TURLEY. 115 George Street Edinburgh EH2 4JN 4Ih September 2012 T:0131 240 5440 F: 01 31 240 5441 Delivered by Email www.turleyassocSates.co.uk
Susan Mitchell Corporate Services Our ref: SAIE2030 North Lanarkshire Council Your ref 11/01231/FUL Civic Centre E: [email protected] Windmillhill Street Motherwell MLI IAB
Dear Susan,
PLANNING APPLICATION 11/01231/FUL - ERECTION OF A SUPERMARKET (CLASS 1) (8,948 SQM), PETROL FILLING STATION, CAR PARKING, ACCESS, LANDSCAPING AND ASSOCIATED WORKS - FORMER FIRST BUS DEPOT -TINKERS LANE - HAMILTON ROAD - AIRBLES ROAD - MOTHERWELL
We write on behalf of the applicants, BDW Trading Ltd (T/A Barratt Homes West Scotland) and Sainsbury's Supermarkets Ltd, on the above application. In your letter, dated 23' August 2012 (received on 28'h August 2012), you outline that the application will be heard at a meeting of North Lanarkshire Council on 12" September 2012 and request to be informed of whether we would intend speaking at the 'Planning Hearings Committee' (PHC) and if any final submission will be lodged to the application.
Hearing Pres8 n ta t ion
We wish to inform you that BDW Trading and Sainsbury's Supermarkets Ltd wish to appear and present their case at the PHC. The people that will present on the day are:
Paul Miller, Sainsbury's Supermarkets Ltd (National Development Surveyor) Jeff Wilson, Sainsbury's Supermarkets Ltd (Town Planning Team Lead - Scotland) Stuart Dodson, BDW Trading / Barratt Homes (Development Director)
Final Submission: Committee Paper Response
In relation to the Planning Committee Report (PCR), produced by the Council's Executive Director of Environmental Services (EDES), we would like to take this opportunity to provide our observations on the report and respond to matters of planning policy or points of fact / omission that should be brought to the attention of the PHC and Full Council, who will be making the final decision on the application.
BELFAST 1 BIRMINGHAM 1 BRISTOL 1 CARDIFF I EDINBURGH I GLASGOW I LEEDS 1 LONDON I MANCHESTER 1 SOUTHAMPTON
Turley Assodales Limited is registered in England, No. 2235387. Registered office: 1 New York Street, Manchesler M1 4HD 2
Planning Policy
A significant proportion of the PCR is based around assessing the application against the key Development Plan Policies and related Material Considerations with a conclusion thereafter on the acceptability of the proposal.
Table 1 below provides an overview of the EDES’s position on the compliance of the proposal against Development Plan Policies, with Table 2 doing likewise with regard to Material Considerations.
Diagram 3 - ‘Spatial Development Strategy - and indicative compatible development’
Diagram 4 - ‘Sustainable Location .)
Site Designation (Commercial Uses) ( RTL 9) YES Residential AmenitylNoise (HSG 7) YES Contaminated Land (ENV 4) YES Vacant and Derelict Land (ENV 3) YES Biodiversity (ENV 13) YES Public Art (ENV 22) YES Transport 8 Accessibility (TR13) YES Ravenscraig Access Improvements (TR6) YES Retail Development (RTL 1) - Assessing Retail Development (RTL 4) YES (Points 4,5,6&7) NO (Points 182) Town Centre Areas (RTL 5) -
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Residential Amenity (HCF1A) YES Amount of Development (DSP 1) NO Location of Development (DSP 2) YES (Points 1,3&4) NO (Point 6) Impact of Development (DSP 3) YES Quality of Development (DSP 4) YES North Lanarkshire Centre Network (RTC 1) * Promoting Town Centre Action (RTC 2) - Assessing Retail Development (RTC 3) YES (Point 1)
Retail (Sequential Approach) YES Retail (Impact on V&V of Town Centre) NO Retail (Qualitative and Quantitative NO Deficiencies) Retail (Other DP Objectives) NO Community Engagement ? Economic Development ? Sustainable Development ?
