WYG Planning & Environment

part of the WYG group

Henderson UK Retail Warehouse Fund

Units 1 and 2, Ashford Retail Park, Barrey Road, Ashford

Planning and Retail Statement

05 November 2013

100 St John Street, London, EC1M 4EH

Tel: 020 250 7538

Email: [email protected] www.wyg.com creative minds safe hands Henderson UK Retail Warehouse Fund – Ashford Retail Park

Planning and Retail Statement

Contents Page

Contents

1. Introduction 2. The Application Site and Proposed Development 3. Planning Policy and Analysis 4. Assessment of Existing Retail Provision 5. The Sequential Test 6. The Impact Assessment: Background Information 7. The Impact Assessment 8. Other Relevant Considerations 9. Summary and Conclusions

Appendices 1. Catchment Area 2. 15 Minute Walk Time Plan 3. Goad Plan of Ashford Town Centre 4. Competing Centres Plan 5. Ashford Town Centre Health Check 6. Sequential Assessment 7. Retail Impact Tables

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1.0 Introduction

1.1 Introduction

1.1.1 This Planning and Retail Statement has been prepared by WYG Planning and Environment, on behalf of Henderson UK Retail Warehouse Fund, in support of a planning application for the refurbishment of two units at the Ashford Retail Park, Barrey Road.

1.1.2 This Statement considers the planning background and scope of the proposed scheme, including a detailed policy review and consideration of relevant planning issues.

1.2 Scope of application and supporting information

1.2.1 The application proposes the refurbishment of Units 1 and 2 at the Ashford Retail Park, including the subdivision of both units along with changes to the external appearance and access arrangements.

1.2.2 This Statement forms part of the application submission package, and should be read in conjunction with the following reports:

1. Design and Access Statement: The Design and Access Statement details the design of the proposed development in the context of the wider area, and explores the rational for the design of the development.

2. Transport Assessment: This considers any potential impact arising from the additional floorspace to be created by the development, as well as exploring the proposed amendments to the servicing arrangements at the site.

3. Flood Risk Assessment: This will explores any flood risk issues associated with the proposed development.

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4. Phase 1 Environmental Due Diligence Report: This report identifies any environmental issues at the site, and concludes that the level of environmental risk at the site is low.

1.3 Content and Structure of Statement

1.3.1 The structure of the remainder of the Statement is as follows:

2.0 The Application Site and Proposed Development: sets out a brief overview of the site context and the amendments to the previously approved scheme proposed by this application.

3.0 Planning Policy and Analysis: Details the planning policy at national and local level, relevant to the proposed development.

4.0 Assessment of Existing Retail Provision: identifies the existing shopping provision and shopping patterns within Ashford.

5.0 The Sequential Test: Considers the application of the sequential test, and assesses all allocated and town centre sites within Ashford town centre. We conclude that the application site is the most sequentially preferable location for the proposed development.

6.0 The Impact Assessment: Background Information: Sets out the background information and the assumptions which back up the Impact Assessment contained at Section 7.

7.0 The Impact Test: The current health of Ashford town centre is examined in detail, as well as the anticipated crossover of trade from the proposed development and the town centre. We conclude that the proposed development fully meets the criteria set out at Paragraphs 23-27 of the NPPF.

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8.0 Other Relevant Considerations: Considers the full range of planning matters associated with the proposed development, including sustainability, flood risk, transport and employment benefits.

9.0 Summary and Conclusions: Provides the conclusions of the assessment.

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2.0 The Application Site and Proposed Development

2.1 Application Site and Surroundings

2.1.1 The application site is located at Ashford Retail Park, which is located on the north western side of the A2070, Bad Munstereifel Road, to the south east of Ashford town centre.

2.1.2 The western part of Ashford Retail Park, which will be subject to the proposed application, currently accommodates two existing retail warehouses, which are approximately 3,400 sq. m and 1,800 sq. m in size, and form part of a retail park originally developed in the 1980’s.

2.1.3 Immediately adjacent to the application site are other retail warehouse buildings of various sizes, which accommodate a number of national retailers. The two parts of the Retail Park share the same surface level car park. The units on the eastern part of the Retail Park are considerably more modern than the two units on the western part, and were upgraded approximately ten years ago.

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2.1.4 To the north of the Retail Park lies a large, medium density, residential area which is within comfortable walking and cycling distance of the site. To the south and east of the A2070 lies open agricultural land, which is allocated for urban expansion within the Core Strategy. The M20 lies approximately one mile to the north east of the site.

2.1.5 Unit 1 at the site was previously occupied by Allied Carpets until they vacated the site three years ago, while Unit 2 was previously occupied by , which occupied the unit until 2012. As such, both units within the application site are currently vacant.

2.2 Planning History

2.2.1 Both units were constructed under Planning Permission AS/85/1399, approved by Ashford Borough Council on 29 January 1986. Condition 11 states that there shall be no food retailing, other than ancillary sales of confectionary from the checkouts and in the snack bar of the Texas Homecare, which subsequently became Homebase. This permission therefore allowed Units 1 and 2 to be used for open A1 (non-food) sales.

2.2.2 More recently, a planning application was submitted to Ashford Borough Council on 20 July 2012 to re-clad Unit 2 to provide a more modern façade to secure the ability to re-let the unit to a modern day operator (Ref. 12/00849/AS). Following the non-determination of the application within the Statutory time period, an appeal was submitted to the Planning Inspectorate (Ref. APP/E2205/A/12/2186132). The decision dated 25 February 2013 confirmed that the appeal was allowed, granting permission for the re-cladding of the unit. The Appeal Decision did not contain any conditions restricting the use of unit.

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2.2.3 A subsequent application was submitted to Ashford Borough Council on 02 May 2013, to re- apply for the re-cladding of the former Allied Carpets unit (Ref. 13/00497/AS). Following a positive recommendation by the Planning Officer, planning permission for the recladding was granted on 01 October 2013.

2.2.4 Most recently, a planning application was submitted on 06 June 2013 (Ref. 13/00631/AS) for the installation of a storage mezzanine within Unit 2. Permission was granted for the development on 31 July 2013, with Condition 2 confirming that the permitted mezzanine shall not exceed 465m2 and shall only be used for storage purposes ancillary to the use of the building.

2.2.5 There is no further relevant planning history at the application site. However, Ashford Borough Council is currently considering three applications at the opposite end of the Ashford Retail Park which are all outside of the application site the ownership of Henderson UK Retail Warehouse Fund. These are as follows:

• Ref. 13/00853/AS: Unit 5 Ashford Retail Park , Variation of Condition 17 of Planning Permission 01/01747/AS to increase the range of goods that can be sold from Unit 5, including up to 140 sq. m to be used for the sale of food and drink;

• Ref. 13/00891/AS: Unit 4 Ashford Retail Park, Extension to existing mezzanine floor comprising 1,044 sq. m of retail floorspace, including external alterations; and

• Ref. 13/00930/AS: Unit 4 Ashford Retail Park, Variation of Condition 17 of Planning Permission 01/01747/ AS to allow increase the range of goods that can be sold form the unit, including a café.

2.2.6 Whilst these three applications are currently being considered by the Council, they are not commitments. As such they will not be taken into account when considering the retail impact of the proposed development at Units 1 and 2.

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2.3 The Proposed Development

2.3.1 The application proposes the redevelopment of the existing Unit 1 and Unit 2 at the Ashford Retail Park, to include an additional 2,135 sq. m net floorspace at mezzanine level (above that already permitted, 2,600 sq. m in total), the reconfiguration of the internal ground floor area and relocation of the garden centre (resulting in an additional 2,104 sq. m of retail floorspace ( 2,043 sq. m GIA) overall at the site), the subdivision of both units, external alteration and re-cladding, and to allow up to 300 sq. m within Unit 2 to be used for the sale of convenience goods. It is anticipated that the description of development will be as follows:

“Full refurbishment of Units 1 and 2 at Ashford Retail Park to include the subdivision and alterations to Units 1 and 2, installation of mezzanine floorspace, external alterations, relocation of garden centre, and amendments to servicing arrangements”

2.3.2 It is intended that Unit 1 will be subdivided into two separate units, with Unit 2 being subdivided into four units. The existing frame of the two units will remain in place, but both units will be recladded to include a mix of high quality glazing and cladding, to fully meet the expectations of modern retailers, and also to improve the sustainability credentials of both units.

2.3.3 Up to 2,600 sq. m of mezzanine floorspace will be applied for across the two units. This mezzanine floorspace will replace of the 465 sq. m storage mezzanine that was previously granted within the former Homebase unit, resulting in net increase of 2,135 sq. m . Following the floorspace lost by the subdivision of the units, the proposal will result in an overall increase in GIA at the site of 2,043 sq. m , resulting in a net increase in the sales area at the site of 2,104 sq. m . The existing and proposed floor areas are set out in Tables 2a, 2b and 2b below:

Existing Proposed Ground Floor Mezzanine Ground Floor Mezzanine GIA Sales GIA Sales GIA Sales GIA Sales Unit 1a 840 756 465 419 1,710 1,539 0 0 Unit 1b 840 756 465 418 TOTAL 1,710 1,539 0 0 1,680 1,512 930 837 Figure 2a: Existing and Proposed Floorspace in Unit 1

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Existing and Approved Proposed Ground Floor Mezzanine Ground Floor Mezzanine GIA Sales GIA Sales GIA Sales GIA Sales Unit 2a 1,394 1,254 185 167 Unit 2b 465 418 370 333 3,315 3,137 465 0 Unit 2c 465 419 185 167 Unit 2d 930 837 930 837 TOTAL 3,315 3,137 465 0 3,253 2,928 1,670 1,503 Figure 2b: Existing and Proposed Floorspace in Unit 2

Existing Proposed Difference GIA Sales GIA Sales GIA Sales 5,025 4,676 7,533 6,779 2,043 2,104 Figure 2c: Summary of Existing and Proposed Floorspace at the site

2.3.4 The application also seeks for up to 300 sq. m of convenience retailing to take place from one of the new units created within Unit 2. The convenience floorspace will be ancillary to the main use of the unit as a comparison goods store, but will include a number of chiller cabinets selling fresh milk, butter, fresh and processed meats and cheese.

2.3.5 The application also seeks the relocation of the existing garden centre from the southern to the northern side of Unit 2.

2.3.6 Amendments will also be made to the servicing at the site to enable each of the newly created units to be adequately serviced.

2.4 Justification for the Development

2.4.1 The application site encompasses Units 1 and 2 at the Ashford Retail Park. Originally granted planning permission in 1986, both units have remained vacant since each of the previous operators vacated the Retail Park.

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2.4.2 Despite being actively marketed, the landlord has been unable to re-let either of the units in their current state. As such, the purpose of this application is to refurbish the units to create modern sustainable retail units, as expected by modern retailers.

2.4.3 The design of the units will reflect that of the eastern part of the Ashford Retail Park, the result of which is to rejuvenate tired and dated retail units, to make them marketable to modern retailers.

2.4.4 The Ashford Retail Park is a long established retail destination, which accommodates a range of comparison retail units. In line with Paragraph 17 of the NPPF, the proposals will result in the re-use of two existing retail units for their originally intended use.

2.4.5 The units both currently benefit from an open A1 (non-food) planning permission. In order to maintain the investment value of the site, the application proposes to maintain this open A1 (non-food) permission across both the existing and proposed additional floorspace. As such, while it is anticipated that the proposed occupiers of the development will be a mix of furniture, furnishing and household goods retailers, the retail assessment for the additional floorspace will be based on the assumption that the units could be operated by any open A1 (non-food) retailer.

2.4.6 The proposed development will ensure that the long established retail site remains and active and viable location for out-of-town retailers. Combined with the proposed amendments at Units 4 and 5 of the Park, the proposed application will ensure that the units, originally constructed in the 1980s, are brought up to modern day standards, thereby improving both the overall appearance of the site, and in line with NPPF policy, enables the re-occupation of existing buildings.

2.5 Discussions with Ashford Borough Council

2.5.1 A meeting took place between Henderson and planning officers from Ashford Borough on 18 July 2013 to discuss the proposed refurbishment of the units. It was agreed at this meeting that the planning officers would speak to members about the proposals and confirm that in order to retain the investment value on the park, any subsequent planning permissions at the

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site would be subject to the original conditions at the site, meaning that the original open A1 non-food permission would be retained. This position was subsequently confirmed in an email from Ashford Borough Council on 18 September 2013.

2.5.2 A Retail Scoping Report was submitted to the Council in September 2013. The purpose of this Report was to set out the scope of the proposed planning application, and to agree the methodology to be used within the Retail Impact Assessment (RIA). This Report was subsequently passed to Peter Brett Associates (PBA), Ashford Borough Council’s retained retail advisors.

2.5.3 A letter was received from Peter Brett Associates on 10 October 2013 suggesting a number of amendments to the draft RIA. These amendments have been incorporated into the final application, where possible.

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3.0 Planning Policy and Analysis

3.0.1 This section of the Statement assesses the planning policy which is relevant to this application. This includes reference to the National Planning Policy Framework (NPPF) and current and emerging Ashford Borough Council policies.

3.1 National Planning Policy Framework

3.1.1 The National Planning Policy Framework (NPPF) was published by the DCLG on 27 March 2012. The intention of the document was to simplify and streamline the planning process to facilitate an increased growth in sustainable development. The document sets out the Government’s overriding planning policies and a framework on which Councils should produce their Local Plans.

3.1.2 The NPPF revoked previous planning policy set out within the numerous PPS’s, PPG’s and other material policy documents. However the Practice Guidance documents which were supplementary to the PPS policy documents, such as the PPS4 Guidance documents have not been revoked and remain in force as a material consideration. These documents provide further guidance and clarity on plan making for Councils, as well as providing the framework on which relevant assessments are formulated.

3.1.3 As Paragraph 14 of the NPPF notes, a presumption in favour of sustainable development should be seen as a ‘golden thread running through both plan-making and decision taking’. For decision making, this means that planning authorities should approve development which accords with the development plan. However where relevant policies are out-of-date, planning permission should be granted unless:

• Any adverse impact of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken a whole; or • Specific policies in this Framework indicate development should be restricted. Retail

3.1.4 The NPPF continues to champion the Government’s main aim of promoting the vitality of town centres.

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3.1.5 Local Planning Authorities should still apply the sequential test to any planning application for main town centre uses that are:

• Not in an existing centre; and • Are not in accordance with an up to date Local Plan.

3.1.6 In this case the application site can be considered to be an out-of-centre site, and therefore a sequential assessment has been undertaken to identify any town centre or edge-of-centre sites capable of accommodating the proposed development.

3.1.7 Paragraph 26 of the NPPF sets out the impact criteria against which proposals for retail developments that are not in accordance with an up-to-date Local Plan and not in a town centre location should be assessed against. Where a development proposes an additional 2,500 sq. m or more of retail floorspace, the application should be accompanied by an impact assessment, which should consider the impact of the proposal on any future public and private investment in a designated centre, as well as the impact on town centre vitality and viability up to five years from the time the application is made.

3.1.8 The application proposes an increase in retail floorspace of 2,104 sq. m. As such, a full impact assessment is not required for the application. Notwithstanding this, the application does include a full assessment, considering the health of Ashford town centre and identifying where trade to the proposed development might be diverted from. The report also considers the investment coming forward in the Borough, with a focus on Ashford town centre, and how the proposed development could impact on this investment.

3.1.9 In line with the provisions of the NPPF, this assessment concludes that the proposed development will not prejudice any forthcoming town centre investment, nor does it have a significant adverse impact on any of the centres within the catchment area. The proposal therefore satisfies the tests within the NPPF.

3.1.10 Paragraph 27 stipulates that in the failure to satisfy the sequential test, or if assessment of impacts results in identification of likely significant adverse impacts, the proposed development should be refused. As demonstrated above, the proposal meets the requirements of the sequential test and will not cause significant adverse impact on any designated centres, and should therefore be approved.

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Building a Strong and Competitive Economy

3.1.11 Paragraphs 160 and 161 of the NPPF require Local Planning Authorities to have a ‘clear understanding of business needs within the economic markets operating in and across their area’. They should use this evidence base to assess the need for land or floorspace for economic development for all foreseeable types of activity over the plan period.

Requiring Good Design

3.1.12 Good design is a key aspect of sustainable development (paragraph 56) and great importance is attached to this in the NPPF. Paragraph 61 emphasises the importance of securing high quality and inclusive design.

3.2 Ashford Policy

Ashford Core Strategy (2008)

3.2.1 The Ashford Borough Core Strategy was adopted in July 2008. The Core Strategy forms the main body of the Local Development Framework (LDF), and sets out the strategic vision for development in the Borough between 2006 and 2021.

3.2.2 The document identifies at Policy CS2 that land for about 16,770 new dwellings and related uses, and about 16,700 additional jobs plus contingency allowanced for about 10% and 40% respectively will be identified within the Ashford Growth Area. This is in line with the allocation of Ashford as a Growth Area.

3.2.3 Policy CS16 addresses retailing within the Borough and identifies that the existing hierarchy of retail provision in Ashford should be protected and enhanced, and that major new retail development should be located in Ashford town centre. The supporting text confirms that site selection for retail development should follow a sequential process, with preference to town centre development, followed by peripheral sites and lastly sites outside centres.

