The Pensions Trust

Retail Statement

Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester, GL4 4LP

Planning Application to vary Condition 9 attached to Planning Permission: 98/0019/FUL

August 2012

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

CONTENTS

1.0 INTRODUCTION ...... 1 2.0 SITE AND BACKGROUND ...... 4 3.0 RELEVANT PLANNING POLICY CONTEXT ...... 6 4.0 HOME BARGAINS ...... 12 5.0 SEQUENTIAL APPROACH TO SITE SELECTION ...... 15 6.0 ASSESSMENT OF THE IMPACT OF THE PROPOSAL ...... 30 7.0 CONCLUSION ...... 43

APPENDICES

1. Plan Reference 02 – Indicative Proposed Floor Plan

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

1.0 INTRODUCTION

Introduction

1.1 Savills has prepared this Retail Statement on behalf of The Pensions Trust as part of a planning application at the former Apollo 2000 retail unit at Unit 2b of 108 Eastern Avenue. The application is to vary Condition 9 attached to Planning Permission: 98/00119/FUL in order to enable Home Bargains to operate from the unit and bring it back into beneficial economic use.

Application Proposal

1.2 The application seeks to vary Condition 9 attached to Planning Permission: 98/0019/FUL. The condition restricts the floorspace at the application site to be used for the sale of the following goods:

• carpets • furnishings • electrical goods • pets and pet supplies • office equipment • DIY products for the maintenance and improvement of the home • garden • motor vehicle • any goods ancillary to the permitted uses

1.3 A proportion of the Home Bargains product range is compliant with the current goods restriction. However, Home Bargains require consent to allow the sale of an ancillary food and drink product range (approximately 30% of retail floorspace) and a wider non food offer.

1.4 The application does not propose any additional floorspace or external works to the retail unit (which would be subject to a subsequent application). Illustrative drawings of how we anticipate the unit would be broken up are included at Appendix 1. The drawings show a downsizing of the Staples unit and an enlarged Unit 2b of 1,115 sq.m (12,000 sq.ft). Otherwise the unit would be too small for Home Bargains.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

1.5 As such, the application proposes the following additional condition to control the retail use of part of the site:

In addition to the goods stated at Condition 9, the following additional categories of goods can be sold from a single unit not exceeding 1,115 sq.m (12,000 sq.ft), provided that no single category exceeds 20% of the floor space of the unit, other than (i) (food & drink), where the limit is 30%:

a. Furniture b. Toys and games c. Travel goods d. Children and infants goods e. Sports and leisure goods f. Bicycle and bicycle accessories g. Toiletries and health and beauty products h. Household goods i. Food and drink

Structure of the Statement

1.6 The Statement appraises the relevant retail planning issues relating to the proposed development and is structured as follows:

Section 2.0: Site and Background: Provides details of the application site and the surrounding area and the planning history and policy allocation.

Section 3.0: Relevant Planning Policy Context: Provides a review of the relevant policies within the NPPF relating to this proposal.

Section 4.0: Home Bargains: Describes the business model and product range of the intended occupier.

Section 5.0: Sequential Assessment: Provides an assessment of whether there are any sequentially preferable alternative sites that could accommodate the proposal.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Section 6.0: Impact of the Proposed Development: Considers the impact that the proposed development could have on Gloucester City Centre and the other defined centres assessed by the criteria laid out in the NPPF.

1.7 Our overall conclusion is that:

1. The proposal is necessary to return the unit to beneficial use. 2. The proposal will not have a ‘significant adverse impact’ on Gloucester City Centre of any of the other defined centres. 3. There are no sequentially preferable sites that can accommodate the proposal. 4. The proposed development accords with the latest Government guidance which seeks to secure sustainable economic growth and sets out a clear presumption in favour of such development.

1.8 In the light of the above, we conclude that the proposal accords with the retails policies set out in NPPF.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

2.0 SITE AND BACKGROUND

Site Description

The Application Site and Surrounding Area

2.1 The application site is the retail warehouse units at 108 Eastern Avenue Unit 2b currently measures approximately 647 sq.m and has been vacant since March 2009 when the retailer Apollo 2000 Limited ceased trading when it entered into administration.

2.2 The current configuration of the other units at is as follows:

• Staples (Unit 1) 1,858 sq.m • Maplin (Unit 2a) 460 sq.m

2.3 As explained in the Introduction, please note a separate application would be required to reconfigure the units to provide 1,115 sq.m in Unit 2b for Home Bargains.

2.4 The site is accessed via the A38/Eastern Avenue, which is a principal route through Gloucester.

2.5 The site is located out-of-centre but within the area that is the principal location for retail warehouses in the City. Immediately adjacent to the north of 108 Eastern Avenue is Eastern Avenue Retail Park, which comprises:

• Currys (Unit 1 & 2) 3,100 sq.m • Vacant (Unit 3) 930 sq.m • Harvey’s (Unit 4) 980 sq.m • Carpetright (Unit 5) 980 sq.m • Pizza Hut (Pod unit) 350 sq.m

2.6 A freestanding Lidl foodstore measuring 1,590 sq.m is located immediately adjacent to the south of the site. Immediately to the rear of the site is a Gloucester Cemeteries and Crematorium, Coney Hill. On the opposing side of Eastern Avenue is Eastern Avenue Trading Estate. The surrounding areas are predominantly housing estates with some additional retail warehousing extending along Eastern Avenue. For example, the Halfords store located on Eastern Avenue The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

(1,050 sq.m), the Homebase unit located off Eastbrook Road (3,580 sq.m) and Gloucester Retail Park off Eastern Avenue, where current occupiers are XXX.

Development Plan Allocation

2.7 The application site is unallocated within the Second Stage Deposit Local Plan 2002, which we understand is used by the LPA for development control purposes as an important material consideration.

Retail Conditions and Relevant Planning History

2.8 The planning history relevant to the proposal is as follows:

1. On 14 July 1998 the Council granted planning permission: 98/00119/FUL for the ‘erection of building to provide 2 No Class A1 non-food retail units together with associated service area and parking’. The building sub-divided the unit to create Units 1 and 2. Condition 9 controls the retail use of the site, it states: “The retail units hereby permitted shall be used only for the sale of carpets, furnishings, electrical goods, pets and pet supplies, DIY products for the maintenance and improvement of the home, garden and motor vehicle, and any goods ancillary to these permitted uses and for no other purpose without the prior permission of the City Council”. Condition 10 stated that the units could not be sub-divided to create units of less than 929 sq.m.

2. On 7 July 2010 the Council granted planning permission: 10/00381/FUL for a ‘variation of Condition 10 of 98/00119/FUL to allow for the sub-division of Unit 2 into 2 units’. The permission enabled the sub-division of Unit 2 to form Units 2a and 2b measuring at ground floor level 461 sq.m and 697 sq.m respectively.

3. On 3 November 2010 the Council approved ‘minor amendments to planning permission ref. 10/00381/FUL comprising the re-positioning of internal sub-dividing wall, adjustments to approved mezzanine floor and re-positioning of internal stairs’. The repositioning of the internal sub-dividing wall to create units measuring 461 sq.m (GIA) (Unit 2a) and 650 sq.m (Unit 2b) (Ref. 10/01051/NMA).

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

3.0 RELEVANT PLANNING POLICY CONTEXT

The National Planning Policy Framework

3.1 The National Planning Policy Framework (NPPF) for England was published by the Government on 27 March 2012. The NPPF replaces over a thousand pages of previous planning policies with around fifty, and takes effect immediately.

3.2 The NPPF now replaces all its predecessors as planning policy documents. All Planning Policy Statements/Planning Policy Guidelines (PPS/PPG) are replaced [Annex 3 of the NPPF].

3.3 It is important to note that the NPPF does not change the statutory basis on which planning decisions are founded. So, Section 38 (6) of the Planning and Compensation Act 2004 remains in full effect. Thus if regard is to be had to the “Development Plan” for the purposes of any determination, then that decision must be made in accordance with the plan unless material considerations indicate otherwise. The plan-led system continues [paragraphs 11 and 12].

3.4 The NPPF is though a strong “material consideration” in such a determination [paragraph13]. Government expects communities to plan positively to support local development [Paragraph 16]. It also follows that “development plans”, under the current plan-led system ought to be consistent with the objectives, principles and policies now set out in the NPPF.

3.5 So, local authorities are urged [at Paragraph 213] to get their plans (in the form of new style local plans) – up to speed as quickly as possible. To achieve this, support will be given to local authorities via transitional arrangements. For 12 months, decision takers may continue to give full weight to policies adopted since 2004, even if there is some degree of conflict with the NPPF [see paragraph 214]. If development plans still remain absent, silent, indeterminate or out of date, then the presumption in favour of sustainable development should apply [Paragraphs 14 and 197].

