Appeal Ref: APP/U1620/A/14/2214917

Units 3a & 3b, Peel Centre, St Ann Way, Gloucester

Proof of Evidence of Robin Denness FRICS on behalf of Peel Land & Property Investments Plc & Gloucester Quays LLP

August 2014 Proof of Evidence of Robin Denness 30 July 2014

Contents

1 Experience & Qualifications ...... 2 2 Introduction...... 4 3 Gloucester...... 5 4 Retail Provision within Gloucester City Centre...... 6 5 Retail Provision within the Region...... 7 6 Gloucester Rental Values Profile ...... 8 7 Kings Quarter - The Background and History...... 9 8 My previous involvement in the Kings Quarter Regeneration Proposals ...... 12 9 Current Proposals for Kings Quarter...... 14 10 Kings Quarter Suitability For Home Bargains...... 19 11 Conclusion ...... 21

Appendices

A Goad plan showing the extent of retail provision in Gloucester City Centre B Goad plan showing JLL view of the prime retail locations in the City Centre C Plan of the proposed City Centre boundary D Colliers International Gloucester Zone A rent profile E JLL Gloucester / Cheltenham Zone A rent profile F JLL Zone A rent / Milestone event graph G Stanhope Vision submission plans for Kings Quarter (June 2011) H Press commentary extracts from: i) shopping centre magazine ii) BBC news iii) Gloucester Citizen iv) Punchline v) Career Structure I Gloucester City Council Action Plan (December 2012) J JLL correspondence with major retailers K Stanhope Kings Quarter plan (May 2014) L Plans: i) Thornfield plans (November 2009) ii) Hammerson plans (April 2010) iii) Stanhope Vision plans (June 2011) iv) Stanhope plan (February 2013) v) Stanhope plan (May 2014) M Thornfield plans (November 2009) / Hammerson plans (April 2010) N Gloucester City Council OJEU Invitation (February 2009) O Correspondence between Home Bargains and Stanhope’s agents regarding Hereford

1 Experience & Qualifications

1.1 My full name is Robin Murray Denness. I am a Director within the National Retail Team of Jones Lang LaSalle (JLL), 30 Warwick Street, London, W1B 5NH. I have over 30 years' relevant experience within the retail development sector having specialised in the regeneration and development of town centre schemes. I am a Fellow of the Royal Institution of Chartered Surveyors.

1.2 Prior to the amalgamation of Jones Lang LaSalle and King Sturge I was a partner of Churston Heard for seven years, responsible for town centre and high street development (2001-2008). Previously, I was a Director of Lambert Smith Hampton (1995-2001) following the takeover of Connell Wilson, where I was a Director (1989- 1995). Prior to this I was a Partner of Shearer Harris & Partners (1980-1989) and Conrad Ritblat & Company (1971-1982). My involvement with town centre development commenced during my employment with Conrad Ritblat & Company.

1.3 My knowledge of Gloucester and the surrounding region dates back as far as the early 1970s when I dealt with retail agency matters in the South-West of England and South Wales, at Conrad Ritblat & Company. I was responsible for both the acquisition and disposal of retail properties, together with the negotiations of rent reviews and lease renewals, on behalf of both landlords and tenants. These retail agency instructions included properties in Eastgate Street, King’s Walk, Eastgate Centre, Northgate Street, The Oxbode and Market Parade. I also was retained as property advisor to local retail companies, who were active at that time, these being EM Merrett & Co and Peter Richards / Crisco Carpets.

1.4 For the past six years (2009-present), I have been on part-time secondment to Land Securities where I advise The Harvest Partnership a 50/50 joint venture between Land Securities and Sainsbury’s which specialises in the redevelopment of jointly owned assets and the identification of new development opportunities to provide mixed use schemes including a foodstore for Sainsbury’s together with supporting retail, leisure or residential uses. Current and completed schemes include Lindis Park, Lincoln, Garratt Lane, Wandsworth and Selly Oak, Birmingham whilst several additional new developments are well advanced.

1.5 I specialise in advising private developers and property companies in the identification, design, occupier demand and viability of town centre schemes and, during my career, I have been directly involved in the provision of over 2.5 million ft2 of shopping centre floorspace in town and city centre locations. This has included both new schemes and the refurbishment and reconfiguration of existing ownerships. This has involved locations throughout the UK including Chesterfield, Oxford, Shrewsbury, Dundee and Stockton on Tees.

1.6 Most recently, I have been involved throughout the delivery process of Fremlin Walk in Maidstone 32,515 m2 (350,000 ft2) which opened in March 2005, Arc in Bury St Edmunds 24,155 m2 (260,000 ft2) which opened in March 2009, and Parkway in Newbury 26,012 m2 (280,000 ft2) which opened in October 2011. I am currently advising Centros who have been appointed by Lancaster City Council to undertake Castle View, a mixed use development within the City Centre and where a revised planning application for a scheme of 34,374 m2 (370,000 ft2) is in preparation. My clients include Land Securities, Standard Life, Peel Holdings, Centros, Shearer Property Group, BAM and Ignis.

1.7 I am instructed by Peel Land & Property Investment Plc and Gloucester Quays LLP in respect of Units 3A and 3B, The Peel Centre, St Ann Way, Gloucester GL1 5SF. Reference 13/00559/FUL.

1.8 Declaration:

i) I confirm that my report has drawn attention to all material facts which are relevant and have affected my professional opinion.

ii) I confirm that I understand and have complied with my duty to the Inquiry as an expert witness which overrides any duty to those instructing or paying me, that I have given my evidence impartially and objectively, and that I will continue to comply with that duty as required.

iii) I confirm that I am not instructed under any conditional or other success-based fee arrangement.

iv) I confirm that I have no conflicts of interest.

v) I confirm that I am aware of and have complied with the requirements of the rules, protocols and directions of the Planning Inquiry.

vi) I confirm that my report complies with the requirements of the RICS - Royal Institution of Chartered Surveyors, as set down in the RICS practical statement Surveyors acting as expert witnesses.

2 Introduction

2.1 Peel Land and Property Investments Plc are the freehold owners of The Peel Centre, Gloucester

2.2 My colleague, Nick Seary, will describe his long-standing involvement on behalf of Peel Land & Property Investments Plc in the marketing of available accommodation in The Peel Centre. He will, also, provide a commentary on the current provision of Retail Park accommodation in Gloucester and within the wider region.

