section 4 of the GGA Planning Statement.

3 THE CURRENT PROPOSAL

Page 4 3.1 The proposal seeks the change of use of the existing building (Unit 1) to provide for a mix of economic development uses (Class A1/B1/Sui Generis) together with external alterations. 3.2 In summary, the proposed mix of uses by floorspace is as follows:  Ground Floor  Class A1 (retail) – 216 sq. m (2,325 sq. ft)  Sui generis (dog day care centre) -218 sq. m (2,347 sq. ft)  First Floor  Class B1(a) (office) – 164 sq. m (1,765 sq. m) via a new mezzanine.

Retail Use - Pets Corner 3.3 It is proposed that the retail floorspace (216 sq. m) will be occupied by Pets Corner, an established national pet store retailer, focused on the sale of specialist and high quality natural pet foods, accessories and treatments predominantly for dogs and cats, but also for small animals, reptiles, birds, wildlife and tropical and cold water fish. The stores typically carry 5,000 lines for all types of pets. 3.4 Founded in 1968 in Haywards Heath (West Sussex), the retail operator has grown significantly over recent years and is predominantly located at out of centre locations (circa 90% of its locations), particularly garden centres, but also standalone stores reflecting the need for display areas and sale of elements of bulky goods. 3.5 The growth of the business has continued over recent years with the acquisition of PamPurredPets, which increased the portfolio of stores by 51. As a consequence, the growth and investment by Pets Corner is reflected in its status as the second largest pet retailer in the country. 3.6 The retailer represents a privately owned, ethical and innovative business that prides itself on providing the best animal welfare in the industry through a strong focus on animal health, nutrition and classroom-trained staff. Sui Generis Use – Doodley Dogs, Dog Day Care Business 3.7 A dog day care business is proposed at ground floor level, totalling 218 sq. m, within the western element of the unit. The use is intended to provide flexible accommodation for dogs (up to 20 in total), whilst their owners are unavailable due to work or other commitments. It is understood that the business will allow owners to leave dogs at the facility on a regular or flexible basis. 3.8 The business model provides for a main arena which allow for the exercise and interaction of dogs, with group and behavioural training also provided. There is no overnight accommodation for dogs. 3.9 The proposed occupier, Doodley Dogs, successfully operate from industrial estate locations at Storrington and Horsham.

Office Use – Pets Corner 3.10 At first floor level, a new mezzanine is proposed to provide 164 sq. m of Class B1(a) floorspace, for use by Pets Corner. It is intended that that office would provide an office headquarters for the applicant and complement the retail unit at ground floor

Page 5 level by serving a dual function as a training facility for new staff training. As a consequence, it is anticipated there is likely to be a significant overlap between the office floorspace and the retail unit for training purposes. 3.11 It is proposed that the HQ office function will account for the relocation of this role from the existing ancillary office premises in Queensway in Crawley town centre, which at 94 sq. m, is physically constrained in its ability to continue its training and administrative role and function. A clear operational need exists for new office floorspace together with the ability to link with the retail unit. Furthermore, the location of the subject site ensures easy accessibility for existing office employees given its proximity to the existing location and Crawley town centre. 3.12 In job creation terms, it is estimated that the change of use will support the following new jobs:  Retail: 5 employed (4 x full-time and 1 x part-time), 2-3 staff on site.  Dog care: 4 employed (3 x full-time and 1 x part-time), 2 staff on site.  Office: 20 employed; 15-17 staff on site at any one time. 3.13 In total, the proposed use has the potential to support approximately 29 jobs. This is significantly higher than the 9 jobs that were previously associated with the use as a former tyre recycling site. 3.14 Additional details relating to the current proposal are set out at Section 5 of the GGA Planning Statement.

4 RELEVANT PLANNING POLICY FRAMEWORK

National Policy

National Planning Policy Framework (NPPF) (March 2012)