3.6 It is intended to refocus planning policy on encouraging growth, and thus includes a powerful presumption in favour of sustainable development [see Paragraph 14 of the NPPF document]. Government expects that this presumption should run as a “golden thread” through all plan making and decisions on planning applications henceforth.

3.7 For decision-taking this means:

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

• 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: o any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or o specific policies in this Framework indicate development should be restricted.

3.8 The NPPF is intending to be strongly pro-business and thus pro-development. It does not, contrary to some views, release unbridled development upon the nation. Important checks and balances will remain in place, such as the plan-led approach and continued protection of the Green Belt etc. However it is a major policy shakeup.

3.9 A clear message is being sent out to all concerned that the planning system should better support the delivery of growth, jobs and homes than it has often done in the past.

3.10 This is highlighted in the Ministerial foreword:

‘Development that is sustainable should go ahead, without delay - a presumption in favour of sustainable development that is the basis for every plan, and every decision.’

Specific advice on retail matters

3.11 The headline note for retail land uses is that, despite an overall commitment and desire to promote economic growth, the long established ‘town centre first’ approach of previous national policy documents remains the core theme.

3.12 It is important to note however, that within the positive framework for growth, the NPPF does impose a requirement upon local planning authorities to plan positively for the growth of retail and other forms of main town centre uses. The Policy states explicitly that the need for such uses should not be compromised by limited site availability. These clear obligations to deliver growth provide useful policy support for opportunities for new development outside defined town centres.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

3.13 The NPPF confirms a commitment from the Government to delivering economic growth and a presumption in favour of sustainable development which it states should be a ‘golden thread running through both plan-making and decision-taking’. It follows that proposals or opportunities for development of retail and other main town centre uses outside defined centres can be supported provided it can be demonstrated they accord with sustainability objectives.

3.14 The principal issue is whether the proposal would be sustainable having regard to the requirement to ensure the vitality of town centres. The vitality of town centres is ensured by promoting them as the first choice location for town centres uses, including retail, and requiring (edge or out of centre proposals for) new town centre uses to not significantly adversely impact on proposed in- centre investment or consumer choice and trade.

3.15 The policy is be a refinement of the established approach that retail development should be focused in existing centres and any out-of-centre proposals must not have a significant adverse impact.

3.16 Although National Planning Policy Framework has replaced PPS4, the Practice Guidance that accompanied PPS4 remains in place, and so is a material consideration[1]. Therefore, when applying the concepts of impact and the sequential approach, full regard should still be had to the Practice Guidance.

The Sequential Test

3.17 The NPPF seeks to ensure that proposals for economic development are not frustrated by limited site availability. Paragraph 23 of National Planning Policy Framework comments at the 6th bullet point that:

“It is important that needs for retail, leisure, office and other main town centre uses are met in full and are not compromised by limited site availability…”

3.18 Applying the sequential approach should have regard to the need that will be met by the development. It is not an academic exercise divorced from the commercial realities of what it is that developers and landlords are seeking to supply in response to market demand. For it to have

[1] DCLG has confirmed to Savills on 28 March 2012 that the only documents that have been replaced by the NPPF are the documents set out at Annex 3. DCLG therefore confirmed that the Practice Guidance on need, impact and the sequential approach has been retained. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

meaning, the sequential approach must be applied in a way that allows the identified need to be fully met. That is the essence of paragraph 23 of National Planning Policy Framework. Paragraph 23 is entirely consistent with paragraph 5.7 of the Practice Guidance which states:

‘If the LPA proposes to refuse an application involving town centre uses on the basis of the sequential approach, it should be on the basis that it considers there is, or maybe, a reasonable prospect of a sequentially preferable opportunity coming forward which is likely to be capable of meeting the same requirements as the application is intended to meet.’

3.19 Paragraph 6.9 of the Practice Guidance makes it even clearer that the realities of market requirements should be fully considered stating the following:

‘Whilst the sequential approach applies to all main town centre uses, local planning authorities should consider the relative priorities and needs of different main town centre uses, particularly recognising their differing operational and market requirements. For example, a hotel associated with a motorway service area is likely to cater for a distinct market compared to a traditional city centre hotel. Similarly, a town centre office development will serve a different function and market compared to a business park’.

3.20 The considerations arising from the sequential approach are separate from the consideration arising from an impact assessment. It follows that a proposal may satisfy the sequential approach, but still prove unacceptable if the impact of the proposal is likely to cause significant harm to the town centre. This is widely understood good practice.

3.21 Paragraph 24 of the NPPF explains that local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. Applying the sequential approach in this case means assessing whether there are any sites in existing town centre in the catchment area that can meet the identified need. Further, if there are no such sites, the sequential approach also requires an assessment of sites at the edge of the identified centre. Even then, if there are no edge-of-centre sites, preference should be given to out-of-centre sites that are well connected to the town centre.

Impact

3.22 Impact considerations have been changed significantly in National Planning Policy Framework compared with PPS4. Paragraph 26 is clear that the emphasis of impact is on a centre. The The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

terms used at the two bullet points at paragraph 26 are defined in Annex 2 of the National Planning Policy Framework. It is abundantly clear that consideration of impact is directed towards impact on defined town centres, including district and local centres.

3.23 Paragraph 26 sets out two specific considerations:

1 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.

2 impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area

Ministerial Statement: Planning for Growth (March 2011)

3.24 The written statement by the Minister of State for Decentralisation (Mr Greg Clark) of 23 March 2011 sets out clearly the Government’s expectations of local planning authorities and the planning system to help secure a swift return to economic growth. It states:

“Government’s clear expectation is that the answer to development and growth should be wherever possible be ‘yes’, except where this would compromise the key sustainable development principles set out in national planning policy’.

‘When deciding whether to grant planning permission, local planning authorities should support enterprise and facilitate housing, economic and other forms of sustainable development. Where relevant – and consistent with their statutory obligations – they should therefore, inter alia:

(i) Consider fully the importance of national planning policies aimed at fostering economic growth and employment, given the need to ensure a return to robust growth after the recent recession…

(iii) Consider the range of likely economic, environmental and social benefits of the proposals; including long term or indirect benefits such as increased consumer choice, more viable communities and more robust local economies (which may, where relevant include matters such as job creation and business productivity)

(v) Ensure that they do not impose unnecessary burdens on development. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

The Secretary of State for communities and Local Government will take the principles in this statement into account when determining applications that come before him for decision. In particular he will attach significant weight to the need to secure economic growth and employment.”

A Presumption in Favour of Development (June 2011)

3.25 On 15 June 2011, the Government released a statement which introduced a presumption in favour of sustainable development, which fulfils the commitment set out in the Planning for Growth referred to above. It states:

‘There is a presumption in favour of sustainable development at the heart of the planning system, which should be central to the approach taken to both plan-making and decision- taking. Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible.

Local planning authorities should: • Prepare local plans on the basis that objectively assessed development needs should be met, and with sufficient flexibility to respond to rapid shifts in demand or other economic changes; • Approve development proposals that accord with statutory plans without delay; and • Grant permission where the plan is absent, silent, indeterminate or where relevant policies are out of date.

All of these policies should apply unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits, when assessed against the policy objectives in the National Planning Policy Framework taken as a whole.’ (Savills emphasis).

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

4.0 HOME BARGAINS

The discount retail sector

4.1 The retail sector has shown itself to be remarkably resilient during the economic downturn by adapting to reflect current consumer demand. Over the last few years, discount operators have been a key growth area and have helped to provide consumer choice.

4.2 The convenience market has a well established discount sector. National multiple operators such as Aldi, Lidl and Netto1 established presence within the UK in the early 1990s and have experienced significant growth in store numbers and market share as demand has risen steadily over the last decade.

4.3 The discount sector within the comparison market is still somewhat embryonic, although it has experienced significant growth over the last five years (certainly in terms of new national multiple operators). Key players that have emerged and driven the market on a nationwide and regional scale include:

1 Wilkinsons 2 Home Bargains (TJ Morris) 3 B&M Bargains 4 Quality Save 5 Family Bargains/99p Stores 6 Poundworld 7 Poundland

The Home Bargains Business Model

4.4 Home Bargains is a large format national multiple discount mixed goods retailer. The business is run on one key principle: to sell quality branded goods at the lowest prices possible2.

1 Now part of Asda Wallmart. 2 www.tjmorris.co.uk/about-us.html The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

4.5 The business has rapidly expanded in recent years as a direct result to wider economic considerations and the customer demand shifting towards achieving value for money. Home Bargains now has over 190 stores and employs over 7,000 people across the country.