2.3 This Proof describes the current retail provision in Gloucester City Centre and other main Centres in the sub- region, a summary of previous and prevailing rental evidence, the history of proposals for redevelopment of Blackfriars and Kings Quarter, together with a description of my prior involvement in the Kings Quarter regeneration proposals on behalf of Thornfield Properties and Hammerson.

2.4 Finally, I will comment on the much reduced scheme now proposed by Stanhope Plc based on the plans and information we have been able to secure. This will include an explanation of how the scheme has substantially changed in the time since their bid document was drawn up as the basis for them to secure development partner status and an assessment of scheme progress relative to the delivery programme milestones set out in the Kings Quarter Action Plan (December 2012) and which I will refer to later within this Proof.

3 Gloucester

3.1 The cathedral city of Gloucester is the second largest in the county, having an estimated population of 121,700 (Source: Census 2011).

3.2 Gloucester is located 32 miles north-east of Bristol and approximately 7 miles from Cheltenham. Junctions 11/11A and 12 of the M5 motorway to the east provides easy access north/south to Worcester/Bristol, whilst the A40 offers an easy dual carriageway link to Cheltenham. The major shopping destinations within the wider region are Hereford (32 miles) to the west, Worcester (29 miles) to the north, Bristol (36 miles) to the south, and Oxford (48 miles) to the east.

3.3 Gloucester Station provides services to London, Reading, Bristol and Cardiff, with the station being conveniently located close to the City Centre.

3.4 The city has a long history with the aerospace industry and is home to Cheltenham & Gloucester (a subsidiary of Lloyds TSB), and Ecclesiastical Insurance. Other major employers within the local economy include Messier-Bugatti-Dowty, Stagecoach West and Gloucestershire County Council.

4 Retail Provision within Gloucester City Centre

4.1 The shopping provision in the City Centre covers a wide area based on the four historic streets still referred to by the Middle-English word for Street: gate. They are collectively known as the “Gates”. More recent developments have provided enclosed shopping facilities within the Eastgate Centre and Kings Walk.

4.2 The estimated retail floorspace within the City Centre is 109,260 m2 (1,176,075 ft2) (Source: Goad plans 2014). I attach in Appendix A a Goad plan showing the extent of the shopping provision within Gloucester.

4.3 In my opinion and distinct from any reference by Mr Hutton to the retail core in planning terms it is my opinion, from a long-standing knowledge of Gloucester City Centre, that the prime retail core is concentrated on Eastgate Street (between The Cross and Kings Walk) and within Kings Walk from Eastgate Street to Kings Square. Within these locations a large majority of the major multiple companies represented in Gloucester are situated, which include Marks & Spencer, Bhs, Boots, Primark, H&M, Topshop, Waterstones, River Island and WH Smith. I attach in Appendix B a Goad plan identifying the prime retail core and the major multiple occupiers with ground floor footprints in excess of 500 m2.

4.4 The other “Gates” are varied in their retail strength and customer attraction. Northgate Street, historically a strong location, has lost Marks & Spencer (following their consolidation into a single store in Eastgate Street), Retailers within the lower section of Northgate Street includes Sports Direct, Peacocks and Bonmarché all being “value” retailers. The presence of Debenhams is of major benefit to Northgate Street, although their main entrance and frontage faces Kings Square. The upper section of Northgate Street houses a Wilkinsons and small Sainsbury’s store,

4.5 Southgate Street is a secondary location but benefits from an entrance to the Eastgate Centre and, more recently, is now on the main pedestrian route from the City Centre to Gloucester Quays Outlet (GQ Outlet). This route has benefitted from recent and extensive public realm improvements to encourage pedestrian movements between the City Centre and GQ Outlet. From my observations during visits to the city, this route is reasonably well used and the improvements have, therefore, been successful. In my opinion there is scope for additional linked trips to the City Centre and GQ Outlet to result from the regeneration of The Peel Centre and its location immediately adjoining the proposed boundary of the City Centre.

4.6 Westgate Street is a secondary street with a mix of retail and non-retail uses, but is on a route to Gloucester Cathedral, with access via College Street.

4.7 The Eastgate Shopping Centre opened in 1973 creating a link between Eastgate Street and Southgate Street, and providing an enclosed shopping environment with an overall area of approximately 23,226 m2 (250,000 ft2). The scheme provides accommodation on two levels with car parking above for 370 vehicles. In addition to an enclosed Market Hall there are some 32 shop units at ground floor level with a variety of multiple and independent retailers, and occupiers include H&M, Blue Inc, Specsavers and Poundland.

4.8 Kings Walk Shopping Centre opened in 1972 creating a covered pedestrian route from Eastgate Street, to the newly created Kings Square. The scheme consists of approximately 11,613 m2 (125,000 ft2) of single level retail floorspace with car parking above for 293 vehicles. Retailers represented include Primark, Superdrug, River Island and Greggs.

4.9 Within the proposed City Centre Boundary (as defined by the Draft City Plan - Strategy Consultation, May 2013) at its southern end, GQ Outlet forms a more recent retail and leisure addition which is a major tourist attraction and destination within the City Centre. I attach in Appendix C a plan extract defining the proposed City Centre boundary. The emerging Joint Core Strategy confirms that GQ attracts significant levels of expenditure for local clothing (Source: Household Survey). The pedestrian and public realm improvements referred to in paragraph 4.5 have been added since the construction of GQ Outlet to ensure the City Centre as a whole gains maximum benefit from the visitors and tourists which Gloucester Quays attracts.

5 Retail Provision within the Region

5.1 In addition to the shopping provision within Gloucester City Centre additional facilities are available at Quedgeley District Centre and Abbeydale District Centre. These Centres both have a major foodstore provision (Tesco at Quedgeley and Morrisons at Abbeydale), and the supporting retail and other uses serve the immediate residential catchments, rather than compete with the City Centre.

5.2 Within the sub-region, Stroud and Tewkesbury both provide shopping facilities of a modest scale which serve their immediate catchments. Further afield, although with excellent access from Gloucester via the M5 motorway, The Mall at Cribbs Causeway is only approximately 40 minutes’ drive to the south. The Mall is a major regional shopping centre providing 92,436 m2 (994,981 ft2) comprising 135 stores, cinema and associated leisure, together with 7,000 car parking spaces.

5.3 The major competing retail centre within the region is Cheltenham, due to its very close proximity, ease of access and a diverse offer of retail and complimentary uses.

5.4 Cheltenham Town Centre has an estimated retail floorspace of some 141,000 m2 (1,517,724 ft2) and in addition has further retail provision at Montpellier, Bath Road District Centre and Coronation Square District Centre.