3.2.4 Chapter 11 of the Core Strategy focuses on transport within the Borough and refers to the Ashford Parking Strategy, which identifies that long term parking in the town centre will be discouraged in favour of promoting public transport usage. Policy CS15 advocates that

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“maximum parking standards will accord with national standards and the South East Plan except where existing SPG6 applies or where superseded by more restrictive standards in DPDs ”.

3.2.5 Policy CS10 addresses sustainable design and construction and states that all major developments (i.e. over 1,000 sq. m in size), must incorporate sustainable design features to reduce the consumption of natural resources and to help deliver the aim of zero carbon growth in Ashford.

3.2.6 The adopted Sustainable Design and Construction SPG (July 2009) which accompanies Policy CS10 requires that “unless it can be demonstrated that doing so is not technologically practicable, would make the scheme unviable or impose excessive costs” developments for refurbishment should target an overall BREEAM rating of very good, with excellent energy and water crediting and very good materials crediting. The target minimum carbon dioxide reduction is 10%.

3.2.7 As the proposed development simply proposes the refurbishment of the two units, it is not possible to meet the provisions of Policy CS10. However, the replacement of the cladding with new energy efficient materials will greatly increase the overall sustainability of the development. This is explored in more detail in Section 8 of the Statement.

Ashford Town Centre Area Action Plan

3.2.8 The Ashford Town Centre Area Action Plan DPD (AAP) was adopted in February 2010 and supports the Core Strategy by identifying key sites for development across the town centre by which the visions and objectives for the town centre can be met. The AAP identifies key guiding principles for the town centre at Policy TC1, which includes creating a balance and mix of uses within sites and around the town centre as a whole, and delivering an attractive and safe urban environment with a strong sense of place.

3.2.9 Policies TC3 – TC20 identify specific sites within the town centre which should be developed in order to achieve the objectives for Ashford town centre as a whole. A number of these development allocations include retail uses, and are assessed in more detail in Section 5 of this report when we consider the sequential approach to site selection for the proposed development.

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Urban Sites and Infrastructure DPD

3.2.10 Ashford Borough Council adopted their Urban Sites and Infrastructure DPD in 2012, which identifies sites outside of Ashford town centre which should be developed in order to accommodate additional growth in the Borough.

3.2.11 The document states that, in line with the NPPF, the majority of the available retail capacity in the Ashford area to 2021 has been allocated in the town centre.

3.2.12 The document does not identify any sites to be specifically developed for retail purposes, although small scale retail is proposed for a mixed use site. None of the sites have been considered suitable for additional convenience goods floorspace.

3.2.13 Land in very close proximity to site (Land at Sevington) has been allocated for B1 light industrial, B2 and B8 uses.

3.3 Summary of Relevant Planning Policy

3.3.1 This section has addressed the planning policy which is of relevance to this application on a national and local level, and the planning application has been prepared with the above planning policy in mind.

3.3.2 Although the site is in an out-of-centre location, the development has been tested against Paragraphs 23-27 of the NPPF, and represents a suitable location for additional retail development.

3.3.3 Taking account of the above, we conclude that the proposals fully accord with provisions of national, regional and local planning policy, and should therefore be approved without delay.

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4.0 Assessment of Existing Retail Provision

4.0.1 This section of the report considers the existing shopping provision and shopping patterns within Ashford. As part of the assessment we have visited and assessed all of the competing retail destinations within Ashford.

4.0.2 Ashford’s Core Strategy identifies Ashford as the main location for retail development within the Borough. Below Ashford, Tenderden serves as a secondary retail centre, while the villages of Wye, Charing and Hamstreet all play a local centre role, mainly serving the local population and the surrounding parishes.

4.0.3 Ashford benefits from considerable retail presence in the town centre, as well as a number of out of town retail parks, including the McArthur designer outlet village. These are identified on the plan which is attached at Appendix 4.

4.1 Retail Provision in Ashford Town Centre

4.1.1 A full health check report of Ashford town centre has been carried out, and is attached at Appendix 5 . The health check identifies that the town centre has a good mix of retail provision, has a range of unit sizes and is well represented in terms of comparison retailers. The town centre boasts a high proportion of national multiple retailers, and of the top 30 retailers, 23 are present within Ashford, including Debenhams, Marks and Spencer and . Plans identifying the retail composition of the town centre can be found at Appendix 3.

4.1.2 Overall, Ashford boasts a healthy town centre and provides a pleasant shopping environment for shoppers. The town centre has fairly recently seen some major investment by way of the extension to the County Square Shopping Centre, which has allowed a number of major retailers to take up modern retail floorspace in the town.

4.1.3 The vitality and viability of Ashford town centre is assessed further in Section 7 of this Statement as part of the Impact Assessment considering the provisions of the NPPF.

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4.2 Existing Retail Provision in the PCA

4.2.1 The Primary Catchment Area for the proposed development represents the area from which the store would be expected, under normal trading circumstances, to derive the majority, but by no means, all of its trade.

4.2.2 In assessing the impact of the proposed development, we have assumed a fifteen minute walk time for the convenience element and ten minute drive time catchment area from Ashford Retail Park for the comparison element. These two catchment areas are shown on the plans attached at Appendix 1. Following comments from PBA in October 2013, we explored the possibility of extending the Catchment Area based upon a 15 minute drive time. However, as this would extend to areas well outside of the Ashford area, such as Folkestone, a catchment based upon a 10 minute drive time has been maintained.

4.2.3 Within the PCA, there are a number of retail parks, as we well as a number of stand along retail units and foodstores. These range from traditional retail park destinations such as the Ashford Retail Park and the Warren Retail Park, which also includes one of the largest Sainsbury’s stores in the Country, to the Ashford Designer Outlet, which lies to the south of the town centre. There are also a number of solus units, including the Waitrose store at the former Ashford Barracks site, and the Matalan store at Brookfied Road. A new standalone John Lewis Home store is due to open in November 2013, located close to Junction 9 of the M20.

4.3 Centres to Assess

Centres within Ashford Borough

4.3.1 As with any Retail Impact Assessment, the application considers impact on the centres from which it may draw trade from. As the proposed development is located adjacent to Junction 10 of the M20, it is possible that trade to the store may be drawn from centres other than just Ashford town centre.

4.3.2 Notwithstanding this, it is important to consider how the type of retail development proposed might impact on settlements across the settlement hierarchy. It is considered that Ashford is

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the only town centre within the Borough from which the development is likely to draw any significant trade. As such, it is the only centre within the Borough which will be assessed in detail as part of the retail assessment. This approach has been agreed by peter Brett Associates in the pre-application advice.

4.3.3 The Ashford Designer Outlet Centre provides a comprehensive range of comparison retailing, and will also be assessed as part of the application, although the crossover of trade between the outlet centre and the Ashford Retail Park is likely to be limited.

Centres outside of Ashford Borough

4.3.4 The anticipated Catchment Area of the Retail Park, attached at Appendix 1 , demonstrates that there are no other large town centres from which a significant amount of trade will be drawn from. As such, we do not consider it necessary to assess the impact of the proposed development on any centres outside of Ashford Borough.

4.4 Conclusions of the Level of Existing Retail Provision

4.4.1 Ashford is identified as a Primary Regional Centre and a Growth Area, and as such is the main location for additional retail development within the Borough. As well a vital and viable town centre, Ashford also benefits from a number of out of centre retail facilities.

4.4.2 There are a number of retail facilities situated in out-of-centre location, including traditional retail warehousing, supermarkets and the designer outlet centre. The impact on all existing and proposed retail facilities within Ashford, have been considered as part of the RIA attached at Appendix 7 .

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5.0 The Sequential Test

5.1 Introduction

5.1.1 This section of the Statement assesses the proposed development against the provisions of Paragraph 24 of the NPPF. Here we assess the potentially sequentially preferable sites that have been identified through a combination of a review of the Ashford Borough Council planning policy, namely the Ashford Town Centre Action Plan DPD and a site visit to Ashford town centre.

5.2 Threshold for Assessing Sequential Sites

Paragraph 24 of the NPPF states that Local Planning Authorities should apply a sequential test to planning applications that are not in an existing centre and are not in accordance with an up-to-date Local Plan.

5.2.1 The application site is located outside of Ashford town centre, and as such, a sequential test is required in support of the planning application.

5.2.2 Paragraph 24 continues to state that applications for main town centre uses should be located in town centres, then in edge-of-centre locations and only if suitable sites are not available should out-of-centre sites be considered. When considering out-of-centre sites, preference should be given to accessible sites that are well connected to the town centre.

5.2.3 The extant PPS4 Practice Guidance in Need, Impact and the Sequential Approach identifies ‘in centre’ sites for retail development as being sites located within the PSA. ‘Edge-of-centre’ sites are considered to be sites in locations well connected to, and within easy walking distance (i.e. up to 300 metres from the PSA). This means that sites which are not easily accessible from the PSA can be considered to be out-of-centre, even if they are within 300 metres from the PSA.

5.2.4 Paragraph 6.22 of the Practice Guidance notes that when considering applications, Local Planning Authorities need to consider the extent of the catchment area likely to be served by

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the proposal, and identify alternative sites located in existing centres within the catchment area. Ashford is the largest centre in the Borough, and it has been agreed that Ashford is the only centre considered for the sequential test.

5.2.5 Paragraph 6.27 of the Guidance notes the requirement for developers and operators to demonstrate flexibility in their business model when considering sites in, or on the edge of existing centres. This may involve retailers trading through multi-level stores, and/or through shared or multi level car parking and innovative servicing solutions.

5.2.6 As noted in Paragraph 6.29, LPA’s need to also be flexible in terms of their expectation, which will require them to consider the benefits of major private sector investment in their town centres against the implications of development occurring in other, less central locations. Paragraph 6.31 confirms that in the case of retailers selling bulky durable goods, the development in many cases can be regarded as complementary to the role of town centre retailing and do not generate sufficient sales productivity to trade in prime town centre locations. However, as confirmed at Paragraph 6.33, while there is no policy requirement to demonstrate need, an operator claiming that it is unable to be flexible about its chosen business model would be expected to demonstrate why a smaller store or stores could not meet a similar need.

5.2.7 CBRE have provided a helpful guide for use by both developers and Local Planning Authorities when considering the Sequential Approach, based upon the criteria set out in the PPS4 Practice Guidance.

5.2.8 The criteria for availability, suitability and viability are set out in turn on the following page.

Legal or Ownership Pre -conditions to Ownership Problems Development Such as: Such as: • Willingness of owner to • • Multiple ownerships Allocation in DPD bring forward the site • • Ransom strips Remedial action by third for development within • Tenancies parties a reasonable timescale: • Operational or requirements of • Progress made by the

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landowners authority on site assembly through compulsory purchase

Table 5.1 – Availability

Policy Restrictions Physical Problems Potential Impacts Such as: Such as: Such as effects on: • Designations and • Access • Landscape features protected areas • Infrastructure • Built heritage • Existing planning policy • Ground conditions • Corporate or community • Flood Risk strategy policy • Hazardous risks • Pollution or contamination

Table 5.2 – Suitability

Market Factors Cost Factors Delivery Factors Such as: Such as: Such as: • Adjacent uses • Site preparation costs • Developer’s own • Economic return of related to any physical phasing existing, proposed and constraints • Realistic build-out rates alternative uses in • Any exceptional works on larger sites terms of land values • Planning policies or (including likely earliest • Attractiveness of the obligations bearing on and latest start and locality the site completion dates) • Level of potential • Prospect of funding or • S106 / CIL costs market demand investment t o address • Whether there is a identified constraints or single developer or assist development several developers and their size and capacity.

Table 5.3 – Viability

5.2.9 All of the above will be taken into account when considering the sequential test.

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5.3 Threshold for Assessing Sequential Sites

5.3.1 The application proposes the refurbishment of the existing units at the retail park, and the creation of an additional 2,043 sq. m of floorspace (GIA), above that already approved at the site. The additional floorspace will be located at mezzanine level, within the current footprint of each of the buildings. The application also proposes the use of up to 300 sq. m of floorspace within one of the units to be used for the sale of convenience goods.

5.3.2 Paragraph 24 of the NPPF confirms that both applicants and local planning authorities should demonstrate flexibility on issues such as format and scale. Flexibility may include providing under-croft or decked car parking, or providing the development over two or more levels. It does not however require the applicant to disaggregate separate parts of the business model.

5.3.3 The Supreme Court held in March 2012 in Tesco Stores Limited v. Dundee City Council [2012] UKSC13 that the construction of a planning policy is a matter of law. In the Tesco case, the equivalent wording in the adopted planning policy document to that contained in the NPPF was whether a “suitable site” was available for the “proposal for retail development”. This latter wording is practically identical to that contained at Paragraph 24 of the NPPF. Consequently, the legally correct approach to the sequential test set out in the NPPF as determined by this case would be the same. It was summarised by Lord Hope as follows:

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

5.3.4 The relevant question is therefore not whether there is a site “suitable for meeting identified deficiencies in retail provision in the area” but whether there is a site “suitable for the development proposed by the applicant” . Further, the question is “not whether the proposed development can be altered or reduced so that it can be made to fit an alternative site”.

5.3.5 With this in mind, the sequential test will assess whether sites in Ashford town centre are suitable for the entire floorspace of each of the units at the Ashford Retail Park, i.e. the full resultant floorspace in each of the two units. In line with the Dundee decision, while it may

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be acknowledged that a number of sites could accommodate retail development of some sort, the assessment will look at whether they could accommodate the end development proposed by the forthcoming application.

5.3.6 Given the above, and taking account of an acceptable level of flexibility, the sequential test will only assess sites which can accommodate either one of the two units, as proposed (i.e 2,610 sq. m GIA and 4,923 sq. m GIA)

5.4 Sequential Sites to Assess

5.4.1 The following list of potentially sequentially preferable sites has been compiled from a combination of sites contained within the Ashford Town Centre Area Action Plan and a recent site visit to Ashford town centre:

1. AAP Site TC3 – Elwick Place 2. AAP Site TC4 – Park Mall 3. AAP Site TC5 – Vicarage Lane Car Park 4. AAP Site TC6 – Corner of Elwick Road and Station Road 5. AAP Site TC9 – The Commercial Quarter 6. AAP Site TC10 – The Southern Expansion Quarter 7. AAP Site TC11 – Victoria Way East 8. AAP Site TC12 – Former Powergen North 9. AAP Site TC15 – The International Station Quarter 10. AAP Site TC16 – Former B&Q Site, Beaver Road 11. AAP Site TC17 – The Civic Quarter 12. AAP Site TC18 – The Residential Quarter

5.4.2 In addition to the sites identified in the Town Centre Area Action Plan, we have also identified one other site within the town centre which we will assess as part of the sequential assessment: 13. Vacant Retail Unit (119/121), County Square

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5.5 Demonstrating Compliance with the Sequential Test

5.5.1 The scale of the proposed subdivided retail units has arisen following discussions with potential retailers. As such, while the sequential test considers flexibility in terms of servicing, scale and car parking, it does not assess the potential for disaggregating the floorspace into separate units. If the additional floorspace was separated, the current deficiencies with the existing buildings would remain.

5.5.2 Section 6 of the extant PPS4 Practice Guidance provides a useful checklist for considering the sequential test. We have therefore adopted the checklist to undertake the sequential test for the application. The checklist asks the following questions:

1. What is the scale and form of the development needed?

2. Is the need ‘location specific’ or even ‘site specific’, or is it more generalised?

3. Are the PSA and wider town centre properly defined in the development plan?

4. How should the site / proposals in question be defined? Is it ‘in centre’, ‘edge- of-centre’ or ‘out-of-centre’?

5. Have all more central opportunities been considered / identified?

6. Have they been thoroughly tested, having regard to their suitability, viability and availability having regard to the identified need / demand and the timescales over which it arises?

7. Has the assessment adopted a sufficiently flexible approach?

8. Has the potential to overcome any obstacles to the availability of more central sites been discussed with the LPA?

5.5.3 These are considered in turn below.

What is the scale and form of the development needed?

5.5.4 The proposed development is a necessity as the current retail units do not deliver the scale and layout of floorspace currently required by retailers. Additional floorspace at mezzanine

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level will allow for greater flexibility which will enable the development to respond appropriately to market demand and ensure the full occupation of the existing buildings.

5.5.5 Further, the mezzanine floorspace will allow the potential operators to maximise the ground floor level for retail display purposes. This would not necessarily mean an increase in the amount of products sold, rather it allows for more imaginative product displays and an increased amount of circulation space. This is particularly important for retailers moving forward as more of their sales take place online, with the physical retail stores acting as a show room for these online purchases.

5.5.6 The proposed development therefore needs to be of the scale proposed to allow for sufficient display of product ranges.

Is the need ‘location specific’ or even ‘site specific’, or is it more generalised?

5.5.7 As set out above, it has become clear from discussions with potential operators for the Ashford Retail Park development that there is a demand for the type of development proposed by this application in this particular location. The area around Ashford Retail Park has been developed as an out-of-town retail destination which has been partly due to its strategic location close to Junction 10 of the M20. As such, where retailers either cannot locate in an existing town centre, or is seeking to complement a town centre store with an out of centre offer, the Ashford Retail Park area an attractive location for retaining trade which would otherwise be lost to the competing centres of Maidstone and Canterbury. As such, we consider the identified need to be site specific to the individual units at the Ashford Retail Park.