4.6 In order to meet its key principle, the business model drives a requirement for large format, cost effective premises. Such accommodation enables the Company to offer a comprehensive product range and offer products at a discounted rate. This business model is now well established and the core product ranges include:

• Household goods • Furniture and furnishings • Health and beauty products • Toys and games • Ambient food and drink • A limited range of clothing (mainly underwear and baby and children’s clothing) • Seasonal goods (such as garden equipment and Christmas decorations)

4.7 The business concept and overall product range is focused on goods to be provided for the household (meaning that the inclusion of a limited range of food and drink is directly linked to a shop for homeware and household goods). The list below provides a breakdown of the range of goods likely to be sold from a Home Bargains. Those highlighted in bold are the products which can already be sold at the application site:

• Toys & Games • Homeware • Electrical • Furniture • Sports & Leisure • Travel Goods • DIY & Hardware • Baby & Child • Garden • Pets & Pet Supplies • Arts & Crafts • Health & Beauty The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

• Ambient Food & Drink Household (Up to 30%)

4.8 Home Bargains’ direct competitors are typically other ‘variety discounters’ but also large format national multiple superstores (such as Tesco and Asda). Customers will typically supplement their main weekly food shopping trip with a visit to a ‘variety discounter’ for specific goods or promotions. This is particularly the case with the food and drink goods sold, which are ‘ambient goods’.

4.9 The Competition Commission3 defines an ‘Ambient Grocery Lines’ as goods which can be stored for long periods at an ambient temperature (i.e. without refrigeration). The goods sold by the Company are therefore predominantly non-perishable, typically branded items and principally include: tinned goods, condiments, pet food and multi-packs of packaged dried goods (e.g. crisps, chocolate bars etc).

4.10 Home Bargains serves very little refrigerated, fresh or frozen produce and therefore it does not compete with independent specialist retailers often found in defined centres (e.g. butchers, greengrocers, bakers etc). Over 40% of the product range is one-off clearance or close-out products. Given the specific nature of the food and drink products sold by Home Bargains, shoppers would not generally conduct a ‘main’ grocery shop at its stores.

4.11 The products sold within the store are always changing, and customers can expect to see different product lines each time they visit the stores.

3 The Supply of Groceries in the UK Market Investigation (April 2008). The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

5.0 SEQUENTIAL APPROACH TO SITE SELECTION

Introduction

5.1 Paragraph 26 of the NPPF requires planning applications for main town centre uses that are not in existing centres or in accordance with an up to date development plan to be subject to a sequential assessment.

5.2 We have undertaken a sequential assessment in accordance with the methodology promoted within the NPPF and the Practice Guide and assessed all in and edge of centre sites. The criteria used to assess whether alternative sites exist are commercial criteria that examine the availability, suitability and viability as follows:

• Availability – Whether sites are available now or are likely to become available for development within a reasonable period of time having regard to the urgency of the need that exists in any particular case.

• Suitability – Whether a site could be developed for the proposal having regard to the requirement to demonstrate flexibility and whether the site is suitable to accommodate the specific need or demand the proposal is intended to meet4.

• Viability – Whether there is a reasonable prospect that the development will occur on the site at a particular point in time, again having regard to the specific nature of the need or operator demand the proposal is intended to meet.

5.3 A sequentially preferable site is one that accords with all three criteria i.e. available, suitable and viable for the proposed use.

5.4 Paragraph 24 of the NPPF requires applicants to demonstrate flexibility in the proposal in terms of the following criteria when considering the potential of alternative sites:

i. Scale; ii. Format; iii. Car parking provision; and iv. The scope for disaggregation.

4 See Paragraph 6.37 of the PPS 4 Practice Guide. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

5.5 In relation to flexibility, the most relevant consideration is referred to at Paragraph 6.33 of the Practice Guide, which states that:

‘…every case requires decision makers to strike an appropriate balance between the requirements of the commercial sector and national policy based on local considerations.’

5.6 Paragraph 6.30 of the Practice Guide provides further guidance in respect of disaggregation and confirms that:

‘In the case of a single retailer or leisure operators, it is not the purpose of national policy to require development to be split into separate sites where flexibility in their business model and the scope for disaggregation have been demonstrated.’

Operational and Market Requirements

5.7 The NPPF and the commentary in the accompanying Practice Guide makes it clear that the sequential assessment is to be applied with balance between the objectives of focussing appropriate development in town centres while recognising the specific commercial and market requirements of certain operations. Paragraph 6.9 of the Practice Guide states:

‘Whilst the sequential approach applies to all main town centre uses, local planning authorities should consider the relative priorities and needs of different main town centre uses, particularly recognising their differing operational and market requirements..’

5.8 Understanding the requirements of different retail operations is critical to ensuring that any given town or area benefits from a comprehensive range of retail provision. It also ensures that economic development and therefore competition between retailers can be effectively promoted.

5.9 It is essential that the LPA considers the proposed development in the correct context in respect of the specific consumer need and operator demand that the proposal is intended to meet.

5.10 Paragraph 6.42 of the Practice Guide comments that where a more central site is suitable to meet the market and operational needs does not require evidence demonstrating the existence of a site The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

that can precisely meet the scale and form of the development proposed on a less central site. However, it is necessary to consider what contribution more central sites are able to make in meeting the same requirements. Given Paragraph 6.9 of the Practice Guide, the “same requirements” means both the consumer need and operational requirement that the proposal is intended to serve.

Sequential Assessment Methodology

5.11 If the application is approved a subsequent application will be made to reconfigure the units at 108 Eastern Avenue to provide approximately 1,115 sq.m in Unit 2b5. The changes are necessary to meet Home Bargains operational requirements.

5.12 The alternative sites that are considered in respect of the criteria stated above are as follows:

City Centre sites 1. Kings Quarter 2. Greater Blackfriars 3. Greyfriars (Bowling Green and Indoor Market) 4. City Centre vacant units: a. 12 -18 Eastgate Street b. 13 – 23 Northgate Street c. 13 – 15 Southgate Street d. 4 – 6 Eastgate Street

Edge of centre sites 5. Greyfriars – Hampden Way Car Parks & Gloscol Sites 6. Station Road Car Park 7. Southgate Moorings Car Park 8. Edge of centre vacant units: a. 103-111 Northgate Street (Former Kwik Save) b. Bruton Way (Former Courts) c. 31 – 33 Worcester Street

5 This will provide the following floorspaces at 108 Eastern Avenue: Unit 1 (1,398 sq.m), Unit 2a (460 sq.m) and Unit 2b (1,115 sq.m). The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

5.13 In addition, while it is not a policy requirement to consider out of centre sites, we also provide comments on the following:

Out of centre sites 9. Gloucester Quays 10. Land adjacent to Dry Docks 11. Kimberley Warehouse 12. Unit 4b The Peel Centre

Assessment of Potential Alternative Sites

Town Centre Sites

1. Kings Quarter

5.14 The draft Kings Quarter Planning Concept Statement identifies an area of approximately 11 hectares in the north east quadrant of the city centre for retail development, expansion of the PSA and public realm.

5.15 The site is allocated in the development plan for retail development under Policy S3, which states:

‘Planning permission will be granted for part of Kings Square, as shown on the Proposals Map, for new retail development for comparison goods. Site Specific Obligation: • Contribution towards the cost of remodelling Kings Square’

5.16 The draft Gloucester Central Area Action Plan (CAAP) identifies the Kings Quarter as a priority for redevelopment for a retail-led mixed use scheme. Policy CA20 sets out the indicative capacity for retail as 25,000 sq.m of comparison goods (non-food) to be located at the bus station and market parade.

5.17 The entire site is comprised by Kings Square, the bus station and market parade and the adjoining multi-storey car park and other development sites located within the border for the site, which is defined in the draft concept statement.

5.18 Currently, most of the existing buildings on site are in use and under the ownership of Aviva. It is unclear how the Council and Stanhope PLC, the chosen developer, will progress with acquiring The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

the various sites for development. It may involve Compulsory Purchase Orders, although this is not confirmed at this stage.

5.19 The site is therefore currently unavailable, and with reference to the forthcoming re-development of the bus station and market parade to provide 18,500 sq.m of retail floorspace, the development may not be available within a reasonable timeframe (3 – 5 years).

5.20 Although no formal planning applications have been made, we understand from indicative plans that the scheme will comprise a series of high quality retail units for comparison retailers, with a strong focus on high street fashion, potentially anchored by a department store or a series of larger stores. It is expected that the units at the Kings Quarter site will measure between 93 sq.m – 836 sq.m, with up to five medium sized units measuring 1,300 sq.m – 4,645 sq.m6.

5.21 As such, we consider the smaller units (93 sq.m – 836 sq.m) are not sufficient in size to maintain a viable discount variety retail warehouse operation. For example, the units could not provide the required ancillary storage space required by most bulky goods retail warehouse operators.