5.5 There are plans to further enhance the town centre retail provision with the proposed redevelopment of 233-269 High Street to form Phase II of The Brewery. This is currently planned to start on site during 2014. The proposed scheme will consist of some 9,290 m2 (100,000 ft2) of retail floorspace together with a 104 bed hotel and 34 town centre apartments above the retail units.

6 Gloucester Rental Values Profile

6.1 In common with the general retail town centre sector, rental values in Gloucester City centre showed consistent growth during 2000 onwards,

6.2 Whilst retail rent studies concentrating on Gloucester City centre show differing values this disparity is not significant and is often based on a single, or limited number of transactions, and differing bases of analysis. In general there is broad agreement that, in common with the national trend, the peak Zone A value was achieved in 2007/8 just before the turmoil that engulfed the financial sector in the Autumn of 2007 and which resulted in the general recession of 2008.

6.3 The subsequent resultant correction in rental values has been evident in Gloucester where a substantial reduction has taken place, with occupier demand now less focussed on branch expansion as multi-channel and, more recently, Omni-channel retailing increases. Retailers such as Next and John Lewis have been pioneers of these changes where seamless approaches are provided to consumers through various channels including retail stores, online stores, mobile internet devices, direct mail, mobile App stores etc. All shopping channels work from the same database of products, prices etc and the brick and mortar stores become an extension of this supply chain. Whilst this has had a dramatic effect on certain retailers such as HMV and Jessops, others particularly within the fashion sector, have successfully embraced this technology and still trade successfully in the traditional manner.

6.4 In considering current rental values the DPDS Joint Core Strategy Retail Study 2011/2013 Phase (December 2011) comments on the rental trends from 2008/9 (the peak value) and acknowledges a marked reduction in prime Zone A rent has occurred over recent years. No indication is provided on estimated prevailing values at that time.

6.5 Colliers International Prime In Town Retail Rents Study (2013) shows values between 1987 (£65) to 2013 (£90) with the peak reached in 2007/8 (£145). This is attached in Appendix D.

6.6 The internal research undertaken by JLL tracking both Gloucester and Cheltenham town centre retail values shows similar levels to Colliers with a peak achieved during 2006 (£145) and a current tone of £80. This is attached in Appendix E.

6.7 The conclusion when taking into account current availability, modest demand and reduced rental values is that a new shopping centre of sufficient scale, built quality and tenant attraction is extremely difficult to deliver on a viable basis. This is taking into account the Council’s requirements when appointing Stanhope that the development will be transformational, deliverable and result in a significant improvement in the performance and retail ranking of Gloucester City Centre. The current proposals now accommodate only a single anchor store, of modest size, involving, I understand, the relocation of an existing retailer within the city. In addition the reduced number of shop units and sizes, together with non-retail uses such as cinema, residential etc illustrate that the city’s existing retail offer deals, fairly adequately, with current demand.

6.8 I attach in Appendix F my estimation of the Zone A “tone” in Gloucester City Centre at the time of key milestone events in the Kings Quarter process over the last 8 years. This illustrates the challenge to viability presented by declining rental values in the City. My conclusion is that, despite the considerable efforts of the Council, there has been no clear demonstration that the aspirations in the Vision will be delivered. This view is supported by the frequent re-designs, reducing retail scale and changing mix of uses.

6.9 When rental values were at their peak resulting in favourable conditions that saw other town centre schemes being undertaken it would be expected that, at that time, a viable development might have been possible. It is difficult to see how it may now be reasonably expected to be implemented with the rental tone substantially below peak values and expected to remain so.

7 Kings Quarter - The Background and History

7.1 The desire to improve the shopping facilities within Gloucester City Centre is long-standing and alternative proposals to Kings Quarter were pursued previously elsewhere within the Centre. The Council’s original proposal for improved shopping facilities identified the Blackfriars area as the preferred location. This site is located to the rear of Southgate / Westgate Streets, and was initially partially cleared in the 1970s for future comprehensive development.

7.2 Following initial proposals which included new public buildings including Magistrates Court etc, Arrowcroft Plc were appointed Development Partner for Blackfriars, my recollection being that this was during the mid / late 1980s.

7.3 In April 1990 Arrowcroft secured planning permission for a £60 million / 17,170 m2 (185,000 ft2) shopping development, comprising up to 100 shops, a department store and 900 car parking spaces. The original anchor tenant was Marks & Spencer, who withdrew in 1998 and were replaced by the department store, Beatties.

7.4 Subsequently, as I recall, Beatties withdrew and an alternative smaller scheme was proposed comprising retail, offices, a multiplex cinema, housing and car parking for 674 vehicles.

7.5 The proposals for the site required compulsory purchase to enable complete site assembly, and British Telecom Plc and Bloomsbury Land Investments both objected to the requisite Order. The High Court upheld their objections in 2002.

7.6 The failure of the Blackfriars’ proposals resulted in the subsequent Vision and Gloucester Renaissance initiatives.

7.7 The current Vision for Kings Square and Bus Station was outlined in the GHURC Framework prepared by Gloucester Renaissance and Terence O’Rourke (July 2006).

7.8 This envisaged a substantial expansion of City Centre retail floorspace and a significant enhancement in the quality of the shopping area. A total of 35,000 m2 (376,740 ft2) new and replacement retail floorspace was indicated, with a variety of unit shops anchored by a major new department store (of up to 10,000 m2 (107,640 ft2) visible from Kings Square and the ring road. (The Vision paragraph 8.35).

7.9 In February 2007 Gloucester City Council appointed Aviva and Thornfield Properties to formulate proposals for the redevelopment of Kings Square and adjacent properties which would meet the aspirations set out in The Vision document. This appointment reflected the extensive ownerships of Aviva within the Kings Square vicinity and the experience of Thornfield Properties in evaluating and delivering town centre retail schemes of a similar scale. The combination of sustained rental growth and steady demand fuelled an active town centre development market at this time. The subsequent financial crisis and rapidly changing technology resulted in a sharp correction of both rents and demand. This lead to numerous proposed schemes being moth-balled, or abandoned.

7.10 The original joint appointment of Aviva and Thornfield Properties underwent change in February 2009 with the Council advertising a restricted procedure invitation via the OJEU process. I understand this was as a result of Aviva withdrawing from the previous joint appointment but Thornfield Properties, with the Council’s support, continued to progress their proposals.