Page 6 4.1 The National Planning Policy Framework (NPPF) introduced a presumption in favour of sustainable development, which for decision-taking means, “…approving development proposals that accord with the development plan without delay; and where the development plan is absent, silent or relevant policies are out of date, granting permission unless…any adverse impacts would significantly and demonstrably outweigh the benefits…” (paragraph 14). 4.2 At paragraph 17, the NPPF identifies core planning principles that should underpin decision making (and plan making), a number of which are of relevance to the current proposal, which include to:  Proactively drive and support sustainable economic development (3rd bullet)  Encourage the effective use of land by reusing previously developed land (8th bullet)  Promote missed use developments and encourage multiple benefits from the use of land in urban and rural areas (9th bullet) 4.3 Of relevance to the current proposal is Section 1 of the NPPF which relates to the building of a strong competitive economy. It outlines the government’s commitment to securing economic growth in order to create jobs and prosperity (paragraph 18). This support is outlined further at paragraph 19, which states: “ The government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not cat as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system”. 4.4 At paragraph 22, the NPPF outlines that planning policies should avoid the long term protection of sites allocated for employment use, where is no reasonable prospect of a site being used for that purpose. It supports proposals for the alternative use of land or buildings on their merits, which have regard to market signals and the relative need for different land uses to support sustainable local communities. 4.5 In retail planning terms, section 2 is relevance and particularly paragraphs 23 – 27 which set out the Government’s approach to ensuring the vitality of town centres. 4.6 Paragraph 24 requires that LPAs apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. The paragraph states that: “ … ..they (i.e. LPAs) should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered. When considering edge of centre and out of centre proposals, preference should be given to accessible sites that are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale ”. 4.7 Paragraph 26 of the NPPF requires an Impact Assessment to be undertaken for applications for retail development outside of town centres which are not in accordance with an up-to-date Local Plan, and if over a locally set floorspace threshold (if none applies, the default is 2,500 sq. m, as relevant in the current case). It outlines two impact tests related to:  The impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal,

Page 7  The impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made. 4.8 Where an application fails to satisfy the sequential test or is likely to have significant adverse impact on one or more of the above factors, the NPPF states that the application should be refused (paragraph 27). 4.9 To promote sustainable transport, paragraph 34 requires that decisions should ensure that developments that generate significant movement are located where the need for travel will be minimised, and the use of sustainable transport can be maximised. 4.10 In determining applications, paragraph 197 reinforces the central theme of the NPPF and states that: “ ….in assessing and determining development proposals, local planning authorities should apply the presumption in favour of sustainable development”.

National Planning Practice Guidance (NPPG) 4.11 The National Planning Practice Guidance (NPPG) provides guidance related to ‘Ensuring the Vitality of Town Centres’. 4.12 Paragraph 11 recognises that certain uses require certain locations. It states: “ Use of the sequential test should recognise that certain main town centre uses have particular market and locational requirements which mean that they may only be accommodated in specific locations”. 4.13 Paragraph 16 of the NPPG advises that any impact should consider the scale of the proposals relative to town centres, the existing vitality and viability of centres, effects of town centre strategy, impacts on planned investment and implications for vulnerable town centres. This statement has had full regard to the guidance set out in this relevant NPPG. The Development Plan 4.14 The Development Plan comprises the adopted Crawley Borough Local Plan 2015 -2030 (2015). Crawley 2030: Crawley Borough Local Plan 2015 – 2030 (December 2015) 4.15 The Proposals Map of the adopted Local Plan identifies the subject site as located within a Main Employment Area, in this case as part of the Three Bridges Corridor. This is subject to Policy EC2.

Employment Land Policy Considerations 4.16 The Local Plan sets out a spatial context, which amongst others, seeks to ensure economic growth is achieved through the consolidation and enhancement of the existing employment areas, and identifies a key role for the town centre. 4.17 Policy SD1 (Presumption in Favour of Sustainable Development) outlines the Council’s positive approach towards the consideration of development proposals which are sustainable. It states that development will be supported where it meets strategic objectives, including where it provides for the social and economic needs of Crawley’s current and future population.