5.22 A discount variety retail warehouse store is contrary to policy objectives for the Kings Quarter and as such, is an unsuitable form of retail in the context of the vision for the area. Further to this, accommodating discount variety retailers at Kings Quarter could be detrimental in attracting the type of retailers required for the development to be viable and meet policy objectives.

5.23 An application made by Peel Land and Property Investments for the redevelopment of the Cineworld at The Peel Centre on St. Ann Way to provide a series of retail units was approved on 10 July 2012. The application received representations from objectors, who were mainly Kings Quarter stakeholders, who considered that the application should have been refused on sequential and impact grounds.

5.24 In response to some of the representations, Peel’s planning consultants, White Young Green Planning and Design (WYG), issued correspondence dated 26 January 2012 which set out a list of potential tenants for Kings Quarter. The list was produced by Jones Land LaSalle and set out a over 90 retailers who they considered could realistically locate to Kings Quarter, some of the retailers from that list are set out below:

• Ted Baker • Banana Republic • Jack & Jones

6 Paragraph 6.9 of Appraisal of Planning Application No. 11/01292/FUL – report reference: DJ/DM/C10177 produced by DPDS Consulting, dated February 2012. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

• Hugo Boss • Radley • Bertie • Warehouse • Champneys • American Apparel • Scotts • Ralph Lauren • Yard • Quiz • Lipsy • Toast • Bank • Timberland • Republic • Miss Selfridge • AX Armani Exchange • Jones Bootmaker • Cult • L’Occitane • Vans

5.25 In light of the above list, we conclude that a Home Bargains operating from any of the five larger units (1,300 sq.m – 4,645 sq.m), would not provide a suitable anchor for a high quality fashion retail destination where operators such as the above are trading. Further, it is notable that Home Bargains or any other discount variety retailers are absent from the list highlighting that it is unlikely that such retailers will realistically locate in Kings Quarter.

5.26 Overall we conclude that Kings Quarter fails the policy tests for availability and suitability and is therefore not sequentially preferable to the application site.

2. Greater Blackfriars

5.27 The Greater Blackfriars Planning Brief SPD identifies a large site between the Cathedral and the Docks measuring 11.76 ha for comprehensive redevelopment. The majority of the development brief site lies in the Western Waterfront, which is allocated in the Second Deposit Draft Local Plan under Policy MU.2 for mixed-use development including residential, employment, retail education, leisure, hotels, culture, community facilities and services, open space, public car parking and tourist coach parking.

5.28 Policy CA19 of the draft CAAP identifies the Fleece Hotel and surrounding buildings to be a focus for small-scale specialist retail development including the demolition of the Longsmith Street Car Park. The draft Gloucester CAAP sets out the Council’s intention for the site Greater Blackfriars area to be the cultural and creative heart of the City Centre.

5.29 The development of the Blackfrairs Cultural Quarter has commenced. Construction work has started on the Language Immersion Centre which was approved in 2010.

5.30 Given the context and the policy aspirations for the development of a cultural quarter on the site we consider a proposal for retail warehousing on any part of the site to be an unsuitable form of The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

development. Further to this, development for retail warehousing on the site may prejudice the delivery of other elements of the proposals for the site such as the hotel, community facilities and public open space.

5.31 The Fleece Hotel is among Gloucester’s oldest and historically famous buildings, it is a Grade 1 Listed Building dating back to the 12th Century. The hotel has listed buildings consents: 11/01400/LBC and 12/00111/LBC for structural improvements and restoration. The Council intend to bring the building back into use as a hotel. The Fleece Hotel is therefore not available for retail development. The site is also unsuitable, as the significance of the building to the heritage of Gloucester City means that retail warehousing would be undesirable, and the necessary amendments required to accommodate a retail warehouse format store could not be achieved through building control restrictions.

5.32 The wider Greater Blackfriars site is under multiple ownership and we are unaware of any of the land within the site being marketed. We therefore conclude that that it is unlikely that any sites within the area are likely to become available within a reasonable period of time.

5.33 We conclude that the site fails the policy tests for availability and suitability. For these reasons we have not assessed viability. Our overall conclusion is therefore, that the site is not sequentially preferable to the application site.

3. Greyfriars – City Centre sites

5.34 The Greater Greyfriars SPD identifies a large site measuring 7.9ha for a mixed-use development. The SPD and Policy CA18 of the CAAP identify six potential development sites within the wider site as follows: • Gloucestershire College Main Site (Gloscat) • Gloucestershire Media (Gloscat) • The Greyfriars Monument • Bowling Green and Indoor Market • Hampden Way Car Parks • St. Michaels Square

5.35 The only sites from the above list allocated for commercial development is the Gloscat Sites (Gloscat Main and Gloscat Media), which are located on the edge of the city centre in policy terms. As such, the sites are considered later in the assessment with the other edge of centre The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

sites. The SPD allocates the Bowling Green and Indoor Market for retail units. The Indoor Market is located in the PSA and is therefore considered in this section below.

5.36 The other sites from the above list are allocated for purposes other than commercial (or retail). Those sites are therefore not considered in this assessment as a proposal for retail would be contrary to policy and therefore an unsuitable form of development.

Bowling Green and Indoor Market

5.37 The SPD identifies the site for development for retail units as an extension to The Mall Shopping Centre and to provide a more open setting for Blackfriars Priory. As stated above, proposals on the site would be subject to the relocation of the market.

5.38 The site is currently in use as a bowling green and market and we are unaware of the site being marketed or any planning permissions or applications for the redevelopment of the site. The site therefore is unavailable, and is not likely to become available within a reasonable period of time.

5.39 As stated above and set out in the relevant policy, the development of the site is to be sympathetic and complementary to the Blackfriars Priory. As such, we consider that development of the site for retail warehousing would be unsuitable and contrary to policy.

5.40 We conclude that the Bowling Green and Indoor Market element of the Greyfriars site fails the policy tests for availability and suitability. For these reasons we have not assessed viability. Our overall conclusion is therefore, that the site is not sequentially preferable to the application site.

4. Vacant units within the Primary Shopping Area

5.41 Using a Goad plan of Gloucester City Centre which was surveyed on 15 September 2011 we have identified vacant units exceeding 500 sq.m to be considered in the sequential assessment as units that provide less than this amount of floorspace could only potentially accommodate the proposal where an unreasonable level of flexibility is demonstrated on scale and format.

5.42 Using the criteria set out above, we have identified the following vacant units: a. 12 -18 Eastgate Street b. 5 – 6 Eastgate Street

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

5.43 As a result of further research into the above units we have also identified the following vacant units: c. 13 – 23 Northgate Street d. 13 – 15 Southgate Street

a. 12 – 18 Eastgate Street (Former Woolworths)

5.44 The former Woolworths unit located at 12 – 18 Eastgate Street measures approximately 3,251 sq.m. The unit became vacant in January 2009 when the retailer went into administration, however, Marks and Spencer have now revamped and occupied the unit opening the new store on 26 July 2012. The move for Marks and Spencer involved the closure of their stores at 13 – 23 Northgate Street and 13 – 15 Southgate Street.

b. 4 - 6 Eastgate Street

5.45 A unit located at 4 – 6 Eastgate Street measuring 820 sq.m is currently vacant. We understand that the unit is due to become occupied by Poundland who have secured Planning permission: 11/01146/FUL, which was approved on 9 December 2011, for the installation of a new shopfront for the unit. The site is therefore unavailable.

c. 13 – 23 Northgate Street

5.46 The vacant former Marks and Spencer at 13 – 23 Northgate Street measures approximately 2,090 sq.m. We understand that B&M Bargains are due to occupy the unit on a long-term lease. As such, the former Marks and Spencer unit on Northgate Street is not available.

d. 13 – 15 Southgate Street

5.47 The vacant former Marks and Spencer located at 13 – 15 Southgate Street measures approximately 1,080 sq.m. We understand that retailers have been in negotiations to occupy the unit which implies the may already be unavailable7. Further, it is unlikely that the proposed Home

7 See for instance ‘Discount retailer to fill old M&S and MFI stores in Gloucester’ reported on The Citizen on 7 August 2012, accessible at: http://www.thisisgloucestershire.co.uk/Discount-retailer-old-M-amp-S-MFI-stores/story- 16660484-detail/story.html

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Bargains could be accommodated in the unit and be a viable business venture for the retailer, who are seeking to operate a retail warehouse format store in Gloucester.

Edge of centre sites

5.48 The following sites are located on the edge of the city centre in policy terms i.e. they are located within 300m of the PSA.