7.11 Subsequently, with no responses to the OJEU invitation, the Council resolved to appoint Thornfield Properties as their Development Partner on Kings Quarter, but this was pre-empted as a result of Thornfield Properties’ entering Administration in March 2010.

7.12 In April 2010 the Council approached Hammerson to establish whether they would be interested in undertaking the redevelopment of Kings Quarter. Hammerson engaged new consultants and undertook a full appraisal of demand and viability, but advised the Council in July 2010 that, in their view, a viable development was not achievable.

7.13 Following further approaches to potential Development Partners in December 2010 Stanhope Properties were granted a six month exclusivity period to progress design and viability for the Kings Quarter development. This resulted in July 2011 in the Council resolving to appoint Stanhope Properties as its Development Partner subject to full Council approval by the end of December 2011.

7.14 The Council and Stanhope Properties completed a Development Agreement in September 2012, almost two years ago.

7.15 Following their formal appointment in September 2012 there has been intermittent information issued by Stanhope on the progress of the development. During preparation of this Proof a revised plan has been released although with very limited supporting information, whilst there is still no reference to any prospective tenants having been secured. This revised plan appears to be substantially less ambitious than previous iterations of the proposals.

7.16 The Stanhope tender submission document (June 2011) sets out the objectives they intended to satisfy. This would be transformational, ambitious, deliverable and most ultimately result in a noticeable step change in the performance and retail ranking of Gloucester City Centre. Attached in Appendix G are the scheme plans titled as a mixed use retail led development providing additional retail floorspace creating vibrancy and richness. The document also refers to delivering a scheme that addresses “…Gloucester’s considerable gap in the “affordable premium brand” category, which are brands that have a particularly strong desire to locate their shops in very atmospheric surroundings…” Stanhope’s proposals intend to provide accommodation that “…enable them (brand stores) to have a stronger feel of retail “theatre” within the stores…”.

7.17 The retail mix and strategy is clearly set out to increase the quality of the retail offer with important store sizes not currently available and therefore attract new retailers. Suggested larger store tenants for the scheme include John Lewis, House of Fraser, Next, Primark, TK Maxx and Marks & Spencer.

7.18 Within the major brand retailers target occupiers would be large flagship stores from the UK and international fashion brands. Relocations will be facilitated only where an operator’s space is compromised … leading them to consider leaving the town. It continues in Gloucester these potential relocations include Top Shop, Next and River Island. Non-fashion users such as Whole Food Markets and Waitrose are suggested whilst, finally, unit shop tenants proposed include Fat Face, French Connection, All Saints, North Face, Jones, Goldsmiths, and Jack’n Jones, plus Scotts, Footlocker, G Star, La Senza, White Stuff and Lakeland.

7.19 I have continued to monitor the position in the interim and the information has been provided by either the national property journals, or local media. I attach in Appendix H extracts from Shopping Centre Magazine, BBC News, Gloucester Citizen, Punchline and Career Structure reporting the situation.

7.20 The information referred to above has been of a general nature without the benefit of plans, or any precise indication of timing or likely “key” occupiers. The following press comments illustrate the continual changes to the scheme design, proposed range of uses and uncertainty over the timing of key events such as major lettings, submission of a planning application and timescale for delivery. I attach in Appendix I the Gloucester City Council Action Plan from December 2012 and which, in my view, shows little progress since then as the target date for securing planning permission was scheduled for the end of 2013, with a start on site proposed next year (2015). In January 2011 Shopping Centre Magazine reported “…the development could incorporate up to 250,000 ft2…”.

7.21 In September 2012 Career Structure published an article reporting that around 40 new shops including an anchor store were planned and that Construction work is anticipated to start in 2013.

7.22 The same month BBC News Gloucestershire referred to 30 new shops and the signing of the legal agreement between the two parties, but it is not a guarantee the revamp will take place.

7.23 Finally in March 2014 the Gloucester Citizen confirmed that Next and Superdry are among the big firms being eyed up by Stanhope. I have since contacted both these companies and both have confirmed that they are not interested in acquiring representation in the Kings Quarter development. I include in Appendix J correspondence with Next and Superdry, together with other major retailers all of whom, very recently, advised that they have no plans to acquire representation within the proposed Kings Quarter development.

7.24 During the preparation of this Proof (May 2014) a plan has just been released by Stanhope to the local press. This is included in Appendix K. The brief commentary refers to:

* A reduced number of retail units from 30 to 22 to reflect the economy (this coincided with a BBC Business News headline released on the same day confirming UK retail sales growth hit a 10 year high in April 2014).

* City centre living on the upper floors.

* A smaller but streamlined Bus Station.

* Restaurants and a small Cinema.

7.25 The plan does not show the detail of the extent or location of the City Centre living space, nor the Cinema or the proposed access points to these upper floor areas/uses. Neither is the precise extent of the car park, or number of parking spaces indicated.

7.26 In the light of the very limited information provided the scale of the proposed development is disappointing including only a single, medium size anchor store which, we understand it would be intended will provide occupation for an existing retailer to relocate from elsewhere within the City Centre.

7.27 When considered against the aspirations for the regeneration of the Kings Square area it is neither transformational nor ambitious and will certainly not by any objective measure ultimately result in a noticeable step change in the performance and retail ranking of Gloucester City Centre. I attach at Appendix L plans of the various proposals for Kings Quarter dating from the Thornfield scheme in November 2009. This consisted of an anchor store and 45 units of varying size. The Hammerson proposals in April 2010 consisted of two anchor stores and 52 shop units of varying size. The original Stanhope proposals in 2011 envisaged five stores (ranging from 14,000 - 50,000 ft2) and 21 shops. Their proposals in 2013 revised the plans to show one anchor store, 35 units and six restaurants. Finally the current proposals in 2014 propose one anchor store of medium size and 22 shop units.

8 My previous involvement in the Kings Quarter Regeneration Proposals

8.1 Morley Properties (AVIVA) and their Development Partner, Thornfield Properties, were appointed by Gloucester City Council in February 2007 to progress proposals for the redevelopment of Kings Square and adjacent properties.

8.2 I was instructed by the Managing Director of Thornfield Properties to provide advice on their proposals. This advice extended to scheme design, anticipated tenant demand and estimated rental values and, in conjunction with colleagues, anticipated investment value.

8.3 Initially progress was slow as various options were assessed including the preferred location of the new public square, scheme boundaries and mix of uses

8.4 I understand that during 2008 the proposed scheme design and viability was largely driven by Thornfield Properties with reduced involvement of Aviva. The Council elected to formalise the appointment of a Development Partner and consequently an OJEU Notice was published in February 2009. No bids were received and discussions continued with Thornfield Properties.

