Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

on behalf of Morbaine Limited and Ackroyd & Abbott May 2019

Contact

Eastgate 2 Castle Street Castlefield Manchester M3 4LZ

T: 0161 819 6570 E: [email protected] Job reference no: 33982

Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

Contents

1.0 Introduction ...... 1 2.0 Site, Proposed Development and Application Context ...... 3 3.0 Planning Policy Context ...... 14 4.0 General Compliance with the Development Plan and National Planning Policy ...... 28 5.0 The Sequential Test ...... 35 6.0 The Impact Test ...... 40 7.0 Summary and Conclusions ...... 52

Appendices

Appendix A: Plan of Sequential Alternative Sites Appendix B: Retail Impact Assessment Tables

Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

1.0 Introduction

Scope and Purpose

1.1 This Planning and Retail Statement has been prepared on behalf of joint applicants Morbaine Limited and Ackroyd & Abbott (hereafter referred to as ‘the applicant’) in support of an outline planning application to Sheffield City Council (‘the Council’), which provides for the redevelopment of vacant

land at Lane End in Chapeltown. The site was previously occupied by South Yorkshire Trading Standards, but has now been vacant for more than a decade.

1.2 The description of development for which outline planning permission is sought is as follows:

‘Erection of Class C3 residential dwellings and Class A1 foodstore, together with access, car parking, servicing, landscaping and associated works (with all matters reserved except for access).’

1.3 The proposed residential dwellings would front Thorncliffe View, which is an existing residential street of modern, detached dwellings.

1.4 The proposed foodstore would have a gross internal area of 1,951 sq.m and would be served by a total of 115 car parking spaces. The foodstore would be of sufficient scale to support main food shopping

trips and would accommodate a discount operator. It is proposed that the residential element of the development would take the form of eight detached dwellings, which would all front onto and be accessed from Thorncliffe View.

1.5 The purpose of this Statement is to consider the proposal’s compliance with the adopted development plan and other material considerations, including the National Planning Policy Framework (published February 2019) (‘the NPPF’).

1.6 The planning application has been the subject of a formal pre-application consultation with the Council

(reference 18/04683/PREAPP), which has directly informed the scale, design and siting of the submitted scheme. In addition, a formal public consultation strategy was adopted at pre-application stage, the findings of which have also informed the proposed development. Full details in respect of the pre- application public consultation strategy and feedback are provided in the Consultation Statement,

prepared by Counter Context.

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1.7 This Statement should be read in conjunction with the full package of documents that support the application, including the Design & Access Statement and Transport Assessment.

Structure of Report

1.8 The remainder of this document is structured as follows:

. Section 2 provides a detailed description of the proposed development and the site, and sets out the site’s relevant planning history;

. Section 3 identifies the planning policy context at local and national level; . Section 4 confirms the proposal’s general compliance with relevant planning policy;

. Section 5 sets out the proposal’s conformity with the sequential retail test, with reference to the requirements of paragraph 86 of the NPPF;

. Section 6 considers the proposal’s conformity with the retail impact test, with reference to the requirements of paragraph 89 of the NPPF; and

. Section 7 provides an overview of the proposed development and sets out our conclusions.

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2.0 Site, Proposed Development and Application Context

Application Site and Surrounding Area

2.1 The application site extends to 1.1 hectares and has been vacant (and cleared) for more than a decade, having previously been occupied by South Yorkshire Trading Standards. The site is overgrown scrubland, with an area of hardstanding to the north west. It is served by an existing access point on

Thorncliffe Lane.

2.2 The site slopes from east to west (down from the junction of Land End and Thorncliffe Lane), and is currently screened by a number of fences. Whilst the site accommodates shrubs and some self-seeded trees, it is not accessible to the public and not used for any purpose. It is a cleared, previously-

developed site which is well located to accommodate sustainable development.

2.3 The application site is bounded by: the rear gardens of residential dwellings at Thorncliffe View to the north; Thorncliffe View to the east; Lane End to the south; a small police station (which now appears vacant) to the south west; and Thorncliffe Lane to the west. Beyond the residential dwellings on

Thorncliffe Lane and Thorncliffe View lies Thorncliffe Business Park, which accommodates a range of

industrial and office premises.

2.4 The site is located approximately 800 metres to the south east of High Green neighbourhood centre

and approximately 1.1 kilometres to the north west of Chapeltown district centre. As such, the application site is ‘out of centre’ for the purpose of the retail planning policy. Notwithstanding this, it is served by adjacent bus stops on Lane End which support the high frequency 1 and 1a services which run from High Green in the north, to Batemoor and Herdings in the south (via Sheffield city centre). As

a consequence, the application site is considered to represent an accessible and sustainable location to accommodate the proposed development.

Proposed Development

2.5 This application seeks outline planning permission for eight detached residential dwellings, together

with a foodstore (with all matters reserved, except for access). As set out by the accommodation schedule provided below at Table 2.1, the proposed foodstore would have a gross internal area of 1,951 sq.m and an estimated net sales area of 1,268 sq.m. Of this, we estimate that approximately 80%

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of the floorspace would be dedicated to the sale of convenience goods and approximately 20% to the sale of comparison goods.

Table 2.1: Proposed Accommodation Schedule Net Net Gross internal Net sales area convenience comparison Proposed Use area (sq.m) (sq.m) goods sales goods sales (sq.m) (sq.m) Foodstore to accommodate 1,951 1,268 1,015 254 ‘discount’ operator

2.6 The site plan submitted with the application (drawing number 7255/11) indicates that the development

is proposed to be orientated such that the foodstore will occupy the central part of the site, with the car parking to the west. The entrance to the foodstore is at the south eastern corner of the store, close to Lane End (thereby allowing straightforward access from the nearby bus stops). Both customer and

service vehicular traffic will access the site from Lane End, with the internal access road leading to a servicing area to the north of the site. The store is sited so as to be distant from the front elevation of existing dwellings at Thorncliffe Lane and landscaping is proposed to screen the site from existing and proposed residential dwellings. The scheme has evolved as a consequence of a public consultation

event in order to provide a greater degree of separation between the proposed foodstore and nearby dwellings.

2.7 The proposed foodstore includes the provision of an appropriate level of car parking to serve the retail unit, totalling in 115 space which include eight parent & child spaces, six disabled spaces and cycle

parking.

2.8 The proposed residential dwellings at Thorncliffe View are all detached and are sited and designed so as to complement neighbouring existing housing. Each of the proposed dwellings has an extensive garden to the rear and off-street parking at the front.

2.9 As we go on to consider in greater detail at Sections 6 and 7 of this report, the location of the application site (being outside both High Green neighbourhood centre and Chapeltown district centre) allows the proposed development to ‘fill a gap’ in provision, in order that residents can undertake food shopping close to home.

2.10 Whilst we reiterate that the application is in outline, the submitted plans and drawings demonstrate that a high quality, modern retail scheme can be appropriately accommodated on the site. The

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indicative scheme has evolved with reference to pre-application discussions with Council Officers and seeks to make best use of an existing previously developed site, whilst improving local accessibility and choice in respect of main food shopping provision. Full details in respect of the proposed scheme and its evolution are provided in the submitted Design & Access Statement.

2.11 Whilst no operator is formally associated with the proposed foodstore, the development would provide modern retail accommodation to meet existing retailer requirements in the Chapeltown area. The format of the proposed foodstore is consistent with occupation by a discount food operator and the

applicant continues to engage with prospective tenants in this sector. The grant of planning permission

would assist in reaching formal agreement with an operator.

The Context for the Application

2.12 The Chapeltown and High Green area currently benefits from a very limited main food offer, which is evidenced by the findings of the Sheffield & Rotherham Joint Retail & Leisure Study, published in

February 2017.

2.13 Chapeltown and High Green is accommodated within Zone 2 of the Retail & Leisure Study Area. Within

this zone:

. there is a single dominant main food shopping destination, this being the Asda foodstore in

Chapeltown, which secures around half of all first choice main food shopping trips that originate within the zone; and

. there are no discount foodstores within the zone.

2.14 As such, there is both limited choice in respect of food shopping destinations and a qualitative

deficiency in respect of the discount foodstore market. Indeed, the closest discount foodstores are located in Ecclesfield and Birdwell. As a consequence, there is operator interest in meeting this need

in order to allow the Chapeltown and High Green residents to source good value groceries close to home.

2.15 The residential element of the proposal ensures that efficient use is made of this previously developed site and makes a valuable contribution to Sheffield’s housing land supply. As we go on to consider in greater detail below, the planned redevelopment of the site for just residential purposes has stalled and the application proposal provides an appropriate mix of uses which comprises a viable

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development. In this regard, the proposed foodstore would support the delivery of residential dwellings on the eastern part of the site.

Relevant Planning History

2.16 There have been two planning applications which sought to provide for the redevelopment of the site

for residential purposes. These comprise:

i) Outline planning permission reference 06/02366/RG3, which was approved on 27 September 2006

and provided for the redevelopment of the site for 30 residential dwellings (comprising a range of three and four bedroom semi-detached, detached and townhouse accommodation).

ii) Detailed planning permission reference 08/01151/FUL, which was approved on 9 June 2008 and provided for 24 residential dwellings and garages. The development was to be provided in two parts, the first relating to a cul-de-sac to be accessed off Thorncliffe Lane and the second comprising seven dwellings to be sites along Thorncliffe View. The scheme comprised a mix of

three, four and five bedroom dwellings, 10 of which were to be detached and 14 of which were to be semi-detached.

2.17 Both of the above planning permissions have now lapsed. We note that the Area Board Report which considered the second of the above schemes found the site to be a previously developed site in a

sustainable location, that is ‘…situated favourably with respect to public transport service, which is approx.

80 metres walking distance to bus stops on Lane End.’

Pre-Application Discussions and Public Consultation

2.18 This current planning application has been the subject of formal pre-application consultation with the Council (enquiry reference 18/04683/PREAPP). Whilst the scheme presented to Officers as part of the pre-application process provided for a broadly similar type of development to that which is now

proposed, the foodstore element was sited such that it occupied the western part of the site (with the rear elevation adjacent to Thorncliffe Lane).

2.19 The Council’s formal pre-application response1 indicates that the Sheffield Unitary Development Plan

1 Email of Bob Turner, Principal Planning Officer at Sheffield City Council, to Keith Nutter of Morbaine, dated 4 March 2019, which followed a meeting between the project team and Council officers on 15 February 2019

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(adopted March 1998) identifies that site within a ‘washed over’ housing area, where residential uses are identified as a ‘preferred use’ by UDP Policy H10.

2.20 We return to the matter of UDP policy and the weight which should reasonably be afforded to later in this Statement.

2.21 The pre-application response also states that the site is identified as a proposed housing allocation by the Pre-Submission Draft City Policies and Sites Local Plan, which was available for consultation in December 2013. However, we note that the Council took the decision in December 2013 not to

progress the City Policies and Sites Local Plan and, as such, no material weight can be afforded to it.

2.22 As a consequence of the historic planning policy, the Council’s response concluded that, whilst the proposed residential use on part of the site would be welcomed, the retail use would be the subject of the sequential test in accordance with paragraphs 86 and 89 of the NPPF. The response confirmed that, as a consequence of the limited scale of the retail element of the proposal, there is no formal

requirement to consider the retail impacts arising from the proposal. Notwithstanding this, the Council has requested that the application submission addresses the matter of retail impact and, as such, Section 6 of this Statement identifies the likely magnitude of the impacts which would arise from the

proposal.

2.23 In terms of the initial proposed siting of the foodstore on the western part of the site, the Council’s response indicated that:

‘The proposed siting of the food store relates poorly to the streetscene with parking and access dominating the frontage. Consideration should be given to siting the building close to the main road frontage.’

2.24 The proposed development has been substantially redesigned in order to directly address these comments. As a consequence, the foodstore is now proposed to be centrally located on the site, as

close as practicable to Lane End (whilst still providing access directly off this arterial route). As a consequence, we believe that the revised scheme better relates both to the existing street scene and

in respect of its relationship with existing residential dwellings.

2.25 We believe that the proposed layout allows for an appropriate development which relates to the local context, but (importantly) is also able to meet the needs of modern discount foodstore operators.