Page 8 4.18 Chapter 5 of the Local Plan is concerned with economic growth. It recognises that Crawley is a key economic driver in the South East region, and sets out a clear Plan vision that promotes a strong and competitive economy. As such, the Plan adopts a policy framework based on promoting the continued economic growth of the town whilst ensuring that it prospers in its role as an employment destination (locally and as part of the wider Gatwick Diamond). 4.19 The supporting justification to Chapter further notes the need to utilise and intensify existing sites in Crawley, including the protection of the Main Employment Areas for economic development purposes. It should be noted that the NPPF definition of economic development (Annex 2: Glossary) includes retail alongside the traditional class B uses and other uses in an expanded definition of economic development. 4.20 Policy EC1 (Sustainable Economic Growth) seeks to protect and enhance Crawley’s role as the key economic driver for the Gatwick Diamond. The policy aims to enhance and maintain this role, by amongst others, ensuring that the town’s Main Employment Areas are the focus for sustainable economic growth. 4.21 Given the importance of the Main Employment Areas (MEA), Policy EC2 (Economic Growth in Main Employment Areas) seeks to protect and improve the existing economic areas, and to maximise the potential to utilise existing employment sites, before other sites are considered. The Three Bridges Corridor is identified as one of the MEA’s, which includes Spindle Way and the application site. 4.22 The Plan recognises that each of the MEA’s has a different character and function. Supporting justification paragraph 5.26 states that the role and function of a number of Main Employment Areas, including the Three Bridges Corridor, for economic development use will be protected. It further outlines that further intensification of employment uses within these sustainable locations will be supported. 4.23 Policy EC2 specifically states the following: “..Proposals for employment generating development at the seven locations [including the Three Bridges Corridor] above will be supported where they contribute to the specific characteristics of the main employment area, and overall economic function of the town, through providing a mix of employment generating uses. Proposals that would involve a net loss of employment floorspace in any Main Employment Area, including Manor Royal, Gatwick Airport and Crawley Town Centre, will only be permitted where they are able to demonstrate that: i. the site is no longer suitable, viable or appropriate for employment purposes; and ii. ii. the loss of any floorspace will result in a wider social, environmental or economic benefit to the town; and iii. there is no adverse impact on the economic role or function of the Main Employment Area, and wider economic function of Crawley”. 4.24 The Plan Policy recognise that the role and function of each area is strengthened to enhance economic growth. At paragraph 5.32, the character of the Three Bridges Employment Corridor is described as follows: Three Bridges Employment Corridor: A local small business location, The Three Bridges Employment Corridor is situated in a highly sustainable location between Three Bridges railway station and Crawley Town Centre. It offers a selection of older and smaller units at a location close to the town centre, and includes Denvale

Page 9 Trade Park, Spindle Way, Stephenson Way and Hazelwick Avenue. It supports a diverse range of economic uses including light storage, distribution, trade, car showroom and automotive uses. Residential uses surround and split the Main Employment Area. 4.24 In summary, the sustainable attributes of the Three Bridges Corridor (including Spindle Way) are recognised in the Plan, including its diversity and range of economic uses within the MEA. 4.25 It is considered the current mix of uses proposed, fully accord with the range and nature of existing uses that are well accepted and considered acceptable in planning terms at the MEA. An assessment of the current proposal with regard to the requirements of Policy EC2 is provided at Section 5. 4.26 Furthermore, the characteristics of a number of the other MEA’s confirm a mix of employment use within sites, including non-Class B uses (e.g. Lowfield Heath). Retail Policy Considerations 4.27 The subject site falls outside of the Town Centre Boundary. As such, all locations beyond the Town Centre Boundary are, in retail terms, considered to represent out- of-centre locations. Notwithstanding this, the Three Bridges Corridor MEA immediately abuts the defined town centre boundary to the west. 4.28 On this basis, given the proposed retail use (albeit of a limited scale of 216 sq. m for a specialist retail occupier), Policy EC7 (Retail and Leisure Development outside the Primary Shopping Area) is relevant. This states, in part, that: “Retail and leisure proposals in Crawley will follow the NPPF ‘Town Centre first’ principle with development directed to the most sequentially preferable and sustainable locations, firstly within the Primary Shopping Area. Proposals for edge-of-centre or out-of-centre development, will be permitted where it can be demonstrated that: a) the proposed development cannot be met on more central sites, having applied the sequential test; and b) the impact of the development will not undermine the vitality and viability of the town centre, as existing and planned, or neighbourhood centres. In assessing the impact of out-of-centre retail development proposals under part b), a retail impact assessment will be required to support proposals for 2,500sqm gross floorspace or greater…..”. 4.29 In accordance with Policy EC7 and the NPPF, this statement provides a sequential assessment for the proposed retail use at Section 6. However, given the minor scale of the proposed Class A1 retail use (216 sq. m), a retail impact assessment is not required given the proposed quantum of floorspace falls well below the local threshold (2,500 sq. m) set out in Policy EC7. That aside, brief commentary is provided to demonstrate that the proposed development will not result in a significant adverse impact on the vitality or viability of the town centre, or the deliverability of planned development (particularly of the development sites identified in Policy EC6). Relevant Evidence Base 4.30 The Council’s has an extensive economic growth evidence base contained within a variety of documents, which include the following:

Page 10  Crawley Economic Growth Assessment Update (2015), Economic Growth Assessment (2014) and Economic Growth Assessment: Crawley Emerging Findings Paper (2013)  Employment Land Review Part 2 (2010)  Employment Land Trajectory 2015-2030 (2015)  Crawley Borough Council Retail Capacity Update (2013) and Crawley Retail Capacity and Impact Study (2010)  Crawley Town Centre Strategy (2008) Conclusions on Relevant Planning Policy 4.31 The application site forms part of the Three Bridges Corridor MEA, which as an MEA is characterised as providing for a diverse range of economic uses. Furthermore, Policy EC2 supports the intensification of employment generating uses at such sites, and in the context of Three Bridges MEA, the area is recognised to be located in close proximity to the town centre and represents a highly sustainable location. 4.32 On this basis, the current proposal provides for a mix of uses, including an office (Class B1a use) for up to 20 employees, which fully accords with the provisions of Policy EC2. Furthermore, the proposed retail and sui generis use (dog day care business) represent complementary economic development uses that contribute to the employment generating and economic growth objectives of the Plan. A diverse mix of uses is acknowledged within the Three Bridges Corridor MEA whilst analysis of the nature of existing occupiers in the MEA confirms many non-Class B uses, including retail and quasi retail uses. 4.33 In accordance with Policy EC7, a sequential assessment is provided at Section 6 together with appropriate commentary to address vitality and viability considerations. However, given the small scale nature of retail floorspace involved, no retail impact assessment is required by Policy EC7.

5 EMPLOYMENT LAND CONSIDERATIONS

5.1 At the fundamental level, the current proposal for a mix of Class A1, B1(a) and sui generis uses represent employment generating uses. This fully accords with the objective of Local Plan Policy EC2 which is supportive of proposals for employment generating development at the designated Main Employment Areas, including the Three Bridges Corridor, subject to its contribution to the characteristics of the MEA and the overall economic function of Crawley.

5.2 At justification paragraph 5.32 of the Local Plan, the Three Bridges Corridor MEA is summarised as an employment area which supports a diverse range and mix of economic uses which include sui generis, and quasi retail uses. The same paragraph acknowledges that the Three Bridges benefits from close proximity to the town centre and represents a highly sustainable location.

Page 11 5.3 Drawing on the requirements of Policy EC2, it is considered that the proposed mix of uses not only directly contribute to employment generation (potential for up to 29 jobs), but also contribute towards and accord with the specific characteristics of the economic composition of the Three Bridges Corridor MEA, as identified at paragraph 5.32. None of the proposed uses at the individual level conflict with the nature of existing uses within the MEA, and at the strategic level, the proposal helps to support and enhance the overall economic role and function of Crawley through the provisions of a mix of employment generating uses.

5.4 Indeed, the proposal provides for an uplift in employment numbers (a net increase of 20 jobs) when compared to the previous use of the subject site by a waste tyre storage and recycling centre. It also seeks the reuse of a vacant unit, which despite active marketing, has remained vacant until commercial interest from the applicant. This in itself is a positive contribution towards maintaining and enhancing the economic function and health of Crawley.

5.5 The proposed mix of uses all accord with the NPPF definition of economic development (refer to Annex 2: Glossary, NPPF). This defines uses relating to Class B use classes, together with main town centres uses, which include Class A1 retail. In this regard, the proposed Class A1 and B1(a) uses fully accord with the NPPF definition. With regard to the dog day care business, whilst sui generis uses are not specifically defined within NPPF definition, the individual merits of the proposed sui generis use, represents an employment generating use which is complementary to the proposed specialist pet retail use, and which benefits from its sustainable location in close proximity to Crawley town centre. It is further relevant to note that the acceptability of a sui generis use of the site has been considered acceptable in planning terms, as evidence by the approval for the previous use (ref: CR/02/0336).

5.6 Policy EC2 is further concerned with addressing those proposals that involve a net loss of employment floorspace within the designated MEA. This objective of the policy is not relevant to the current proposal given that:

 The proposal does not involve the net loss of employment floorspace given that a mix of employment generating uses are proposed;

 The proposal equates to a total of employment floorspace of 598 sq. m which represents a net increase in employment floorspace of 43 sq. m over the previous use of the unit. A net gain in employment floorspace is therefore proposed;

 The mix of uses generate a higher level of employment compared to the previous use at the site; a net increase of 20 jobs;

 The proposed use seeks to occupy a vacant unit, which has remained vacant since January 2016, despite active marketing by commercial agents;

 The criteria requirements listed at i-iii of Policy EC2 are not relevant.