Are the PSA and wider town centre properly defined in the development plan?

5.5.8 The adopted Local Plan Policies Map clearly identifies a defined Primary Shopping Frontage and a Town Centre Boundary.

How should the site / proposals in question be defined? Is its ‘in centre’, ‘edge-of- centre’ or ‘out-of-centre’?

5.5.9 The site is situated in an out-of-centre location as it is located more than 300m from the Primary Shopping Area of Ashford.

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Have all more central opportunities been considered / identified?

5.5.10 All suitable sites identified in the Ashford Town Centre Area Action Plan (2010) have been assessed as part of the sequential test. Further, any additional sites not forming part of the SPD identified on recent site visits were also considered. As such, we contend that all more central opportunities have both been identified and considered as part of this application. The full list of sites, as set out in Table 5.1 below were provided to Ashford Borough Council in advance of the application, after which no further sites were suggested by the Council.

Have they been thoroughly tested, having regard to their suitability, viability and availability having regard to the identified need / demand and the timescales over which it arises?

5.5.11 The following sites have been assessed in terms of their availability, suitability and viability. Detailed summaries of the sequential assessments are contained at Appendix 6 of this Report, along with a plan showing the locations of the sequential sites.

5.5.12 A summary of the finding of the sequential test is set out in Table 5.1 below.

Site Available Suitab le Viable

Elwick Place  x x

Park Mall  x x

Vicarage Lane Car Park  x x

Corner of Elwick Road and Station Road x x x

The Commercial Quarter x x x

The Southern Expansion Quarter x x x

Victoria Way East  x x

Former Powergen North x x x

The International Station Quarter x x x

Former B&Q Site, Beaver Road x x x

The Civic Quarter x x x

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The Residential Quarter x x x

Unit (119/121), County Square  x x

Table 5.1: Summary of Sequential Assessment

5.5.13 In the absence of any available, suitable and / or viable sites which are sequentially preferable to the application site, it is concluded that the proposed development passes the sequential test, as set out at Paragraph 24 of the NPPF.

Has the assessment adopted a sufficiently flexible approach?

5.5.14 The sequential test, as set out in detail at Appendix 6, has been fully flexible. Ideally the retail floorspace of the development would be located over a single level, as it is generally accepted that mezzanine floors trade at a lower efficiency than sales areas at ground floor. However, the sales area of the proposed development will be situated over two floors so as to decrease the overall footprint of the building.

Has the potential to overcome any obstacles to the available of more central sites been discussed with the LPA?

5.5.17 There has been no in depth discussion with the LPA about how the obstacles identified through this sequential test may be overcome. However, we are happy to enter into such discussions, if required.

5.6 Conclusions of Sequential Test

5.6.1 When considering the sequential test, the assessment has focused on sites within Ashford town centre only, being the only centre in the anticipated catchment of the store that could accommodate the proposed development.

5.6.2 We have set out why the development needs to be of the size and in the location proposed, and have demonstrated flexibility by assessing sites all sites allocated for retail development with the Ashford Town Centre AAP. In doing so, we have fully assessed all potential town and edge-of-centre sites.

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5.6.3 However, as set out at Table 5.1 above, we have not been able to identify any more centrally located sites that are available, suitable and viable for the proposed development.

5.6.4 Given the above, and the details provided at Appendix 6, we conclude that the application site is considered to be the most sequentially preferable location for the proposed development.

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6.0 The Impact Assessment: Background Information

6.0.1 This section of the Report assesses the potential impact of the proposed development in terms of diversion of retail trade from existing stores and centres, as well as the impact on potential planning investment in the Catchment Area, in accordance with policy contained at Paragraphs 23-27 of the NPPF.

6.0.2 Paragraph 26 of the NPPF confirms that all applications for retail developments which are located outside of town centres, and are not in accordance with an up-to-date Local Plan, require an impact Assessment if the development is over a proportionate, locally set threshold. Where no threshold has been set, the default is over 2,500 sq. m.

6.0.3 This application proposes an additional GIA of 2,043 sq. m over and above what has previously been approved at the site, resulting in a net additional retail floorspace of 2,104 sq. m. As such, a full retail impact assessment of the proposed additional floorspace is not required. However, for completeness a full RIA has been undertaken to understand any potential effects of the development on the turnover of Ashford town centre. This Section sets out the background work which has been undertaken in order to assess the impact of the proposed development.

6.1 Establishing Current Shopping Patterns

6.1.1 The starting point for considering the capacity, and therefore the potential impact of new retail floorspace would usually be the Local Authority’s latest Retail Study. Although various reports have been produced in recent years assessing the need for a new foodstore within Ashford town centre, the last Report assessing comparison floorspace in Ashford was produced back in 2003 by CBRE. As this Study is now ten years old, it does not provide a sound basis for understanding the current position within Ashford.

6.1.2 A Household Survey was undertaken by NEMS in June 2011 in support of an application for a new comparison retail unit at the Warren South, to be occupied by John Lewis Home. As the Household Survey was undertaken for a particular retailer, the questions focussed on goods

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that would be sold from the unit. As such, respondents were not asked about their shopping habits relating to a number of key areas, such as clothing and footwear, toys and games, and DIY goods. Given the lack of information on a number of key comparison ranges, it would not be statistically robust to use the information from this Household Survey.

6.1.3 Given the above, and due to the limited amount of additional floorspace proposed at the site, the decision has been taken to undertake a crude RIA based on anticipated Benchmark turnovers of the stores within the 10 minute Primary Catchment Area of the site. These turnovers have been considered in the light of the latest expenditure information to understand whether the stores are indeed likely to be trading at or around benchmark. As set out in the notes to the RIA Tables at Appendix 7, the floorspace figures have been taken from the 2010 application to extend the Sainsbury’s store at the Warren Retail Park (Ref. 10/00811/AS).

6.1.4 Pre-application advice from Peter Brett Associates confirmed that the option of commissioning a new household survey should be explored in more detail. However, given the relatively small level of floorspace proposed within existing retail units, we feel that the timings and costs involved with undertaking a new survey would be excessive. Despite the lack of a recent retail study, there have been a number of planning applications in recent years which are able to provide a sound base on which to consider the current shopping patterns within Ashford. It should be noted that of all of the recent planning applications for additional floorspace in the Borough, only the application for the new John Lewis store which was for 3,637 sq. m of additional sales floorspace was accompanied by a new household survey. As such, the methodology adopted in the retail impact tables contained at Appendix 7, represent a sound base by which to assess the anticipated impact of the development.

6.2 Catchment Area

6.2.1 The anticipated catchment area for the proposed development is based on a 10 minute catchment area. This is the area where it is anticipated that most, although not all, of the trade to the proposed development will be drawn. A map of the catchment area is included at Appendix 1 of this Report. We have also considered the amount of available convenience expenditure within a 15 minute walk from the site, to help understand the local ‘convenience need’ at the site.

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6.2.2 With the extent of the Catchment Area established, we have used information from Experian Micro Marketer G3 to identify the current and projected population within the area, alongside the available expenditure for comparison goods retailing to 2018.

6.2.3 The catchment area as a whole has a population of 85,101 at 2013, rising to 87,650 by 2015 and 91,542 by 2018.

6.2.4 It is anticipated that the vast majority of the trade to the Ashford Retail Park development will be drawn from this catchment area, with no more than 20% for comparison goods, and 10% for convenience goods being drawn from beyond.

6.2.5 In the pre-application advice PBA suggested that a 15 minute catchment area would more accurately capture the extent of the likely trade draw to retail facilities. We acknowledge that Ashford has a wider retail draw than simply a ten minute catchment, and given the distance between Ashford and the competing centres of Canterbury, Maidstone and Folkestone, there are people who would indeed travel further than 10 minutes to shop in Ashford. However, due to the location of the Ashford Retail Park close to Junction 10 of the M20, a 15 minute drive time extends well beyond the Ashford area, almost reaching Hythe and Folkestone to the south east. It is considered that many living between the 10 and 15 minute drivetime from the site to the west and north of Ashford are just as likely to travel to Maidstone or Canterbury, where there is a greater level of retail provision available.

6.2.6 The retail impact assessment assumes that up to 20% of trade is likely to come from outside of the Catchment Area, thereby acknowledging that those living beyond the 10 minute drive time are likely to travel to the store. For ‘flagship; style stores, such as John Lewis and Marks & Spencer, the catchment area would be significantly larger as customers will travel further distances to these stores. However, this application proposed smaller scale A1 retail, likely to be a mix of homeware, furniture and other ‘traditional retail park’ retailers, the catchment area is likely to be much smaller. As the 10 minute drive time captures the whole of the urban area of Ashford, as well as a number of surrounding villages, we contend that it remains an appropriate catchment on which to base the assessment of impact.

6.2.7 The 15 minute walking catchment has a population of 4,277, and a total available convenience expenditure of around £7.57m. It is anticipated that the proposed convenience

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element proposed within one of the new units within Unit 2 will serve as a local convenience store for these residents, as well as providing ‘impulse’ convenience purchases for those living elsewhere in the catchment area. This is explored in more detail in Section 7 of this Statement.

6.3 Turnover of the Proposed Development

6.3.1 The anticipated turnover of the proposed development is set out at Table 7 of Appendix 7. The sales density of the proposed development has been taken from the average of the non- bulky retail park operators as set out in the Mintel Retail Rankings (2012). As such, although the proposed occupiers at the site are likely to include bulky, furniture and homeware retailers, the retail assessment has been undertaken on the basis that the units could be occupied by any non-food A1 retailer.

6.3.2 It is anticipated that the additional floorspace at the site proposed by this application will have a turnover of £ £8.46m at 2015, increasing to £8.59m by 2018. Of this, the majority will be for comparison goods with just £0.91m at 2015 and £0.92m at 2018 being for the sale of convenience goods.

6.4 Trade Diversion to Commitments

6.4.1 Tables 10a and 10b set out John Lewis commitment, which is the only commitment to have been modelled as part of the impact assessment. Although the Council is currently considering a number of applications for additional retail floorspace in the Borough, including at the opposite end of the Ashford Retail Park, as none of these have been determined at the time of the application submission, these have not been included as commitments. Other approved developments, such as the Zed Homes scheme to the south of Ashford Town Centre have also not been modelled, as there are currently no timescales in place for these coming forward.

6.4.2 The trade diversion figures for John Lewis have been taken from the retail impact assessment submitted in support of the application. It is anticipated that the John Lewis development will divert £0.86m of trade from the town centre at 2015 , increasing to £0.87m by 2018 .

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6.5 Trade Diversion to Proposed Development

6.5.1 As with all additional retail floorspace, trade to the proposed development will be diverted from existing retail developments, both within and outside of the Catchment

6.5.2 Tables 11, 12, 14 and 15 of Appendix 7 demonstrate where we anticipate the diverted comparison trade to be drawn from. We have produced two separate scenarios to consider varying levels of trade being diverted from Ashford town centre. Scenario A assumes that 30% of the turnover of the proposed development will be diverted from Ashford town centre. This figure is based on the crossover between the stores in the town centre and the proposed retailers which are likely occupy the units. Scenario B assumes that 45% of the turnover will be diverted from Ashford town centre. This scenario assumes that the proposed retailers will have a greater crossover with Ashford town centre, as would be the case with more fashion orientated retailers.

6.5.3 Given the relatively small scale of the convenience floorspace proposed at the site, a full impact assessment has not been undertaken. However, Tables 17a and 17b set out the current turnover of the existing convenience stores in the Catchment Area, and demonstrates that at 2015 the additional floorspace accounts for just 0.51% of total convenience expenditure.

6.6 Conclusions on Background Information

6.6.1 In this Chapter we have provided a summary of the background information and assumptions which will allow us to consider the potential impact of the development against the provisions of the NPPF.

6.6.2 More detail is provided in the Retail Tables attached at Appendix 7 of this Statement.

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7.0 The Impact Assessment

7.1 Introduction

7.1.1 This section of the Report considers the impact of the proposed development in terms of diversion of retail trade from the existing stores and centres within the identified Catchment Area, as well as impact on potential investment in these centres.

7.1.2 Paragraph 26 of the NPPF confirms that when assessing applications for retail development outside of town centres, which are not in accordance with an up-to-date Local Plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold. As Ashford does not have a locally set threshold, a default position 2,500 sq. m should be applied. The impact assessment should include as assessment of the following:

• The impact on existing centres, committed and planned public and private investment in a centre, or centres, within the catchment area.

• The impact on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area up to five years from when the application is made.

7.1.3 This application proposes an increase in the sales area at the site of 2,104 sq. m. As such, a full retail impact assessment is not required for the application submission. However, for robustness, a full assessment has been undertaken, which considers the potential impact of the proposed development against the provisions of Paragraphs 23-27 of the NPPF.

7.1.4 It has been confirmed by Peter Brett Associates that Ashford town centre is the only centre that could be affected by the additional floorspace at the site, although trade will also be diverted from the Ashford Designer Outlet and out-of-centre retail parks within the Borough. As such, this section of the Report focuses predominantly on the potential impact of the development on Ashford town centre only.

7.1.5 This section builds upon the information already set out in this Statement, and considers the potential impact of the proposed development in terms of diversion of retail trade from

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existing stores and centres, as well as potential investment in centres within the catchment area.

7.1.6 This section also sets out the assumptions that have been made in terms of turnover of the proposed development, as well as the turnover of the existing and planned floorspace within the catchment area. We then consider the likely trade draw and diversion patterns to both the proposed development and the commitments coming forward.

7.1.7 The information contained in this section is set out in more detail in the Impact Tables contained at Appendix 7 of this report.

7.2 Available Expenditure in Catchment Area

7.2.1 Table 4 at Appendix 7 sets out the total amount of available comparison expenditure within the Catchment Area. This is based on the information contained within the Experian Area Reports dated September 2013, and includes a deduction for Special Forms of Trading (SFT), such as internet sales. There is a total of £226.87m of expenditure for comparison goods available at 2013 , increasing to £242.07m by 2015 and £268.61m by 2018 .

7.2.2 Table 5 at Appendix 7 identifies that there is £155.34m of available convenience expenditure in the catchment area at 2013, increasing to £160.00m at 2015 and £166.94m by 2018 .

7.3 Turnover of Existing Retail Floorspace

7.3.1 Table 9 sets out the anticipated turnover of the existing comparison stores within the Catchment Area. This identifies the turnover of the stores / centres based on the turnover of the Catchment Area only . There will also be inflow of expenditure from outside of the Catchment Area. The inflow estimates have not been included within the assessment, as they would only be estimates, and are not necessary to assess impact from within the catchment area.

7.3.2 The turnover figures in Table 6 are based upon benchmark turnovers for all stores expect for Ashford town centre. Due to the current vacancy rate within Ashford, we have reduced the

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benchmark turnover by 10%, which has the potential to reflect a more accurate turnover for the centre as a whole, and provides a robust base for analysis. This deduction is not usual WYG practice, but follows the pre-application advice from PBA.

7.3.3 Table 6 demonstrates that Ashford town centre has a turnover of approximately £115m from within the catchment area, and has the largest turnover of any retail destination in the Borough. The actual turnover of Ashford will be significantly higher than this, as this only represents the turnover from within a 10 minute catchment from the application site. Given Ashford’s strategic location adjacent to the M20, this figure will be much higher when taking account of inflow.

7.4 Turnover of the Proposed Development

7.4.1 The anticipated turnover of the proposed development is set out at Table 7. The sales density for the proposed development is based on an average of the non-bulky retail park operators from Mintel Retail Rankings 2012. This is a robust approach as the application seeks permission for open A1 (non-food) retail floorspace.

7.4.2 The additional comparison floorspace at the site will have a turnover of £7.55m at 2015 , increasing to £7.67m by 2018 . The convenience floorspace will turnover £0.91m at 2015, increasing to £0.92m by 2018 .

7.4.3 The accompanying Impact Tables have assumed that the turnover of the development will increase over time due to increase in sales efficiency. However, this historic trend is less likely to continue at the current rate due to pressure from online sales and increases in the cost of materials. The tables have also not assumed a deduction in the sales density of the mezzanine floorspace. In many cases mezzanine floor areas can trade up to 50% lower than the ground floor areas. As such the figures set out at Table 7 of the Impact Tables are considered to be fully robust.

7.5 Trade Draw to Proposed Development

7.5.1 Tables 8a and 8b detail the anticipated trade draw to the proposed development. It is anticipated that 80% of the turnover to the comparison floorspace will be drawn from within

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the Catchment Area, with 20% being drawn from beyond. As the application site is located close to Junction 10 of the M20, it is inevitable that trade will be drawn from outside of the Catchment Area. Nonetheless, the majority of the trade will be drawn from within the Ashford urban area and surrounding villages.

7.5.2 It is anticipated that up to 90% of the turnover of the convenience floorspace will be drawn from within the Catchment Area. This is because as well as providing an ‘impulse’ ancillary function, the convenience element will also meet the day to day convenience needs of the local population.

7.6 Trade Diversion to the Proposed Development

7.6.1 As with all new development, trade to the proposed development will be diverted from existing retail development, both from within and outside of the Catchment Area.

7.6.2 Tables 11, 12, 14 and 15 set out the anticipated diversion from existing stores and centres to the proposed development at both 2015 and 2018 . As set out above, we have considered two scenarios, each applying a different trade diversion from Ashford town centre.