Design and Visual Impact YES Transport and Access YES Noise YES Air Quality YES Ecology YES Consultations YES
The above table shows, in the EDES’s opinion, that the proposal adheres to all relevant policies within the Development Plan, with one noted exception in the EDES’s opinion, that being Policy RTL 4 - Points 1&2 (SALP). With regard to SPP, the EDES, in our opinion, has failed to highlight the support to proposals that assist in meeting the principles of ‘Economic Development‘ and has also failed to report fully on the community consultation report lodged with the application. This report showed, of
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those attending the public exhibition, 90% supported the need for a new supermarket in Motherwell, with the same level of support (90%) for it being on the application site.
The EDES is recommending that Members set aside the fact the proposal complies with all relevant policies and material considerations because, in their opinion, it does not meet (1&2) of Policy RTL 4. Table 3 below outlines the key reasons why the EDES recommends refusal of the application, together with a response as to why we consider refusal is not justified.
Table 3: EDES Refusal Reasoni
Recommendation Response
1. That there is no knowr The Development Plan (nor DSPI of the FNLLP) has demandheed not been informed by any detailed or recenl demandheed retail assessment. In order to identify whether demand or need exists, it is therefore necessary to consider the submitted RIA.
In responding to the SDP’s Diagram 4 we would note the Scottish Government Reporter’s comment at the examination stage. That being: ’In cases where retail or commercial leisure development is contrary to the development plan, the proposal should “help to meet qualitative and quantitative deficiencies Identified in the development plan” (paragraph 64); in other words, there is no mention of “need” (Page 15 - Point 9 of the Scottish Government’s ‘Strategic Development Plan Examination’] March 2012).
The proposed Sainsbury’s has shown that it will “help” meet qualitative and quantitative deficiencies.
The Sainsbury’s RIA has identified deficiencies (demandlneed) within the local catchment. The primary catchment (2015) alone has a demandheed of:
0 Convenience: f17.54 million
0 Comparison: f151.98 million Total: f169.52 million
As part of the demandheed assessment it is 5
important to look into the detail, in particular deficiencies in the form of ‘overtrading’ within the existing supermarkets. Asda in Motherwell, for example, is trading (‘Actual’ Turnover) some €14.82 million above the identified ‘benchmark’. This is a form of deficiency and an indicator of lack of choice and competition in the town.
The ‘actual’ turnover figures in the Sainsbury’s model are not altered by “professional judgement” (as suggested within the PCR) but derived from an independent household survey, which asked local people where they shop. The ‘actual’ turnover figures therefore provide the most robust picture of local trading conditions.
The proposal is supported by expenditure in the primary catchment. The reason being that it: addresses retail leakage, reduces ‘overtrading’ within catchment supermarkets, and does not have a significant adverse impact on any identified town centre.
There are clear qualitative deficiencies in the lack of main food choice. This is proven in ‘overtrading’ levels identified at Asda and public consultation feedback where the need for a new supermarket in Motherwell dominated responses. Comments regarding qualitative provision included:
‘A better qualify of product and will create competition for ASDA’
‘We, at present, only have one supermarket - no choicel’
‘Currently very limited/poor shopping facilities in fhe town and my spend here Is very low’
‘Because if will save me travelling to Hamilton‘
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2. The proposal represents ai - A retail proposal cannot be deemed unsustainablf unsustainable location as i simply because it is outwith the existing town centre does not fall within the networl boundary. The related policy tests on this subject is of centres and therefore doe! the sequential approach (ie. RTL 4 (3)) anc not follow the Spatia accessibility to public transport (ie. RTL 4 (4)) Development Strategy. Indeed, in the report the site is noted as having gooc transport links, including public transport (see para 8.11).
- The EDES has accepted that the proposal meets planning policy with regard to the sequential approach.