2.26 A public consultation exercise was undertaken between 22 March and 9 April 2019 on a scheme which

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provided the foodstore on the central part of the site, the car parking to the west (adjacent to Thorncliffe Lane), and the residential dwellings to the east (fronting Thorncliffe View). The consultation exercise incorporated a drop-in event at the Staindrop Lodge Hotel in Chapeltown on 3 April 2019, which has resulted in further amendments to the proposal.

2.27 Key revisions include:

. the realignment of the foodstore and the reduction of its footprint in order that it is set further back from existing residential dwellings on Thorncliffe View (the foodstore is at least 10 metres

from the curtilage of all existing residential properties);

. additional proposed planting to provide a dense buffer between existing dwellings and the foodstore; and

. the provision of a new pedestrian zebra crossing across Lane End, with a further pedestrian route along Lane End from the east.

2.28 Full details in respect of the evolution of the scheme are provided in the submitted Design & Access Statement. The application submission also includes a Consultation Statement which summarises the consultation process, key areas of concern, and how the scheme has been revised in order to address

such matters.

Supporting Documents

2.29 The required supporting documents were also confirmed by the Council in its pre-submission response. As such, this planning application is accompanied by:

. Design & Access Statement, prepared by GWH;

. Transport Assessment and Draft Travel Plan, prepared by Turner Lowe Associates; . Air Quality Assessment, prepared by Turner Lowe Associates;

. Flood Risk Assessment & Drainage Strategy, prepared by Waterco Consultants; . Preliminary Risk Assessment, prepared by DTS Raeburn;

. Noise Impact Assessment, prepared by Hepworth Acoustics; . Ecological Assessment, prepared by WYG; and . Consultation Statement, prepared by Counter Context.

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2.30 We summarise the key conclusions from these reports below in order to provide for a comprehensive assessment of the merits of the application proposal and its compliance with relevant planning policies in subsequent sections of this Statement.

Design & Access Statement

2.31 The Design & Access Statement identifies the matters that have influenced the development’s proposed indicative design, and sets out how the proposed scheme has evolved throughout the pre- application process to address the Council’s comments and operational requirements. The Design &

Access Statement demonstrates that, whilst the planning application is in outline and the design of the

scheme purely indicative, the proposed foodstore would comprise a simple building form, with a low eaves line at the rear eastern side rising towards the west facing the car park and entrance. The frame of the foodstore is proposed to be clad in white flat composite panels at a low level, with grey panels above a canopy line, with aluminium framed windows and glazed curtain walling around the entrance.

2.32 The height of the store is such that it is able to meet prospective retailers’ operational requirements, whilst remaining of a scale that is appropriate to existing nearby uses. The service area is to the north of the site and has been moved significantly away from nearby boundaries. In addition, the service

area is screened by a 3 metres high acoustic fence.

2.33 In terms of the proposed residential dwellings on the eastern boundary of the site, these have been designed to be in-keeping with the existing properties along Thorncliffe View and the rear gardens will be screened from the proposed foodstore by an extensive landscaped zone and timber fencing. The

dwellings will also incorporate integral garages with front drives and gardens.

2.34 The Design & Access Statement indicates that the proposed site layout has been directly informed by the need to secure inclusive access for all in the safest and most straightforward manner. The indicative layout provides for the separation of servicing and customer vehicular traffic, and there is a clear

emphasis on enhancing pedestrian connectivity to and within the retail element of the site. In this regard, the site provides easy access to bus stops on Lane End.

2.35 The Design & Access confirms that the final layout of the scheme has been arrived at in order to address residents’ concerns whilst still providing for a viable form of development in order to ensure that the

benefits of the development are delivered in practice.

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Consultation Statement

2.36 The Consultation Statement provides an overview of the pre-application public consultation undertaken with local communities concerning the redevelopment of the currently vacant site. The public consultation strategy was designed to reflect guidance within Sheffield’s Statement of

Community Involvement (adopted in August 2014) and the NPPF.

2.37 The consultation period ran from the end of March to the beginning of April 2019, during which a range of communication methods were used to reach-out to relevant stakeholders.

2.38 A drop-in event was held on 3 April 2019 which was well attended by 93 visitors, and 41 feedback forms

were completed on the day. The feedback received raised a large variety of topics in relation to the proposals. The main areas of interest related to:

. traffic and highways concerns; . impact on residents, including privacy concerns;

. location and purpose of the development; . pollution impacts; and

. potential anti-social behaviour resulting from the development.

2.39 As a consequence of the consultation feedback and receipt of several valid concerns and suggestions,

a number of changes to the proposals were made. The resultant changes include reorienting the food store to maximise the amenity buffer spaces along the site edges and putting measures in place to minimise disturbance from noise and light pollution.

Transport Assessment

2.40 The Transport Assessment assesses the traffic and highways implications of the proposed development,

including parking provision, HGV manoeuvring and recorded road traffic accidents in the vicinity. The accessibility by other modes of transport to the car is also considered.

2.41 The Assessment demonstrates that the proposed foodstore will be accessible on foot and will encourage walking as a mode of transport. Furthermore, a new pedestrian crossing will be provided on Lane End to further assist pedestrian trips.

2.42 The proposed access to the site will function with reserve capacity and no queueing issues. In addition,

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the parking area for the residential properties on the south side of Lane End and bus stop box markings are also proposed and these have been allowed for in the capacity calculations.

2.43 Overall, it is concluded that the site is accessible by a choice of modes of transport and that there are no highways/traffic related reasons why the proposed development should not be approved.

Noise Impact Assessment

2.44 The Noise Impact Assessment includes an inspection of the site and environs, measurement of the

prevailing noise climate of the area, assessment of the potential noise impact on surrounding residents and recommendations of appropriate noise mitigation measures.

2.45 Overall, appropriate noise control design limits have been specified for external plant in order to protect residential amenity. In addition, the assessment of delivery noise to the proposed foodstore has found that, with the proposed acoustic fence, there will not be any unacceptable noise impact. Turning to potential noise impact of car parking, again, the acoustic fencing has been recommended

in the vicinity of rear gardens. Based on the recommended mitigation measures, it is concluded that the proposed development will not result in any unacceptable noise impact on the amenity of local

residents.

Flood Risk Assessment & Drainage Strategy

2.46 The purpose of the Flood Risk Assessment is to outline the potential flood risk to the site, the impact of the proposed development on flood risk elsewhere, and the proposed measures which could be incorporated to mitigate the identified risk.

2.47 The site is located within Flood Zone 1, an area considered to have less than 0.1% annual probability of flooding from rivers or the sea. As such, in accordance with Table 2 of the NPPG: Flood Risk and

Coastal Change, both the residential and commercial elements of the proposal comprise appropriate development. The development therefore passes the flood risk Sequential Test and the Exception Test

does not need to be applied.

2.48 The risk of flooding from all sources has been assessed and the flood risk to the site is considered to be very low. Therefore, no site-specific flood mitigation measures are considered necessary. The

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proposed development will include impermeable drainage area in the form of the building, car park and access road.

2.49 All methods of surface water discharge have been assessed. Where soakaways are not possible, surface water will be discharged to the 225mm public surface water sewer located in Thorncliffe View (30

metres north east of the site).

Preliminary Risk Assessment

2.50 The principal objective of the Preliminary Risk Assessment (PRA) was to assess whether the land is potentially contaminated or whether there are other potential geo-environmental liabilities. These

could include, but are not limited to, subsidence hazards due to shallow mining, the generation or migration of soil gas to beneath the site and other geotechnical abnormalities.

2.51 Table 9.1 of the PRA provides a summary of the main identified risks and the overall recommendations in order to move the project forward and redevelop the site for the intended uses. The

recommendations are:

. excavations to confirm accurately the location of the mine entry, followed by surveying of its

location. Coal Mining Risk Assessment recommended once the location of the mine entry has been recorded;

. the production of a geo-technical report; . intrusive investigation, including contamination laboratory testing of soil and groundwater samples;

. gas monitoring as part of any future ground investigation works; . undertaking timely eradication in order to prevent spread; and . specialist ecological inspection.

Ecological Assessment

2.52 The Ecological Appraisal has been informed by a desk study and field survey in order to record habitat

types, dominant vegetation, the potential for habitats to support protected/notable species, the presence of any non-native invasive species, and to identify any constraints.

2.53 The Ecological Appraisal finds that:

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. the habitats on site (following recent scrub clearance) are considered to be common and widespread in the locale, with limited ecological value;

. limited suitability has been highlighted for bats, birds and badgers; and . non-native invasive Japanese knotweed and wall cotoneaster have been identified on site.

2.54 As a consequence of the above, there are no ecological concerns which should impact on the ability to

bring forward the proposed development at the site.

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3.0 Planning Policy Context

The Application of Planning Policy

3.1 We set out below the planning policy of relevance to the Council’s consideration of the application. At the outset, it is important to recognise that the statutory development plan is generally the starting point in considering the acceptability of a proposal. In this regard, Section 38(6) of the Planning and

Compulsory Purchase Act 2004 provides that:

‘…if regard is to be had to the Development Plan for the purpose of any determination to be made under the planning acts, the determination must be made in accordance with the plan unless material consideration indicate otherwise.’

3.2 The adopted development plan of relevance in this instance comprises the Sheffield Core Strategy (adopted March 2009), read together with the ‘saved’ policies of the Sheffield Unitary Development Plan (adopted March 1998).

3.3 We set out our summary of relevant planning policy below.

The Development Plan

Sheffield Core Strategy

3.4 The Core Strategy provides an overall strategy and framework to guide future development across the

City of Sheffield in the period to 2026.

3.5 Paragraph 2.28 sets out the Vision for the future of the City, which indicates that:

‘Sheffield will be a successful, distinctive city of European significance at the heart of a strong city region,

with opportunities for all.

Our approach to achieving this vision will be built upon three key principles:

. Prosperity: We will actively seek to make the city competitive in economic terms, attracting investment and providing an environment that enables wealth to be created. . Inclusion: We will promote access to opportunities and services, so that all residents can take advantage of the benefits of living in the Sheffield area.

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. Sustainability: Our actions will meet the needs of the present without compromising the ability of future generations to meet their own needs.’

3.6 In respect of the Chapeltown area, paragraph 4.27 of the Core Strategy states that:

‘Chapeltown and Stocksbridge are both designated as ‘Principal Towns’ in the Regional Spatial Strategy, which fulfil a regionally significant role as service, employment and transport hubs for their surrounding area. Development in these settlements will be confined to their existing urban areas and expansion into the surrounding countryside not already protected as Green Belt will be strongly resisted. Provision for

local jobs will be promoted on redevelopment sites in the Chapeltown area and in Stocksbridge to support a degree of self-containment to reduce the need to travel out to work.’

3.7 In terms of redevelopment, Policy CS14 indicates that new shops and leisure facilities with City-wide and regional catchments will be concentrated in the city centre primary shopping area and immediately adjacent shopping streets. The policy is not of relevance to this application proposal given that it will meet localised needs and has a limited catchment area as a consequence.

3.8 In respect of new housing, Policy CS22 indicates that there should be an average of 1,425 net additional dwelling completions between 2008/09 and 2025/26. The policy indicates that sufficient sites will be

allocated to meet the housing requirement until at least 2020/21, and that a five-year supply of deliverable sites should be maintained at all times.

3.9 Policy CS23 indicates that new housing development will be concentrated where it would support urban regeneration and make efficient use of land and infrastructure. It goes on to state that:

‘In Chapeltown/High Green and in the larger villages of Oughtibridge, Worrall and Wharrall and Wharncliffe Side housing development will be limited to suitable, sustainable sites within the existing built- up areas.’

3.10 Policy CS24 states that priority will be given to the development of previously developed sites and that

no more than 12% of dwelling completions should be on greenfield sites between 2004/05 and

2025/26.

3.11 Policy CS34 relates to Sheffield’s district centres and indicates that such centres:

‘…will be encouraged in fulfilling their role of providing for everyday needs with a range of retail, leisure and community facilities, appropriate in scale and function to the role of the centre. They may also include

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concentrations of specific shops or services in response to the market in their particular area. Smaller-scale offices and residential development away from shop frontages will complement shops and services.’

3.12 Neither Policy CS34 nor any other Core Strategy policy specifically addresses the matter of out of centre retail proposals.

3.13 Policy CS53 indicates that increasing demand for travel through all parts of the city will be managed

through, inter alia:

. implementing Travel Plans for new developments to maximise the use of sustainable forms of travel and mitigate the negative impacts of transport, particularly congestion and vehicle emissions; and

. applying maximum parking standards for all new developments to manage the provision of private parking spaces.