Scenario A

7.6.3 Scenario A assumes that 30% of the comparison trade to the proposed development will be diverted from Ashford town centre. This is based on the assumption that the proposed retailers at the application site will be a mix of homeware, furniture and other bulky retailers, and will therefore have little crossover with Ashford town centre retailers.

7.6.4 Trade is also expected to be drawn from a number of out-of-town retail destinations including the Warren Retail Park, including Sainsbury’s (11%), the other stores at the Ashford Retail Park (10%), Asda at Kimberley Way (6%), and the Tesco Extra store at Hythe Road (6%).

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Scenario B

7.6.5 Scenario B assumes that up to 45% of the trade will be diverted from Ashford town centre, with a further 10% being diverted from the Ashford Designer Outlet. This is based on the assumption that the proposed occupiers of the developments will be more fashion orientated.

7.7 Impact of the Proposal in Existing Stores and Centres

7.7.1 Tables 13 and 16 set out the anticipated impact of the development of the existing stores following the implementation of both the proposed development and the John Lewis store at 2015 and 2018. Both Scenario A and B are considered in turn below.

Scenario A

7.7.2 Table 13 demonstrates that the development alone will have a 1.57% adverse effect on Ashford town centre at both 2015 and 2017 . This increases to a 2.3% adverse effect when the cumulative impact with John Lewis is considered.

7.7.3 Table 13 demonstrates that there are also negative impacts on other stores within the Catchment Area. However, as these are located out-of-centre, they are afforded no policy protection in NPPF terms.

Scenario B

7.7.4 Table 16 demonstrates that the development alone will have a 2.26% adverse effect on Ashford town centre at both 2015 and 2017 . This increases to 3.08% when the cumulative impact with John Lewis is considered. This is considered to be a worst case scenario as it assumes that the additional floorspace at the site will be occupied by a typical high street / fashion retailer.

7.7.5 Both of these Scenarios are based upon Ashford town centre maintaining its current market share, which is currently causing it to trade below benchmark. In reality, as the economic position improves and Country Square becomes fully let, and other town centre schemes come forward, the overall turnover of Ashford town centre is likely to increase, thereby

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reducing the impact of the proposed development. As such, these figures represent a worst case scenario for Ashford.

7.7.6 More importantly, the impact figures set out in Tables 13 and 16 also do not take account of the inflow to Ashford from outside the catchment area . There will be a degree of inflow from outside the Catchment Area which has not been identified through in the RIA. For Ashford this may be as much as an additional 30% - 40% of the turnover from the Catchment Area.

7.7.7 It is difficult to accurately estimate the level of inflow of expenditure from outside the Catchment Area to Ashford town centre, and this information is not required to undertake an RIA. The effect of this is the RIA setting out the worst case scenario, by effectively reducing the amount of turnover of all of the retail destinations. If inflow of expenditure from outside of the Catchment Area were to be considered, the impacts as set out in Tables 13 and 16 would be considerably lower.

7.8 Impact on Existing, Committed and Planned Public and Private Investment

7.8.1 Paragraph 26 of the NPPF confirms that applicants should assess the impact of a proposal of existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal. It has previously been agreed that Ashford is the only centre that needs to be considered in terms of impact.

7.8.2 The Ashford Town Centre Area Action Plan identifies a number of sites in and around Ashford town centre that could accommodate either new or replacement retail provision. All of these sites have been fully assessed as part of the sequential assessment in Section 5. Given the scale and type of retail floorspace proposed at these sites, the creation of additional floorspace at mezzanine level within existing buildings at an established retail destination are unlikely to impact upon the ability to deliver the redevelopment of these sites. The majority of the town centre sites are large, complex sites, which will accommodate a mix of uses including office and residential uses, which will be unaffected by the development proposed by this application.

7.8.3 The Town Centre AAP suggests that the Park Mall Shopping Centre could be redeveloped to accommodate a foodstore, and we acknowledge that Ashford town centre could benefit from

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an improved convenience offer. Although the application proposes up to 300 sq. m of convenience goods, this will be located within a larger comparison store, and will not act as a convenience store in its own right. The majority of convenience purchases will ‘impulse’ buys, with customers visiting the unit for the comparison offer. It will also serve as a local convenience store for those living close to the site. The proposed convenience floorspace will therefore not directly compete with the Council’s aspirations for a medium size foodstore within Ashford.

7.8.4 Given the above, we conclude that the proposed development will not adversely impact upon any committed or planned investment within Ashford town centre.

7.9 Impact on Town Centre Vitality and Viability

7.9.1 A health check of Ashford town centre has been undertaken to support the planning application, and is attached at Appendix 5 of this Report. This was underpinned by a site visit to the town centre in September 2013.

7.9.2 The Health Check of Ashford town centre demonstrates that the town provides a mix of comparison, convenience and service provision. The town is well represented in terms of comparison retaliating, but is under provided for in terms of convenience stores. It is evidenced by the lack of a main supermarket in the town.

7.9.3 There are a couple of ‘clusters’ of vacant units, most notably at the Park Mall Shopping Centre, which is need of inward investment, and the County Square Shopping Centre, where some units have remained un-let since the extension to the shopping centre opened.

7.9.4 Notwithstanding the current vacancy rates in the town, given the Council’s aspirations set out in the Town Centre AAP, and the modern floorspace available in County Square, Ashford is in a good position to recover from the economic downturn.

7.9.5 Although the development proposes an increase in retail floorspace at the site, much of this will be used for display purposes, and to allow flexibility for potential occupiers, as set out earlier in this Statement. In addition, the types of retailers Henderson is currently in discussion with to occupy the units, have little, crossover with the existing retailers Ashford

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town centre, meaning that there will only be a small level of trade diversion from existing stores in Ashford, as set out in the accompanying Impact Tables.

7.9.6 Whilst it is inevitable that some trade will be drawn from the town centre, this will not be of the level to materially affect the turnover of any of the stores within Ashford. The ‘worst case’ Scenario B as set out at Table 16 of Appendix 7 identifies a cumulative impact of 3.08% on the comparison turnover of the Ashford town centre from within the ten minute catchment. This will be significantly lower when inflow is taken into account. Table 16 identities that the proposed development could divert up to £2.72m from town centre comparison stores at 2015, increasing to £2.76m by 2018. This diversion will be spread over a large number of stores within the centre, meaning that no one store will be so adversely affected to the stage where it will close.

7.9.7 For the reasons set out above, we conclude that the proposed development will not impact on the overall vitality and viability of Ashford town centre.

7.10 Impact on Local Consumer Choice and Trade in the Area

7.10.1 The proposed layout of the subdivided units will allows for a degree of flexibility for the proposed occupiers of the site. For example, as well as traditional in-store retail sales, the additional floorspace could allow browsing for customers who will subsequently buy products online.

7.10.2 The application will result in an increase in the amount of net retail floorspace of 2,104 sq. m. However, in terms of diversion of trade to the proposed retailer, Henderson has been in discussions with a range of fashion, DIY, and furniture / home furnishing retailers, all of which have little, if any cross-over with the existing retailers in Ashford town centre (although a worst case scenario has been adopted for the purposes of the RIA). As such, while the development proposed an increase in retail floorspace, it is anticipated that trade will be diverted from a range of existing retail destinations, both inside and out of the Catchment Area.

7.10.3 Given the range of non-retail services provided for within Ashford town centre, such as banks, offices and other services, the shoppers who currently undertake their day-to-day comparison shopping in Ashford are unlikely to change their shopping habits as a result of the proposed development.

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7.10.4 The proposal will result in increase in choice and competition in Ashford by allowing new retailers with new specific formats to enter the market, whilst not affecting the current choice and retail offer in the town centre.

7.11 Conclusions on Impact

7.11.1 In this Section we have considered the effects of the proposed development on Ashford town centre. The Impact Tables at Appendix 7 of this Statement demonstrate that the proposals, cumulatively assessed with the John Lewis development, are likely to have between a 2.3% and a 3.08% impact on the turnover of Ashford town centre at both 2015 and 2018. However, this represents a worst case scenario and does not take account of the inflow to Ashford town centre from outside of the Catchment Area, which could be in the regions of 40%. Scenario B also assumes that the development will be occupied by more ‘high street’ fashion retailers, which would have more of a crossover with the town centre than the proposed retailers Henderson are currently in discussions with to occupy the units.

7.11.2 Given the above, we conclude that the proposed development fully meets the requirements of Paragraph 26 of the NPPF.

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8.0 Other Planning Issues

8.1 Introduction

8.1.1 NPPF sets out at paragraph 6 that:-

“The purpose of the planning system is to contribute to the achievement of sustainable development” .

8.1.2 There are three dimensions to this which mean the planning system must perform an economic, social and environmental role.

8.1.3 The NPPF does not change the statutory status of the development plan as the start point for decision making. The proposed development that accords with an up to date local plan should be approved. However, at the heart of the NPPF is a ‘presumption in favour of sustainable development’. he NPPF sets out under 13 headings the guidance for achieving sustainable development. In this part of the Statement, we adopt these headings for consideration of this application:

1. Building a strong, competitive economy

2. Ensuring the vitality of town centres

4. Promoting sustainable transport

7. Requiring good design

8. Promoting healthy communities

10. Meeting the challenge of climate change, flooding and coastal change

11. Conserving and enhancing the natural environment

8.1.4 The sections in the NPPF at 3, 5, 6, 9, 12 and 13 are not relevant to the consideration of this application.

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8.2 Building a strong, competitive economy

8.2.1 Paragraph 18 of the NPPF notes that the Government is committed to securing economic growth in order to create jobs and prosperity.

8.2.2 Both Units 1 and 2 of the Ashford Retail Park are currently vacant, with Unit 1 having been vacant for a number of years. As such, although the retail floorspace exists, it currently does not provide any jobs. Despite trying the let the floorspace for a number of years, all attempts to let the retail units to new occupiers have been unsuccessful due to the dated appearance of the buildings .

8.2.3 The application will result in a total Gross Internal Area at the site of 7,533 sq. m across both of the units. According to the HCA Employment Densities Guide (2 nd ed) 2010, this will result in a total of 84 full time equivalent jobs . This figure is based upon the information for retail warehousing. In reality, it is likely that many of the retailers who are currently in discussion to occupy the new units will have much higher employment densities than 1 per 90 sq. m, as set out in the guide.

8.2.4 Of these, typically about a quarter of these would be full time positions, with the remainder being part time. As such, it is estimated that the proposed application could create in excess of 200 new positions at the site. Given that the retail units are currently vacant and therefore not employing any workers, this is a significant increase in the number of jobs available and will thus positively contribute to the employment offer in the local area.

8.2.5 The jobs will range from high end management roles to shop floor positions, and will be available for local residents within Ashford. Many of the retailers currently in discussion to occupy the units offer dedicated training schemes for all employees, with some also offering a range of qualifications. The part time positions of offer also suit single parents and students, who are seeking employment to fit around an existing routine. 8.2.6 As well as the jobs created in-store, there will also be a number of jobs created by the construction phase of the development.

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8.3 Ensuring the vitality of Town Centres

Sequential Assessment

8.3.1 Paragraph 24 of the NPPF confirms that local planning authorities should apply the 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. As the application site is located out-of- centre, and is unallocated, the application site must meet the requirements of the sequential test.

8.3.2 As set out in Section 5 and Appendix 6 of this Report, and in accordance with Paragraph 24, we have considered the suitability and availability of all in and edge-of-centre sites which could accommodate the proposed development, within the borough of Ashford. Following the assessment of the potentially sequentially preferable sites, it was concluded that the application site is the most appropriate site for the proposed development.

Impact Assessment

8.3.3 As set out in more detail in Section 7 of this report, the potential impact of the proposed development has been fully assessed in line with Paragraph 26 of the NPPF and the extant PPS4 Practice Guidance.

8.3.4 The impact assessment at Appendix 7 has been undertaken on a ‘worst case’ scenario assuming that the units will be occupied by ‘high street’ retailers, thus directly impacting with Ashford town centre. In reality, all of the retailers currently in discussion to occupy the units are typical ‘retail park’ operators, selling predominantly a mix of bulky, furniture, homewares and discounted goods. As such, the potential ‘worst case’ impact figure of 3.08% on Ashford town centre, as set out at Table 16 of Appendix 7, is likely to be a very robust assumption. This figure also does not allow for inflow into the town centre from outside the Catchment Area. Nonetheless, a impact figure of 3.08 % is not considered significant enough to have a material effect on the overall vitality and viability of Ashford town centre.

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8.3.5 This Statement has also demonstrated that the small convenience element proposed by this application (up to 300 sq. m) is unlikely to have any material effect on any convenience store within Ashford.

8.3.6 We therefore conclude that the proposed development meets the test set out in Paragraphs 23 - 27 of the NPPF by ensuring the continued vitality and viability of Ashford town centre

8.4 Promoting Sustainable Transport

8.4.1 In accordance with Paragraphs 32 and 36 of the NPPF, the planning application is accompanied by a Transport Assessment .

8.4.2 The Transport Assessment considers the existing situation at the application site, followed by the potential effects of the proposed development on the local highway, public transport, and the walking and cycling networks.

8.4.3 The Assessment confirms that the number of cycle parking spaces to be located at the site is in line with Kent County Council’s current guidelines. In terms of traffic generation resulting from the additional floorspace, the Assessment notes that the proposed development will generate a minimal number of vehicle trips during the Saturday peak hour. However, it is concluded that this will have no material impact on the operation on the surrounding highway network. It is also demonstrated that there is sufficient car parking at the site to accommodate the proposed development.

8.4.4 Given the conclusions contained within the accompanying Transport Assessment, we conclude that the application is acceptable in transport and traffic terms.

8.5 Requiring Good Design

8.5.1 Paragraph 56 of the NPPF notes that good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people.

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8.5.2 This planning application is accompanied by a Design and Access Statement (D&A) which illustrates the concept behind the proposed refurbishment. In brief, the intention is to visually re-invigorate the existing units to provide modern retail warehousing for new tenants.

8.5.3 As set out in the D&A, the application has been evolved to replace the existing unit’s cladding to sensibly and effectively reflect the general feel of the retail park, and of the broader modern retail warehousing environment. The steel frame, roof and concrete floor slab of the existing unit are to be retained. The wall cladding is to be replaced in its entirety with new coated mini-rib panels, brickwork and glazing units to the frontages.

8.5.4 The proposal is to simply replace the existing cladding to provide a modern retail environment in line with the adjacent upgraded units within the park and in accord with the requirements of a modern retail park, but with the servicing and car parking facilities upgraded to provide a modern retail warehouse environment. The form and massing remains exactly as the existing units and to facilitate access where required by the retailer. The existing landscaping at the site will be retained as part of the proposals.

8.5.5 Both local and national policies were considered in the design of the refurbished units, which fully meets the aspirations set out in Paragraphs 65 onward of the NPPF, by achieving the following:

• Adding to the overall quality of the Retail Park • Helping to create a sense of place by applying the same design criteria as used at the opposite end of the Park • Ensuring the development is visually attractive

8.6 Promoting Healthy Communities

8.6.1 Paragraph 69 of the NPPF notes that the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. In accordance with Paragraph 69, the design of the proposed development aims to maintain pedestrian access to

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and through the site. Additional cycle hoops are also proposed at the site to encourage the cycling to and from the site by both staff and customers.

8.7 Meeting the challenge of climate change, flooding and coastal change

8.7.1 Paragraph 93 of the NPPF notes that planning plays a key role in helping to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure.

8.7.2 The accompanying Design and Access Statement identifies the important factors relating to sustainability, as follows:

• The existing structure, sub-structure, car parking areas and building form are to be retained, thereby avoiding the need for extensive works to alter the units.

• The new cladding that is to be installed throughout will meet the upgraded thermal requirements of the current Building Regulations

• Energy saving lighting and heating will be provided throughout by the tenant as part of their fit-out.

• The car parking layout has been amended to allow for more effective servicing of all units so as to separate goods vehicles from the car parking as much as possible.

• Glazed sections are to be provided to allow for natural daylight to mitigate the use of artificial lighting. The proposed entrance doors and glazing provides more glazing than exists, allowing more light to naturally illuminate the units interiors.

8.7.3 Paragraph 100 of the NPPF notes that inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing the flood risk elsewhere.

8.7.4 The accompanying Flood Risk Assessment (FRA) confirms that the development is located within Flood Zone 1. As such, the NPPF flood risk vulnerability and compatibility requirements have been satisfied. The proposed development can also be deemed appropriate in terms of flood risk vulnerability and compatibility, therefore the Exception Test is not required.

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8.7.5 This FRA concludes that the development will not adversely affect onsite, neighbouring or downstream developments and their associated residual flood risk. Having identified and categorised the potential sources of flood risk, including the redevelopment site’s location in a Flood Zone 1, it has also been possible to identify that no specific mitigation measures for each of the sources of potential flooding are required, including surface water management.

8.7.6 The residual flood risks can be judged low to zero and this replicates the best practice approach promoted by the NPPF Technical Guidance and contemporary flood risk management. The flood risk assessment has not identified any significant on or off site flood risk implications arising from the redevelopment proposals that could be regarded as an encumbrance to the development. It is therefore recommended that the proposals set out within this FRA will ensure that the proposed redevelopment on the Ashford Retail Park will be compliant with the requirements of the NPPF.