3. That Motherwell Towr - The EDES on numerous occasions notes the lack oi Centre is considered to bc historic Town Centre Health Check (TCHC] fragile and of a lower standinf comparison with that undertaken in the RIA. It is than that reported in the agreed this would have been a useful exercise, Sainsbury’s RIA. however, the Council has not undertaken such an exercise. It is therefore impossible to make such a comparison.
- The lack of historical information does not, however, prevent the Council from making a judgement on the I health of the town centre today. Again, no such analysis has been undertaken by the Council. We believe that our TCHC shows the centre to be robust. This is supported by comments made by the owners of the Brandon Shopping Centre to Councillors on the 2gm August 2012, which stated:
It is this sort ofjoined up thinking which has enabled us to create increased footfall, more shops, more jobs and the ingredients for economic Growth in Motherwell Town Centre. We are bucking the trend in Motherwell &utcannot rest on our laurels.
- The reporting on the health of Motherwell Town Centre has failed to acknowledge the significant recent investment in the town centre, including the occupation of the remaining vacant unit at the former Asda and the announcement that Aldi is to locate on
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the former Dalziel House site. This will provide a significant ‘boost’ and further support the vitality and viability of the centre.
4. The proposal is likely tc - It is important to correct a number of inaccuracies in have an unacceptable adverse the reporting on the scale and level of retail impacts impact on Motherwell towr caused by the proposal.
Expenditure (demand) currently exceeds supply (turnover) in Motherwell (ie. the centre should be larger than it is). Beyond this, the proposal’s net floorspace represents 22% of what exists in Motherwell Town Centre, not over 25% as has been suggested. The comparator has not accounted for Ravenscraig Town Centre (the future focus for retailing) which has a net floorspace level of circa. 35,000 sqm net. Had it done so, the proportional scale of the Sainsbury’s store, within the local area, would drop to 9%.
The EDES has not appropriately reported on the catchment area. It was emphasised within the RIA that the wider catchment area reflects that used for the Household Surveys. It was to gauge shopping patterns in a wider area given the potential of people travelling from North into South Lanarkshire (eg. people travelling from Motherwell to Hamilton). However, it does not mean that the proposal will draw residents from this secondary area to any significant degree. The trade diversion to the Sainsbury’s supermarket reflects a much smaller catchment and based on proximity and similarity of offer.
The EDES has misinterpreted elements of the RIA, in particular trade draw (to the proposal). The ECES suggests that the retail analysis is showing that the Sainsbury’s will be attracting residents, for example, from Blantyre, to the supermarket. This is not the case. The trade draw relates to the clawback of local expenditure
c TURLEYASS 4 8
(eg. Motherwell residents) that is currently being lost to supermarkets in the secondary catchment (eg. Blantyre) no attracting a significant proportion of people from the secondaty catchment.
The analysis therefore shows more money being spent locally. This analysis is based on information provided by real people’s answers to the shopper survey.
The EDES has failed to report the benefits of clawing back retail leakage and reducing ‘overtrading’ levels in local shops. It has also not accounted for the benefits of new expenditure coming into Motherwell and the likelihood of beneficial linked trips with the town centre.
- Visiting the town centre one can see that the car parks are well utilised, the footfall along Brandon Parade is strong, the vacancies are reducing and there is a good mix of uses. We are confident that our reporting of a robust and healthy town centre is accurate and based on the evidence available. Recent comments by the owner of the Brandon Shopping Centre provide further confirmation on this point (letter to Councillors dated 2gth August 2012). Furthermore, the EDES did not seek the relevant comparator or historic TCHC analysis that they note.