3.14 In respect of climate change, Policy CS63 indicates that priority will be given to development in areas that are well served by sustainable forms of transport and to the redevelopment of previously

developed land where this is sustainable located.

3.15 Policy CS66 indicates that action will be taken to protect air quality in all areas of the city. Further action to improve air quality will be taken across the built up area, and particularly where residents in road corridors with high levels of traffic are directly exposed to levels of pollution above national

targets.

3.16 Policy CS74 states that:

‘High-quality development will be expected, which would respect, take advantage of and enhance the distinctive features of the city, its districts and neighbourhoods, including:

a. the topography, landforms, river corridors, Green Network, important habitats, waterways, woodlands, other natural features and open spaces; b. views and vistas to landmarks and skylines into and out of City Centre and across the city to surrounding countryside; c. the townscape and landscape character of the city’s districts, neighbourhoods and quarters, with their

associated scale, layout and built form, building styles and materials; d. the distinctive heritage of the city, particularly the buildings and settlement forms associated with:

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i. the metal trades (including workshops, mills and board schools) ii. the City Centre iii. Victorian, Edwardian and Garden City suburbs iv. historic village centres and the city’s rural setting.

Development should also:

e. contribute to place-making, be of a high quality, that contributes to a healthy, safe and sustainable environment, that promotes the city’s transformation;

f. help to transform the character of physical environments that have become run down and are lacking in distinctiveness; g. enable all people to gain access safely and conveniently, providing, in particular for the needs of families and children, and of disabled people and older people; h. contribute towards creating attractive, sustainable and successful neighbourhoods.’

Sheffield Unitary Development Plan

3.17 We summarise saved UDP policies of relevance to the application proposal below.

3.18 In respect of building design and siting, Policy BE5 indicates that, inter alia:

. original architecture will be encouraged but new buildings should complement the form and

architectural style of surrounding buildings; and

. in all new developments, design should be of a human scale wherever possible.

3.19 Policy BE6 states that good quality landscape design will be expected in new developments and refurbishment schemes.

3.20 Policy BE7 identifies that, in buildings that are to be accessed by the public, provision will be expected

to allow people with disabilities safe and easy access to the building and appropriate parking spaces.

3.21 Policy BE9 indicates that new developments should provide a safe, efficient and environmentally acceptable site layout for all vehicles and pedestrians. This will include:

. a clear definition of vehicle access and exit;

. good quality design of internal roadways and signs; . adequate turning and manoeuvring space for emergency vehicles; and

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. adequate safeguards for people living, working or walking at the site or nearby from exhaust fumes, traffic noise or risk of accident.

3.22 As identified at Section 2 of this Statement, we note that the Council’s Proposals Map identifies the application site is being within a ‘washed over’ housing area, with UDP Policy H10 being of relevance as a consequence. Policy H10 indicates that within housing areas the preferred use will be residential,

with a wide range of other commercial and institutional uses being acceptable (including small scale Class A1 retail uses).

3.23 We note that the policy indicates that other Class A1 uses will acceptable when they are ‘…at the edge

of the Central Shopping Area or a District or Local Shopping Area.’

3.24 As such, it is clear that the purpose of the policy is not to prohibit retail development as a matter of principle, rather the policy instead seeks to direct such uses to the edge of existing retail areas. As a

consequence, it is our view that the policy effectively imposes a sequential test which is inconsistent with that set out in national planning policy. In accordance with paragraph 213 of Annex 1 of the NPPF2, this impacts on the weight that can be afforded to the policy. We go on to consider this matter in greater detail in the following Section 4 of this Statement.

3.25 In respect of retail policies, Policy S5 provides for ‘appropriately sized’ foodstores outside of defined centres where a proposal satisfies the following criteria:

. it would not undermine the vitality and viability of the City Centre or any District Shopping Centre as a whole, either taken alone or cumulatively with other recent and proposed development; and

. it would not prejudice private sector investment need to safeguard the vitality and viability of the Central Shopping Area or District Shopping Centres or put at risk the strategy for these areas; and

. it would be easily accessible by public and private transport and provide satisfactory access for

people with disabilities and those arriving by foot, cycle or public transport; and

. it would not have a significant harmful effect on public transport services or priority measures or on other movements on the surrounding road network as existing or, where appropriate, as proposed to be improved; and

. the traffic generated would not result in a significant increase in the number and length of

2 Which indicates that weight should be afforded to development plan policies in accordance to their consistency with the NPPF (the closer development plan policy is to that set out in the NPPF, the greater the weight that may be given

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customer trips; and

. it would not take up land where other uses are required; and . it would comply with other policies of the plan.

3.26 Policy S11 relates to the design of retail development and indicates that proposals will be required to:

. provide access for pushchairs and people with disabilities; and

. provide for safe and easy pedestrian movement at ground level; and . provide car and cycle parking for people who live or work in the development; and

. provide or contribute towards appropriately shoppers’ car and cycle parking or measures to assist

public transport, walking or cycling required as a direct result of that development, either as part of the development or elsewhere in the shopping centre; and

. have shop fronts which are in keeping with the building which they are contained.

3.27 Policy T21 indicates that provision will be made for car parking where, inter alia, it meets the operational needs of businesses or is essential for the viability of a development.

3.28 Similarly, Policy T22 states that, for non-office development outside Sheffield city centre, developers

will be expected to make provision for sufficient off-street car parking to meet the needs of their development.

The National Planning Policy Framework

3.29 The revised NPPF was published in February 2019. It sets out the Government’s overarching policy objectives and, at paragraph 6, identifies that the purpose of the planning system is to contribute to the achievement of sustainable development.

3.30 Paragraph 8 indicates that there are three dimensions to sustainable development: economic, social

and environmental. It goes on to identify that:

‘These dimensions give rise to the need for the planning system to perform a number of roles:

. an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth,

innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;

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. a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being; and . an environmental objective – to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.’

3.31 Paragraph 11 sets out a presumption in favour of sustainable development. It indicates that:

‘For decision-taking this means:

. approving development proposals that accord with an up-to-date development plan without delay; or . where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date, granting permission unless: - the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or - any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.’

3.32 The Government’s policies for delivering sustainable development are set out at Section 1 to 13 of the

NPPF.

3.33 Of particular relevance to this application are Sections 1, 4, 5, 7, 8, 9, 12 and 14, which we summarise below.

Section 4: Decision Making

3.34 In considering the requirements of national planning policy, it is important to recognise the instruction provided to local planning authorities in respect of the determination of planning applications. Paragraph 38 of the NPPF states that authorities should approach decision-making in a positive way to foster the delivery of sustainable development.

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Section 5: Delivering a Sufficient Supply of Homes

3.35 Paragraph 59 of the NPPF states that in order to boost the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.

Section 7: Ensuring the Vitality of Town Centres

3.36 Paragraph 86 sets out the sequential approach to development that is to be applied to proposals for

main town centre uses (including retail and food and drink uses) which are not in an existing centre and not in accordance with an up-to-date development plan. In terms of local planning authorities’

consideration of such planning applications, paragraph 24 states that:

‘They should require applications for main town centre uses to be located in town centres, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered. When considering edge of centre and out of centre proposals, preference should be given to accessible sites that are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale.’

3.37 Paragraph 89 sets out a streamlined impact test which focuses on two particular issues. It states that:

‘When assessing applications for retail, leisure and office 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 (if there is no locally set threshold, the default threshold is 2,500 sq.m). This should include assessment of:

. the impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and . the impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider area, up to five years from the time the application is made. For major schemes where the full impact will not be realised in five years, the impact should also be assessed up to ten years from the time the application is made.’

3.38 Paragraph 90 suggests that, where an application fails to satisfy the sequential test or is likely to have

significant adverse impact, it should be refused.

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3.39 A reading of paragraph 90 in isolation may give rise to the suggestion that it could act to set out two ‘gateway’ tests (a sequential test and an impact test), which have to be ‘passed’ before other considerations could be weighed in the balance. However, such an interpretation is contradictory both to the remainder of the NPPF – which gives primacy to the development plan where it is up to date –

and to the key principle established by Section 38(6) of the Planning and Compulsory Purchase Act 2004 which requires both the positives and negatives of any application proposal to be considered before reaching a balanced decision. Notwithstanding this, it is accepted that whether a proposal complies with the requirements of the NPPF’s sequential and impact tests will clearly be a material

consideration to be afforded appropriate weight in the decision making process.

3.40 We assess the application proposal in terms of its accordance with the two key national retail policy tests at Sections 5 and 6 of this Statement.

Section 8: Promoting Healthy and Safe Communities

3.41 Paragraph 92 identifies that planning decisions should provide for community facilities (including local shops) and other local services to enhance the sustainability of communities and residential environments. The same paragraph also advocates an integrated approach in considering the location

of housing, economic uses, and community facilities and services.

Section 9: Promoting Sustainable Transport

3.42 Paragraph 108 states that in assessing specific applications for development, it should be ensured that:

. appropriate opportunities to promote sustainable transport modes can be, or have been taken

up, given the type of development and its location;

. safe and suitable access to the site can be achieved for all users; and . any significant impacts from the development on the transport network (in terms of capacity and

congestions), or on highway safety, can be cost effectively mitigated to an acceptable degree.

3.43 Paragraph 109 then states that development should only be prevented or refused on highways grounds

if there would be an unacceptable impact on highways safety, or the residual cumulative impacts on the road network would be severe.

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Section 12: Achieving Well Designed Places

3.44 Paragraph 124 of the NPPF identifies that good design is a key aspect of sustainable development and should contribute positively to making places better for people.

3.45 Paragraph 127 identifies that planning decisions should, amongst other considerations, add to the

overall quality of the area and reflect the identity of local surroundings.

3.46 Paragraph 130 indicates that permission should be refused for development of a poor design that fails

to take the opportunities available for improving the character and quality of an area and the way it functions.

Section 14: Meeting the Challenge of Climate Change, Flooding and Coastal Change

3.47 In respect of flooding, paragraph 163 of the NPPF indicates that proposed development should not increase flood risk elsewhere. The Policy states:

‘Development should only be allowed in areas at risk of flooding where, in the light of this assessment (and the sequential and exception tests, as applicable) it can be demonstrated that:

a) within the site, the most vulnerable development is located in areas of lowest flood risk, unless there are overriding reasons to prefer a different location; b) the development is appropriately flood resistant and resilient; c) it incorporates sustainable drainage systems, unless there is clear evidence that this would be inappropriate; d) any residual risk can be safely managed; and e) safe access and escape routes are included where appropriate, as part of an agreed emergency plan.’

3.48 In this instance, the site falls within Flood Zone 1 and all elements of the proposal are appropriate development.

Other Material Considerations

Ensuring the Vitality of Town Centres Planning Practice Guidance

3.49 The Ensuring the Vitality of Town Centres Planning Practice Guidance (‘the Town Centres PPG’) provides direction in respect of how the NPPF retail and town centre policies should be applied in practice. It

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seeks to ensure that local planning authorities plan positively in order to meet identified needs, promote competition, and support local employment.

3.50 With specific reference to meeting future needs, paragraph 006 of the Town Centres PPG identifies that:

‘It may not be possible to accommodate all forecasts needs in a town centre: there may be physical or other constraints which make it inappropriate to do so. In those circumstances, planning authorities should plan positively to identify the most appropriate alternative strategy for meeting the needs for these main town

centre uses having regard to the sequential and impact tests.’

3.51 In respect of the sequential test, paragraph 010 indicates that the test should be applied in a proportionate manner, with reference to the suitability of individual sites to accommodate the

proposal.

3.52 Paragraph 011 recognises that main town centre uses have particular market and locational requirements which mean that they may only be accommodated in specific locations.

3.53 In respect of impact, paragraph 017 indicates that it is relevant to consider the current vitality of relevant

centres and examine the ‘no development’ scenario. Paragraph 017 goes on to state that a judgement as to whether identified impacts are significant can only be reached in light of local circumstances.