5. Greyfriars – Edge of centre sites

Gloscat Sites

5.49 As stated above, the Gloscat sites are allocated in the Greater Greyfriars SPD for development for commercial uses. The sites are located approximately 50m from the PSA.

5.50 The sites are under being developed by Linden Homes Ltd pursuant to planning permission: 11/00107/FUL, for a comprehensive redevelopment of the site for a mixed-use development comprising residential, offices, community and PCT buildings and restaurant/cafes. The site is therefore not available for development.

6. Station Road Car Park

5.51 The site is unallocated in the development plan and emerging policy documents and located approximately 195m from the PSA. The car park is currently in use as a car park and we understand that the site is not currently on the market. The site is therefore not available for development.

7. Southgate Moorings Car Park

5.52 The site is allocated in the Second Deposit Draft Local Plan under Policy CL1 as a site for new major commercial leisure development. The draft CAAP identifies the site for office development under Policy CA21. The site is located approximately 200m from the PSA. The site is currently in use as a car park and we understand that Ecclesiastical Insurance have agreed with the landowner to acquire the site, develop it for offices and relocate to the site. As such, the site is therefore not available for development.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

8. Edge of centre vacant units

5.53 Applying the same methodology as set out above for vacant units located within the PSA, we have identified the following edge of centre units that are currently vacant: a. 103-111 Northgate Street (Former Kwik Save) b. Bruton Way (Former Courts) c. 31 – 33 Worcester Street (Conway House)

a. 103-111 Northgate Street (Former Kwik Save)

5.54 The former Kwik Save unit located at 103 – 111 Northgate Street is located approximately 75m from the PSA and offers approximately 2,590 sq.m of floorspace. Newland Homes achieved planning permission to develop the site for high density residential development in 2007 (Ref. 07/00134/FUL). The developer renewed the permission in 2010 (Ref. 10/00239/FUL) and amended the plans in 2011 (Ref. 10/00769/FUL).

5.55 We understand that the project has recently been put on hold due to viability issues. However, due to the extant permissions on the site, we consider that it is not available for development.

b. Bruton Way (former Courts)

5.56 The former Courts unit located on Bruton Way is located approximately 145m from the PSA and offers approximately 2,560 sq.m. The use of the building was changed from retail to self storage and office pursuant to planning permission: 10/00719/COU. The ground floor of the unit was converted by Formal Investments Limited pursuant to planning permission: 11/01174/FUL for offices. The development was completed in January 2012 and as such, the site is not available for development.

c. 31 – 33 Worcester Street (Conway House)

5.57 The site is a former office which has been vacant for approximately six years and provides 1,615 sq.m of floorspace. The site is located approximately 85m from the PSA and is therefore in an edge of centre location in policy terms.

5.58 A planning application was submitted by Vaneli Investing Corporation on 17 May 2012 to change the use of the building from office to hotel (12/00487/COU). The application also seeks the The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

external alterations required for the proposed change of use. The application is still under consideration from the Council. The Design and Access Statement submitted with the above application states that following a pre-application meeting with the Council in relation to the proposal, planning officers welcomed the change of use (11/01114/PREAPP).

5.59 We therefore conclude that the site is not available. Further to this, the ground floor of the site provides approximately 94 sq.m floorspace. The proposed format of the proposed retail warehouse requires the store to be at ground floor level, which cannot be provided at the site even where a reasonable level of flexibility is demonstrated.

Out of centre sites

5.60 The following sites are located outside of the city centre in policy terms i.e. they are located more than 300m of the PSA. We provide comments on these sites for completeness, but there is no policy requirement to consider out of centre sites.

9. Gloucester Quays

5.61 Outline approval for the redevelopment of Gloucester Quays was granted by the Secretary of State for the Department of Communities and Local Government on 22 June 2002 (Ref. 02/00271/OUT). The development is a major £400m regeneration scheme of the Gloucester Quays and docks area. The Peel Group are the landowners and are in the process of developing parts of the site. The Gloucester Quays Outlet Village, which was Phase 1 of the development, is now complete and mostly occupied.

5.62 It is worth noting that the factory outlet village is restricted by Conditions 12 - 16 of outline planning permission: 02/00271/OUT to occupation by retailers operating a factory outlet format store. As such, vacant units within the Gloucester Quays Outlet Village could not become occupied by the proposed Home Bargains store as this would result in a breach of the planning permission. Any vacant units within the outlet village are therefore considered unsuitable.

5.63 The consideration of Gloucester Quays for the sequential assessment will focus on the remaining undeveloped sites and vacant buildings within the development site.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Downings Malthouse

5.64 The above site is a Grade II listed building allocated in the Gloucester Docks Masterplan for residential and leisure uses. Approval for the demolition of the Downings Malthouse building was approved on 28 May 2009 (Ref. 09/00346/LBC). Reserved matters approval following outline permission: 02/00271/OUT was approved on 23 February 2010 for the siting, design and external appearance of building B10 of the development, which is comprised by Downings Malthouse and a new build, which will be used for office, leisure and residential uses (Ref. 09/01096/REM). The site is currently being marketed in accordance with the approved uses.

5.65 As such, the site is not available, nor would the proposed retail use accord with the approved use of the site or the policy aspiration. We therefore also conclude that the site is also unsuitable.

Llanthony Wharf Area

5.66 The Llanthony Wharf area is allocated in the draft CAAP for residential use and public open space. The area is part of the wider site benefitting from the outline planning permission referred to above for residential development, offices and a hotel (Ref. 02/00271/OUT). In addition to this, part of the site has planning permission to be developed for a public house (Ref. 11/00409/FUL).

5.67 As such, the site is not available. Further to this, the proposal does not accord with policy, developer aspirations and the relevant planning permissions for the site, therefore, the site is also unsuitable.

Peel House

5.68 The site is located adjacent to the Peel Centre on the edge of the site location boundary for outline planning permission: 02/00271/OUT. We understand that the owners intend to progress with the development approved under the outline permission for use as an office. The site is not being marketed for retail use and as such, is not available.

Provender Mill and Transit Shed

5.69 In May 2009 the owner was granted listed building consent to demolish a steel framed shed to the north of the mill and a single storey extension to the south along with the Downings Malthouse The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

building (Ref. 09/00346/LBC). The City Council are encouraging the owner to progress with the demolition works so that scaffolding can be erected around the building and a program of urgently required repair works can be carried out.

5.70 In light of the listed building status of the mill, and the urgently required works to the building, we consider that the site is not suitable to accommodate retail development. In addition to this, retail use in this specific part of Gloucester Wharf would be contrary to policy objectives for the regeneration of the area.

Numold (UK) Ltd

5.71 The Numold (UK) Ltd building is located off Merchants Road within the Gloucester Quays development site. The site is within the development area set out in outline planning permission: 02/00271/OUT and as such, is considered in the sequential assessment. The building measures approximately 1,975 sq.m and is currently occupied by and in active use. We understand that the building is not being marketed for any form of redevelopment and as such, is not available.

Block Q

5.72 Block Q of the Gloucester Quays development site is located at the corner of Llanthony Road and the canal. Planning permission: 08/00681/FUL was granted on 5 November 2008 to enable the building to be used for food and drink within Use Classes A3 – A5. Construction pursuant to the permission is nearing completion and part of the site is already occupied by A3 users. As such, the site is not available nor would A1 retail use on the site accord with the relevant planning permissions or policy aspirations for the site.

10. Land adjacent to Dry Docks

5.73 Policy CA21 of the draft CAAP allocates the land at the Dry Docks for mixed-use development including multi-decked parking, restaurants, visitor facilities/workspace and residential. The supporting text states that the policy seeks to retain the dry docks as a visitor attraction and enhance the qualities of the area to create an attractive gateway to the city. As such, development of the site for the proposal would not accord with policy objectives for the area and is therefore not a suitable form of development.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

11. Kimberley Warehouse

5.74 The site is located within a conservation area and is a Grade II listed building. The building provides approximately 740 sq.m over two floors. We understand that a long ground lease is available for this unit. The scale and format of the building is also unsuitable for the proposal and significant works would be required to provide a retail warehouse development in the building. To this end, it is also highly unlikely that listed buildings consent would be achieved for such a development.

Conclusion

5.75 We are unaware of any other vacant sites that are within, or on the edge of, Gloucester City Centre that satisfy the NPPF and Practice Guidance tests of availability, suitability and viability. We have also considered a number of out of centre sites and have not identified any that meet the policy tests and are better connected to the City or other centres.

5.76 We consider that the application site, given its situation within Gloucester’s principal location for retail warehousing at an established retail destination, is the most sequentially preferable location for the proposed development.