8.5 I continued to provide advice to Thornfield Properties and my last report was issued in December 2009, providing a detailed commentary on scheme design, occupier demand, letting prospects and progress on comparable developments elsewhere.

8.6 During the latter part of 2008 and the following year the scheme options had been refined and detailed plans produced for appraisal, this process continuing through 2009. Whilst not personally involved in the preparation of the development appraisals it became evident in discussions with the client that achieving the required level of financial viability was a continuing challenge.

8.7 My understanding is the Council had resolved to appoint Thornfield Properties as its Development Partner in early 2010, but this was pre-empted by their entering into liquidation in March 2010.

8.8 However, very shortly after, in April 2010 I was contacted by Hammerson and instructed by them on the Kings Quarter opportunity. Hammerson, as owners of St Oswalds Retail Park, enjoy a long established relationship with Gloucester City Council and have an excellent reputation in delivering successful shopping centres throughout the UK. Hammerson had also been appointed by the Joint Receivers of the Thornfield Group of Companies to manage part completed shopping developments in Bury and Thornaby-on-Tees to completion and disposal.

8.9 Hammerson appointed new architects and consultants and implemented a complete review of the development in terms of design, scale and mix of uses. Considerable work was undertaken, including fresh engagement with potential key occupiers. Following this Hammerson concluded that a viable development was not achievable and in July 2010 they advised the Council accordingly. This was due to various factors including site assembly costs, relatively low achievable rental values and high tenant incentive costs.

8.10 I am attaching in Appendix M plans of the schemes proposed by Thornfield Properties and Hammerson. They both involve a scale of development that sought to achieve the stated step change desired in the City’s central retail offer.

8.11 I was aware that the Council would continue to pursue their aspirations for the redevelopment of Kings Square and contacted several major development companies to establish whether they might be interested. They all declined the opportunity.

8.12 Having continued to monitor the situation I understand that Gloucester City Council advertised a restricted procedure invitation in the Official Journal of the European Union and that no tenders were received. Following this the Council pursued a negotiated procedure and identified Stanhope Plc as a suitable Development Partner. I attach in Appendix N a copy of the Short description of the contract or purchase(s) and the obligations assumed by Stanhope.

9 Current Proposals for Kings Quarter

9.1 Over a period of more than four years Stanhope have been unable to demonstrate any certainty in implementing the long planned redevelopment of Kings Square. Whilst I accept market conditions have been challenging the scheme is relatively simple in both scale and design. However, there is still a possibility that a CPO will be required to complete site assembly. There are now only a modest number of units proposed and Stanhope have indicated that they will be targeting a significant proportion for non-retail use (i.e. A3/A4/A5 occupiers) to support the cinema that is proposed.

9.2 It is my belief that the combination of continuing poor tenant demand, significantly reduced rental values, with the consistent strengthening of Cheltenham as the dominant retail destination in the region, all adversely affect the financial viability of the project. I remain sceptical of even the most limited scheme coming forward in the near future, as I would expect that there will be yet further iterations before a workable planning consent is secured and contracts let. Given the history and the need for significant (and as yet unsecured) pre-lettings for such a scheme, Stanhope together with the Council remain at the earliest stages in the promotion of such a scheme in my view.

9.3 If the acquisition of extensive City Centre land and buildings, together with a major car park and Bus Station is to be justified in terms of financial viability, a scheme of significant scale and high value is required to generate the necessary residual value. This needs to be a substantial figure to justify the initial purchases from the Council and third parties. That is most certainly not what is now being suggested by Stanhope

9.4 In addition the scheme costs are considerable. They include securing vacant possession, demolition of existing buildings and car park, construction of the new development (including new car park, Cinema and residential space) whilst maintaining equivalent geared income for the Council during construction (presumably including the new car park) Added to these are the costs of incentives on the key lettings (including capital contributions and/ or enhanced specifications ) plus possible guarantees on the disposal of existing leases where tenants are relocating. Finally a sufficient return on costs (with overage to be shared with the Council) needs to be achieved. I am also aware that a £3m loan has been made available to Stanhope, subject to conditions, which could part-fund the provision of the new Bus Station but which of course will require repayment. This is not a grant which can provide gap-funding. Finally, this all assumes that a CPO Inquiry will not be necessary which would add considerably to both the programme and costs, with the consequent further negative impact on deliverability and viability. Even without a CPO and ignoring doubts about actual viability, is the programme even achievable given where Stanhope are (or more to the point are not) at.

9.5 In the current market any anchor tenant and key complementary occupiers will seek - and secure - concessionary deals in relation to the lease terms (length of lease, break clauses, turnover provision, co- tenancy agreements etc). These will all potentially affect the investment value of the development and severely undermine the ability to secure short term finance, or the long term funding.

9.6 The success of any major town / city centre development requires the combined presence of a core of high end fashion retailers to create a new destination of sufficient scale. In my experience, from numerous similar schemes this will require securing at least five or six of the major brands. This is the minimum that would be needed to then attract a range of complementary uses such as jewellers, cosmetics, fashion accessories etc that could establish the required quality of offer necessary to compete effectively with other destinations.

9.7 Within recent shopping centre developments with which I have been involved the fashion sector has been a vital part in this process and has been identified and accommodated at the earliest stage, as it dictates the scale, design and viability of the development. This is demonstrated by the scale of the fashion sector at Fremlin Walk, Maidstone where 55% of the units, by number, are occupied by fashion retailers which represents just over 73% of the ground floor floorspace of the development.

9.8 Arc, Bury St Edmunds has 45% by number, which represents 78% by ground floor area whilst Parkway, Newbury has 64% by number and 76% by ground floor floorspace.

9.9 These schemes are all larger than Kings Quarter with anchor store occupiers between 7,246 m2 and 9,290 m2 (78,000 ft2 and 100,000 ft2) and units numbering between 38 and 52. The current ambition of Stanhope appears comparable to the much more modest redevelopment of Urmston in Greater Manchester, where in a much smaller town, a Sainsbury’s anchored scheme with a further 20 units has recently been constructed. However, even in this instance the second phase only proceeded once it was almost entirely pre-let.