Sheffield & Rotherham Joint Retail & Leisure Study 2017

3.54 Paragraph 5.64 of the Joint Retail & Leisure Study identifies that Chapeltown is a relatively compact district centre, which is principally surrounded by residential uses. Based on a survey of the centre undertaken in June 2016, the Retail & Leisure Study identifies that at that time:

. the centre had a total of 71 commercial units, which is an increase of two from the level of provision

identified by the Council’s own survey of July 2015;

. there were eight convenience goods retailers (including an Asda superstore, Premier convenience store and Tesco Express at the petrol filling station), which accounted for 11.3% of the stock of all units,

. there were 20 comparison goods units, which accounted for 28.2% of all units; . there were 37 units occupied by service uses, which accounted for 52.1% of all units (indicating that the service sector is of particular importance to Chapeltown); and

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. there were six vacant units, which equated to a vacancy rate of 8.5%.

3.55 The dominance of the Asda superstore at Market Street as a main food shopping destination is identified by paragraph 5.70 of the Retail & Leisure Study which states that:

‘The 2016 household survey results indicate that convenience goods stores in Chapeltown have a high market share for main food shopping trips, with a 49% share of first choice main food trips in Zone 2 (Zone 2 is where Chapeltown is located). The large Asda store contributes a 48% market share to this total. Chapeltown is also able to attract 6% of shopping trips from Zone 1 residents. Outside of the district centre,

the closest large supermarket is Morrison on The Common in Ecclesfield. It manages to attract an 11% market share of trips within Zone 2 for second choice main food shopping.’

3.56 Paragraph 5.80 of the Study provides an overview of local retail provision and confirms that:

‘…Chapeltown is considered to be a reasonably healthy district centre located in the northern part of the Sheffield urban area. There remains a lower than average proportion of vacancies within the centre and it continues to serve an important service-related role for the local community. The ASDA supermarket dominates the centre’s convenience goods shopping function and allows the centre to retain half of first choice main food trips and the district centre as a whole is able to attract four out of every ten top-up food

shopping trips from local residents.’

3.57 Section 8 of the Retail and Leisure Study identifies that there is a convenience goods expenditure

surplus equating to around £10.9m at 2016, which is available to support additional floorspace across Sheffield. Based on the retention of the existing convenience goods market share across the authority area, it is estimated that this will increase substantially to £48.3m at 2021 and to £82.7m at 2026. Paragraph 8.6 of the Study indicates that, on an indicative basis, this surplus expenditure equates to

the equivalent of 4,000 sq.m net convenience goods sales floorspace at 2021 and 6,900 sq.m net at

2026.

3.58 It is also relevant to this application proposal that the Retail and Leisure Study provides straightforward and unambiguous advice in respect of Sheffield’s application of a local impact threshold in association

with the retail impact test. Paragraph 10.25 of the Study states:

‘…unless SCC sets a different threshold in its Sheffield Plan, all retail proposals below 2,500 sq.m gross floorspace in the city will not be assessed against their impact on the health of, and investment within, all

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defined ‘town centre’ in Sheffield. This will include the City Centre, district and local centres across the city.’ (Our emphasis.)

3.59 As we confirm in greater detail at Section 6 of this Statement, the application proposal does not exceed the 2,500 sq.m threshold and, as we indicated at Section 2, the Council has already accepted at pre- application stage that there is no formal requirement to undertake an impact assessment in association

with the application.

Summary

3.60 The Council’s Proposals Map identifies the application site is being within a ‘washed over’ housing area, with UDP Policy H10 being of relevance as a consequence. UDP Policy H10 indicates that within

housing areas the preferred use will be residential, with a wide range of other commercial and institutional uses being acceptable (including small scale Class A1 retail uses). However, the policy also indicates that other Class A1 Uses will be acceptable when they are located at the edge of a district centre.

3.61 As such, it is clear that the purpose of the policy is not to prohibit retail development as a matter of principle, rather the policy instead seeks to direct such uses to the edge of existing retail areas. As a

consequence, it is our view that the policy effectively imposes a sequential test which is inconsistent with that set out in national planning policy. In accordance with paragraph 213 of Annex 1 of the

NPPF3, this impacts on the weight that can be afforded to the policy. We go on to consider this matter in greater detail in the following Section 4 of this Statement.

3.62 In respect of retail policies, UDP Policy S5 provides for ‘appropriately sized’ foodstores outside of

defined centres where a proposal satisfies a series of criteria, relating to the protection of the vitality and viability of defined centres, the accessibility of the site and development and the associated traffic generation, and the proposal’s compliance with the other policies of the plan.

3.63 We consider the application proposal’s compliance with general plan policy in the following Section 4

of this Statement. We then provide a detailed assessment of the proposal’s compliance with the retail sequential and impact tests at Sections 5 and 6. Given that the retail policies of the development plan predate and do not entirely reflect the key retail tests set out at paragraphs 86, 89 and 90 of the NPPF,

3 Which indicates that weight should be afforded to development plan policies in accordance to their consistency with the NPPF (the closer development plan policy is to that set out in the NPPF, the greater the weight that may be given

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we believe that national retail planning policy (and how it has been clarified by the Courts and the Secretary of State) should be afforded significant weight in determining the application.

3.64 In order to deal with development plan policy in a straightforward manner, we provide an overview of policy on a thematic basis at Section 4.

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4.0 General Compliance with the Development Plan and National Planning Policy

4.1 We provide our assessment of the proposal’s general compliance with the adopted development plan and national planning policy below.

Presumption in Favour of Sustainable Development

4.2 As set out at Section 3 above, Paragraph 8 of the NPPF states that achieving sustainable development

means that the planning system has three overarching objectives: an economic objective; a social objective; and an environmental objective.

4.3 The planning application would provide an appropriately located foodstore which would meet needs which arise locally, alongside new, well designed residential dwellings in a highly sustainable location.

4.4 In doing so, the development of a new foodstore would improve consumer choice, reduce the need to travel further afield in order to source day-to-day retail and service needs, and support jobs. The proposal would therefore make a substantial contribution to reducing overall journeys in the local area.

Furthermore, the provision of new dwellings will assist in promoting vibrant communities, providing

space for residents within Chapeltown.

4.5 In addition, the proposed development scheme would bring back into active a use a currently vacant, previously developed site at a highly sustainable location within the existing built up part of

Chapeltown.

4.6 The proposal also fully accords with development plan policy seeking to provide for sustainable development which enhances economic, environmental and social conditions in accordance with the

Core Strategy Vision. By reducing the need to travel and providing key facilities in a central location,

the proposal is also consistent with the requirements of Core Strategy Policies CS63 and CS66 which seek to prioritise development served by sustainable forms of transport and improve air quality levels throughout the city.

The Principle of Residential Development

4.7 The adopted development plan recognises the importance of ensuring that there is enough good

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quality housing for everyone, located in sustainable and accessible places. Indeed, Policy CS23 of the Core Strategy guides new housing development to areas where it would support urban regeneration and make efficient use of land and in particular within Chapeltown to suitable and sustainable sites within the existing built-up areas. Furthermore, Policy CS24 of the Core Strategy seeks to maximise the

use of previously developed land for new housing through the prioritisation of the development of previously development sites.

4.8 The Council’s Proposals Map identifies the application site as being within a ‘washed over’ housing

area, with UDP Policy H10 indicating that the preferred use in such areas will be residential, but that

other commercial uses and institutional uses will be acceptable. As such, the proposed dwellings are consistent with the Council’s general aspirations for the area.

4.9 Policy H14 states that new development will be permitted provided that (amongst other things):

. new buildings are well designed and would be in scale and character with neighbouring buildings;

. new development would be well laid out; . the site would not be over-developed or deprive residents of light, privacy or security; . would provide safe access to the highway network;

. would not suffer from unacceptable pollution;

. not lead to a concentration of non-housing uses which would threaten the residential character of the Housing Area; and

. not prejudice the provision of sufficient housing.

4.10 The application site has been vacant for a number of years and has previously benefitted from planning permission for residential development on two separate occasions, neither of which have been implemented. The suitability of the site to accommodate residential development has therefore been previously established through the grant of the previous planning consents, and relevant development

plan policy (including Core Strategy Policies CS22, CS23 and CS24) is supportive of the residential element of the proposal.

4.11 This application proposal now seeks to provide a viable mixed-use development, which will allow this previously developed and sustainable site in the built up area Chapeltown to come forward for

development and make the best use the site. As we set out in more detail later in this section, the scheme will not have a material impact on pollution and will not deprive existing or future residents of

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natural light, privacy or security.

4.12 The proposed development seeks outline permission for the erection of eight dwellings, to front on to Thorncliffe View. Although the detailed design of the proposed dwellings is not being applied for at this stage, it is intended that the residential properties will be in keeping with existing residential

properties in the surrounding area.

4.13 The indicative layout demonstrates that the proposed buildings (both retail and residential) can be accommodated in an appropriate manner on the site and that the proposal has been designed and

sited in order to fit within the existing urban environment. As part of the pre-application public

consultation exercise, queries were raised by interested parties in respect of the layout and design of the scheme, and subsequent changes were made to the proposal, taking these comments on board. The full details of the public consultation exercise are provided in the Statement of Community Involvement, produced by Counter Context.

4.14 The application site will not be over-developed as a result of the proposal and will provide safe access to the surrounding highways network, as demonstrated in more detail in the submitted Transport Statement.

4.15 To summarise:

. the proposal complies with the policies within the adopted development plan; . the residential element of the scheme has been designed to be in keeping with the surrounding uses and particularly the existing residential properties;

. the residential element of the scheme will not result in over-development or unduly impact on pollution, residential amenity or highways safety; and

. the proposed dwellings will assist in providing much needed housing, within a sustainable and accessible location in an existing urban area of Sheffield.

The Principle of Retail Development

4.16 The type and format of foodstore proposed is such that the development will cater for needs which arise in the local area. Consequently, it is anticipated that the vast majority of customers will be Chapeltown and High Green residents, as it would generally be illogical for residents in outlying areas

to drive past more convenient options in order to access the site. As we go on to consider in detail at

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Section 6 of this Statement, the impacts arising from the proposal would generally be borne by retailers which currently trade successfully and would likely continue to do so subsequent to the proposal’s implementation.

4.17 In any event, given the scale of the proposal, no formal impact assessment is required to be submitted

with the application and the assessment provided at Section 6 has been provided for completeness. As such, there we believe it to be clear that the impact test could not support the refusal of the application in any event.

4.18 Policy H10 specifically provides for small-scale retail uses, but indicates that larger format retail

development will only be acceptable in such areas when they are ‘…at the edge of the Central Shopping

Area or a District or Local Shopping Area.’

4.19 As such, the policy does not seek to preclude retail development as a matter of principle; instead, it seeks to direct such uses to the edge of existing retail areas.

4.20 As a consequence, the policy provides for a form of sequential test4 which is inconsistent with the sequential test set out by the NPPF5. Due to this inconsistency, we believe that Policy H10 is not up to

date and can therefore only be afforded limited weight.

4.21 We understand that the Council has previously formed the same view when interpreting the policy. In this regard, we note the Officer’s report which commended the grant of planning permission for a food retail development at the Former Hatfields Garage site on Abbeydale Road South (planning permission

reference 09/01676/CHU).

4.22 In considering the principle of a retail use within a ‘washed over’ housing area, the Hatfields Garage site Officer’s report states that:

‘The adopted Unitary Development Plan (UDP) shows that the site is within a housing policy area. Policy

H10 says that housing is the preferred use…However this policy, as it relates to retail uses, has been superseded by national guidance...’ (Our emphasis.)

4.23 The location of the proposal is such that it meets a local deficiency in terms of foodstore provision that

4 Effectively directing larger retail development within defined centres or to edge of centre locations 5 Which directs main town centre uses to town centre sites, then edge of centre locations, and then out of centre locations

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is able to support main food shopping trips. As such, the site is both attractive to prospective operators and can be accommodated without any one centre being the subject of an unacceptable impact.

4.24 As a consequence of the above, the proposed development would not undermine the viability of any existing centre and is particularly well located in terms of being access by a range of means of transport

(most obviously by car, by bus, on foot and by bicycle). The proposal is therefore consistent with Core Strategy Policy S5, which provides for appropriately sized foodstores in accessible locations.

4.25 As we go on to explain in greater detail in Sections 5 and 6 of this Statement, the proposed

development also accords with the requirements of the sequential and impact tests as articulated by

paragraphs 86, 87, 89 and 90 of the NPPF.

Employment

4.26 The Homes & Communities Agency Employment Density Guide 3rd Edition (November 2015) is typically used to provide an estimate of the employment associated with retail proposals. However, the

employment density for foodstore development provided at Section 4 of the Employment Density Guide provides for a level of employment in excess of that which we believe will be supported in

practice. In actuality, we believe that a foodstore of the scale proposed would likely support in the order of 40 FTE jobs (based on our experience of comparable schemes elsewhere).