5.77 The application site is the most suitable site to accommodate the proposal.

5.78 The overall conclusion is that the former Apollo 2000 unit at 108 Eastern Avenue is the most sequentially preferable site for the proposed development and therefore the proposal accords with Paragraph 24 of the NPPF.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.0 ASSESSMENT OF THE IMPACT OF THE PROPOSAL

6.1 Unless there is a locally set proportionate threshold, Paragraph 26 of the NPPF requires planning applications for retail and leisure developments that exceed 2,500 sq. m (gross) and are not in an existing centre and not in accordance with an up to date development plan, to be accompanied by an assessment of the impact of the development.

6.2 The proposed unit intended to be occupied by Home Bargains is 1,115 sq. m. Accordingly, the retail floorspace in this case is materially below the threshold specified in the National Planning Policy Framework and there is no requirement in this case for an impact assessment. The effect of this is that as the NPPF does not require an impact assessment to be submitted, then there can be no grounds for refusing the planning application on the grounds of significant adverse impact at paragraph 27 of the National Planning Policy Framework.

6.3 Nevertheless an impact assessment is provided and it is proportionate to the level of floorspace proposed, which is over 50% below the threshold where an impact assessment is required. The conclusions are that there are no significant adverse impacts. The impacts are certainly a long way below the threshold of significant.

6.4 Paragraph 26 sets out two specific considerations:

1. 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.

2. impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area.

6.5 Weight must be given to the fact that the NPPF is concerned with ‘significant impact’. The Policy has been purposefully drafted in these terms because all development will have an impact. As the Practice Guide states, it is axiomatic that new development will have some impact on existing facilities8. The pertinent question therefore is not whether there will be an impact, but whether that impact is significant. The Practice Guide states that an assessment of impact should focus on the five years after the anticipated implementation of a proposal9.

8 See specifically Paragraph B2 (Appendix B) of the PPS 4 Practice Guide, but also Paragraph 7.28. 9 See Paragraph 7.1 of the PPS 4 Practice Guide. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.6 The requirement to demonstrate need has been abandoned for development management decisions because it has proved dysfunctional in that it has unintentionally stifled diversity and consumer choice. The main purposes of the new policies are to better understand the effect of economic development outside of town centres and whether such development will harm or benefit consumer choice.

6.7 The purpose of a retail impact assessment is to enable decision makers to gauge the impact of a proposal on development plan strategy, planned new investment and the overall consequences on the vitality and viability of existing retail centres. A retail impact assessment submitted in support of a planning application should be designed to test the detailed impacts of a specific proposal. As such, a retail impact assessment submitted to support a planning application is different from a retail assessment that may be required for plan-making10.

6.8 The difference is in the assessment of the quantitative effects of a specific proposal, rather than wider considerations of need11. The main objective of a retail impact assessment is to quantify the effects the effects of trade diversion, rather than assess the overall capacity for new floor space. The concepts of retail capacity and retail impact are closely related. Both concepts use similar data and methodologies to assess the scope of locations to absorb new development. A retail impact assessment builds on the evidence of a retail capacity assessment.

6.9 A retail impact assessment uses the data to assess likely turnover and trade draw of a specific proposal. A retail capacity study uses the data to assess likely levels of expenditure available within an assessment area by the end of the forecast period12. In other words, the two types of assessments have very different subjects as their focus. Retail impact assessments focus on turnover and trade diversion, and capacity assessments focus on per expenditure and expenditure growth.

Vitality and Viability of Gloucester City Centre

6.10 The following section of the Statement provides our comments on the mix of uses and the vitality and viability of Gloucester City Centre. We have also referred to the 2008 Gloucester Retail Review which was produced by Chase and Partners on behalf of Gloucester City Council, although this document is considered somewhat out of date.

10 See paragraphs 7.3 & 7.6 of the Practice Guidance 11 See paragraph D.1 of the Practice Guidance 12 See paragraphs of the Practice Guidance D.23 & B.45 The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Mix of Uses

6.11 The table below sets out the mix of uses in Gloucester City Centre:

Operator type No. of units % of units Floor space % of total (sq.ft) (Floorspace) Convenience Goods 34 6.42% 190,400 11.80% Comparison Goods 166 31.32% 563,600 34.94%

Retail Services 65 12.26% 83,000 5.15% Leisure Services 103 19.43% 353,500 21.92% Financial and 53 10.00% 124,300 7.71% Business Services Vacant Units 108 20.38% 297,000 18.41%

Figure 7.1: Mix of uses in Gloucester City Centre Source: Goad Category Report (26/03/2012)

6.12 There are a total of 530 commercial units in Gloucester City Centre with a total of approximately 149,843 sq.m of floorspace. The following paragraphs describe the table in more detail.

Convenience Goods

6.13 The UK national average for convenience retail units within town and city centres is 9.34%, which is nearly 3% higher than Gloucester City Centre. This demonstrates that the centre is not reliant on its convenience retail offer. Despite this, the following national multiples are represented:

• Sainsbury’s • Marks and Spencer • Iceland • Tesco (Express)

Comparison Goods

6.14 The 106 units in the city centre used for comparison goods represent 31.32% of the total floorspace. This is lower than the national average of 41.86%. The town centre is however supported by the Gloucester Quay’s Factory Outlet Village, which is within walking distance of the PSA (circa 450m) and comprises approximately 20,000 sq.m of comparison retail floorspace. This is not included in the study area used by Experian to survey the centre.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.15 Further to this, the forthcoming development of the bus station and market parade at Kings Quarter to provide a series of high quality retail units with a total floorspace of 18,500 sq. m will have a positive impact on the City’s comparison goods offer and is likely to increase the proportion of comparison goods retail floorspace in the town centre. It is expected that the development will attract a number of high quality fashion retailers, which the Council hope will have a positive impact on footfall and attracting other unrepresented retailers to Gloucester to other City Centre areas, not just in Kings Quarter.

Services (Retail, Leisure and Financial & Business)

6.16 There is a significant amount of floorspace in the centre dedicated to services. The average for these uses in UK towns and cities is 34.74% which is below the rate for Gloucester (41.89%). This figure is partly due to the GL1 Leisure Centre, which is located to the south-east of the city centre and covers around 8,000 sq.m of floorspace.

Vacant units

6.17 The rate of vacant units in the City Centre is 20.38%. When compared with the national average of 12.87%, it is clear that Gloucester has a significant number of empty outlets compared with other towns and cities. The vacant units range from 20 sq.m to 2,590 sq.m, with an average of 259 sq.m. The vacancies are scattered across the City Centre, however, there are some clusters, which are discussed in the following paragraphs.

6.18 A cluster of vacant units currently exists on Worcester Street and Black Dog Way, with the largest being the former Kwik Save unit and Conway House, which are considered above in the Sequential Assessment. As stated above, both units have planning permission to return them to beneficial use as offices and apartments, when these permissions are fully implemented this will increase footfall and activity in the immediate area and may enable some of the other vacant units to become re-occupied.

6.19 There is a further cluster of vacant units in Eastgate Shopping Centre along Bell Walk. The vacancies are located in close proximity to the former Marks and Spencer store on Southgate Street and their new premises on Eastgate Street. The new Marks and Spencer store, which benefitted from significant works prior to the retailer opening the store, is expected to have a positive impact on the entire centre.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.20 It is worth noting that at the time of the survey the former Woolworths on Eastgate Street was vacant and undergoing works in order to become occupied by Marks and Spencer. The move by Marks & Spencer left two other large City Centre units vacant. However, B&M Bargains will occupy the Northgate Street and an announcement is expected on the Southgate Street unit imminently. Overall, once the moves are complete and all stores are trading this will have a positive impact on the rate of vacant floorspace.

6.21 As stated above, the completion of the retail-led Kings Quarter scheme is expected to have a positive impact on the retail offer in the City Centre, for example, by increasing operator demand resulting in a reduction in the number of vacant units. The various City Centre regeneration schemes currently underway in Gloucester are expected to increase footfall to the centre and in the medium/long-term we expect the City’s vacancy rate to begin falling closer to the national average.

Primary Shopping Area (PSA)

6.22 The Local Plan Proposals Map sets out the boundary for the PSA. The PSA is the retail core of any town or city centre. The following paragraphs describe the Gloucester City Centre PSA in more detail.

6.23 The total amount of floorspace in the PSA is 78,610 sq.m which is comprised by 317 units. These units are predominantly retail units operating within Use Classes A1 – A5, the vast majority of which are Class A1 retail units. The average unit size in the PSA is 248 sq.m.

6.24 There are a total of approximately 300 Class A1 – A5 retail units in the PSA totalling 74,170 sq.m of floorspace. When looking specifically at Class A1 retail, the total is 240 units and the floorspace totals 59,230 sq.m.