8.8 Conserving and Enhancing the Natural Environment

8.8.1 Paragraph 109 of the NPPF notes that the planning system should contribute to and enhance the natural and local environment, by amongst other things, protecting and enhancing valued landscape, geological conservation and soils, and preventing both new and existing developing from contributing to or being put at risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution, or land instability.

8.8.2 A Screening Opinion request has been included as part of the application covering letter to confirm whether a full Environmental Statement will be required. However, given the scale of the development and the surrounding uses we would not anticipate the development constitutes EIA development.

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9.0 Summary and Conclusions

9.0.1 This Planning and Retail Statement has been submitted in support of an application to refurbish the existing Units 1 and 2 of Ashford Retail Park which includes the installation of additional floorspace at mezzanine level.

9.0.2 This Statement has set out the scope of the proposed development in light of the existing land uses at the site and the relevant planning policy at a local and national level.

9.0.3 Taking account of all planning matters relating to the proposed development, this Statement concludes that the proposed development will achieve the aims of the NPPF, by achieving the following:

• The proposed development will help to build a strong and competitive economy by providing jobs at the site in place of the existing vacant retail units which do not provide any jobs at present. The proposed retailer will offer comprehensive training opportunities for all staff; • The development ensures the vitality of existing town centres by meeting the sequential test, and being unlikely to have a significant adverse impact on any of the criteria at Paragraph 26 of the NPPF; • The development is well located to promote sustainable transport, and includes proposals to improve access for pedestrians, cyclists and users of public transport; The development is of a good design, and the proposed refurbishment will enhance the design of the existing buildings. • The development meets the challenge of climate change, flooding and coastal change by improving the overall sustainability of the buildings and allowing increased levels of natural light.

9.0.4 The proposed development is also in accordance with Ashford Borough Council local policy.

9.0.5 In light of our analysis, it is concluded that the proposal is consistent with the requirements of current planning policy, and should therefore be treated favourably.

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15 Minute Walk Time

10 Minute Drive Time

Site Location

Catchment Area Plan

Plan Ref Appendix 1 Project Units 1 and 2, Ashford Retail Park Date November 2013

WYG Planning & Environment

Tel: +44(0)20 7250 7500 Fax: +44 (0)20 7250 7501 Appendix 2 - 15 Minute Walk Time Plan Legend

15 Minute Walk Time

Site Location

15-Minute Walk Time Plan

Plan Ref Appendix 2 Project Units 1 and 2, Ashford Retail Park Date November 2013

WYG Planning & Environment

Tel: +44(0)20 7250 7500 Fax: +44 (0)20 7250 7501 Appendix 3 - Goad Plan of Ashford Town Centre Legend

Primary Shopping Frontage

Bank Street Frontage

Convenience

Comparison

Vacant

Other

Services

Miscellaneous

Ground Floor Level

N.B. map not to scale

Ashford Town Centre Land Use Plan

Plan Ref Appendix 3 Project Units 1 and 2, Ashford Retail Park Date November 2013 Lower Ground Floor Level WYG Planning & Environment Tel: +44(0)20 7250 7500 Fax: +44 (0)20 7250 7501 Appendix 4 - Competing Centres Plan Legend

1 Ashford Retail Park Vacant unit (former Allied Carpets) Vacant unit (former Homebase) TK Maxx PC World Boots Argos 17 12 2 Ashford Town Centre 11 3 McArthur Glen Designer Outlet Village

Food Stores 4 15 4 Lidl, New Street/Forge Lane 5 Co-op, Brookfield Court 2 6 Tesco, Park Farm Estate 7 Asda, Kimberley Way 8 Co-op, Hunter Avenue 9 Tesco Extra, Crooksfoot 10 Tesco Express, Mace Lane 11 Waitrose, Templer Barracks 14 10 Retail Warehousing 8 12 Warren Retail Park 5 Dreams Staples 3 Family Bargains

13 7 13 Gallagher Retail Park B and Q Pets at Home Currys Halfords Paul Simon 1 16 14 Matalan

15 Mace Lane Tile Giant HSS Hire Kwick-fit 6 16 Ashford Trade Centre Topps Tiles Bathstore Carpetright Carpets for Less Orbital Beds City Electrical Factors Various car showrooms and trade units

17 John Lewis at Home

Competing Centres Plan

Plan Ref Appendix 4 Project Units 1 and 2, Ashford Retail Park Date October 2013

WYG Planning & Environment

Tel: +44(0)20 7250 7500 Fax: +44 (0)20 7250 7501 Appendix 5 - Ashford Town Centre Health Check Appendix 5 Ashford Town Centre Health Check

Introduction

A full health check of Ashford town centre was carried out by WYG Planning & Environment on 19 September 2013. In accordance with the extant PPS4 Practice Guidance, this report analyses the ‘health’ of Ashford town centre by assessing a number of indicators, including diversity of uses, vacancy rates, accessibility, and quality of the urban environment among others. The report provides useful insight into the state of Ashford’s town centre.

Ashford is large town in the centre of Kent, located approximately 75 km south east of London and approximately 20km to the south west of Canterbury. The town centre is enclosed within a central ring road and contains a large covered shopping centre, County Square, and a smaller part-covered shopping centre at Park Mall. The remainder of the town centre retailing is focussed along High Street and Bank Street. The town centre is well connected to the transport network and lies to the south of both the M20 and the A20, which connect Ashford to Folkestone and Dover in the east and Maidstone and London to the north-west.

The town falls within the Ashford Borough and is allocated as a town centre within the adopted Ashford Borough Core Strategy. It is the largest centre within the Borough and as such, sits at the top of the retail hierarchy. Ashford town centre is made up of a mix of small, medium and large retail units and acts as a sub-regional shopping destination.

Image 1: The main High Street. Image 2: Park Mall Shopping Centre

Diversity of Main Town Centre Uses

Table 1 below sets out the composition of uses in Ashford Town Centre on 19 September 2013 compared to national averages supplied by GOAD (June 2013). The survey shows that there are 304 retail units within Ashford Town Centre which offer a range of retail goods including convenience, comparison, and retail services.

National Floorspace National Retail Category No. Units Ashford % Ashford % Average % (sq. m) Average % Convenience 19 6.0 8.73 4650 7.0 17.64 Comparison 128 42.0 41.22 37,570 57.0 46.44 Services 109 36.0 36.32 15,720 24.0 24.27 Vacant 41 14.0 12.58 940 10.0 10.60 Other 7 2.0 1.15 6470 2.0 1.05 Total 304 100 100 65,530 100 100 Table 1: Retail composition in Ashford September 2013. Appendix 5 Ashford Town Centre Health Check

Our analysis of the current retail composition in Ashford shows that the town centre is slightly over represented in terms of comparison retailers. This would be expected for a town such as Ashford which is well connected to a large population and has recently seen the completion of the extension to the County Square Shopping Centre. The town centre is however underrepresented in terms of convenience stores. Although the town centre boasts an Iceland and a Marks and Spencer Food Hall, there are no major supermarkets located within the town.

The town is well represented by retail services, including hairdressers and travel agents, as well as financial services, which include banks and estate agents. The town centre is however underrepresented by way of eating and drinking establishments, suggesting that the town centre is not seen as somewhere with a thriving night time economy, and where people choose to eat and drink.

There are 46 vacant units within Ashford which is 2.6% above the national average. Although many of these can be found along the primary shopping frontages, 14 of the vacant units are located within Park Mall. It is anticipated that many of these vacancies will be filled once the extended shopping centre has had a chance to establish itself as a prime retail destination, which may have been hindered by the economic downturn. The majority of the vacant units across the town centre are small, with the exception of one of the new units within County Square, which measures 1,460 sq. m in size.

The above analysis excludes retail categories such as pubs and betting offices.

Amount of Floorspace Uses in Edge-of-Centre and Out-of-Centre Locations

The majority of the retail provision within Ashford is found within the inner ring road, in a town centre location. There are a few edge of centre sites, including the Lidl / Fitness First development on New Street, and the Farmfoods and Bensons for Beds, also on New Street.

There are a number of out of centre retail parks and stand alone units within the Borough including the Warren Retail Park, Ashford Retail Park, Gallagher Retail Park and Ashford Trade Centre. Ashford also boats a designer outlet centre which is located to the south east of the town centre and includes over seventy stores, including fashion, sports and homeware retailers. A new John Lewis development, located on Fougeres Way, is due to open in November 2013. The store is a two storey, 40,000sq ft John Lewis at Home which will sell furniture and electrical goods as well as a café and Click & collect service point.

Retailer Representation

Ashford is a large, well connected town, which acts as a sub-regional shopping centre within Kent. The town has a strong representation of national multiple retailers, with 21 of the top 30 retailers present in the town centre (Goad 2011). Key retailers who are not currently present include House of Fraser and Primark. the number of retail requirements in Ashford was 93 in October 2013 (EGi, 2013). This indicates that there is significant demand for retailers to locate in Ashford. The retailers with current requirements within Ashford town centre include Robert Dyas, Sainsbury’s Local and Waitrose. Appendix 5 Ashford Town Centre Health Check

Yield Data

There is currently no up-to-date data available for Ashford.

Vacancies

As outlined above, 14% of retail units in Ashford are vacant. This is slightly higher than the national average of 12.58% - a difference of 1.42%. Vacant floorspace in Ashford accounts for 10% of the total floorspace compared to the national average of 10.60%.

During the time of the survey, vacancies within Ashford were largely concentrated within the Park Mall Shopping Centre. This may signify that comprehensive redevelopment the Park Mall shopping centre is needed in order to attract new occupiers.

Pedestrian Flows

Pedestrian footfall within Ashford was considered to be highest along High Street with the junction of Bank Street and the County Square Shopping Centre. Within the County Square Shopping Centre, pedestrian footfall was highest in the older part of the building, with the extension experiencing relatively low levels of footfall when the site assessment was carried out. Footfall was also very low throughout Park Mall when site assessment was undertaken.

Accessibility

Train Ashford is served by Ashford mainline and International stations to the south east of the town centre, with services provided by Eurostar, Southeastern and Southern trains. The services into London take approximately 38 minutes in London St Pancras, and trains depart half-hourly. The station also provides services to other towns in Kent, including Folkestone, Dover, Ramsgate and Canterbury.

Bus Ashford is served by a number of bus routes, with Park Street acting as the main bus interchange for the town centre. There are a large number busses serving the International Station and nearby residential areas, as well as other towns in Kent including Folkestone and Dover.

Private Car Ashford has good road links, being close to the M20 and A20, making it very accessible for private vehicles. Car parking is provided within the town by 17 car parks. Ashford Council manages 8 of these whilst the remaining 9 are privately controlled. The average cost of parking within the town centre is 90p per hour.

Pedestrian and Cycle Ashford town centre is surrounded by a ‘shared space’ ring road, which makes it easy for both pedestrians and cyclists to access the town centre. There are a number of cycle hoops located at various points within the town centre, which encourages local residents to visit the town by bike. The railway to the south of the town centre acts as a barrier to pedestrians wishing the access the town centre from the south, but the town is easily accessible for pedestrians living to the north of the town centre. Appendix 5 Ashford Town Centre Health Check

Customer Views and Residents Views and Behaviours

The Council has not commissioned a Retail Study since the CBRE report was published in December 2003. We therefore do not have access to any up to date information on the current customer and resident’s views on Ashford town centre.

Perception of Safety and Occurrence of Crime

Ashford town centre falls within the Ashford urban and rural neighbourhood policing team of the Kent Police patrol area. According to Kent Police’s website (www.kent.police.uk), there are no major crime and safety issues currently affecting the town centre. Kent Police have reported that crime remained broadly stable between March 2011-2013 and in the last year, crime was below the national average.

State of Town Centre Environmental Quality

The majority of Ashford town centre is either pedestrianised or contained within the County Square Shopping Centre, providing a pleasant, traffic free environment for the shoppers using the town. At the time of the site visit, the town centre was considered to be clean with little evidence of litter or graffiti. In general, the quality of the town centre environment is considered to be quite good, although there are areas of the town centre which are in need of investment, including Park Mall and the eastern end of the High Street.

Future Investment in Ashford Town Centre

The Ashford Core Strategy (2008) and Town Centre Area Action Plan (2010) note that development of the town centre is a priority and sites will be identified for an additional 8,000 jobs and up to about 2,500 new dwellings by 2021. It is not apparent, however, that there is an emerging scheme for new development in the town centre.

The Area Action Plan identifies a number of sites that could accommodate additional retail development in the town centre. The potential for these sites to come forward for development is explored in more detail within the accompanying Planning and Retail Statement.

Conclusion

Ashford Town Centre provides a mix of comparison, convenience and service retailing, and is the largest centre within the Borough. The town acts as a sub-regional retail destination, which is enhanced due to the presence of a large designer outlet centre just to the south east of the town centre. Recent investment has taken place in the town by way of the extension to the County Square Shopping Centre, although the Council has identified a number of key town centre sites where they feel further investment is required. Overall, we consider the general health of the town centre to be average. Appendix 6 - Sequential Assessment Legend

1 Elwick Place

2 Park Mall 12 13 3 Vicarage Lane Car Park 2 Corner of Elwick Road 4 and Station Road 5 The Commercial Quarter

6 The Southern Expansion 3 Quarter 11 7 Victoria Way East 14 8 Former Powergen north The International Station 8 1 9 Quarter 4 Former B & Q Site, Beaver 10 Road 6 11 The Civic Quarter 7 12 The Residential Quarter

13 New Street North 10 9 Vacant Retail Unit, County 14 Square

N.B. map not to scale

Sequential Sites Plan

Plan Ref Appendix 6a Project Units 1 and 2, Ashford Retail Park Date November 2013

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Site 1 – Elwick Place

Introduction: The site is situated to the south of Elwick Road between Beaver Road Bridge and Gasworks Lane. The site is identified as one of the most important of the development sites in Ashford, it is therefore fundamental that any development on the site is of the highest quality.

Address: Elwick Road, Ashford, TN23 1PD

Size: Approximately 31,790 sq. m

Designation: Edge of centre: 250 – 300 metres outside of the Primary Shopping Area (PSA).

Within the adopted Ashford Town Centre Area Action Plan (AAP), the site is allocated as Policy TC3. This policy outlines how a masterplan will be developed and agreed with the Council in the future. It is considered the most appropriate mix of development for the site will be retail-led development to the west of Elwick Square and a mix of uses including residential and commercial to the east of Elwick Square. The AAP states that outline master-planning studies have shown that the site has the potential to accommodate around 27,000 sq.m of floorspace in addition to residential uses.

Current Use and Part of the site is used as a car park whilst the rest of the site lies vacant. Planning History: A draft masterplan was published by the Council in 2010, but it is not apparent that an application for the site’s redevelopment has come forward.

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Availability The Council’s aspirations are for the development at the site to be brought forward in phases. Although a draft masterplan has been produced, it is not clear whether this will be implemented in the near future. Nonetheless, as the majority of the site is vacant, and clear of buildings, it is considered that the site could become available in the short to medium term. Suitability The Ashford Town Centre Area Action Plan outlines how, due to the size of the site, development will have to take place in phases. Policy TC3 of the adopted AAP states that the site will provide a mix of uses and that the quality of development is imperative given the site’s strategic importance. In light of this, it is considered that the Council’s visions for the site are not in line with the proposed development for the Ashford Retail Park units. This application proposes large scale retail warehouse buildings and would therefore not be appropriate at this key strategic site, especially given the emphasis by the Council on high-quality, diverse urban design. Further, locating the proposed increase in sales floorspace at Elwick Place would result in the disaggregation of floorspace from the current retail units and therefore the Elwick Place site is not appropriate for the proposed development. Viability Any development for a retail unit at the site would have to form part of a wider development and it would not be viable to develop the site for the proposed mezzanine extension. Assessment Given the above, the site is not suitable or viable for the proposed development; however the site could be available in the short-medium term.

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Appendix 6b Sequential Site Assessment

Site 2 – Park Mall

Introduction: This site is located towards the northern part of the town centre and currently comprises a mix of comparison retail floorspace and a multi storey car park. The shopping centre is anchored by Wilkinson.

Address: Park Mall, Ashford, Kent TN24 8RY

Size: Approximately 22,710 sq. m

Designation: Primary Shopping Area

Policy TC4 of the 2010 Ashford Town Centre Area Action Plan (AAP) allocates the site for a comprehensive mixed use redevelopment. The majority of the floorspace should be for comparison goods, but three should also be a limited amount of convenience floorspace, as well as residential.

Current Use and The site is currently occupied by the Park Mall shopping centre and car park. 12 of Planning History: the centre’s 30 units are currently vacant.

There have been a couple of applications to change the use of individual units over the past few years, but there is no recent planning history for the site as a whole.

Availability: Many of the individual retail units within Park Mall are currently vacant, meaning that part of the site is available for replacement retail. However, these are all small in scale, the largest once being just 320 sq. m in size. Many of the units within Park

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Appendix 6b Sequential Site Assessment

Mall are currently occupied, and the car park provides a valuable parking facility for the town. Nonetheless, while the site is not immediately available, we acknowledge that, given the allocation within the Town Centre AAP, the site might come forward for redevelopment in the short-medium term.