9.10 Since they were originally granted an exclusive position in December 2010 Stanhope have had over 3½ years to establish demand, progress the scheme design and assess viability. During this period the scheme has not progressed. Instead, further revised sketch proposals have reduced the potential scheme from the original Vision scale of 35,000 m2 (376,740 ft2) to the development in the Stanhope / CTP submission in June 2011 consisting of five stores ranging from 1,300 m2 to 4,645 m2 (14,000 ft2 to 50,000 ft2) and 21 shops ranging from 93 m2 to 836 m2 (1,000 ft2 to 9,000 ft2) and now, again, to a single mid-range anchor store, 1 smaller store and 21 standard units.

9.11 A redevelopment of Kings Quarter, in common with all other town / city centre shopping centre redevelopments requires a range of established retailers having a strong fashion emphasis, with a significant proportion being new brands attracted in to the location. Where possible, complementary independent non-fashion retailers increase variety and attraction although, frequently, the high occupational costs prove prohibitive to such potential tenants.

9.12 Were a new offer of this variety and quality to be delivered, it could be expected that customer leakage to alternative more distant retail destinations would be reduced, resulting in additional custom being diverted to Gloucester. However, there are few, if any, examples of newly successful shopping centre redevelopment schemes having been achieved without these key fashion elements.

9.13 Stanhope referred to this aspect at the outset placing emphasis on the important brands not represented in Gloucester, with the majority already trading in Cheltenham. It is difficult to envisage Kings Quarter delivering the required step change, or normal commercial viability, if it is unable to deliver a quality A1 tenant mix especially as non-A1 uses (A3/4/5) are being proposed to support the cinema now being suggested.

9.14 Furthermore the latest plans now show a medium size anchor and just a single larger unit (Unit 16) with the remainder of the proposed scheme consisting of “standard” units, a variety of which are already available elsewhere in the City Centre. With other proposed uses including Cinema, car parking and residential space I assume there is now only limited additional space at first floor level for either additional sales, or ancillary storage use.

9.15 This further reinforces the likely lack of many major fashion brands who normally occupy overall accommodation between 696 m2 - 1,850 m2 (7,500 ft2 - 20,000 ft2) over two floors, with a minimum ground floor area of circa 696 m2 (7,500 ft2). The opportunity to combine units to create such floorspace is further limited as it becomes uneconomic in terms of overall rental costs, whilst also disproportionately absorbing display frontage. It would appear, therefore, that the scheme would be dominated by “standard” units which, without the benefit of scale drawings, would seem to provide a range of sizes between 139 m2 - 232 m2 (1,500 ft2 - 2,500 ft2).

9.16 The established retail tenants within The Peel Centre include Toys “R” Us, Hobby Craft, Shop for Shoes, Rosebys / Bensons Beds and Dreams. The non-A1 uses are Burger King, Gala Clubs, Angel Chef and Pizza Hut. There is currently vacant accommodation available which Mr Seary will refer to in his evidence. The retail tenants all occupy larger footprints and involve uses within the “value” sector. They rely upon accessibility, adequate servicing, adjacent surface customer car parking and the presence of other occupiers with a similar customer profile. None of these elements are available in Kings Quarter.

9.17 My understanding in discussions with Mr Seary, is that Home Bargains’ requirement for accommodation in Gloucester is for a gross area of circa 1,858 m2 / 2,322 m2 (20,000 ft2 / 25,000 ft2) at ground floor. They have no requirement for additional sales or ancillary storage / staff accommodation, as their business model is to operate from a single level. They seek locations where adjacent at-grade surface customer car parking is available, with easy customer trolley access, secure and unrestricted at-grade servicing facilities capable of accommodating the entire range of vehicle sizes. Whilst rates form a normal part of their occupational costs, they do not expect to pay a significant service charge and, thus, their preferred representation is within a Retail Park format.

9.18 I simply fail to understand how the allowing of this Appeal could have any impact upon the aspirations of either Stanhope, or Gloucester City Council.

9.19 A key factor to take into account is the disparity in occupational costs between a unit in Kings Quarter and The Peel Centre. For the purposes of comparison assuming a ground floor unit of 464 m2 (5,000 ft2), I estimate the costs in Kings Square (adopting a rental value of £968 m2 (£90 ft2) Zone A) would be in the order £175,500 per annum, equating to approximately £385 m2 (£35.80 ft2). This compares with sub £10 ft2 in The Peel Centre. These costs exclude any service charge or rating liability, both of which will be greater within the Kings Quarter development.

9.20 In considering the proposals at Kings Quarter it is my view that the further contraction of floorspace and the continuing absence of confirmed pre-lettings after such a long period must indicate uncertainty over the delivery of a viable development. The suggested introduction of non-retail uses i.e. residential, cinema and restaurants, particularly the former two uses, are of questionable value in viability terms. Gloucester City Centre residential values are modest and the cost/value of the cinema is likely to be marginal. They both impact on the retail use with entrances, escape routes and services provision being disruptive to the ground floor configuration. These aspects are not identified in the plan made available.

9.21 I consider, with the exception of Primark as a rumoured potential anchor tenant, very few if any of the major fashion retailers will wish to be represented and the consequent effect on tenant mix, rental tone and investment value will continue to present a major obstacle to viability and, thus, delivery of the development for the foreseeable future. The relocation of Primark will have considerably less positive impact than a major retailer new to Gloucester and most certainly would fail to create anything approaching the step change aspired to in the Vision.

9.22 It is also, in my view, relevant to consider the limited experience Stanhope has in delivering major town centre retail developments. Their experience in the offices sector is unquestioned but, to my knowledge, Hereford is the only major shopping centre development that has been implemented. The other developments where Stanhope has been appointed as Development Partners include the following:

Stevenage: 18,580 m2 (200,000 ft2). Appointed by Stevenage Borough Council in Joint Venture with ING in February 2004. Withdrew May 2012.

Truro: 27,870 m2 (300,000 ft2). Promotion of a Joint Venture with LIM in February 2011. Latest press comment in August 2013 stated “…working behind the scenes to bring the proposal forward…”.

Salisbury: 23,225 m2 (250,000 ft2). Appointed by Wiltshire County Council and Salisbury Vision in February 2012. Original appointment envisaged planning application would be submitted during 2013. Latest press comment in March 2014 states “…hope to submit a planning application towards the end of 2015…”.

Ashford: Appointed by SEEDA in March 2010 to develop a Masterplan for a mixed use scheme. No information on current position readily available.

Crawley: £200 million regeneration of town centre. Appointed by Crawley Borough Council in July 2012. Latest press comment in June 2014 reveals “…£200 million plan to regenerate Crawley Town Centre is scrapped…”.