5.7 It remains that current proposal will safeguard the use of the subject unit for employment purposes, and will provide a range of uses that deliver economic and social benefits for the town. The mix of uses all represent employment generating uses which will positively contribute towards the key economic role and function of

Page 12 the Three Bridges Main Employment Area, and the wider economic function of Crawley.

5.8 For the reasons outlined, it is considered the proposed development fully accords with Policy EC2 of the adopted Crawley Borough Local Plan (2015).

6 COMPLIANCE WITH THE SEQUENTIAL APPROACH 6.1 The requirements of paragraph 24 of the NPPF are well known, and form the basis for Policy EC7 of the adopted Crawley Borough Local Plan (2015). 6.2 Importantly, NPPF paragraph 24 outlines the requirement for applicants and local planning authorities to demonstrate flexibility on issues such as format and scale when applying the sequential approach. This is considered relevant to the current proposal once account is taken of the characteristics and nature of the mixed uses at the application site. 6.3 Further to the advice and guidance set out in the aforementioned NPPF and NPPG, there have been a number of recent high profile Supreme and High Court judgments and appeal/called-in decisions that provide help and clarification relevant to the wider interpretation and application of the sequential test for decision-taking. The impact of recent case law arising from the following are material:  Tesco Stores Limited v Dundee City Council [2012] UKSC 13 – Supreme Court ruling (referred to as the ‘Dundee decision’).  Zurich Assurance Limited (trading as Threadneedle Property Investments v North Lincolnshire Council [20th December 2012] – High Court of Justice [EWHC 3708 (Admin)] (referred to as the ‘Zurich decision’).  Scottish Widows v Cherwell District Council [17th December 2013] – High Court of Justice [EWHC 3968 (Admin)]

Page 13  Application by LXB (Rushden) Limited, Northampton Road, Rushden (11 June 2014) - Section 77 (Call-in Inquiry) (ref: APP/G2815/V/12/2190175) 6.4 In assessing flexibility in more detail, it is not the purpose of national policy to require a development proposal be split over separate sites, where the scope for disaggregation and flexibility in the business model has been demonstrated. This is reinforced by the Dundee and the Rushden judgments, which report that account must be taken of the business model of an applicant when assessing the potential of alternative sites, and that such assessments should not consider the hypothetical ways in which the goods can be sold and which have no relationship to the proposal in hand. 6.5 This is directly relevant to the current proposal that includes a mix of uses that are complementary, and in the case of the office and retail use by Pets Corner, ancillary to each other. As outlined at Section 3, the applicant, Pets Corner, propose an office use at first floor level to provide HQ administration and training whilst at ground floor level, the retail floorspace (to be occupied by Pets Corner) will provide for the sale of specialist products and provide an ancillary training facility for new staff at the company. This represents an operational requirement for Pets Corner, particularly in view of its need for larger office/training premises (which is no longer meet at its existing office floorspace at Queensway) to help support its operational expansion and the need for the retail unit to provide a training function. Furthermore, the proposed dog day care business has obvious distinct, locational requirements and represents a use which is complementary alongside a specialist pet retailer. On this basis, and reflecting the national policy advice, it is reasonable to conclude there is no specific requirement to consider the scope to ‘disaggregate’ specific parts of this proposal onto separate, sequentially preferable, sites. 6.6 Advice set out in paragraph 11 of NPPG (Ensuring the Vitality of Town Centres) is further relevant. This recognises that certain uses require certain locations. It states: “Use of the sequential test should recognise that certain main town centre uses have particular market and locational requirements which mean that they may only be accommodated in specific locations” (Reference ID: 2b-011-20140306). 6.7 This is considered of direct relevance to the current proposal, in that a strict interpretation and application of the sequential test involving new floorspace can be considered to be inappropriate. This reflects the complementary nature of the proposed uses, and the need to occupy a functional site with adjacent supporting car parking, particularly for users of the dog day care business and also elements of bulky goods associated with the retail sales, which could not typically be accommodated in town centre locations. These represent specific and distinct operational requirements, which are recognised by paragraph 11 of the NPPG. It is against this background that the current proposal should be assessed. 6.8 Furthermore, in view of the policy comments relevant to disaggregation, a strong case can be made that there is no reasonable requirement or logical commercial rationale to assess the scope to split floorspace to potentially sequentially preferable alternatives, where this would fundamentally conflict with the applicant’s business model in operational and viability terms. 6.9 At the fundamental level, it is firstly impractical to consider the practicality of units in the town centre, and edge of centre locations, for the dog day care business. Fundamental issues of accessibility, amenity and viability considerations are relevant, which is evidenced by the proposed occupier’s existing units being located and considered acceptable at industrial estates. The application site represents an industrial estate location in the wider sense but equally benefits from close proximity