6.25 The vacancy rates for the PSA are as follows:

• Units 18.6% • Floorspace 14.5%

6.26 The vacancy rates set out above show a lower level of retail vacancy in the PSA compared to the wider survey area employed by Experian. The vacancy rate is reduced by almost 4% when the PSA is compared to the city centre boundary as defined by Experian. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Impact on Investment

6.27 As set out above, the first of the two impact considerations stated at paragraph 26 of the NPPF requires applicants to assess the impact of a proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal. We provide commentary on this below.

Gloucester City Centre

6.28 The assessment considers the following schemes:

• The Kings Quarter • Greater Blackfriars • Greyfriars

6.29 We are not aware of any current planning applications for retail development that are being considered by the Council.

The Kings Quarter

6.30 We understand that the Council’s principal consideration in terms of impact is the Kings Quarter scheme.

6.31 There are no formal planning applications that have been made in respect of Kings Quarter. We understand that the Council will sign a development agreement for the scheme on 30 September 2012 and that a planning application is expected around the end of 2012 or the first part of 2013. The Kinqs Quarter Planning Concept Statement and Policy CA20 of the draft CAAP provide the policy framework. Policy CA20 allocates the wider area for major new comparison goods retail development as part of a mixed-use scheme to also include commercial, leisure, residential, offices and a replacement bus station.

6.32 We understand that there is a mix of ownerships with the key landowners being the Council and Aviva. We also understand that Stanhope PLC are the appointed development partner for the site.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.33 A recent consideration for the above stakeholders was planning application reference 11/01292/FUL, which is referred to above in the Sequential Assessment. The application was made by Peel and sought approval for 5,292sq.m (gross) open A1 non-food retail floorspace to replace the Cineworld at the Peel Centre on St. Ann Way. The description of the development as shown on the permission is: ‘Alterations to and change of use of existing cinema building to retail use (class A1), erection of extension to building for retail use (class A1), and associated alterations to parking and servicing arrangements, landscaping and public realm works’.

6.34 The Peel proposal sought to provide a series of retail units ranging from 697 sq.m to 1,045 sq.m, which could be used for the sale of any goods excluding food. We understand that the Kings Quarter development seeks to provide a total of 18,500 sq.m (gross) comprising five medium sized units ranging between 1,300 sq.m and 4,645 sq.m and 21 smaller units ranging between 93 sq.m and 836 sq.m13.

6.35 A concern for stakeholders was that the development would cause potential retailers to locate to the Peel Centre as an alternative. On this basis, various representations were made throughout the application process detailing how the Peel proposal would cause significant harm to the deliverability of the Kings Quarter scheme. As referred to in the Sequential Assessment, in response to the representations the applicants planning consultants WYG issued correspondence which set out a list of potential tenants for Kings Quarter. The list was produced by Jones Lang LaSalle and set out over 90 retailers whom they considered could locate to Kings Quarter, it included the following retailers:

• Hollister • Superdry • Monsoon • TM Lewin • All Saints • Mango • Bench • Fossil • Radley • Jack Wills • Accessorize • Gant • Sole • Zara • Kurt Geiger • Levis • North Face • Karen Millen • Moss • Aspecto • Oasis • Reiss • Fat Face • The Kooples

6.36 It is notable that the target list is comprised by generally high end fashion retailers not currently registered in Gloucester. Home Bargains or other discount variety retailers are absent. We

13 Paragraph 6.9 of Appraisal of Planning Application No. 11/01292/FUL - report reference: DJ/DM/C10177 produced by DPDS Consulting, dated February 2012. The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

consider that a scheme with potential to attract the types of retailers as referred to in the above list could not realistically be harmed by a discount variety retailer operating from a 1,115 sq.m unit at the application site. In light of the above, we consider that the proposal will not have a significant adverse impact upon the deliverability of the scheme, as the retail offers will be complementary and will not compete directly with each other.

Greater Blackfriars and Greyfriars

6.37 The specific sites earmarked for retail development in the Draft CAAP and their respective SPDs are set out below, and considered in the following paragraphs:

• Greater Blackfriars – The Fleece Hotel • Greyfriars – Bowling Green and Indoor Market

6.38 As set out above in the Sequential Assessment, the above sites are not suitable to accommodate the proposal. The redevelopment of these sites will deliver very different retail destinations to the application site and will therefore not compete directly.

6.39 In the case of the Fleece Hotel, policy is seeking a development to provide small-scale specialist retail units within the setting of a 12th Century hotel building. For the reasons described above in relation to Kings Quarter, the proposed goods restriction at the application site would prevent any potential Fleece Hotel retailers from locating to the application site as an alternative. It follows that the proposal could not prejudice the deliverability of the scheme.

6.40 With regards to the Bowling Green and Indoor Market sites at Greyfriars, policy is seeking a development that complements and creates space for Blackfriars Priory. Public space and the character of the area are integral part of the policy aspirations for the whole area. For this reason the Sequential Assessment concluded that the proposed development was contrary to policy objectives for this site and therefore it is not a suitable location for the proposal.

6.41 For the same reasons as for the Fleece Hotel, we consider that the proposal will not harm the deliverability of a scheme that seeks to deliver a very different retail experience. The two retail offers will be complementary.

6.42 In light of the above, our overall conclusion is that the proposal will not have a significant adverse impact on existing, committed and planned public and private in centre investments.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

Impact on Vitality and Viability

6.43 As set out earlier in the Statement, the business concept and overall product range of Home Bargains is focused on goods to be provided for the household. The ethos of a discount variety store is to sell goods at a discounted rate. There is a limited, ancillary element of food and drink sold (no more than 30% of the sales area). The inclusion of a limited range of food and drink is directly linked to a shop for homewares and household goods. Accordingly, this means that Home Bargains’ direct competitors are large format national multiple superstores (such as Tesco). This is particularly the case with the food goods sold, which are principally tinned goods, condiments, pet food and multi-packs of packaged dried goods (e.g. crisps, chocolate bars etc).

6.44 We have undertaken an assessment of the potential trade draw of the proposal on Gloucester City Centre, the findings of which are set out in the following paragraphs.

6.45 The below table sets out the predicted uplift in turnover as a result of the proposal:

Gross Net Goods Use Sales Density Turnover Floorspace Floorspace Options (£/sq.m) (£m) (sq.m) (sq.m)

Existing 1,115 892 3,000 2.68 (Bulky)

Open A1 (non-food) 1,115 892 4,000 3.57

Home Bargains 1,115 892 4,000 3.57 (including 30% food)

Figure 7.2: Uplift in turnover Source: Sales densities are Savills Estimates (2012) Net floorspace is forecast to be 80% of gross

6.46 The table shows:

• The estimated turnover of the unit if occupied in accordance with the current (bulky) goods restriction is £2.68m. • There is an estimated uplift of approximately £0.89m to £3.57m if the goods restriction was widened to permit a Home Bargains store.

6.47 Although the proposal represents an uplift in turnover of just £0.89m, we have also considered the The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

trade draw of the full £3.57m potential turnover for the site. However, it is important to note that it is a material consideration that the application site is an existing, established retail destination that has the potential to trade at a level that is less than £1m per annum below the trading level forecast by the application.

6.48 The turnover figures in relation to the comparison goods assessment below were quoted in application reference 11/01292/FUL, which has recently been considered and supported by the Council. We have used figures quoted in Table 15.d of the Statistical Tables included at Appendix F of the PPS4 Retail Statement prepared by White Young Green which was submitted with the application in order to assess the likely trade draw impacts of the proposal.

6.49 The Council’s consultants, DPDS, who reviewed the evidence, stated:

‘WYG’s estimate of the town centre turnover is £363.9m in 2011, increasing to £421.4m in 2016 on the basis of a constant market share. Adjusted to 2009 prices this would be £408.2m. We have noted earlier that the expenditure per head figures quoted by WYG are significantly higher than those we obtained from Experian. Allowing for this, WYG’s estimate of town centre turnover may not be that far adrift from the estimate of £371m (£383.4m in 2010 prices) we made in relation to the recent Oswalds application by Tesco, or indeed DPP’s estimate of £366m. In our view the primary cause for the difference is likely to be difference in figures of local expenditure supplied by Experian.’

6.50 It follows that on the basis of the above, the use of the WYG data prepared in support of planning application: 11/01292/FUL, is considered to be robust.

6.51 As the proposal seeks approval for a wider non-food product range to be sold from the site (i.e. comparison goods), and an ancillary food and drink range (i.e. convenience goods), we have considered the trade draw impacts separately.

6.52 As set out above, the total turnover of the store is forecast to be £3.57m. The sales area dedicated to the sale of ancillary food and drinks goods is 30%. Accordingly, the forecast turnovers for the non-food element of the proposal is considered to be £2.49m (i.e. 70% of the turnover) and the food element £1.07m (i.e. 30% of the turnover).