9.23 The project delivery cannot be assessed due to the absence of any firm commitment to programme for the submission of a planning application, although this has been promised on various occasions, for dates which have then slipped by. Whilst Stanhope have previously stated that a figure of £100,000 had been committed to assist with the progressing of an application (January 2013) this sum would only cover some preliminary costs. (I estimate the cost of progressing the scheme design and securing a detailed planning permission would be between £500,000 and £1,000,000). From my understanding of the Development Agreement summary the only financial commitment made by Stanhope Properties to-date is a contribution of £50,000 towards the Council’s costs in completing the Development Agreement. This indicates an unwillingness to commit even to the full costs of a detailed planning application, presumably due to the continuing change in the design and mix of uses within the scheme and a lack of interest from occupiers. It is understandable that there has been no commitment to the significant expenditure of a planning application in the absence of any agreed lettings or Agreements for Lease.

9.24 This uncertainty also affects the possible programme for delivery of the proposed development itself, when taking account of the various “milestones” that would need to be satisfied prior to commencement of work on site. In normal circumstances a prudent developer will require binding agreements to have been completed with key tenants prior to the submission of a planning application. This would ensure that the specific requirements of these occupiers are incorporated in the plans, have been costed and are acceptable in financial viability terms. The normally adopted threshold of pre-lettings is at least 60% of the projected income, or equivalent capital value if long leasehold terms are negotiated. It is unlikely that detailed plans for the planning application will be progressed until this target is shown to be achievable and initial lettings are either completed by way of Agreements for Lease, or in solicitors’ hands. As far as I am aware no pre lettings have been completed in Kings Quarter. It is therefore difficult to see that a planning application will be forthcoming in the foreseeable future.

9.25 The negotiating of the required income threshold would involve the simultaneous and successful conclusion of various discussions with a number of retailers because frequently such occupiers require the comfort of “co- tenancy” agreements. This would involve a minimum number of identified complementary retailers willing to commit to the development at the same time and is a particular requirement within the major fashion sector companies i.e. Arcadia, Next, H&M, River Island, New Look etc. I have, during the course of this year, been in contact with many of the major retailers who Stanhope have suggested would establish Kings Quarter as a prime retail destination. I have referred previously to the correspondence included in Appendix J having contacted retailers all of whom, at some stage and most recently at March 2014, have been identified by Stanhope Properties as target occupiers. It was confirmed by all the retailers approached that they had no interest in Kings Quarter as a new store opportunity. This is at variance with press comment in the Gloucester Citizen on 9 December 2013 when Stanhope stated “…there is plenty of interest from retailers already…”.

9.26 The final important issue that affects the submission of a detailed planning application is the current archaeological investigation works that are taking place. I understand that the archaeological potential across King’s Quarter is high with the prospect of significant remains being discovered.

9.27 In my experience a prudent developer will work closely with the archaeological team and arrange for them to have full access to the site prior to the final design of the scheme being concluded and a planning application submitted. This will enable the developer to be confident that the scheme for which permission is sought accommodates the agreed pre-lettings and meets the required viability tests.

9.28 The result is that there will be delay in the programme for securing planning permission and the delivery of the scheme whilst the works are undertaken.

9.29 The unknown risk relates to further archaeological investigations when the demolition of existing buildings within the site, takes place. To reach this point the developer will have spent a considerable sum in securing the necessary planning permission whilst the later archaeological finds could then require the re-design of the development with the consequent impact on time and costs. This does, therefore, represent a significant risk which the developer will have to underwrite, unless the Council are prepared to share the liability.

9.30 Whilst I acknowledge it was an extreme case a scheme at Coppergate, York involved archaeological investigation over a 5 year period prior to development commencing. This demonstrates how archaeology is a highly relevant issue in assessing the likely delivery of new development in the King’s Quarter area.

9.31 In the circumstances I cannot envisage how Stanhope can achieve the necessary pre letting threshold, accommodate the archaeology investigations (and any required re-design), complete the statutory assessments and have detailed plans completed in readiness for a planning application before the end of 2014. As recently as 10 May 2014 Gloucestershire Citizen reported that “…a planning application will be submitted by developers Stanhope…by the end of the year…”.

10 Kings Quarter Suitability For Home Bargains

10.1 It is suggested by the Council that, in sequential test terms, Kings Quarter is a viable, available and suitable opportunity for Home Bargains’ occupation.

10.2 I do not accept viability can be satisfactorily demonstrated when, after such a long period, the current proposals are still at nothing more than a very preliminary stage, and where the timescales for delivery have repeatedly slipped. To be confident that viability has been satisfied the scheme design, site assembly and build costs will have to be completed, with a programme for development which would probably need to be delivered in phases to accommodate a bus station, car park, leisure and residential occupation in addition to the retail element. In addition to all of this a minimum level of pre-lettings (normally at least 60%) would have to be secured under Agreement for Lease otherwise short / long term finance arrangements could not be secured.

10.3 For availability to be assured and a retailer to be confident that a new store is available, the landlord/developer would need to demonstrate a clear programme for delivery with dates for commencement of work on site, hand- over for fitting out, scheme opening and key pre-lettings to an agreed list of co-occupiers. It would be assumed that by this stage site assembly and planning permission had been achieved.

10.4 With regard to suitability, I cannot see how Kings Quarter meets the requirements of Home Bargains, or assists Stanhope in the delivery of the proposed development. I cannot envisage any circumstances under which a flagship regeneration scheme which is intended to be a “transformational, ambitious and ultimately result in a noticeable step-change in performance and retail ranking” can accommodate Home Bargains as a key anchor tenant, or even a principal covenant in view of their floorspace requirement. Their successful business model requires an extensive ground floor only footprint where they can retail “top brands bottom prices” encompassing a range of household goods, food, health and beauty products and toys. This range of merchandise within a value offer does not, in my opinion, constitute an acceptable use in delivering the transformational regeneration of Gloucester City Centre. It is my view that such a letting, particularly at an early stage, would impact negatively on the potential for further lettings, to the extent that it would effectively remove any interest from conventional fashion and complementary users thereby reducing tenant demand, lowering rental expectations and adversely affecting investment yield.

10.5 I believe this view is strongly supported by the discussions between Stanhope and Home Bargains in Hereford. Home Bargains had an active requirement for representation in Hereford and approached Stanhope’s letting agents to establish whether suitable accommodation might be available within their proposed town centre redevelopment. The response confirmed that Stanhope were unable to consider a letting to Home Bargains due to a lack of suitable space and for “tenant mix reasons”. I attach in Appendix O copies of the correspondence between the agents acting for Home Bargains and Stanhope. In my view this is further reinforced by comments made by Gloucester City Councillors at the planning meeting when the Home Bargains’ application was heard. Councillor Lise Noakes (C, Barnwood) saying “…it (Home Bargains) is not the type of brand the city needed in Kings Quarter…”.