Page 14 to the town centre, which is recognised by the Local Plan to represent a sustainable location. 6.10 The proposed office use seeks larger floorspace (156 sq. m) which is no longer provided for at the unit on Queensway (94 sq. m). Furthermore, given that the subject site provides office floorspace at a Main Employment Area which supports comparable office uses, the principle of office use at the subject site is considered wholly acceptable. Furthermore, as discussed, there is an operational requirement for synergy between the office floorspace and the retail unit, to provide for training of staff. Given the aforementioned limitations of the ancillary floorspace at the Queensway unit, the current proposal seeks to address this through the provision of larger premises which maintain the synergy for training. 6.11 To meet the requirements of the Policy EC7, it is considered in its strictest terms, that the requirements of the sequential assessment would apply only to the proposed retail use (216 sq. m). However, this statement demonstrates the interlinked nature of the proposed retail and office floorspace use by Pets Corner. Furthermore, the dog day care business is considered a complementary use to the retail use, but equally is subject to distinct operational requirements which together confirm the suitability of the subject site, which whilst out of centre in retail policy terms, is located in close proximity to Crawley town centre. 6.12 Notwithstanding the reasons outlined above, a sequential assessment has been undertaken. This has focused on those units that are available for sale/rent alongside suitability and viability considerations. The search area has focused on Crawley town centre and has adopted a floorspace size in the range 170 – 260 sq. m (to allow for flexibility considerations related to the proposed retail unit of 216 sq. m). A summary of the identified available units identified by site survey and published online commercial data, is provided below:  Unit 68/69 County Mall Shopping Centre (agents, JLL) – located on the Upper Mall of the shopping centre, the unit provides for 376 sq. m. This is unsuitable given the excessive level of floorspace available notwithstanding viability considerations associated with the headline rents sought. Discounted.  Unit 11 County Mall Shopping Centre (agents, JLL) – located in the Lower Mall, the unit provides for 147 sq. m. This is well below the level of floorspace sought by the applicant’s business model, even allowing for flexibility. Discounted.  8 – 9 Queens Square (agents, Cradick Retail) – A large unit with ground and first floor sales area providing over 780 sq. m. This is unsuitable given the excessive level of floorspace available. Discounted.  Unit 64/65, Unit 72 and Unit 96, County Mall Shopping Centre (agents, JLL and Cushman) – a prominent unit located at the upper mall, comprising 315 sq. m, with neighbouring occupiers including Next, River Island, Robert Dyas. The unit is excessive and is considered unsuitable. In regard to Unit 72, this is too small at 118 sq. m. Similar comments apply to unit 96 (108 sq. m). All Discounted.  Unit 28/29 and Unit 57, County Mall Shopping Centre (agents, JLL and Cushman) - units located on the lower mall of the shopping centre, the unit (28/29) provides 190 sq. m, and is opposite Primark and in close proximity to Debenhams and WH Smith. The agents report good interest in the unit whilst the headline rent sought are unviable for a pets retailer. Unit 57 is 42. Sq. m and is too small. Both discounted.