4.27 Given the above, we believe that the proposal clearly accords with the NPPF, which indicates that the planning system should support sustainable economic growth. The proposed development is also consistent with the overall Vision for Core Strategy and with paragraph 4.27 which indicates that

‘…provision for local jobs will be promoted on redevelopment sites in the Chapeltown area.’

Design

4.28 The proposed indicative development seeks to respond to the local context and provide a development

which improves the existing vacant and overgrown site. The indicative submitted scheme has evolved to address comments made by the Council and the local community at the pre-application stage.

4.29 Whilst we reiterate that the application is in outline, the submitted indicative elevation drawings demonstrate that a modern development can be secured which is appropriate to and reflective of the

local context.

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4.30 The height of the store is such that it is able to meet prospective retailers’ operational requirements, whilst remaining of a scale that is appropriate to existing nearby uses.

4.31 In terms of the proposed residential dwellings on the eastern boundary of the site, these have been designed to be in keeping with the existing properties along Thorncliffe View and the rear gardens will

be screened from the proposed foodstore by an extensive landscaped zone and timber fencing. The dwellings will also incorporate integral garages with front drives and gardens.

4.32 The Design & Access Statement indicates that the proposed site layout has been directly informed by

the need to secure inclusive access for all in the safest and most straightforward manner. The indicative

layout provides for the separation of servicing and customer vehicular traffic, and there is a clear emphasis on enhancing pedestrian connectivity to and within the retail element of the site. In this regard, the site provides easy access to bus stops on Lane End.

4.33 Overall, the submission demonstrates that the proposed development accords with Policy CS74 of the

Core Strategy and paragraph 130 of the NPPF.

Transport and Accessibility

2.55 A Transport Assessment, prepared by Turner Lowe Associates, has been submitted in support of the application proposal. The Assessment demonstrates that the proposed foodstore will be accessible on

foot and will encourage walking as a mode of transport. Furthermore, a new pedestrian crossing will be provided on Lane End to further assist pedestrian trips.

4.34 The proposed access to the site will function with reserve capacity and no queueing issues. In addition,

the parking area for the residential properties on the south side of Lane End and bus stop box markings are also proposed and these have been allowed for in the capacity calculations.

4.35 Overall, it is concluded that the site is accessible by a choice of modes of transport and that there are no highways/traffic related reasons why the proposed development should not be approved.

4.36 As a consequence of the above, the proposal is consistent with Policy BE9 of the UDP and paragraphs 109 of the NPPF (relating to the potential impact of the proposal on the surrounding highways network) and 110 of the NPPF (which seeks to encourage sustainable and accessible development).

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Flood Risk

4.37 A Flood Risk Assessment & Drainage Strategy, prepared by Waterco Consultants, accompanies this application. The Flood Risk Assessment demonstrates that the proposed development and any associated earthworks would not reduce flood storage capacity and not result in an increased risk of

flooding elsewhere.

4.38 As a consequence of the above, there are no particular issues relating to flood risk or drainage arising from the application proposal. The proposal is thereby compliant with the requirements of Section 10

of the NPPF.

Conclusion

4.39 This application proposal comprises a comprehensive set of documents, which set out the proposal’s compliance with relevant planning policy. Our above summary indicates that the development is generally consistent with the general requirements of: the NPPF; the adopted Sheffield Core Strategy

and the Sheffield Unitary Development Plan; and, all other policy considerations of material relevance. Whilst UDP Policy H10 effectively provides a sequential approach to development which only allows

larger scale retail development at edge of centre locations in housing areas, the Council has previously confirmed that this policy is out of date. As such, it could not support the refusal of this planning

application.

4.40 Notwithstanding the above, given that the application seeks to provide main town centre uses in an out of centre location, it is appropriate to provide detailed consideration of the proposal’s compliance

with the key sequential and impact tests. As such, the below Section 5 addresses the requirements of the sequential test and Section 6 considers the town centre impacts arising from the proposal.

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5.0 The Sequential Test

Application of the Sequential Test

5.1 As highlighted at paragraph 3.41 of this Statement, paragraph 86 of the NPPF sets out the sequential approach to development proposals for main town centre uses that are not in an existing centre and not in accordance with an up-to-date development plan. Paragraph 86 indicates that proposals for

main town centre use should be located in town centres, then in edge of centre locations, and only

then in out of centre locations, should no other suitable sites be available. When considering edge of centre and out of centre proposals, preference should be given to accessible sites that are well connected to the town centre. Paragraph 86 goes on to state that applicants and local planning

authorities should demonstrate flexibility on issues such as format and scale.

5.2 Paragraph 010 of the Town Centres PPG clarifies that, in applying the sequential test, consideration should be given to:

. the suitability of more central sites to accommodate the development proposal; and

. whether there is scope for flexibility in the format and/or scale of the proposal.

5.3 Both the NPPF and the associated Town Centres PPG provide limited clarification in respect of how the above criteria should be applied and, as such, it is appropriate to consider how the concepts of ‘suitability’ and ‘flexibility’ have been considered by the Courts and by the Secretary of State (‘SoS’).

Suitability and Flexibility

5.4 Case law has emphasised that the ‘suitability’ of sequential alternatives must be considered with reference to the subject application proposal and whether the proposal (or a variant thereof, allowing for some flexibility in respect of its format) could be accommodated at a sequentially preferable

location.

5.5 In particular, it is helpful to take into account the Tesco Stores Limited v Dundee City Council [2012] UKSC 13 Supreme Court Judgment which gave specific consideration to the meaning of ‘suitable’ in respect of the application of the test.

5.6 Paragraph 38 of the Dundee Judgment states that:

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‘The issue of suitability is directed to the developer’s proposals, not some alternative scheme which might be suggested by the planning authority. I do not think that this is in the least surprising, as developments of this kind are generated by the developer’s assessment of the market that he seeks to serve. If they do not meet the sequential approach criteria, bearing in mind the need for flexibility and realism…they will be rejected. But these criteria are designed for use in the real world in which developers wish to operate, not some artificial world in which they have no interest in doing so.’ (Our emphasis.)

5.7 The Supreme Court has jurisdiction over England and, whilst there is a clearly need to consider its

findings in the appropriate local policy context, both the Courts and the SoS have found the direction

to apply the test ‘in the real world’ to be of some relevance to the English planning system. This is demonstrated by the ‘call in’ decision in respect of an application by LXB RP (Rushden) Limited to provide for large-scale retail-led development at land adjacent to Skew Bridge Ski Slope at Rushden

Lakes (Planning Inspectorate reference APP/G2815/V/12/2190175).

5.8 Paragraph 8.46 of the Rushden Lakes Inspector’s Report states that:

‘It is important to bear in mind that the sequential test as set out in NPPF require applications for main town centre uses to be located in town centres and it then runs through the sequence, edge and then out- of-centre. This makes good the very simple point that what the sequential test seeks is to see whether the

application i.e. what is proposed, can be accommodated on a town centre site. There is no suggestion here that the sequential test means to refer to anything other than the application proposal. So Dundee clearly applies to the NPPF.’ (Inspector’s emphasis.)

5.9 Given the above, it is evident that sequential alternatives must be viewed in the context of whether they meet the specific ‘real world’ requirements of a development of this nature.

5.10 In this regard, the broad type of retail development proposed provides for occupation of the unit by a discount foodstore operator. The business model of such operators is widely known and requires a minimum site size of 0.6 hectares. However, in order to consider all sites with any potential whatsoever

to accommodate the proposal, we have adopted the very cautious position that any available site

comprising more than 0.5 hectares should be given consideration.

5.11 We consider the area of search for the sequential test below.

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Locational Requirements and the Area of Search

5.12 Paragraph 011 of the Town Centres PPG acknowledges that the characteristics of an application proposal and the market it would serve may act to restrict the area within which it can be accommodated. It states that:

‘Use of the sequential test should recognise that certain main town centre uses have particular market and locational requirements, which mean that they may only be accommodated in specific locations.’

5.13 In this case, the proposed development seeks to provide a discount foodstore which is able to meet the shopping needs of residents in the Chapeltown and High Green area. These areas sit slightly apart from the wider Sheffield conurbation and, as such, comprise a relatively discrete catchment. The need

for the area of search to be focussed around the Chapeltown and High Green areas has been accepted by Council Officers at pre-application stage6.

5.14 There is an operational requirement to locate on a site which benefits from a reasonable degree of visibility and is well located in respect of the transport network, in order to be attractive to operators.

Identified Parameters

5.15 Based on the above, we believe that alternative sequential sites should be:

. at least 0.5 hectares in size, in order to accommodate a materially similar form of development; . within the Chapeltown and High Green area, such that any sequential alternative site would serve

the same broad catchment area; and

. in a visible location which benefits from good access to the transport network in order to meet the needs of prospective operators.

5.16 We have undertaken surveys of Chapeltown district centre, High Green neighbourhood centre and

Greengate Lane neighbourhood centre (and the surrounding area) on the above basis to identify potential sequential sites that may be available and suitable to accommodate the broad type of development proposed. We have also referred to the UDP Proposals Map and to aerial photographs

of the area.

6 Over the course of discussions with Bob Turner, Principal Planning Officer, and Matt Gregg, Planning Officer, in February 2019

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Review of Sequential Alternative Sites

5.17 Our research has identified a single site which meets the above criteria, this being Thorncliffe Cricket and Social Club in Chapeltown (which is an edge of centre site). The Cricket and Social Club comprises approximately 1.2 hectares. However, the site does not offer any realistic potential to accommodate

the application proposal as it is neither available nor suitable given that it:

. remains in active use and is a well-used community facility; and . is protected as Open Space through Policy CS57 of the Core Strategy.

5.18 The redevelopment of the Cricket and Social Club site is neither policy-compliant nor desirable. It can

be straightforwardly discounted from the sequential assessment.

5.19 We are aware of four additional sites which have recently offered some potential for redevelopment, albeit each comprises a substantially smaller area than that required for the application proposal.

5.20 In this regard, we note that:

. the former Sinemaster motor vehicle parts unit at Burncross Road in Chapeltown remains vacant

and comprises approximately 0.1 hectares;

. Chapeltown Swimming Baths on Burncross Road comprises 0.3 hectares and benefits from a resolution to grant planning permission (subject to legal agreement) for redevelopment for

residential purposes (planning application reference 18/02327/FUL);

. land adjacent to the Scout Hut at Pack Horse Lane in High Green is vacant and comprises approximately 0.1 hectares; and

. the former Market Inn site in High Green comprises approximately 0.1 hectares and is currently

being built out for residential purposes (planning permission reference 18/04443/FUL).

5.21 A plan illustrating the extent and spatial distribution of each of the above sites is provided at Appendix A.

5.22 It is evident that each site is far too small and that none offers any potential whatsoever to

accommodate the application proposal.

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Conclusion in Respect of the Sequential Test

5.23 The application proposal would meet main food shopping needs which principally arise in Chapeltown and High Green and, as such, the sequential test is necessarily focused around sites located in this area.

5.24 Our assessment has identified only a single site that meets the parameters of the search, this being

Thorncliffe Cricket and Social Club in Chapeltown, which is a well-used community facility and is protected Open Space.

5.25 There are no other sites which offer any potential to accommodate the application proposal; as such, the proposal clearly accords with the requirements of the NPPF sequential test as set out at paragraph

86.

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6.0 The Impact Test

Application of the Impact Test

6.1 The NPPF requires an impact assessment to be submitted for proposals which provide greater than 2,500 sq.m of retail and leisure floorspace (unless there is a different, locally set threshold). In this case, there is no such local threshold and the 2,500 sq.m figure applies (which is 549 sq.m above the

proposed gross floorspace of the foodstore). As such, we believe it to be clear that there is no

requirement to formally assess impact as part of this application submission.

6.2 In this regard, we are aware that costs have been awarded against local planning authorities at appeal where they have sought to rely on the NPPF impact test to support the refusal of planning applications

for less than 2,500 sq.m of retail floorspace (and where there is no adopted local impact threshold). Most specifically, we note the Inspector’s findings in the Costs Decision awarded against Bracknell Forest Borough Council in respect of a proposal to change the use of an office building in Bracknell to an ‘apart-hotel’ with two Class A1 units at ground floor level (PINS reference APP/R0335/A/12/

2181506).