Suitability: The Council’s vision, as set out in the AAP, is that the site will come forward as part of a comprehensive redevelopment to include replacement car parking, comparison retailing, up to 2,000 sq. m net of convenience retailing, and some residential units. The current application at the Ashford Retail Park proposes the creation of additional floorspace within existing units at the Park. Although up to 300m of this will be for the sale of convenience goods, this is of a significantly smaller scale than that envisaged at Park Mall. As such, it would not be suitable to locate the additional floorspace proposed at the Ashford Retail Park at Park Mall, as it would not be line with the Council’s aspirations for the site.

It would also not be suitable to relocate the entire development at Ashford Retail Park. AAP Policy TC4 clearly states that development at Park Mall should be of an appropriate scale and massing that relates well to the surrounding buildings. The size of the units proposed at the Ashford Retail Park are not of a scale that would be appropriate in this key entrance site to the town centre.

Viability: The site is located in a town centre location, and presents a viable location for the retailers proposed at the Ashford Retail Park.

The Ashford Town Centre AAP clearly states that the site is allocated for a comprehensive mixed use development. This will involve relocating existing businesses, replacing car parking and providing a new mixed development to include comparison and convenience floorspace, as well as residential uses. It would not be financially viable for the applicant to fully redevelop the Park Mall site to be able to achieve a net increase in sales area of 2,104 sq. m, as proposed by this application. As such, Park Mall does not present a viable location for the proposed development.

Assessment: While we acknowledge that there is a possibility that the site may come forward for redevelopment in the next 5 years, given the aspirations of the adopted Ashford Town Centre SPD, it does not present either a suitable or viable location for the proposed application.

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Site 3 – Vicarage Lane Car Park

Introduction: This site is a key brownfield development site within the former ring road and is located within the Conservation Area. Vicarage Lane Car Park is currently the town centre’s principal surface car park and accommodates around 190 car parking spaces.

Address: Vicarage Lane Car Park, Vicarage Lane, Ashford, TN23 1NJ

Size: Approximately 7,900 sqm

Designation: Edge of centre: 115m metres from the PSA.

Policy TC5 (Vicarage Lane Car Park) of the Town Centre Area Action Plan outlines that the site should be at the centre of a comprehensive redevelopment for a mix of uses to include residential (predominately on the upper floors) with retail, office and leisure on the ground floor.

Current Use and The site is currently occupied by the Vicarage Lane Car Park. There have been a Planning History: few applications for minor changes but there is no recent planning history for the redevelopment of the site as a whole.

Availability: The Town Centre AAP notes that redevelopment proposals will need to demonstrate that there is sufficient capacity in the rest of the car parking stock if no new car parking sites can be brought forward to replace the parking spaces which will be lost. It is therefore envisaged that this site will not be immediately available as a replacement site will need to be identified.

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Suitability: The Ashford Town Centre AAP states that any development within this area should address the Conservation Area setting and the surrounding urban fabric, and accordingly smaller building block forms would be more appropriate. Therefore, the proposed extension is not appropriate development for this location given that it would have a larger footprint. Further, it is not an appropriate configuration for a retail warehouse development.

Viability: The site has a limited frontage onto the High Street and therefore any retail at the site is likely to attract only limited footfall. In order for the proposed retailers to trade successfully, a more centrally placed location would be needed.

Moreover, the Ashford Town Centre AAP clearly states that the site is allocated for a comprehensive mixed use development. This will involve replacing car parking and providing a new mixed development to include comparison and convenience floorspace, as well as residential uses. It would not be financially viable for the applicant to fully redevelop the Park Mall site to be able to achieve a net increase in sales area of 2,104 sq. m, as proposed by this application.

Assessment: The site is currently used as a car park owned by the Council, and whilst the site may be available in the near future, if a suitable alternative car park site can be identified, it is neither suitable nor viable for the proposed development.

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Site 4 – Corner of Elwick Road and Station Road

Introduction: The site is located on the corner of Elwick Road and Station Road, and the site marks an important entrance to the town centre from the railway station and from the south. The site provides a transition between the railway station and the heart of the town centre.

Address: Corner of Elwick Road/Station Road, Ashford, TN23 1NN

Size: Approximately 10,230 sq. m

Designation: Out-of-centre: 360 metres from the PSA.

The site is allocated in the Town Centre Area Action Plan as Policy TC6 which states that development should be for a mix of uses which should include predominantly office development with a focus on retail and/or leisure uses at ground floor level fronting Station Road.

Current Use and On the site currently lies the vacant South Kent College building and Swanton Planning History: House, which is a vacant office building.

An application was submitted in 2011 for the demolition of existing buildings and structures and construction of new college buildings (class D1) of 14,688sqm GEA and associated works. The application was granted subject to a Section 106 agreement (ref: 11/00757/AS). The funding for this project has since fallen through and the Council have agreed plans and designs for a new scheme, subject to securing new funding sources. Nonetheless, the Council wish to keep the site for a college.

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Availability: Although all of the buildings are currently vacant, the Council is actively working to secure a new educational building on the site. We therefore do not consider the site to be available for a retail warehouse development. Suitability: The site is not suitable as it is not large enough to accommodate the existing retail warehouse units and associated facilities. To occupy the site solely with retail uses would also not be in accordance with the aspirations set out in the Town Centre AAP, as the Council envisages a predominantly educational-led development with some office and ground floor retail. Viability: The Ashford Town Centre AAP aspirations for the site include a mix of uses as part of a wider comprehensive scheme, to include predominantly office use, with elements of retail. Having spoken with a member of the policy team, however, it is clear that the Council wish to dedicate much of the site for educational use. A retail use is therefore not in accordance with the Council’s aspirations.

Further, it would not be viable to develop the site for the additional floorspace, as it would have to form part of a wider development. To relocate the retail units to this site would not be viable as the site is not large enough to accommodate them.

The site lies outside of the PSA and is not located near to other retail uses. For this reason, the relocation of the retail warehouse units would not be viable based on a lack of footfall. The units would require a prime town centre location in order to trade successfully. Assessment: Whilst part of the site is being marketed for potential development and is therefore available, the site is neither suitable nor viable for the proposed development.

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Appendix 6b Sequential Site Assessment

Site 5 – The Commercial Quarter

Introduction: This extensive site sits adjacent to Ashford railway station and is identified as the dynamic new main business sector of the town. It is a highly accessible site adjacent to both the domestic and International stations.

Address: Station Road/Tannery Lane, Ashford, TN23 1HU.

Size: Approximately 60,350 sq. m

Designation: Out of centre: 410 metres from the PSA

Policy TC9 of the Ashford Town Centre AAP allocates the site as the location for new office development in the future and playing a fundamental part in the job creation role within the town. It is considered that the site should be able to accommodate around 55,000 sq.m of new office floorspace alongside small scale retail and/or leisure uses of around 2,500 sq.m alongside approximately 150 residential units.

Current Use and Currently on site is a large 11 storey office block, a large car park and small scale, Planning History: mainly light industrial employment uses.

Applications for minor works to some of the buildings on the site have been submitted, however, there are no major applications for the site’s redevelopment. Availability: Although the site is allocated within the Town Centre AAP for new office development, the site is currently mostly occupied. As such, there is no guarantee that it will come forward for redevelopment in the short to medium term.

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Suitability: Although the site could accommodate the proposed development in its entirety, this would compromise the Council’s aspirations for the site as key location for office development. This would mean that the Council would have to find another key town centre site to accommodate the 55,000 sq. m of new office floorspace that is proposed. As such, we consider the site to be unsuitable for the scale and type of retail development proposed. Viability: The AAP allocates the site for approximately 2,500 sq. m of retail and/or leisure uses, which is not of a sufficient scale to accommodate the proposed development. In any event, as the proposed extension is a key ancillary function of the existing store, it would not be viable to disaggregate the two components. It would also not prove a viable option to relocate the retail units on this site given that it is outside of the PSA and will therefore not have the required footfall to sustain the retail units. In order for the proposed retailers to trade successfully, a more centrally placed location would be needed. Further, this option would also result in the relocation of the existing uses on the site, which again would not be viable.

Assessment: Given the above, we can conclude that the site is neither suitable nor viable for the proposed development. It is also not likely to come forward in the short to medium term.

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Site 6 – The Southern Expansion Quarter

Introduction: The land sits to the south of the railway lines and west of Beaver Road.

Address: Victoria Road, Ashford

Size: Approximately 18 ha (180,090 sq. m)

Designation: Out of Centre: 530m from the PSA.

Policy TC10 of the Ashford Town Centre AAP states that the site should accommodate a large development with the primary focus on residential uses, a proposed Learning Campus and a 500 space multi-storey car park, all served by the new Victoria Way. There will also be a mix of uses including retail, leisure, commercial and community-related uses.

Current Use and The site contains a small residential community and primary school, vacant Planning History: brownfield sites and commercial units.

There is an not an application for the redevelopment of the site as a whole but there are applications which are either determined or pending consideration on parts of the site (see availability section below). Availability: There is currently no masterplan in place for the redevelopment of the entire site. Having spoken with a member of the Council’s policy team, we are aware that the western part of the site has planning permission 1250 homes, and this application is due to be resubmitted with a focus on more family housing. The central part of the site (see site 8) has an application for a supermarket which is pending consideration. The eastern edge of the site is currently available but has been

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Appendix 6b Sequential Site Assessment

earmarked for more family housing. Therefore, only the eastern part of the site is available and it is not likely to that will become available in the short term.

Suitability: The Council would like to see the site developed with a predominantly residential focus, with elements of retail. This application proposes the creation of mezzanine floorspace within the existing retail warehouse units. The relocation of the retail units from the Ashford Retail Park to the Southern Expansion Quarter site would not result in a scale of development that fits with the AAP aspirations. It addition, the location of this site (outside of the PSA) would not be appropriate for the proposed development as the retails units would require a more centrally based town centre location to trade successfully. Therefore, the site is not suitable for the scale of retail floorspace proposed by this application. Viability: It would not be a viable option to disaggregate the proposed floorspace from the existing retail units at the Ashford Retail Park. This option would also not promote the occupation of the current retail units at Ashford Retail Park. Assessment: We conclude that only part of site is available and this is unlikely to be available in the short-medium term. The site is not suitable or viable for the proposed development.

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Appendix 6b Sequential Site Assessment

Site 7 – Victoria Way East

Introduction: The land is situated between Beaver Road in the east and the proposed Victoria Square and Learning Link in the west.

Address: Victoria Way, Ashford.

Size: Approximately 92,590 sq. m

Designation: Out of Centre: 450 m from PSA.

Policy TC11 (Victoria Way East) of the adopted Town Centre Area Action Plan allocates the site for future development of residential, office and education uses, with a mix of active uses such as small retail at ground floor level. Current Use and The site currently contains a mix of existing residential, commercial/industrial Planning History: properties, a school and vacant brownfield sites.

Planning permission exists for a Learning Campus on the northern side of Victoria Way and a residential-led development on the southern side of Victoria Way. We understand that the Learning Campus scheme is now unlikely to be implemented. Availability: Although the site as a whole is not currently available, there may be parts of the site which would be available in the short term for retail development.

Suitability: The AAP states that development on this site should be a mix of residential, office and education uses with a small element of retail at ground floor level. It is therefore considered that this site would not be appropriate to locate the proposed development as the unit sizes would be too small. Given the Council’s aspirations for the site, it would not be suitable to relocate the retail units to this site.

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Viability Even if it were possible to amalgamate proposed units so that they could accommodate the proposed increase in floorspace, it does not pose a viable option to disaggregate the proposed additional floorspace as it is a key ancillary element to the existing retail units. Assessment: Given the Council’s aspirations, the site is neither suitable nor viable for the proposed development.

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Site 8 – Former Powergen North

Introduction: The site is situated to the west of the Learning Link, bounded to the west by Gasworks Lane and the south by the proposed route of Victoria Way. It is a key brownfield site in a strategic location, and forms part of a large site which was granted outline planning permission on appeal in 2008 for 1,002 residential units, and 8,229 m² of commercial floorspace, to include retail.

Address: Gasworks Lane, Ashford, TN23 1HS

Size: Approximately 24,530 sq.m.

Designation: Out of centre: 525 metres from the PSA.

Policy TC12 of the Ashford Town Centre AAP allocates development in a serious of phases. The initial phase of development however should include a public car park with 500 spaces. Development which is deemed appropriate on this site includes, residential, food retail and complementary comparison retail space.

Current Use and Currently, the site is largely derelict. Planning History: Having spoken with a Council officer, we have ascertained that an application for a supermarket on this site is currently pending consideration.

Availability Given the current application for a supermarket on this site, it is not likely that the site will be available.

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Suitability It would not be a suitable option to relocate the entire development to this site, given the current application for a foodstore. Viability Whilst the AAP does allocate the site for comparison and convenience floorspace, it would not be a viable option to locate the level of floorspace proposed for the units at Ashford Retail Park, as it would result in disaggregation from the existing warehouse units. We have demonstrated that the proposed extension provides a key ancillary function to the existing units, therefore it would not be a viable option to separate the two elements. Assessment Given the above we conclude that the site is not a suitable or viable option for the proposed development, nor is it likely to come forward in the short term.

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Site 9 – The International Station Quarter

Introduction: The site is to the south of the existing town centre and has been identified as a key gateway site. It is adjacent to the train station with a long-established residential community to the south. It is considered that this site will take an important role in the expansion of the town centre.

Address: Station Road, Ashford, Kent, TN23 1EZ

Size: Approximately 13.8 ha (138,460 sq. m)

Designation: Out of centre: 695 metres from the PSA

Policy TC15 of the Ashford Town Centre AAP states that development should seek to improve the connectivity between the stations, the town centre and the Designer Outlet Centre. A mix of potential uses is expected, with a predominantly office based focus. Furthermore, it is considered that there are retail, leisure and office opportunities on the Romney Marsh Road.

Current Use and The area is currently dominated by the international station, multi-storey and Planning History: surface car parks.

From undertaking a desktop study of the Council’s online planning records, it is not apparent that an application for the redevelopment of the site has come forward. Availability Due to the physical constraints of the site, it is not envisaged that the site is likely to come forward in the short to medium term.

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Suitability The site requires a comprehensive redevelopment, with a focus on public realm and connectivity improvements and any development at the site would have to take account of the potential uses of the entire site. As outlined in the AAP there are some constraints on parts of the site such as the land around South Store and Eastmead Avenues currently lying with the 100 year floodplain.

Although the AAP identifies that there are options for retail along Romney Marsh Road, these are likely to be of a significantly smaller scale than the level of floorspace proposed by this development. The Council would like to see the site developed for a predominantly office led scheme, and therefore accommodating the level of retail floorspace proposed by this application would jeopardise the Council’s aspirations. The site is therefore not considered to be suitable for the proposed development.

Viability Even if the level of floorspace proposed by this application could be accommodated along Romney Marsh Road, it would not be a viable option, as it would result in the disaggregation from the existing retail warehouse units. We have demonstrated that the proposed extension provides a key ancillary function to the existing retail units, therefore it would not be a viable option to separate the two elements.

Assessment To conclude, the site is not a suitable or viable option for the proposed development, nor is it likely to come forward in the short term.

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Appendix 6b Sequential Site Assessment

Site 10 – Former B&Q Site, Beaver Road

Introduction: The site is adjacent to the main entrance to the International Railway Station and is situated at the corner of the Beaver Bridge junction.

Address: Former B&Q Site, Beaver Road, TN23 7ST

Size: 10,630 sq. m

Designation: Out of centre: 695 metres from the PSA.

Policy TC16 of the Ashford Town Centre AAP states that the site is allocated for mixed use development, utilising the gateway location. The main use on the site is envisaged to be a high quality office development, with some residential on the upper floors and retail and/or leisure uses at street level. Current Use and The current building is used as a retail warehouse. Planning History: There are no notable, recent or relevant planning applications for the site.

Availability The site requires a comprehensive redevelopment, with a focus on public realm and connectivity improvements and any development at the site would have to take account of the potential uses of the entire site. As outlined in the adopted AAP the site has physical constraints, for example, part of the site falls within Flood Zone 2. Given the above, and the fact that the retail unit at the site is currently occupied, we do not expect the site to come forward in the short term. Suitability Whilst the AAP identifies that there are options for retail along Romney Marsh Road, these are likely to be of a significantly smaller scale than the level of floorspace proposed by this development. The Council would like to see the site

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developed for a predominantly office led scheme, and therefore accommodating the level of retail floorspace proposed at the Ashford Retail Park would jeopardise the Council’s aspirations. The site is therefore not considered to be suitable for the proposed development. Viability Even if the level of floorspace proposed by this application could be accommodated along Romney Marsh Road, it would not be a viable option, as it would result in the disaggregation from the existing retail units. We have demonstrated that the proposed extension provides a key ancillary function to the existing retail warehouse units; therefore it would not be a viable option to separate the two elements. Assessment Given the above, we conclude that the site is not a suitable or viable option for the proposed development, nor is it likely to come forward in the short term.

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Appendix 6b Sequential Site Assessment

Site 11 – The Civic Quarter

Introduction: This site is situated to the east of the town centre and close to the international and domestic railway stations. The focus of development is to be concentrated on Station Road and Tannery Lane.

Address: Tannery Lane, Ashford, TN23 9SP

Size: Approximately 19.7 ha

Designation: Edge of centre: 20m from the PSA.