Page 15  15 Queensway (agents, JLL) – A unit of 180 sq. m arranged over ground, first and second floor. The agents confirm the unit is under offer. Discounted.  19-21 Queensway (agents, Stiles Harold Williams) – a total of 351 sq. m of ground floor retail. The unit is unsuitable and excessive in size. It is also located in close proximity to the existing unit at Queensway. Discounted.  26-32 High Street (agents, Stiles Harold Williams) – a small unit of 135 sq. m, the agents report the unit is under offer. Discounted.  3A Broadwalk (agents, Stiles Harold Williams) – a very small unit of 20 sq. m, the unit is too small. Discounted.  1 The Marlets (agents, Jackson Crisp) – a total of 121 sq. m arranged over ground, first and second floor. This is unsuitable given the limited level of floorspace. Further, the agents report the unit is under offer. Discounted.  Ground Floor County Mall Shopping Mall (agents, JLL) – a large unit of 839 sq. m. This is excessive and considered unsuitable. Discounted. 6.13 The sequential assessment has identified a number of available units, that are actively marketed. However, the majority of potential units can be discounted given their unsuitability relating to insufficient or excessive floorspace, even allowing for flexibility considerations. In addition, viability considerations are wholly relevant for the applicant, as a pet shop retailer, with a business model based on low value, high bulk products, which for commercial reasons, cannot compete with traditional high street retailers. In addition, a number of other sites can be discounted on availability grounds, given that the units are under offer. 6.14 In terms of emerging supply, we are aware of the new retail development proposed at 15-29 The Broadway, for A1/A2/A3 uses of up to 724 sq. m (marketing agents, Cradick Retail). However, this development is not yet completed (unavailable), and is considered unsuitable and unavailable given that it represents excessive retail floorspace and as new floorspace is targeted at national retailers which has viability implications for future occupiers. 6.15 In summary, this sequential assessment has identified no sequentially preferable sites for the proposed retail floorspace, notwithstanding the justification for the mix of uses set out in the statement. In view of these fundamental comments, it is reasonable and pragmatic to conclude that the current proposal raises no sequential issues. Conclusion 6.16 The current proposal relates to a mix of complementary uses, which ensure a synergy of uses. Furthermore, the disaggregation of uses is not a policy requirement and even allowing for a strict interpretation of the sequential approach for the retail, use only, no sequentially preferable alternative sites have been identified. 6.17 In summary, for the reasons discussed, the proposal raises no concerns with regard to Local Plan Policy EC7 and paragraph 24 of the NPPF.

Page 16 3.22 7 COMPLIANCE WITH THE IMPACT ASSESSMENT 7.1 Given the minor scale of the retail floorspace proposed (216 sq. m), there is no requirement to provide a Retail Impact Assessment (RIA). This fully accords with adopted Local Plan Policy EC7 which identifies that a RIA is only required for proposals of 2,500 sq. m or more. 7.2 Notwithstanding these comments, a proportionate and locally appropriate level of information is set out to demonstrate that the current proposal would not exert a significantly adverse level of impact on Crawley town centre or other protected centres. Our approach has had full regard to the NPPF and National Planning Policy Guidance (NPPG), the latter of which advises that: “ The impact test should be undertaken in a proportionate and locally appropriate way, drawing on existing information where possible” (ID 2b-015-20140306). 7.3 With regard to impact, paragraph 16 of the NPPG advises that any impact should consider the scale of the proposal relative to town centres, the existing vitality and viability of centres, effects on town centre strategy, impacts on planned investment and implications for vulnerable town centres. The impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal 7.4 As discussed in Section 3, the nature and scale of the proposed mix uses seeks to provide for a limited level of retail floorspace (216 sq. m), for the sale of specialist goods (pet foods and supplies). This floorspace will also be utilised for training purposes in association with the office headquarters (156 sq. m) proposed by Pets Corner at first floor level. In addition, a specialist dog day care business is proposed at ground floor level (218 sq. m), that is wholly complementary to the retail use proposed, and which in view of its operational requirements, requires a location that will not be adversely impacted by amenity considerations. 7.5 Given the unique nature of the mixed uses proposed, which total 598 sq. m at a former tyre recycling unit, in investment terms, the proposed use will have no adverse impact on the retail strategy outlined in the adopted Local Plan which seeks to enhance and develop Crawley town centre as the focus for retail development (and investment) in the Borough and the wider sub region. As the only principal town centre at the head of the retail hierarchy this is not surprising, and as a consequence, the centre is subject to a number of specific policy initiatives, with development opportunities identified at Policy EC6 (including the mixed-use allocations at Parkside Car Park; Traders Market, High Street; Central Sussex College (East of Tower), and Brittingham House, Orchard Street). 7.6 We are not aware of any existing, planned or committed investment, which would in any way be adversely threatened or prejudiced by the current proposal at Unit 1, Spindle Way. 7.7 Furthermore, the current proposal is of an insignificant scale and form which would in no way threaten the aims and objectives set out at Policy EC6. It should instead be viewed as a small scale yet positive proposal which represents employment generating activities, and which contributes towards the economic role and function of Crawley. 3.23 The impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made. For major schemes where the full impact will