6.3 Paragraph 7 and 8 of the Bracknell Costs Decision find that:

‘…impact is not relevant to the determination of the appeal scheme as the retail element of the proposal is significantly less than the 2,500 sq.m figure set out in paragraph 26 of the Framework.’

6.4 In addition to the above, the 2017 Sheffield & Rotherham Joint Retail & Leisure Study is similarly unambiguous with regard to the application of the impact test to proposals which provide a lesser amount of floorspace than the relevant threshold. Paragraph 10.25 of the Joint Retail & Leisure Study states that, as things stand:

‘…unless SCC sets a different threshold in its Sheffield Plan, all retail proposals below 2,500 sq.m gross floorspace in the city will not be assessed against their impact on the health of, and investment within, all defined ‘town centres’ in Sheffield. This will include the City Centre, district and local centres across the city.’ (Our emphasis.)

6.5 Given the above, we believe it to be clear that the NPPF impact test could, in this instance, support the refusal of the application proposal under any circumstances.

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6.6 Furthermore, we do not believe that the adopted development plan provides any up to date direct impact test of relevance.

6.7 Notwithstanding the above, we provide below an assessment of the limited impacts arising from the proposal in order to provide the Council with assurance that the foodstore could trade without any

issue.

6.8 In this regard, paragraph 89 of the NPPF requires consideration of:

. the impact of the proposal on existing committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and

. the impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and wider retail catchment (as applicable to the scale and nature of the scheme).

6.9 In considering the impact test, it is relevant to reflect on the direction provided at paragraph 017 of the

Town Centres PPG, which identifies that a judgement as to whether likely adverse impacts are significant can only be reached in light of local circumstances. On this occasion, we note that the Joint

Retail & Leisure Study identifies that Chapeltown district centre is a healthy district centre with a lower than average proportion of vacancies. Whilst the 2017 Retail & Leisure Study is relatively recent, we

visited Chapeltown in February and April 2019, and confirm its continued good health below before then going on to consider both strands of the NPPF policy test.

The Health of Chapeltown District Centre

6.10 In considering the health of Chapeltown district centre, it is relevant to note that the Retail & Leisure

Study concluded that the centre performed well against a number of health check indicators, and that there is a reasonable mix of national and independent retailers in the centre given its size. In this

regard, the Retail Study relied on a survey of Chapeltown district centre which was undertaken in June 2016.

6.11 At that time, Chapeltown district centre had a total of 71 units, of which eight were occupied by convenience operators and 20 were occupied by comparison operators. This equated to 11.3% and 28.2% of the total number of units within the centre, which compared to the UK average at the time of

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9.3% and 39.7% respectively. At the time of the survey, six units were recorded as being vacant, equating to 8.5% of the total number of units.

6.12 Our own survey of the centre in February 2019 also identified that a total of six units are vacant and, as such, the vacancy rate remains substantially below the current national average of 11.5%7.

6.13 The centre accommodates an Asda superstore, which represents the single main food shopping facility in the Chapeltown and High Green area. Adjacent to the Asda superstore is the Waggon public house, which also acts as a focal point for the centre. There are a number of service uses in the centre,

including leisure, retail and business uses, providing a wide and balanced offer to help meet residents’

needs.

6.14 Pedestrian activity in Chapeltown district centre at the time of our site visits was generally strong, with higher concentrations around the Asda foodstore and Waggon public house, demonstrating their ‘pull’ within the centre.

6.15 It is evident from our visits to Chapeltown district centre that the conclusions of the Council’s Retail Study remain entirely valid and that the centre remains vital and viable, with a good mix of retailers

and service operators. As we go on to explain further below, we believe that the good health of the centre is such that it would clearly be able to accommodate any impacts arising from the application

proposal without any material effect in respect of its ongoing viability.

Impact of the Proposal on Public and Private Investment

6.16 The only in-centre investment within the principal catchment area of the proposal that we are aware of

relates to proposed residential development in Chapeltown and High Green8. The implementation of such development will not be impacted by the application proposal and the Council has confirmed that it is of the same view during pre-application discussions.

6.17 We therefore believe it to be clear that the proposal accords with the requirements of the first part of

the NPPF impact test.

7 Experian Goad data, February 2019 8 Such development is identified at paragraph 5.20 of this Statement

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Impact of the Proposal on Town Centre Vitality and Viability

6.18 In order to inform judgements in respect of the likely impact of proposals on established centres, it is necessary to consider the likely diversion of expenditure that may occur when the proposed development is implemented and trading patterns have been established. Whilst the NPPF sets out

the second part of the impact test, paragraph 017 of the Town Centres PPG establishes a checklist for its application in practice.

6.19 The checklist identifies the following steps:

. establish the state of existing centres and the nature of current shopping patterns at base year;

. determine the appropriate time frame for assessing impact, focusing on impact in the first five years, as this is when most of the impact will occur;

. examine the ‘no development’ scenario; . assess the proposal’s turnover and trade draw;

. consider a range of plausible scenarios in assessing the impact of the proposal on existing centres and facilities;

. set out the likely impact of that proposal clearly, along with any associated assumptions or

reasoning, including in respect of quantitative and qualitative issues; and

. any conclusions should be proportionate; for example, it may be sufficient to give a broad indication of the proportion of the proposal’s trade derived from different centres and facilities in the catchment area and the likely consequences to the viability and vitality of existing centres.

6.20 Using the above checklist as a guide, we set out below our methodology and conclusions in respect of the retail impacts arising from the proposal. Detailed tables providing our step-by-step retail impact

assessment comprise Appendix B of this Statement. In order to assist with the interpretation of our assessment, we provide a brief summary of the retail impact tables (and associated inputs) below at

Table 6.1.

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Table 6.1: Summary of Appendix B Retail Impact Tables Table Reference Summary of Information Data Sources Utilised Experian MMG3 2018 data report; allowances made Study Area population and to account for future growth of trading in Tables 1, 2 and 3 convenience and comparison accordance with recommendations of Experian goods expenditure by zone Retail Planner Briefing Note 16. Convenience goods turnover Derived directly from Appendix 2 of the Sheffield Table 4 and market share of relevant and Rotherham Retail Study 2017 existing retail venues at 2016 Derived by multiplying the convenience goods zonal Updated convenience goods market share of venues (as identified at Table 4) by Table 5 turnover of relevant existing the updated available zonal convenience goods retail venues at 2019 expenditure at 2019 (as identified at Table 3) Updated convenience goods Derived by multiplying the convenience goods zonal turnover of relevant existing market share of venues (as identified at Table 4) by Table 6 retail venues at design year the updated available zonal convenience goods 2023 expenditure at 2023 (as identified at Table 3) Estimated convenience and Floorspace of proposal derived from submitted comparison goods turnover of plans and application forms. Convenience goods Table 7 application proposal (there are sales densities derived from Mintel Retail Rankings no commitments of relevance 2018 and Verdict GlobalData Major Grocers Sales to the assessment) Densities 2018 Turnover of stores based on Table 6, with Assessment of convenience assumptions in respect of trade diversion based on Table 8 goods trade diversion Nexus Planning judgement for the planning application

Establish the State of Existing Centres and the Nature of Current Shopping at Base Year

6.21 Our assessment estimates the turnover of existing centres at base year with reference to the quantitative need assessment provided in the 2017 Joint Sheffield and Rotherham Retail Study.

6.22 In order to adopt an approach that is consistent with the 2017 Retail Study, we have sourced up to date Experian MMG3 population and expenditure data9 for those Study Area zones that surround or are proximate to Chapeltown; these being Zones 2, 3 and 16, which form our extended catchment for the proposal.

6.23 Table 1 of Appendix B of this Statement identifies the estimated population of each relevant zone at base year 2019 and design year 2023. Tables 2a and 2b of Appendix B identify the average per capita convenience and comparison goods expenditure which is available on a zonal basis at 2019 and 2023 (after an allowance has been made to account for increases in growth and expenditure committed

9 Derived from a 2018 Experian MMG report

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through special forms of trading in accordance with the recommendations of Experian Retail Planner Briefing Note 16).

6.24 Having estimated the zonal population and the zonal per capita convenience and comparison goods expenditure, it is a straightforward exercise to calculate the overall pot of expenditure that exists to

sustain retail facilities in the area. We set out this calculation at Tables 3a and 3b of Appendix B and provide summary tables below at Table 6.2 and 6.3.

Table 6.2: Estimated Catchment Area Convenience Goods Expenditure at 2019 Zone 2 3 16 Total Per Capita Expenditure at 2019(£) 2,001 1,677 1,947 - Population at 2019 33,220 111,843 52,631 197,694 Total Expenditure at 2019 (£m) 65.7 185.3 101.2 352.2 Note: Extract from Tables 1, 2a and 3a of Appendix B; 2017 prices

6.25 Table 6.2 identifies that a total of £352.2m10 of convenience goods expenditure originates within the

catchment area at 2019.

6.26 The zonal market shares secured by convenience goods retailers are used to apportion to the available expenditure and estimate the turnover of existing retail destinations. The turnover of convenience

goods provision in the catchment area at 2019 is set out at Table 5 of Appendix B.

6.27 In respect of this exercise, we have concerns that the methodology employed by the Retail & Leisure Study household survey acts to understate the turnover of dominant foodstores, including the Chapeltown Asda. This is because household survey respondents are asked to identify their first and second choices for main food shopping; the first choice is then assigned 70% of main food expenditure

and the second choice 30% of main food expenditure. In Chapeltown, the Asda is the single dominant main food shopping destination; as such, it is the first choice main food shopping choice identified by the household survey for many residents in the local area, but barely features as a second choice.

6.28 In actuality, those shopping at the Asda will spend the vast majority of their main food shopping

destination at that store. However, the methodology employed by GVA in undertaking the Retail & Study only allows 70% of the main food shopping expenditure of these residents to be allocated to the Asda store (rather than the 100% allocation of expenditure that a more traditional household survey would more appropriately provide for). As a consequence of the above, we believe that the turnover

10 At 2017 prices, as is every subsequent monetary reference unless specified

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of the Chapeltown Asda is substantially greater than that identified by applying the methodology of the Retail & Leisure Study.

6.29 In order to provide for a more accurate baseline position, our assessment is based on respondents first choice main food shopping destination (to which 70% of individuals’ convenience goods expenditure

is ascribed) and their preferred top-up shopping destination (30% of convenience goods expenditure).

6.30 We believe that this approach is very clearly preferable in providing an estimate of the turnover of the Asda store.

6.31 We summarise the estimated turnover of retail facilities in and around Chapeltown on this basis below

at Table 6.3.

Table 6.3: Turnover of Existing Destinations at 2019 Estimated Convenience Convenience Destination Turnover Goods Total (£m) Derived from Inflow (£m) Catchment (£m) Chapeltown Asda, Market Street, Chapeltown 29.7 0.9 30.5 Chapeltown District Centre 0.7 0.0 0.7 Tesco Express, Burncross Road 3.8 29.2 33.0

Chaucer Asda, Chaucer Road 32.4 13.0 45.3

Other, Out-of-Centre Aldi, The Common, Ecclesfield 8.0 4.8 12.8 Morrisons, The Common, Ecclesfield 29.0 7.3 36.3 Note: Extract from Table 5 of Appendix B; 2017 prices

6.32 As such, we estimate that Chapeltown district centre has a convenience turnover of £34.2m, based on up to date expenditure and population data, and the our methodology as outline above. The principal

convenience goods facility within the district centre is the Asda at Market Street, which accounts for approximately 98% of the district centre’s convenience goods turnover (this strong performance being

reflective of the limited choice in the area).

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6.33 We note that the custom attracted to the Tesco Express on Burncross Road in Chapeltown appears to have been overestimated by the Retail & Leisure Study household survey, which suggests that a high number of trips are made to the store from Zone 24 (which is some distance away from Chapeltown, at the edge of the Greater Manchester conurbation). In our view, it is likely that these trips have been

recorded in error and that respondents were in fact referring to an alternative Tesco or another store11. Whilst we have adopted the findings of the household survey in this regard, we recommend that the turnover of the Tesco Express is adopted with caution.

Determine the Appropriate Time Frame for Assessing Impact

6.34 Paragraph 017 of the Town Centres PPG indicates that the design year for the testing of impact should equate to the year when the proposal has achieved a ‘mature’ trading pattern and that this is conventionally taken as the full second year of trading after the opening of a new retail development. On the basis that the proposal could likely commence trading at some point in 2021, we believe that

2023 could represent the second complete year of trading and should therefore acts as the appropriate design year for the testing of impact.