Policy TC17 of the Ashford Town Centre AAP outlines how there is opportunity for a relatively small amount of new development to help intensify the land fronting Tannery Lane and Station Road, this should be mainly office uses with community, retail and leisure uses on the ground floor. Future plans for the site also include enhancing the open character of the site, respecting the setting of the Green Corridor. Current Use and The current uses on the site are established large scale educational, leisure and Planning History: civic uses with the Civic Centre and the Stour Leisure Centre. Availability The site is virtually all occupied; the site is therefore unlikely to come forward for redevelopment in the short to medium term.

Suitability The AAP advocates that the site should be used for civic and leisure uses, with only a relatively small amount of new development taking place. The AAP states that ancillary retail would be acceptable in this location, although this is likely to be of a

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much smaller scale than that proposed by this application.

Viability To accommodate the proposed extension would result in disaggregation and would not present a viable option given that the proposed extension poses a key ancillary function to the main store.

Assessment In short, we do not consider the site to be suitable or viable for the proposed development, nor do we anticipate the site coming forward in the short term.

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Site 12 – The Residential Quarter

Introduction: The Residential Quarter is situated to the north of the town centre. The focus of development for the Quarter is residential development with small scale retail and leisure uses at ground floor level. The site is to act as a transition between the retail of the town centre and the nearby residential areas.

Address: New Street, Ashford, TN23 8TN

Size: Approximately 14.3 ha (143,440 sq. m)

Designation: Edge of Centre: 290m from the PSA.

The aim of Policy TC18 of the Ashford Town Centre AAP is to act as a careful transition from the substantial and larger scale development proposed in the Town Centre Core to the existing residential areas to the north and west. Small retail or leisure uses may be provided at ground floor level.

Current Use and The site is characterised by mainly terraced residential properties. The area also Planning History: contains a mix of retail and leisure uses at New Street and the Mace Lane industrial estate to the east. The Quarter also includes a small part of the river corridor at the eastern end of Mace Lane and encompasses the Riverside Business park development.

From undertaking a desktop study of the Council’s online planning records, it is not apparent that an application for the comprehensive redevelopment of the site has

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come forward.

Availability The western parts of the site, namely the New Street site, where retail units are located are fully occupied and therefore not likely to become available in the short to medium term. The rest of the site is occupied by existing residential properties, leisure and industrial uses and is therefore unlikely to become available in the short to medium term.

Suitability Given that the Council envisages predominantly small-scale retail at this site, a large scale retail warehouse development would not be suitable at this location.

Viability The site is largely occupied by existing buildings of various uses, any new retail warehouse development would therefore require the relocation of existing uses, which would not be a viable solution.

Assessment In light of the above, the site is not considered to be suitable, viable or available for the proposed development.

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Appendix 6b Sequential Site Assessment

Site 13 – Vacant Retail Unit, County Square

Introduction: The site is located towards the southern part of the town centre. The site is a vacant retail unit in the newly extended County Square Shopping Centre. The County Square Shopping Centre is anchored by Debenhams.

Address: County Square Shopping Centre , Ashford, TN23 1JD

Size: 1,460 sqm

Designation: Town Centre: Although the site is allocated as edge-of-centre in current policy (as it lies 80m from the PSA) given that the development is post-2008 Core Strategy, we consider the site to be of town centre location.

The site is not allocated within the Ashford Town Centre Area Action Plan. Current Use and The retail unit is currently unoccupied. There are no notable, recent or relevant Planning History: planning applications for the site.

Availability The retail unit is currently vacant and therefore available for a new tenant to occupy. Suitability The unit only measures 1,460 sq. m in size, which is considerably smaller than the floorspace requirement of the two retails units at Ashford Retail Park. The site is therefore not large enough to relocate Units 1 or 2. Whilst the site could accommodate some of the mezzanine floorpace, this issue of a lack of occupiers at the existing Ashford Retail Park units would still remain.

WYG Planning & Environment part of the WYG group creative minds safe hands

www.wyg.com Appendix 6b Sequential Site Assessment

Whilst this application proposes a small proportion of convenience retailing, which would be suitable at this town centre location, the convenience offer is very much ancillary to the existing retail units and to disaggregate the convenience offer would not be viable. Again, the issue of occupation of the existing retail warehouse units would remain.

Viability Given that the site could not accommodate the floor area of both the retail units, this would result in disaggregation of the proposed floorspace from the existing building. This would not be a viable solution for the potential occupiers of the retail units, and Paragraph 24 of the NPPF does not promote the arbitrary subdivision of proposals.

Assessment Whilst we acknowledge that the unit is currently vacant and therefore available, it does not present either a suitable or viable location for the proposed development.

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www.wyg.com Appendix 7 - Retail Impact Tables Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 1: Population

Zone 2012 2013 2014 2015 2016 2017 2018

1 83,844 85,101 86,396 87,650 88,972 90,189 91,452 TOTAL 83,844 85,101 86,396 87,650 88,972 90,189 91,452

NOTES: 1. Population data taken from Experian Area Report 23 September 2013 2. Expenditure from 10 Minute Drive Time from application site Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 2a: Per Capita Expenditure - Comparison (£)

Zone 2011 2012 2013 2014 2015 2016 2017 2018

1 2,892 2,932 2,985 3,057 3,146 3,237 3,331 3,427

NOTES: 1. Per Capita data taken from Experian Area Report 23 September 2013 2. Grown from 2011 using Figure 1a of Experian Retail Planner Beefing Note 10.1 (September 2012)

2011 Prices

Table 2b: Per Capita Expenditure - Comparison SFT (£)

Zone 2011 2012 2013 2014 2015 2016 2017 2018 1 2,635 2,642 2,666 2,705 2,762 2,819 2,878 2,937

NOTES: 1. Per Capita data taken from Experian Area Report 23 September 2013 2. Grown from 2011 using Figure 1a of Experian Retail Planner Beefing Note 10.1 (September 2012) 3. Special Forms of Trading based on Appendix 3 of Retail Planner Briefing Note 10.1 (September 2012)

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 3a: Per Capita Expenditure - Convenience (£)

Zone 2011 2012 2013 2014 2015 2016 2017 2018

1 1,857 1,859 1,857 1,857 1,868 1,879 1,891 1,902

NOTES: 1. Per Capita data taken from Experian Area Report 23 September 2013 2. Grown from 2011 using Figure 1a of Experian Retail Planner Beefing Note 10.1 (September 2012)

2011 Prices

Table 3b: Per Capita Expenditure - Convenience SFT (£)

Zone 2011 2012 2013 2014 2015 2016 2017 2018 1 1,824 1,825 1,825 1,825 1,825 1,825 1,825 1,825 NOTES: 1. Per Capita data taken from Experian Area Report 23 September 2013 2. Grown from 2011 using Figure 1a of Experian Retail Planner Beefing Note 10.1 (September 2012) 3. Special Forms of Trading based on Appendix 3 of Retail Planner Briefing Note 10.1 (September 2012)

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 4a: Total Available Expenditure - Comparison (£m)

Zone 2012 2013 2014 2015 2016 2017 2018

1 221.53 226.87 233.73 242.07 250.83 259.54 268.61

TOTAL 221.53 226.87 233.73 242.07 250.83 259.54 268.61 NOTES: 1. Table 1 x Table 2

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 5: Total Available Expenditure - Convenience (£m)

Zone 2012 2013 2014 2015 2016 2017 2018

1 153.05 155.34 157.71 160.00 162.41 164.63 166.94

TOTAL 153.05 155.34 157.71 160.00 162.41 164.63 166.94 NOTES: 1. Table 1 x Table 3

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 6a - Unit 1: Former Allied Carpets

Existing Proposed Difference Total Additional Ground Floor Mezzanine Ground Floor Mezzanine Ground Floor Mezzanine GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales Unit 1a 840 756 465 419 465 419 1,710 1,539 0 0 -30 -27 Unit 1b 840 756 465 418 465 418 900 810 TOTAL 1,710 1,539 0 0 1,680 1,512 930 837 -30 -27 930 837

NOTES: 1.Sales assumed to be 95% of GIA 2. Floor areas taken from Dunthorne Parker plans 23 September 2013 3. All floor areas are in sq. m

Table 6b - Unit 2: Former Homebase

Existing and Approved Proposed Difference Total Additional Ground Floor Mezzanine Ground Floor Mezzanine Ground Floor Mezzanine GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales GIA Sales Unit 2a 1,394 1,254 185 167 185 167 Unit 2b 465 418 370 333 370 333 3,315 3,137 465 0 -62 -209 Unit 2c 465 419 185 167 185 167 1,143 1,294 Unit 2d 930 837 930 837 465 837 TOTAL 3,315 3,137 465 0 3,253 2,928 1,670 1,503 -62 -209 1,205 1,503 NOTES: 1. Sales assumed to be 90% of GIA for existing and proposed 2. All floor areas are in sq. m 3. Assumes approved mezzanine of 465 sq. m would have been in Unit 2d

Table 6c: Unit 1 and 2 Combined

Existing Proposed Difference GIA Sales GIA Sales GIA Sales 5,025 4,676 7,533 6,779 2,043 2,104 NOTES: 1. All floor areas are in sq. m Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 7: Turnover of Proposed Development

Additional Sales Area Sales Density 2013 2014 2015 2016 2017 2018 sq. m £ per sq. m £m Comparison (Unit 1) 4,145 3.36 3.37 3.39810 3.41 3.42 3.44

Comparison (Unit 2) 4,145 4.12 4.14 4.16994 4.18 4.20 4.23

Comparison 1,804 4,145 7.48 7.51 7.55 7.59 7.63 7.67

Convenience 300 3,000 0.90 0.90 0.91 0.91 0.92 0.92

TOTAL 2,104 - 8.38 8.42 8.46 8.50 8.55 8.59

NOTES: 1. Comparison Sales Density at 2013 based on an average of non-bulky retail park retailers (based on Mintel 2012) 2. Convenience Sales Density at 2013 based on WYG assumptions 3. Turnover of floorspace grown at 0.5% per annum to 2018

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 8a Trade Draw to Proposal 2013 - Comparison Goods

2013 2015 2018

% £m

Primary Catchment Area 80% £5.98 £6.04 £6.13

Outside Catchment Area 20% £1.50 £1.51 £1.53

TOTAL 100% £7.48 £7.55 £7.67

NOTES: 1. Trade Draw figures based on WYG assumptions

Table 8b Trade Draw to Proposal 2013 - Convenience Goods

2013 2015 2018

% £m

Primary Catchment Area 90% £0.81 0.82 0.83

Outside Catchment area 10% £0.09 0.09 0.09

TOTAL 100% £0.90 0.91 0.92

NOTES: 1. Trade Draw figures based on WYG assumptions

2011 Figures Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 9 : Benchmark Turnover of Stores in Catchment Area - Comparison

Operator Gross Floorspace Net Floorspace Turnover 2013 Turnover Turnover from PCA Centre / Location sq. m sq. m £ per sq. m £m % £m

Ashford Retail Park Whole Various 10,416 33,469 45.56 80.0% 36.45 Town Centres Ashford Town Centre Various - 49,142 4,253 208.98 55.0% 114.94

Retail Parks / Out of Centre Brookfield Road Matalan 3,923 3,138 2,406 7.55 50.0% 3.78 Norman Road B&Q 7,254 5,803 1,837 10.66 70.0% 7.46 Gallagher Retail Park Whole Various 4,109 3,287 13,810 12.19 70.0% 8.53 Warren Retail Park (Whole) Various 17,648 6,618 13,653 35.02 60.0% 21.01 Ashford Designer Outlet Various - 13,650 4,145 56.58 35.0% 19.80 Other Stores in Primary Catchment Area Various 5,546 4,000 22.18 60.0% 13.31

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street Iceland - 33 8,188 0.27 60.0% 0.16 Ashford Edge of Centre Convenience Stores New Street Lidl - 139 2,731 0.38 60.0% 0.23 New Street Farmfoods 435 31 2,731 0.08 60.0% 0.05 Ashford Out of Centre Convenience Stores Ashford Barracks Waitrose - 198 7,009 1.39 50.0% 0.69 Kimberley Way Asda 5576 1376 8,900 12.25 70.0% 8.57 Park Farm Estate (include extension) Tesco - 2040 11,447 23.35 65.0% 15.18 Hythe Road Tesco 8336 1444 11,447 16.53 75.0% 12.40 Mace Lane Tesco Express 532 65 11,447 0.74 80.0% 0.60 Hunter Avenue Co-Op 259 21 4,184 0.09 80.0% 0.07 Brookfield Court Co-Op - 37 4,184 0.15 30.0% 0.05

NOTES: 1. Floorspace in Ashford Town Centre taken from 2010 Ashford Bybrook Sainsbury's application 2. Turnover of Ashford Town Centre at 2013 based on 2010 Ashford Bybrook Sainsbury's application. Reduced by 5% to take account of 2013 vacancy rate 3. All Sales densities taken from Retail Rankings 2012, unless otherwise stated 4. Matalan, Brookfield Road - Gross figure taken from Completely Retail -assumes 80/20 - gross/net ratio 5. B&Q, Norman Road - gross figure taken from completely retail - assumes 80/20 - gross/net ratio 6. Ashford Retail Park (Phase 2) figures taken from Completely Retail. Assumes 80/20 - gross/net. Argos sales density average on non-bulky retailers. 7. Gallagher Retail Park figures taken from Completely Retail. Assumes 80/20- Gross/net 8.Warren Retail Park figures taken from Completely Retail. Assumes 80/20 - gross/net. Assumes 200 net of Family Bargains is for convenience goods. Family Bargains comparison sales density assumes to be same as Wilkinson 9. Ashford Designer Outlet taken from 2010 Ashford Bybrook Sainsbury's application. Sales density from Mintel 2012, average on non-bulky out of town retailers 10. Other stores in PSA based on 2010 Ashford Bybrook Sainsbury's application 11. Comparison floorspace in convenience stores information taken from Sainsbury's application 2010 RIA Table 13 12. Turnover of comparison floorspace in convenience stores taken from Verdict (2012) unless otherwise stated. M&S figure taken from Mintel 2012. Lidl and Farmfoods based on Iceland figure 13. John Lewis information taken from Planning Application dated 2011 14. Turnover of Ashford Retail Park Units 1&2 assumed to trade over at average of non-bulky out-of-town comparison retailers. Former Currys unit assumed to trade at average of bulky comparison out-of-town retailers (Mintel 2012) 15. Sainsbury's Warren Retail Park included in Warren Retail Park Figure

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 10a : Turnover of Development Commitments

Commitment Sales Turnover Turnover (£m ) Turnover from Study Area

(sq. m) (£per sq. m) 2014 2015 2016 2017 2018 % 2015 (£m) 2018 (£m)

John Lewis 3637 4000 £14.55 £14.62 £14.69 £14.77 £14.84 65% £9.50 £9.65

NOTES: 1. John Lewis taken from RPS Retail Impact Assessment August 2011 Table 12 2.Turnover of Proposed Development grown at 0.5% per annum from 2014

Table 10b: Effect of John Lewis at 2015 and 2018

Existing Turnover 2015 2018 Post John Lewis Centre / Location Trade Diversion (%) 2013 2015 2018 £m £m 2015 (£m) 2018 (£m)

Ashford Retail Park (Whole) 36.45 36.81 37.37 14.00% 1.33 1.35 35.48 36.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Town Centres Ashford Town Centre 114.94 116.09 117.84 9.00% 0.86 0.87 115.23 116.97 0.00 0.00 0.00 0.00 Retail Parks / Out of Centre Brookfield Road 3.78 3.81 3.87 0.00% 0.00 0.00 3.81 3.87 Norman Road 7.46 7.54 7.65 0.00% 0.00 0.00 7.54 7.65 Gallagher Retail Park 8.53 8.62 8.75 7.00% 0.67 0.68 7.95 8.07 Warren Retail Park 21.01 21.22 21.54 2.00% 0.19 0.19 21.03 21.35 Ashford Designer Outlet 19.80 20.00 20.30 2.00% 0.19 0.19 19.81 20.11 Other Stores in Primary Catchment Area 13.31 13.44 13.65 7.00% 0.67 0.68 12.78 12.97 0.00 0.00 0.00 Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.16 0.16 0.17 0.00% 0.00 0.00 0.16 0.17 Ashford Edge of Centre Convenience Stores New Street 0.23 0.23 0.23 0.00% 0.00 0.00 0.23 0.23 New Street 0.05 0.05 0.05 0.00% 0.00 0.00 0.05 0.05 Ashford Out of Centre Convenience Stores Ashford Barracks 0.69 0.70 0.71 0.00% 0.00 0.00 0.70 0.71 Kimberley Way 8.57 8.66 8.79 0.00% 0.00 0.00 8.66 8.79 Park Farm Estate (include extension) 15.18 15.33 15.56 1.00% 0.10 0.10 15.24 15.47 Hythe Road 12.40 12.52 12.71 1.00% 0.10 0.10 12.43 12.61 Mace Lane 0.60 0.60 0.61 0.00% 0.00 0.00 0.60 0.61 Hunter Avenue 0.07 0.07 0.07 0.00% 0.00 0.00 0.07 0.07 Brookfield Court 0.05 0.05 0.05 0.00% 0.00 0.00 0.05 0.05