Page 17 not be realised in five years, the impact should also be assessed up to ten years from the time the application is made. 7.8 The subject site is located in close proximity to Crawley town centre, the main shopping centre in the Borough, and a major sub regional facility alongside Brighton, Croydon and Bluewater. Given its established sub-regional role, the town benefits from a large and reasonably affluent catchment area, and supports a primary shopping area comprising the pedestrianised Queensway, Queens Square and The Martlets, with the County Mall shopping mall to the south, with Marks & Spencer, Argos and Sainsbury‟s forming the northern anchor. In addition, Morrisons provides a new focus within the town centre. This primary shopping area is supported by other secondary shopping streets, namely The Broadway and Broadwalk but also including High Street, Haslett Avenue West and The Boulevard. The town centre supports a good range of multiple retailers throughout the prime shopping area, together with healthy level of service provision and an improving level of food and drink provision. 7.9 Overall, the health of the town centre in vitality and viability terms is considered good. However, the Local Plan strategy recognises the Council’s objective to encourage the regeneration and efficient use of underutilised town centre and edge- of-centre sites (as reflected in Policy EC6), to support and diversify Crawley’s role as a primary sub-regional centre, and to enhance the vitality of the town centre. 7.10 Given the scale and nature of the current proposal, it is considered there would be no impact on the vitality and viability of the town centre, rather the proposal will help to contribute towards the health of the town centre through new job creation, at an employment site located in very close proximity to town centre facilities. 7.11 The scale of the retail use (at 216 sq. m) is insignificant and represents a specialist range of goods, with product overlap focused primarily at retailers at out of centre locations, such as Pets At Home (London Road, Crawley), DIY and home living superstores (with pet related sales), and the large food superstores (pet foods and supplies sales). As such, the scope for product overlap and trade draw from retail facilities in the town centre is considered very limited. 7.12 Overall, it is concluded that the current proposal would not adversely impact on, or undermine the vitality and viability of Crawley town centre. Conclusion 7.13 For the reasons outlined above, the current proposal will not have a significant adverse impact, nor will it undermine the vitality and viability of Crawley town centre or other protected retail centres in the borough. It is considered the proposal fully accords with adopted Local Plan EC7, and meets the impact tests of NPPF paragraph 26.

3.24 8 CONCLUSION 8.1 The current proposal seeks a mixed use of Class A1/B1 and sui generis uses at a vacant unit, located at Unit 1 Spindle Way, Three Bridges industrial estate, Crawley. In total, the proposal relates to 598 sq. m.

Page 18 8.2 The subject site forms part of the Three Bridges Corridor Main Employment Area, which is subject to Local Plan Policy EC2. The policy is supportive of employment generating uses, and supports the intensification of such employment generating uses at the Main Employment Areas. The proposed uses all represent employment generating uses (up to 29 jobs) and offer the potential for a higher level of employment creation at the site than existed by the previous sui generis use of the site. In addition, the current proposal will increase the level of employment floorspace at the unit. 8.3 Furthermore, the proposed scale and nature of mixed uses are considered to accord with the diverse range and mix of uses that already exist within the Three Bridges Corridor, and will help to actively contribute to the economic role and function of the Main Employment Area, and the wider economic role of Crawley. In addition, the Three Bridges MEA is recognised as a highly sustainable location, which is located in close proximity to the town centre. In summary, it is considered that the current proposal is in fully accordance with Local Plan Policy EC2 and fully supports the objectives of Section 1 of the NPPF to support economic growth. 8.4 In retail terms, the retail element proposed (216 sq. m) is small scale and has no requirement for a retail impact assessment. Even from a sequential assessment perspective, no sequentially preferable alternative sites have been identified in Crawley town centre although as this statement demonstrates, the nature of mixed uses must be considered in a complementary and ancillary context, particularly the linkage for training purposes between the retail floorspace and the office floorspace. 8.5 On this basis, the statement clearly demonstrates that the proposal fully complies with the relevant retail policy, as contained in Local Plan Policy EC7, together with the NPPF, and thereby raises no concerns relative to the key retail policy considerations of the sequential approach to site selection, and the impact assessment. The current proposal would in no way adversely impact on the health and performance, shopping patterns or the role/function of Crawley town centre. 8.6 For the reasons outlined in this retail and economic statement, it is considered that planning permission should be approved.

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