Proposal Turnover and Trade Draw

6.35 As set out at paragraph 2.8 of this Statement, this planning application seeks to provide for a

development with a gross internal floorspace of 1,951 sq.m. In considering the impacts arising from the development, it is important to note that no specific retailer is formally associated with the proposal and, as such, Unit 1 could theoretically be occupied by a range of convenience operators. However,

given the proposed floorspace associated with the development, the format of the store is suited to a discount retailer (i.e. Aldi or Lidl).

6.36 We provide our estimate of the turnover of the proposed development below at Tables 7.5 and 7.6. It is assumed that the foodstore would have a net sales area of approximately 1,268 sq.m and that

approximately 80% of the sales area would be dedicated to convenience goods sales (equating to 1,015 sq.m). Given the format of the foodstore, we have estimated its turnover based on the mid-point between the Aldi and Lidl company average sales densities as identified by Verdict GlobalData 2018.

11 The alternative is that multiple persons are undertaking a round trip of over an hour to undertake main food shopping at a petrol filling station retail kiosk, which does not appear credible

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6.37 On this basis, we estimate that the proposal would likely have a convenience goods turnover of up to £10.3m at 2023.

Table 6.4: Estimated Convenience Goods Turnover of Application Proposal at 2019 and 2023 Net Convenience Gross Internal Sales Density 2019 Turnover 2023 Turnover Floorspace Goods Area (sq.m) (£ per sq.m) (£m) (£m) Floorspace (sq.m) Convenience 1,015 10,165 10.3 10.3 1,951 Comparison 253 6,525 1.7 1.8 Note: Extract from Tables 5 and 10 of Appendix 3; 2017 prices

6.38 Given the limited turnover of the comparison goods floorspace proposed as part of the foodstore

(which would equate to approximately £1.8m at 2023), we have not undertaken a full impact assessment of this element of the development. Any trade diversion as a result of the proposed comparison floorspace would be spread over a number of destinations and would be of no material

consequence.

6.39 We have assessed the likely patterns of convenience goods trade diversion to the proposal having regard to existing trading patterns throughout the catchment and the principle identified at paragraph

016 of the Town Centres Planning Practice Guidance that ‘Retail uses tend to compete with their most

comparable competitive facilities’ (often referred to as ‘like competes with like’).

Assessing the Impact of the Proposal

6.40 It is widely accepted that competing facilities with a similar offer, which are located close to the application proposal, are likely to be the subject of greater trade diversion impacts. In this context, it

is necessary to review the trade draw of competing facilities to understand current shopping patterns, and identify those shoppers who may be tempted to visit new facilities. In this regard, we believe that the greatest monetary diversion would be from the Asda at Market Street in Chapeltown, which attracts

approximately 50% of main food trips from Retail & Leisure Study Zone 2 (within which the application

site is situated). However, a substantial proportion of shopping trips in the area are also attracted to destinations in Chaucer and Ecclesfield, including the Aldi and Morrisons located on the Common.

6.41 Of particular importance when analysing the shopping patterns and locations from which trade may be diverted, is the absence of a discounter within Chapeltown. Shoppers are willing to travel to ensure

that they get a good deal on main food shopping and, as such, the proposal has the potential to ‘claw

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back’ trade which is being spent at existing discounters elsewhere within and just outside of the catchment area. It is on this basis that the assessment and assumptions of trade diversion have been applied.

The Identified Likely Impact

6.42 Our detailed convenience goods trade diversion assessment is set out at Table 8 of Appendix B; we provide a summary table below.

6.43 The greatest monetary diversion is expected to arise at Asda in Chapeltown district centre, from which we estimate that 27.0% or £2.8m of the proposal’s turnover will be diverted. However, we estimate

that the store would continue to trade well subsequent to the implementation of the application proposal (at around 83% of its benchmark average) and that the identified 8.4% impact would not be problematic. From our own experience, we can confirm that the Asda appears to trade well with our visits confirming: a good volume of shoppers apparent throughout the store; a high level of car parking

spaces occupied; and numerous tills open even during weekday mornings.

Table 6.5: Estimated Convenience Goods Impact Summary Table at 2023 Trade Estimated Diversion to Solus Impact Convenience Post-Impact Destination Proposal of Proposal Goods Turnover (£m) Foodstore (%) Turnover (£m) (£m) Chapeltown Asda, Market Street, Chapeltown 33.1 2.8 30.3 -8.4% Other, Chapeltown District Centre 0.7 0.0 0.6 -4.7% Tesco Express, Burncross Road 33.5 0.3 33.2 -0.8%

Chaucer Asda, Chaucer Road 46.4 1.5 44.9 -3.3%

Other, Out-of-Centre Aldi, The Common, Ecclesfield 26.2 2.1 24.2 -7.9% Morrisons, The Common, Ecclesfield 37.6 1.0 36.6 -2.7% Note: Extract from Table 8 of Appendix B; 2017 prices

6.44 Based on existing shopping patterns within the catchment area and the likelihood that the proposal will divert trade from other similar discount operators elsewhere in the catchment, we believe that the proposal will also divert trade from foodstores at Ecclesfield, Birdwell and Hoyland12, none of which are

12 A very limited amount of turnover will likely be diverted from the Aldi at Birdwell and the Tesco at Hoyland, which are in the Barnsley authority area and for which no up to date turnover information is available

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located within defined town centres and therefore are afforded no policy protection.

Conclusions in Respect of Trade Diversion Impact

6.45 We believe it to be evident in this case that any identified impacts arising within any defined centre as a consequence of the proposal are substantially below the level that could be deemed ‘significant

adverse’.

6.46 The only identified town centre trade diversion impact which is in excess of 5% arises at the Asda

superstore on Market Street in Chapeltown. In this case, we estimate that the trade diversion impact arising at the Asda in Chapeltown would still allow it to have a convenience goods turnover of £30.3m

at 2023, which equates to 83% of its estimated benchmark turnover.

6.47 In this regard, we refer to the findings of the Inspector, which were supported by the Secretary of State, in respect of the called-in decision for the proposed development at the Meols Cop Retail Park in Southport (reference APP/M4320/V/15/3002637). Paragraph 376 of the Meols Cop Inspector’s report

relates to the trading performance of an in-centre foodstore subsequent to the implementation of an application proposal. It states that:

‘…with the new store in place, its trading performance would reduce to about 76% of its benchmark level. However, this would still be a relatively strong trading performance and on this basis there was no allegation from any of the retail consultants that the store would close.’

6.48 Based on the above, and our own consideration of the trading performance and popularity of the Asda store, we do not consider that the level of diversion would be at a level which would untenably impact

on the store’s performance. Indeed, we are of the view that it the Asda store would continue to trade very successfully subsequent to the implementation of the proposal. As such, the proposed foodstore would not have any material impact on the overall performance of the centre, particularly given the

findings of the healthcheck assessment which demonstrates that the centre remains vital and viable.

6.49 Furthermore, the proposal will ensure (in accordance with the aspirations of paragraph 89 of the NPPF) that there is greater consumer choice within the area by providing an alternative destination for residents to meet their main food shopping needs.

6.50 The level of impact arising at other in-centre destinations is very limited and is not considered to be

such that it would materially impact upon any centre’s role and general trading performance.

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6.51 As a consequence of the above, we believe it to be clear that the impacts arising from the proposal are either very limited or fall at destinations which would continue to trade viably subsequent to the scheme being implemented. There would be no land-use implications arising from the proposal and no material impact on the role and function of any centre. We therefore believe it to be clear that there

would be no significant adverse impacts arising from the application.

Conclusion in Respect of the Impact Test

6.52 Both local and national planning policy is clear that there is no requirement to undertake an impact

assessment, given that the proposed floorspace falls below the local and national impact threshold and

therefore the application could not be refused on impact grounds. In any event, Nexus has undertaken an assessment for completeness.

6.53 The first part of the NPPF impact test relates to the impact of a proposal on existing, committed and planned public and private investment in centres. We are unaware of any investment in any centre

which could be impacted or prejudiced by the application proposal.

6.54 The second part of the impact test relates to the vitality and viability of existing centres, it is clear that

no significant adverse impact would result from the proposal and that the application thereby accords with the provision of paragraph 89 and 90 of the NPPF. In addition, we note that NPPF paragraph 89

supports development which provides (as this development clearly would) for increased consumer choice.

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Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

7.0 Summary and Conclusions

The Proposed Development

7.1 Morbaine Limited and Ackroyd & Abbott seeks outline planning permission for the redevelopment of land at Lane End in Chapeltown, Sheffield.

7.2 The proposed development would provide a Class A1 foodstore, and eight residential dwellings, along

with car parking, servicing and landscaping. The scheme has been submitted in outline only at this stage, but the proposed indicative layout demonstrates how the proposal has been designed to be in keeping with the surrounding uses and will not unduly impact on the amenity of local residents. Importantly, the proposal will improve local consumer choice and redevelop a key brownfield site

within the urban area of Chapeltown, whilst providing new dwellings.

Compliance with the Development Plan and other General Material Considerations

7.3 A comprehensive package of documents has been submitted in order to set out the application proposal and how it relates to its surroundings.

7.4 The submission documents demonstrate that the proposal:

. comprises a contemporary design, which meets the needs of modern operators and significantly improves the appearance of the site;

. can be accommodated without adversely impacting upon the nearby residential uses; . is accessible through a range of means of transport and provides an appropriate level of car parking; and

. would support around 40 full time equivalent jobs.

7.5 In addition, there are no designations, notable habitats or species, contamination or geotechnical issues which impact on the ability to deliver an appropriate development on the site.

7.6 As a consequence, the proposal is generally in accordance with the provisions of adopted and emerging development plan policy, and the general policies of the NPPF. Whilst UDP Policy H10 effectively

provides a sequential approach to development which only allows larger scale retail development at

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Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

edge of centre locations in housing areas, the Council has previously accepted that the policy is out of date. As a consequence, the policy does not support the refusal of this planning application.

The Sequential Test

7.7 Paragraph 011 of the Town Centres PPG acknowledges that not all main town centres uses may be able

to be accommodated ‘in centre’. It indicates that certain main town centre uses have particular market and locational requirements, which mean they may only be accommodate in specific locations. In this instance, there is a clear benefit in providing an additional foodstore in the Chapeltown area that is

capable of competing with the Asda foodstore. As such, it is appropriate for Chapeltown district centre

to be the focus of the sequential test.

7.8 In accordance with paragraph 86 of the NPPF, we have reviewed the potential of sites in and around Chapeltown district centre and find that none is both available and suitable to accommodate the application proposal, even allowing for appropriate flexibility. As such, the proposal accords with the

requirements of paragraph 86 of the NPPF.

The Impact Test

7.9 Both local and national planning policy is clear that an impact assessment is not required to be submitted as part of the application. As such, we believe it to be clear that the impact test could not

support the refusal of the application under any circumstance.

7.10 In any event, we have considered the proposal in terms of its compliance with the two NPPF impact test criteria.

7.11 The first part of the impact test relates to impact on town centre investment and we are unaware of any such existing, committed or planned private or public sector investment which could be prejudiced

by the proposal. The second part of the impact relates to town centre vitality and viability, and we have demonstrated that the impacts arising from the development would be limited and dispersed over a

number of locations. The identified impacts are considered to be substantially below the magnitude of ‘significant adverse’ which could merit the refusal of the application in accordance with NPPF paragraph 89. In any event, the application proposal is well below the relevant impact threshold and, as accepted by the Council own Retail & Leisure Study, the impact test could not form grounds for the

refusal of this application.

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Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

Overall Conclusion

7.12 Based on the detailed analysis contained within this Planning and Retail Statement, it is concluded that the proposal accords with the up to date policy provisions of the statutory development plan and national planning policy, including the requirements of the sequential and impact tests as articulated

by the NPPF.

7.13 Importantly, the proposal would also help improve consumer choice in the area, bring back into active use a previously developed site, and support a greater number of jobs than the previous use of the

site.

7.14 Paragraph 38 of the NPPF commends to decision-makers that they should ‘…seek to approve

applications for sustainable development wherever possible.’ Given the findings of this Statement and the clear benefits associated with the proposal, we commend to the Council that it grants planning permission for this important development.