John Lewis 0.00 0.00 0.00 9.50 9.65

NOTES: 1. Trade Diversion Taken from RPS Retail Impact Assessment August 2011 Table 22 2. Existing Floorspace grown at 0.5% per annum

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 11: Comparison Trade Diversion to Proposed Development 2015 - Scenario A

Turnover from Turnover from Trade DiversionCatchment Area Impact at 2015 Centre / Location Catchment Area Post Development 2015 £m % £m 2015 £m £m %

Ashford Retail Park (Whole) 35.48 10.00% 0.60 40.92 5.44 15.32%

Town Centres Ashford Town Centre 115.23 30% 1.81 113.42 -1.81 -1.57%

Retail Parks / Out of Centre Brookfield Road 3.81 4.00% 0.24 3.57 -0.24 -6.34% Norman Road 7.54 1.00% 0.06 7.48 -0.06 -0.80% Gallagher Retail Park 7.95 7.00% 0.42 7.53 -0.42 -5.32% Warren Retail Park 21.03 11.00% 0.66 20.37 -0.66 -3.16% Ashford Designer Outlet 19.81 5.00% 0.30 19.51 -0.30 -1.52% Other Stores in Primary Catchment Area 12.78 2.00% 0.12 12.66 -0.12 -0.95%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.16 0.00% 0.00 0.16 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.00% 0.00 0.23 0.00 0.00% New Street 0.05 0.00% 0.00 0.05 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.70 0.00% 0.00 0.70 0.00 0.00% Kimberley Way 8.66 6.00% 0.36 8.30 -0.36 -4.19% Park Farm Estate (include extension) 15.24 5.00% 0.30 14.93 -0.30 -1.98% Hythe Road 12.43 6.00% 0.36 12.06 -0.36 -2.92% Mace Lane 0.60 0.00 0.60 0.00 0.00% Hunter Avenue 0.07 0.00 0.07 0.00 0.00% Brookfield Court 0.05 0.00 0.05 0.00 0.00%

John Lewis 9.50 3.00% 0.18 9.32 -0.18 -1.91%

Stores Outside Catchment Area 10.00% 0.60

TOTAL 100% 6.04 271.93

NOTES: 1. Trade Diversion figures based on WYG assumptions - assumes non-bulky non-food retailers in all units

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 12 : Comparison Trade Diversion to Proposed Development at 2018 - Scenario A

Turnover from Turnover from Trade DiversionCatchment Area Impact at 2018 Centre / Location Catchment Area Post Development

£m % £m £m £m %

Ashford Retail Park (Whole) 36.02 10.00% 0.61 41.54 5.52 15.32% 0.00 Town Centres Ashford Town Centre 116.97 30% 1.84 115.13 -1.84 -1.57% 0.00 Retail Parks / Out of Centre Brookfield Road 3.87 4.00% 0.25 3.63 -0.25 -6.34% Norman Road 7.65 1.00% 0.06 7.59 -0.06 -0.80% Gallagher Retail Park 8.07 7.00% 0.43 7.64 -0.43 -5.32% Warren Retail Park 21.35 11.00% 0.67 20.67 -0.67 -3.16% Ashford Designer Outlet 20.11 5.00% 0.31 19.80 -0.31 -1.52% Other Stores in Primary Catchment Area 12.97 2.00% 0.12 12.85 -0.12 -0.95%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.17 0.00% 0.00 0.17 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.00% 0.00 0.23 0.00 0.00% New Street 0.05 0.00% 0.00 0.05 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.71 0.00% 0.00 0.71 0.00 0.00% Kimberley Way 8.79 6.00% 0.37 8.42 -0.37 -4.19% Park Farm Estate (include extension) 15.47 5.00% 0.31 15.16 -0.31 -1.98% Hythe Road 12.61 6.00% 0.37 12.25 -0.37 -2.92% Mace Lane 0.61 0.00% 0.00 0.61 0.00 0.00% Hunter Avenue 0.07 0.00% 0.00 0.07 0.00 0.00% Brookfield Court 0.05 0.00% 0.00 0.05 0.00 0.00%

John Lewis 9.65 3.00% 0.18 9.46 -0.18 -1.91%

Stores Outside Catchment Area 10.00% 0.61

TOTAL 100% 6.13 276.03

NOTES: 1. Trade Diversion figures based on WYG assumptions - assumes non-bulky non-food retailers in all units

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 13 : Summary of Comparison Impact at 2015 and 2018 - Scenario A

Change in Turnover of John Lewis and Proposed No Development Turnover Post John Lewis Turnover Post Development Turnover Change in Turnover from Development Only Centre / Location Development

2015 2018 2015 2018 2015 2018 2015 2018 2015 2018

Ashford Retail Park (Whole) 36.81 37.37 35.48 36.02 40.92 41.54 5.44 15.32% 5.52 15.32% 4.11 11.16% 4.17 11.16%

Town Centres Ashford Town Centre 116.09 117.84 115.23 116.97 113.42 115.13 -1.81 -1.57% -1.84 -1.57% -2.67 -2.30% -2.71 -2.30%

Retail Parks / Out of Centre Brookfield Road 3.81 3.87 3.81 3.87 3.57 3.63 -0.24 -6.34% -0.25 -6.34% -0.24 -6.34% -0.25 -6.34% Norman Road 7.54 7.65 7.54 7.65 7.48 7.59 -0.06 -0.80% -0.06 -0.80% -0.06 -0.80% -0.06 -0.80% Gallagher Retail Park 8.62 8.75 7.95 8.07 7.53 7.64 -0.42 -5.32% -0.43 -5.32% -1.09 -12.63% -1.10 -12.63% Warren Retail Park 21.22 21.54 21.03 21.35 20.37 20.67 -0.66 -3.16% -0.67 -3.16% -0.85 -4.03% -0.87 -4.03% Ashford Designer Outlet 20.00 20.30 19.81 20.11 19.51 19.80 -0.30 -1.52% -0.31 -1.52% -0.49 -2.46% -0.50 -2.46% Other Stores in Primary Catchment Area 13.44 13.65 12.78 12.97 12.66 12.85 -0.12 -0.95% -0.12 -0.95% -0.79 -5.85% -0.80 -5.85%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.16 0.17 0.16 0.17 0.16 0.17 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.23 0.23 0.23 0.23 0.23 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% New Street 0.05 0.05 0.05 0.05 0.05 0.05 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.70 0.71 0.70 0.71 0.70 0.71 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Kimberley Way 8.66 8.79 8.66 8.79 8.30 8.42 -0.36 -4.19% -0.37 -4.19% -0.36 -4.19% -0.37 -4.19% Park Farm Estate (include extension) 15.33 15.56 15.24 15.47 14.93 15.16 -0.30 -1.98% -0.31 -1.98% -0.40 -2.59% -0.40 -2.59% Hythe Road 12.52 12.71 12.43 12.61 12.06 12.25 -0.36 -2.92% -0.37 -2.92% -0.46 -3.65% -0.46 -3.65% Mace Lane 0.60 0.61 0.60 0.61 0.60 0.61 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Hunter Avenue 0.07 0.07 0.07 0.07 0.07 0.07 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Brookfield Court 0.05 0.05 0.05 0.05 0.05 0.05 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00%

John Lewis 0.00 0.00 9.50 9.65 9.32 9.46 -0.18 -1.91% -0.18 -1.91% 9.32 9.46

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 14: Comparison Trade Diversion to Proposed Development 2015 - Scenario B

Turnover from Turnover from Trade DiversionCatchment Area Impact at 2015 Centre / Location Catchment Area Post Development 2015 £m % £m 2015 £m £m %

Ashford Retail Park (Whole) 35.48 10.00% 0.60 40.92 5.44 15.32%

Town Centres Ashford Town Centre 115.23 45% 2.72 112.52 -2.72 -2.36%

Retail Parks / Out of Centre Brookfield Road 3.81 2.00% 0.12 3.69 -0.12 -3.17% Norman Road 7.54 1.00% 0.06 7.48 -0.06 -0.80% Gallagher Retail Park 7.95 4.00% 0.24 7.71 -0.24 -3.04% Warren Retail Park 21.03 6.00% 0.36 20.67 -0.36 -1.72% Ashford Designer Outlet 19.81 10.00% 0.60 19.21 -0.60 -3.05% Other Stores in Primary Catchment Area 12.78 1.00% 0.06 12.72 -0.06 -0.47%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.16 0.00% 0.00 0.16 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.00% 0.00 0.23 0.00 0.00% New Street 0.05 0.00% 0.00 0.05 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.70 0.00% 0.00 0.70 0.00 0.00% Kimberley Way 8.66 4.00% 0.24 8.42 -0.24 -2.79% Park Farm Estate (include extension) 15.24 3.00% 0.18 15.05 -0.18 -1.19% Hythe Road 12.43 3.00% 0.18 12.25 -0.18 -1.46% Mace Lane 0.60 0.00% 0.00 0.60 0.00 0.00% Hunter Avenue 0.07 0.00% 0.00 0.07 0.00 0.00% Brookfield Court 0.05 0.00% 0.00 0.05 0.00 0.00%

John Lewis 9.50 3.00% 0.18 9.32 -0.18 -1.91%

Stores Outside Catchment Area 8.00% 0.48

TOTAL 100% 6.04 271.81

NOTES: 1. Trade Diversion figures based on WYG assumptions - assumes non-bulky non-food retailers in all units

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 15 : Comparison Trade Diversion to Proposed Development at 2018 - Scenario B

Turnover from Turnover from Trade DiversionCatchment Area Impact at 2018 Centre / Location Catchment Area Post Development

£m % £m £m £m %

Ashford Retail Park (Whole) 36.02 10.00% 0.61 41.54 5.52 15.32% 0.00 Town Centres Ashford Town Centre 116.97 45% 2.76 114.21 -2.76 -2.36%

Retail Parks / Out of Centre Brookfield Road 3.87 2.00% 0.12 3.75 -0.12 -3.17% Norman Road 7.65 1.00% 0.06 7.59 -0.06 -0.80% Gallagher Retail Park 8.07 4.00% 0.25 7.83 -0.25 -3.04% Warren Retail Park 21.35 6.00% 0.37 20.98 -0.37 -1.72% Ashford Designer Outlet 20.11 10.00% 0.61 19.50 -0.61 -3.05% Other Stores in Primary Catchment Area 12.97 1.00% 0.06 12.91 -0.06 -0.47%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.17 0.00% 0.00 0.17 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.00% 0.00 0.23 0.00 0.00% New Street 0.05 0.00% 0.00 0.05 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.71 0.00% 0.00 0.71 0.00 0.00% Kimberley Way 8.79 4.00% 0.25 8.54 -0.25 -2.79% Park Farm Estate (include extension) 15.47 3.00% 0.18 15.28 -0.18 -1.19% Hythe Road 12.61 3.00% 0.18 12.43 -0.18 -1.46% Mace Lane 0.61 0.00% 0.00 0.61 0.00 0.00% Hunter Avenue 0.07 0.00% 0.00 0.07 0.00 0.00% Brookfield Court 0.05 0.00% 0.00 0.05 0.00 0.00%

John Lewis 9.65 3.00% 0.18 9.46 -0.18 -1.91%

Stores Outside Catchment Area 8.00% 0.49

TOTAL 100% 6.13 275.91

NOTES: 1. Trade Diversion figures based on WYG assumptions - assumes non-bulky non-food retailers in all units

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 16 : Summary of Comparison Impact at 2015 and 2018 - Scenario B

Change in Turnover of John Lewis and Proposed No Development Turnover Post John Lewis Turnover Post Development Turnover Change in Turnover from Development Only Centre / Location Development

2015 2018 2015 2018 2015 2018 2015 2018 2015 2018

Ashford Retail Park (Whole) 36.81 37.37 35.48 36.02 40.92 41.54 5.44 15.32% 5.52 15.32% 4.11 11.16% 4.17 11.16%

Town Centres Ashford Town Centre 116.09 117.84 115.23 116.97 112.52 114.21 -2.72 -2.36% -2.76 -2.36% -3.57 -3.08% -3.63 -3.08%

Retail Parks / Out of Centre Brookfield Road 3.81 3.87 3.81 3.87 3.69 3.75 -0.12 -3.17% -0.12 -3.17% -0.12 -3.17% -0.12 -3.17% Norman Road 7.54 7.65 7.54 7.65 7.48 7.59 -0.06 -0.80% -0.06 -0.80% -0.06 -0.80% -0.06 -0.80% Gallagher Retail Park 8.62 8.75 7.95 8.07 7.71 7.83 -0.24 -3.04% -0.25 -3.04% -0.91 -10.53% -0.92 -10.53% Warren Retail Park 21.22 21.54 21.03 21.35 20.67 20.98 -0.36 -1.72% -0.37 -1.72% -0.55 -2.60% -0.56 -2.60% Ashford Designer Outlet 20.00 20.30 19.81 20.11 19.21 19.50 -0.60 -3.05% -0.61 -3.05% -0.79 -3.97% -0.81 -3.97% Other Stores in Primary Catchment Area 13.44 13.65 12.78 12.97 12.72 12.91 -0.06 -0.47% -0.06 -0.47% -0.73 -5.40% -0.74 -5.40%

Comparison Floorspace in Convenience Stores Ashford Town Centre High Street 0.16 0.17 0.16 0.17 0.16 0.17 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Ashford Edge of Centre Convenience Stores New Street 0.23 0.23 0.23 0.23 0.23 0.23 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% New Street 0.05 0.05 0.05 0.05 0.05 0.05 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Ashford Out of Centre Convenience Stores Ashford Barracks 0.70 0.71 0.70 0.71 0.70 0.71 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Kimberley Way 8.66 8.79 8.66 8.79 8.42 8.54 -0.24 -2.79% -0.25 -2.79% -0.24 -2.79% -0.25 -2.79% Park Farm Estate (include extension) 15.33 15.56 15.24 15.47 15.05 15.28 -0.18 -1.19% -0.18 -1.19% -0.28 -1.80% -0.28 -1.80% Hythe Road 12.52 12.71 12.43 12.61 12.25 12.43 -0.18 -1.46% -0.18 -1.46% -0.28 -2.21% -0.28 -2.21% Mace Lane 0.60 0.61 0.60 0.61 0.60 0.61 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Hunter Avenue 0.07 0.07 0.07 0.07 0.07 0.07 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00% Brookfield Court 0.05 0.05 0.05 0.05 0.05 0.05 0.00 0.00% 0.00 0.00% 0.00 0.00% 0.00 0.00%

John Lewis 0.00 0.00 9.50 9.65 9.32 9.46 -0.18 -1.91% -0.18 -1.91% 9.32 9.46

2011 Prices Henderson UK Retail Warehouse Fund Ashford Retail Park, Sevington

Table 17a - Turnover of Convenience Stores in Catchment Area

Net Turnover Turnover Turnover Gross size Sales Density Turnover from PCA 2013 Location Occupier Convenience 2013 2015 2018 sq. m sq. m £ per sq. m £m % £m £m £m Ashford Town Centre High Street Iceland - 432 6,657 2.88 60% 1.73 1.74 1.77 County Square M&S Food Hall - 432 11,048 4.77 60% 2.86 2.89 2.94 Other Stores Various - 980 4,000 3.92 60% 2.35 2.38 2.41 0.00 Edge of Centre New Street Lidl - 418 4,000 1.67 60% 1.00 1.01 1.03 New Street Farmfoods 435 313 4,000 1.25 60% 0.75 0.76 0.77

Out of Centre Warren Retail Park Sainsbury's 14,429 4,980 11,738 58.46 60.0% 35.07 35.42 35.96 Ashford Barracks Waitrose - 1,454 11,242 16.35 50.0% 8.17 8.25 8.38 Kimberly Way Asda 5,576 1,900 12,401 23.56 70.0% 16.49 16.66 16.91 Park Farm Estate Tesco - 2,830 10,637 30.10 65.0% 19.57 19.76 20.06 Hythe Road Tesco 8,336 2,804 10,367 29.07 75.0% 21.80 22.02 22.35 Mace Lane Tesco 326 125 10,367 1.30 80.0% 1.04 1.05 1.06 Hunter Avenue Co-Op 259 102 8,172 0.83 80.0% 0.67 0.67 0.68 Brookfield Court Co-Op - 180 8,172 1.47 30.0% 0.44 0.45 0.45

Other Stores in PCA Various - 1,000 4,000 4.00 60% 2.40 2.42 2.46

TOTAL (£m) 114.35 115.49 117.24

NOTES: 1. All floorspace figures taken from 2010 Ashford Bybrook Sainsbury's application 2. All Sales densities taken from Verdict 2011, unless otherwise stated 3. M&S Sales density taken from Verdict 2011 5. Sales densities of Lidl, Farmfoods and other stores in PCA based on WYG estimates 6. Turnover of stores grown at 0.5% per annum

2011 Prices

Table 17b : Convenience Impact Considerations

2013 2015 2018 £m £m £m Benchmark Turnover of Current Convenience stores in 114.35 115.49 117.24 Ashford

Available Convenience Expenditure in Catchment Area 155.34 160.00 166.94

Growth in Convenience Expenditure in PCA from 2013 - 4.65 11.59

Convenience Turnover of Development from Catchment Area 0.81 0.82 0.83

Proposed Development as a % of Total Available Convenience 0.52% 0.51% 0.50% Expenditure in PCA

Growth in Convenience Expenditure following Development 3.83 10.76

2011 Prices