Non-Food Trade Draw

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.53 The non-food trade draw is set out below in Figure 7.3.

Home Bargains Non-Food Turnover 2.5 (£m) (A) Trade Draw Survey Total Total Derived Survey Survey Turnover at Derived Derived 2016 Impact Store(s) / Centre Turnover Turnover % £ following (%) 2011 2016 the (£m) (£m) Proposal (£m) E = A G = E / B C D F = C - E x D C Gloucester City Centre 363.9 421.4 25% 0.63 420.78 0.1% Gloucester Quays Outlet 17.5 20.2 10% 0.25 19.95 1.2% St Oswalds Retail Park 45.9 53.2 10% 0.25 52.95 0.5% Eastern Avenue Retail Park 71.5 82.8 15% 0.38 82.43 0.5% Peel Centre 16.1 18.6 10% 0.25 18.35 1.3% Quedgeley District Centre 17.3 20.1 5% 0.13 19.98 0.6% Other 30.4 35.2 25% 0.63 34.58 1.8% Total 562.6 651.5 100% 2.50 649.00 0.4%

Figure 7.3: Total non-food trade draw Source: Store(s)/centre turnovers are taken from Table 15.d of the Statistical Tables included at Appendix F of the PPS4 Retail Statement planning permission 11/01292/FUL.

6.54 The table shows that the majority of the trade draw will come from Gloucester City Centre. We expect Home Bargains to compete primarily with other discount variety retailers and the City Centre currently accommodates the only other stores. The impact, however, equates to only 0.1% due to the overall strength of the city centre turnover. As such, the impact on the City Centre is not significantly adverse, resulting in an estimated £0.62m decrease in turnover at 2016.

6.55 It is also worth noting that under the current planning permission a retail operation generating a non-food turnover of £2.68m per annum could be achieved. Therefore, the impacts will be significantly less than those stated above, because trade draw from the above destinations can already under the existing permission. Further to this, the proposal will represent a decrease in non-food turnover by £0.18m. It follows that the proposal could result in an increase in non-food spending that could be spent within defined retail centres, than if a retailer operated from the unit under the existing permission.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.56 In addition, as set out above in Section 4 ‘Home Bargains’ the retailer’s main competitors are typically superstores, the majority of which are not located within defined retail centres in Gloucester. Impact on these retailers is not a planning policy concern.

6.57 As described above, planning permission: 11/01292/FUL was recently granted for a significantly larger non-food retail development at The Peel Centre on St. Ann Way. In consideration of the proposal it was concluded that the store would not to have a significant adverse impact in terms of trade draw from the City Centre.

6.58 In light of the conclusions made by the Council in relation to the much larger planning application, we consider that the proposed Home Bargains at the application site could also not be considered to have a significant adverse impact on City Centre trade draw. The overall conclusion is that the proposal will not have a significant adverse impact on the vitality and viability of non-food retailers in any defined retail centre in Gloucester.

Food Trade Draw

6.59 The proposal is only for a small amount of ancillary food and drink goods amounting to approximately 268sq.m. This element of the floorspace will only turnover just over £1m. For the reasons set out above, the significant element of this trade will come directly from superstore retailers. Such retailers are principally not located with defined retail centres and accordingly, the impact on these stores is not a planning policy concern.

6.60 In any event, such a small level of trade draw from these retailers which turnover over tens of millions of pounds from their food retail product range will be imperceptible and cannot be considered to have anywhere near a significant adverse impact on their trading operations.

6.61 Our conclusion in terms of trade draw impacts on food retail is that it cannot be asserted that the proposal will not have a significant adverse impact on the vitality and viability of the food retail offer of Gloucester City Centre.

Economic Benefits

6.62 The proposal will have overall positive economic benefits to Gloucester, which significantly outweigh the low level of impact the proposal could have on the City Centre.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

6.63 By returning a long-standing a vacant unit back into an economically viable use, the proposed development will generate approximately 40 employment positions at the application site. These positions will be a mix of full and part time opportunities and at a range of levels of skill and seniority.

6.64 Bringing existing sites back into an economically viable use is an integral part of the objectives of national planning policy to achieve more sustainable forms of development. Development of an alternative site may require demolition or construction works, when considering that the application site provides a retail unit ready for occupation, it is clear that such works are not necessary.

6.65 Further to this, the proposal will ensure that a national multiple retailer invests in Gloucester, which will enhance consumer choice and competition. This also demonstrates investor confidence in the city, which could assist in attracting additional retailers or secure private investment within the city.

Conclusion

6.66 In light of all of the evidence provided above, our overall conclusion is that the proposal will not have a significant adverse impact on existing, committed and planned public and private in centre investments nor will the impact on the vitality and viability on Gloucester City Centre be significantly adverse. As such, we conclude that the proposal accords with paragraphs 26 and 27 of the NPPF and therefore should not be refused on impact grounds.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

7.0 CONCLUSION

7.1 This report has assessed the proposal to vary Condition 9 attached to planning permission: 98/0019/FUL, which limits the range of goods that can be sold at the site, against the relevant development management policies contained in national policy guidance relating to retail developments (NPPF) and the most relevant retail and town centre policies in the development plan.

7.2 The main conclusions of the report in relation to the NPPF and the Local Plan are that:

1 The application site is the most sequentially preferable site for the proposed development and therefore, the proposal accords with Paragraph 24 of the NPPF. The application site is an established retail destination for large format stores which is considered appropriate for the scale of the proposed development. There are no available, suitable or viable sites in the City Centre that could accommodate the proposed development.

2 There is no clear evidence of a significant adverse impact on existing, committed and planned public and private investment in a centre or centres in the City of Gloucester. This includes the Kings Quarter scheme which could not accommodate the proposal primarily on suitability grounds, nor will its deliverability be impacted adversely by the proposal due to the difference in retail offer of the two schemes.

3 The uplift in the turnover of the floorspace at the application site is estimated to be just £0.89m.

4 The proposal will fill a long standing vacant unit in accordance with key objectives to deliver economic growth. Further to this, there are a number of economic benefits including the creation of a number of employment positions at a range of levels.

7.3 Overall there is a strong case to support the relaxation of existing use restrictions at Unit 2b 108 Eastern Avenue on retail grounds, even before benefits such as improved consumer choice, investment in Gloucester and job creation are taken into account.

The Pensions Trust Former Apollo 2000 Store, Unit 2b 108 Eastern Avenue, Gloucester Retail Statement savills.com/planning

APPENDICIES

Appendix 1 - Plan Reference 02 – Indicative Proposed Floor Plan

General Notes 1. Contractors to advise on all details and to ensure structural stability and strength of all construction. 2. Contractors to ensure that all specified materials are applied and installed as per manufacturers recommendations; Contractor is responsible for obtaining all installation data and related information. 3. Contractors to ensure that all services comply with local authorities, Building Regulations, Environmental Health requirements Planning Regulations and CDM. 4. Contractor to check on delivery times and specified materials and fittings to meet programme and place orders for special items prior to construction. If necessary, Designers and Clients to be advised of any problems in sufficient time to specify alternatives. 5. All construction materials to comply with current fire regulations. Copyright: This document and all information contained herein is the sole property of CB Richard Ellis, reproduction in any form is strictly forbidden unless permission in writing is obtained. Warning: All contractors must visit site and will be responsible for taking and checking all dimensions and conditions related to this work. Designer must be advised of any discrepancies in writing. This document is to be read in conjunction with the specification, bill of schedules and other related drawings where applicable.

paving

rwp Palisade DIS. fencing WC

MALE STORE

FEMALE OFFICE rwp

OFFICE

KITCHEN / STAFF ROOM STORE

Stairs to mezzanine up floor over kitchen and WC area Automatic Automatic ramp down RETAIL AREA 1 doors doors 15053.8sq ft bollards Gas meter

Partition part height Elect

Palisade 11285 fencing

STORE

rwp rwp bollards RETAIL AREA 2b 12000sq. ft 27218 Stone up boundary wall

Canopy over rwp

40960 ramp down Automatic doors Security screen Rev. Amendment Init. Date

SERVICE rwp YARD Client PENSIONS TRUST

bollards

Lamp Project standard Canopy over rwp UNITS 1, 2 & 2a 108 EASTERN AVENUE RETAIL AREA 2a Gloucester

Palisade fencing and Elect gates Title Disabled

BT incoming Kitchen Gas rwp meter rwp PROPOSED FLOOR PLAN bollard

Street sign Cycle parking

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Howard House Queens Avenue Clifton Bristol BS8 1QT Tel: 0117 943 5757 Fax: 0117 943 5756 Date Scale Dec. 2011 1:200 @ A1

Drawn Checked

Drawing No Revision 02