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Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

Appendix A: Plan of Sequential Alternative Sites

Morbaine Limited and Ackroyd & Abbott 55

Client 1 Thorncliffe Cricket Club and Social Club Morbaine Limited 2 Sinemaster site, Burncross Road Project Land at Lanes End, Chapeltown, 3 Chapeltown Swimming Baths, Burncross Road Sheffield 4 Land adjacent to the Scout Hut, Pack Horse Lane, High Green Description 5 former Market Inn site, High Green Location of Sequential Sites Date 14.02.2019 Map data ©2015 Google

Land at Lane End, Chapeltown, Sheffield Planning and Retail Statement

Appendix B: Retail Impact Assessment Tables

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Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 1: Population

Zone 2019 2023 2 33,220 33,706 3 111,843 114,667 16 52,631 53,321 Total 197,694 201,694

Table 2a: Convenience Goods Expenditure Per Capita (2019)

Zone 2018 2019 2023 2 2,061 2,001 1,977 3 1,727 1,677 1,657 16 2,005 1,947 1,924

Table 3a: Total Convenience Goods Expenditure

Zone 2019 2023 2 65.7 66.6 3 185.3 190.0 16 101.2 102.6 Total 352.2 359.2

Table 3b: Main and Top-up Split at 2019 Table 3c: Main and Top-up Split at 2023

Zone Main Top-up Zone Main Top-up 2 46.0 19.7 2 46.7 20.0 3 129.7 55.6 3 133.0 57.0 16 70.9 30.4 16 71.8 30.8 Total 246.6 105.7 Total 251.4 107.8 Notes a. Zones based on postcode sectors derived from Sheffield and Rotherham Joint Retail Study 2017 b. Population estimates at 2019 and 2023 derived from Experian MMG3 2018 data release c. Expenditure estimates at 2018 derived from Experian MMG3 2018 data release d. The household survey results used in the Sheffield and Rotherham Study (2017) include internet responses, and as such we have not made an allowance for a deduction in SFT in calculating the available convenience expenditure e. Expenditure estimates projected forward in accordance with forecasts set out at Figure 6 of Experian Retail Planner Briefing Note 16 2017 prices Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 4a: Main Food Convenience Goods Turnover at 2016 from 2017 Retail Study - Based on First Choice Main Food Shopping Figures Only

Other Zone 2 - PCA Zone 3 - SCA Zone 16 - SCA Total Zones Destination % % % 2016 Est. 2016 Est. 2016 Est. 2016 Est. 2016 Est. Market Market Market T/O T/O T/O T/O T/O Share Share Share Chapeltown Asda, Market Street, Chapeltown £22.54 48.9% £0.74 0.6% £1.38 2.0% £0.5 £28.3 Chapeltown District Centre £0.00 0.0% £0.00 0.0% £0.00 0.0% £0.0 £0.0 Tesco Express, Burncross Road £0.32 0.7% £0.00 0.0% £0.00 0.0% £14.8 £15.1

Chaucer Asda, Chaucer Road £3.55 7.7% £21.88 17.7% £0.00 0.0% £19.1 £44.5

Other Out-of-Centre Aldi, The Common, Ecclesfield £1.61 3.5% £1.61 1.3% £1.52 2.2% £3.3 £8.0 Morrisons, The Common, Ecclesfield £8.16 17.7% £18.54 15.0% £0.41 0.6% £4.7 £31.8

£46.1 £123.6 £68.9 Notes a. Market share at 2016 calculated by dividing the expenditure attracted to each destination by the total available expenditure in each respective zone from the 2017 Sheffield and Rotherham Retail Study b. Market share of convenience goods turnover for each destination derived from turnover of First Choice Main Food Shopping 2017 Prices

Table 4b: Top-up Food Convenience Goods Turnover at 2016 from 2017 Retail Study

Other Zone 2 - PCA Zone 3 - SCA Zone 16 - SCA Total Zones Destination % % % 2016 Est. 2016 Est. 2016 Est. 2016 Est. 2016 Est. Market Market Market T/O T/O T/O T/O T/O Share Share Share Chapeltown Asda, Market Street, Chapeltown £4.32 21.8% £0.48 0.9% £0.4 0.6% £0.3 £5.5 Chapeltown District Centre £0.65 3.3% £0.00 0.0% £0.0 0.0% £0.0 £0.7 Tesco Express, Burncross Road £3.54 17.9% £0.00 0.0% £0.0 0.0% £8.6 £12.1

Chaucer Asda, Chaucer Road £0.00 0.0% £5.62 10.6% £0.0 0.0% £0.4 £6.0

Other Out-of-Centre Aldi, The Common, Ecclesfield £3.15 15.9% £1.48 2.8% £0.0 0.0% £2.9 £7.5 Morrisons, The Common, Ecclesfield £0.83 4.2% £0.58 1.1% £0.0 0.0% £4.0 £5.4

£19.8 £53.0 £29.5 Notes a. Market share at 2016 calculated by dividing the expenditure attracted to each destination by the total available expenditure in each respective zone from the 2017 Sheffield and Rotherham Retail Study b. Market share of convenience goods turnover for each destination derived from turnover of First Choice Top-ip Food Shopping 2017 Prices

Table 4c: Total Convenience Goods Turnover at 2016 from 2017 Retail Study

Other Zone 2 - PCA Zone 3 - SCA Zone 16 - SCA Total Zones Destination % % % 2016 Est. 2016 Est. 2016 Est. 2016 Est. 2016 Est. Market Market Market T/O T/O T/O T/O T/O Share Share Share Chapeltown Asda, Market Street, Chapeltown £26.86 40.8% £1.22 0.7% £1.8 1.8% £0.8 £30.7 Chapeltown District Centre £0.65 1.0% £0.00 0.0% £0.0 0.0% £0.0 £0.7 Tesco Express, Burncross Road £3.87 5.9% £0.00 0.0% £0.0 0.0% £23.3 £27.2

Chaucer Asda, Chaucer Road £3.55 5.4% £27.50 15.6% £0.0 0.0% £19.5 £50.5

Other Out-of-Centre Aldi, The Common, Ecclesfield £4.76 7.2% £3.09 1.8% £1.5 1.5% £6.1 £15.5 Morrisons, The Common, Ecclesfield £8.99 13.6% £19.13 10.8% £0.4 0.4% £8.7 £37.2

£65.9 £176.6 £98.5 Notes a. Turnover at 2016 derived from adding the main and top-up food turnovers from Tables 4a and 4b a. Market share at 2016 calculated by dividing the expenditure attracted to each destination by the total available expenditure in each respective zone from the 2017 Sheffield and Rotherham Retail Study 2017 Prices Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 5: Estimated Convenience Goods Turnover at 2019

Zone 2 Zone 3 Zone 16 Inflow Total Catchment Destination Main (£m) Top-up (£m) Total (£m) Main (£m) Top-up (£m) Total (£m) Main (£m) Top-up (£m) Total (£m) Area Total (£m) (£m)

Chapeltown Asda, Market Street, Chapeltown 22.5 4.3 26.8 0.8 0.5 1.3 1.4 0.2 1.6 29.7 0.9 30.5 Chapeltown District Centre 0.0 0.7 0.7 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0.0 0.7 Tesco Express, Burncross Road 0.3 3.5 3.8 0.0 0.0 0.0 0.0 0.0 0.0 3.8 29.2 33.0

Chaucer Asda, Chaucer Road 3.5 0.0 3.5 23.0 5.9 28.9 0.0 0.0 0.0 32.4 13.0 45.3

Other Out-of-Centre Aldi, The Common, Ecclesfield 1.6 3.1 4.7 1.7 1.6 3.2 0.0 0.0 0.0 8.0 4.8 12.8 Morrisons, The Common, Ecclesfield 8.1 0.8 9.0 19.5 0.6 20.1 0.0 0.0 0.0 29.0 7.3 36.3

Total 36.1 12.4 48.5 44.9 8.6 53.4 1.4 0.2 1.6 103.6 55.1 158.6 Notes a. Estimated turnover derived from convenience goods market shares set out at Table 4 and assumed available zonal expenditure for 2019 set out at Table 3a 2017 Prices Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 6: Estimated Convenience Goods Turnover at 2023

Zone 2 Zone 3 Zone 16 Inflow Total Catchment Destination Main (£m) Top-up (£m) Total (£m) Main (£m) Top-up (£m) Total (£m) Main (£m) Top-up (£m) Total (£m) Area Total (£m) (£m)

Chapeltown Asda, Market Street, Chapeltown 22.8 4.4 27.2 0.8 0.5 1.3 1.4 0.2 1.6 30.1 3.0 33.1 Chapeltown District Centre 0.0 0.7 0.7 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0.0 0.7 Tesco Express, Burncross Road 0.3 3.6 3.9 0.0 0.0 0.0 0.0 0.0 0.0 3.9 29.6 33.5

Chaucer Asda, Chaucer Road 3.6 0.0 3.6 23.5 6.0 29.6 0.0 0.0 0.0 33.2 13.3 46.4

Other Out-of-Centre Aldi, The Common, Ecclesfield 1.6 3.2 4.8 1.7 1.6 3.3 1.6 0.0 1.6 9.7 16.5 26.2 Morrisons, The Common, Ecclesfield 8.3 0.8 9.1 19.9 0.6 20.6 0.4 0.0 0.4 30.1 7.5 37.6

Total 36.6 12.6 49.2 46.0 8.8 54.8 3.4 0.2 3.6 107.7 69.9 177.6 Notes a. Estimated turnover derived from convenience goods market shares set out at Table 4 and assumed available zonal expenditure for 2023 set out at Table 3b 2017 Prices Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 7: Estimated Proposal Convenience Goods Turnover at 2023

Gross Internal Net Sales Net Convenience Sales Density Turnover at 2019 Turnover at 2023 Area (sq.m) Floorspace (sq.m) Floorspace (sq.m)

Convenience Floorspace 1,015 10,165 10.3 10.3 1,951 1,268 Comparison Floorspace 253 6,525 1.7 1.8 Total 1,951 1,268 1,015 - 12.0 12.1 Notes a. Proposal foodstore net sales area based on our understanding of operational requirements b. Convenience and comparison goods sales density for proposal foodstore based on company averages of Aldi and Lidl as derived from Verdict 2018 and Mintel Retail Rankings 2018 c. Turnover of units to 2023 adjusted in accordance with recommendations provided at Figures 4a and 4b of Experian Retail Planner Briefing Note 16 2017 prices Land at Lane End, Chapeltown, Sheffield Retail Impact Assessment Tables

Table 8: Estimated Trade Diversion

Benchmark Turnover Trade Diversion Survey Derived Pre- Post Impact Over/Under Post Development Destination Development Gross Benchmark Impact Turnover as a % of Net Floorspace Net Convenience Sales Density Trading % £m Turnover Turnover Floorspace Turnover Benchmark

Chapeltown Asda, Market Street, Chapeltown 33.1 7,418 4,451 2,754 13,268 36.5 -3.44 27.0% 2.8 30.3 8.4% 83% Chapeltown District Centre 0.7 ------0.3% 0.0 0.6 4.7% - Tesco Express, Burncross Road 33.5 300 200 160 13,401 2.1 31.36 2.7% 0.3 33.2 0.8% 1550%

Chaucer Asda, Chaucer Road 46.4 8,259 4,955 3,067 13,268 40.7 5.75 15.0% 1.5 44.9 3.3% 110%

Other Out-of-Centre Aldi, The Common, Ecclesfield 26.2 1,435 1,005 804 10,517 8.5 17.78 20.0% 2.1 24.2 7.9% 286% Morrisons, The Common, Ecclesfield 37.6 6,840 4,104 3,087 12,293 38.0 -0.32 10.0% 1.0 36.6 2.7% 96%

Other ------25.00% 2.6 -

Total 177.6 125.8 51.14 100.0% 10.3 169.9 Notes a. Estimated turnover derived from convenience goods market shares set out at Table 4 and assumed available zonal expenditure for 2023 set out at Table 3a b. Estimated trade diversion are Nexus' professional judgements based on shopping patterns, nature of existing destination and proximity to the proposed development c. Post development turnover calculated by deducting the trade diversion from the survey derived turnovers d. Gross floorspace figures for existing stores taken from VOA where available. Net figures calculated using Verdict Global Data averages e. Sales densities for existing foodstores taken from Verdict GlobalData 2018 2017 prices

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