10.6 Finally, I have endeavoured to establish how Home Bargains might be accommodated within a Kings Quarter redevelopment, whilst meeting their standard requirements in terms of size, occupational costs, car parking, servicing etc, but find that it is not possible to meet any of Home Bargains’ requirements for new store acquisitions. In the absence of detailed drawings showing the Stanhope proposals, I have had to rely upon sketch plans made available in the local press. This shows an anchor store and 22 shop units.

10.7 I have endeavoured to calculate the size of units within the terrace 1/6 and assumed a building grid of 7.5 m (24’6” gross internal width) and a depth of 36.5 m (125’). This would indicate a terrace of units each providing a gross ground floor area in the order of 262 m2 (2,820 ft2). This would, therefore, provide a gross ground floor area within the entire block of approximately 1,572 m2 (16,920 ft2). This is significantly below the space available at The Peel Centre.

10.8 In terms of servicing there is obviously no precise indication from the sketch plan available as to how these units will be serviced but it would certainly not seem possible to accommodate full length articulated lorries to the rear of this block, in view of potential conflict with the bus station concourse. I assume the intention is for the units to be serviced by smaller delivery vehicles and for these to park alongside the block and for occupiers to trolley merchandise into the rear of each unit. This is obviously totally unacceptable for Home Bargains.

10.9 The car park, not identified on the plan but presumably above the anchor store block, is on upper levels and, thus, totally remote from Units 1/6. This would be totally unsuitable for Home Bargains not least because it certainly precludes the easy and accessible use of trolleys between store and car park.

10.10 The occupational costs would be far in excess of any rental ceiling affordable to Home Bargains. I have used the conventional zoning method to estimate the rental value of each unit which produces an ITZA of 88.5 m2 (952 ft2). Assuming a Zone A value of £968 m2 (£90 ft2) equates to a rental of £90,000 per annum exclusive. The six units combined would, thus, on this basis command a rental value of £540,000 per annum. This then equates to a value of £343.53 m2 (£31.91 ft2). £540,000 is 3 times the level of rent Home Bargains commonly pay elsewhere. Conversely, if the developer was to accept the maximum affordable rent that Home Bargains can pay this would have a disastrous impact on the scheme viability, quite apart from the unacceptable effect on the quality of tenant mix that is required for a town centre scheme which seeks to create a step change in the city’s retail offer.

10.11 In summary I can find no possible basis upon which Kings Quarter can realistically be considered as a location for Home Bargains and it should be acknowledged that the appropriate location and accommodation in all respects is that which can be delivered at The Peel Centre and which, in turn, should assist in achieving the required regeneration of an important site within the city.

11 Conclusion

11.1 Mr Seary will refer in his evidence to the marketing of the available accommodation at The Peel Centre, the limited response and the interest from occupiers who would require the variation of the permitted use sought by the landlords.

11.2 Taking into account the type of use anticipated at The Peel Centre, the requirements of the proposed tenant in respect of floorspace, servicing and parking, combined with the constraints on occupational costs, demonstrate in my view an absence of any conflict with the potential development at Kings Quarter. The accommodation at The Peel Centre is available immediately, subject to modest alteration works, unlike redevelopment of Kings Quarter, delivery of which is unlikely.

11.3 The absence of any firm programme at Kings Quarter in respect of

 a planning application,

 identified anchor tenants or other key pre-lets necessary to secure funding and commit to further significant cost outlay (including the substantial costs of a planning application) which would need first to be secured under Agreements for Lease,

 any certainty on timescales for submission of a planning application, commencement/completion of works and likely dates for occupation

illustrates that the scheme is not “available” in sequential test terms.

11.4 I also consider that due to the various changes in design and the reducing retail floorspace, together with other uses being introduced that it is evident the scheme is not viable. Neither is it a suitable alternative for Home Bargains as it can be seen the current plan cannot sensibly accommodate any of their requirements in terms of store size, rental level, customer car parking, servicing etc. I have also referred to the fact that their presence in the scheme would then preclude any interest from the fashion sector.

11.5 The long term ownership and eventual development of Gloucester Quays, their desire to contribute further investment in The Peel Centre and their ownership of Madleaze Trading Estate is a clear demonstration of Peel’s continuing commitment to enhancing the wider City Centre in Gloucester. The quite different occupier profile that The Peel Centre and Kings Quarter seek to accommodate, would permit Peel to undertake their own regeneration initiatives to enhance the quality and environment of The Peel Centre, for the benefit of Gloucester shoppers. This can be achieved within a short timescale in the event of the required permission being granted.

11.6 In view of continuing uncertainty over Kings Quarter and the absence of any supporting evidence that the redevelopment proposals might be adversely affected by the modest relaxation of use sought at The Peel Centre, I would respectfully submit that Kings Quarter is neither available, suitable, nor viable in terms of sequential assessment and consequently the amended use be permitted.

Appendix A

Goad plan showing the extend of retail provision in Gloucester City Centre

Appendix B

Goad plan showing JLL view of the prime retail locations in the City Centre

Appendix C

Plan of the proposed City Centre boundary

Appendix D

Colliers International Gloucester Zone A rent profile

Appendix E

JLL Gloucester / Cheltenham Zone A rent profile

Appendix F

JLL Zone A rent /Milestone event graph

Appendix G

Stanhope Vision submission plans for Kings Quarter (June 2011)

Appendix H

Press commentary extracts from:

i) Shopping centre magazine ii) BBC news iii) Gloucester Citizen iv) Punchline v) Career Structure

Appendix I

Gloucester City Council Action Plan (December 2012)

Appendix J

JLL correspondence with major retailers

Appendix K

Stanhope Kings Quarter plan (May 2014)

Appendix L

Plans:

i) Thornfield plans (November 2009) ii) Hammerson plans (April 2010) iii) Stanhope Vision plans 9June 2011) iv) Stanhope plan (February 2013) v) Stanhope plan (May 2014)

Appendix M

Thornfield plans (November 2009) / Hammerson plans (April 2010)

Appendix N

Gloucester City Council OJEU Invitation (February 2009)

Appendix O

Correspondence between Home Bargains and Stanhope’s agents regarding Hereford

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