- Even accounting for committed development, we do not accept that an impact of 12% on Motherwell and Belishill Town Centres and a 3% impact on Wishaw Town Centre, is significant. Particularly when one focuses on the detail of where the diversionlimpact is coming from (ie. the major supermarkets). Refer to the Retail Impact Table (4) below. 9
Table 4: Sainsbury’s Retail Impact (Combined-I cluding Committed Development)
Town Centre Impact (Without Major Supermarket)
Motherwell €4.30 million / 5%
Wishaw €1.64 million / 3%
Bellshill €0.67 million / 3%
Town Centre Impact (With Major Supermarket)
Motherwell f 19.01 million / 12%
Wishaw f 1.64 million/3% (f7.78 million / 8% if inc. Tesco)
Bellshill €12.77 million / 12%
The recent permissions granted to Aldi and the Co-op in Motherwell will have little bearing on the impact of this proposal. The turnover generated by these proposals will be on a much smaller scale and will be obtained by trade diversion from nearby discount supermarkets in the case of Aldi. They will have little beneficial effect, in terms of reducing leakage with the catchment.
The key issue is whether what is being proposed will have such a significant impact that it merits setting aside the positive aspects of the proposal which can be seen from the compliance Tables 1 and 2 of this letter.
We do not believe EDES has provided any clear evidence to show that the impacts created would be significant. The EDES has instead focused more on the fact that the proposal does not fall within the town centre and that, in their view, demand is not equal to the proposal’s turnover. Neither of these points determine the impact of the proposal. The Council should not conclude that these are negative points for the proposal because:
the EDES has accepted that the proposal meets the sequential approach (policy) which allows, in principle, developments which cannot be accommodated in the Town Centre to locate elsewhere in a town; and
0 there is no planning policy that requires retail demandheed to be met in full (ie. retail capacity equalling turnover of proposal) for it to be considered acceptable and, in any event, the RIA demonstrates that there is quantitative and qualitative deficiencies which it will “help” to address in accordance with paragraph 64 of SPP.
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We are aware of representations made by Chester Properties regarding a site they own on Brandon Parade East and that they perceive it to be a preferable location for a supermarket in Motherwell. Sainsbury's have provided their review of the site within their 'Response to Retail Comments', May 2012 (document attached. Refer to Page 10-Response 3) as to why this site is not suitable or potentially available under the sequential approach test outlined within SPP. They key points being:
The site is not large enough to accommodate the proposal in its current form a key sequential test outlined within a recent Supreme Court case (Tesco v Dundee City Council, UKSC13);
0 The current plans have not been appropriately scrutinised by the planning department and we consider the scale outlined in indicative plans to be well in excess of what actually could be developed on the site. Beyond this there are considered to be numerous design and accessibility issues which again will likely alter the urban form of what is being proposed; and
That no evidence has been provided on the type of ownership/lease agreements and whether there is agreement to the development within a reasonable time period (ie. 3 years)
The EDES is aware of the site and has agreed that the Sainsbury's proposal complies with the sequential approach to retailing. The site being proposed by Chester Properties does not therefore alter our conclusions or the EDES's conclusions that the Sainsbury's site is acceptable in principle for retail use.
The Retail Impact Assessment lodged in support of the application and in response to Policy RTL 4 shows, that while there will be an impact on Motherwell Town Centre, it cannot be considered as being significant (eg. lead to shop closures / reduce investment in the town centre). The majority of the proposal's turnover comes by way of trade diversion from the major supermarkets in the catchment, none of whom provides a key role in the health of the town centres.
We have provided evidence that supermarkets, like the Asda in Motherwell, do not strongly support the "traditional" town centres, despite some of them falling within the designated boundary (refer to appended Retail Response, Appendix 1 (May 2012)). The linked trip results for the Asda in Motherwell were similar to that of an out of centre supermarket. Asda's withdrawal of their original objection would appear to accept this position.
Points of Fact I Omission
Economic and Social Benefits
The PCR has failed to acknowledge a major material consideration, notably the significant economic benefits this proposal would bring to Motherwell and North Lanarkshire.
Scottish Planning Policy (Feb 2010) or SPP supports the proposed development in a number of areas. SPP states that the planning system should 'proactively support development that will contribute to sustainable economic growth' (para 33) and that planning authorities 'should take a positive approach
TURLEY, ES to development, recognising and responding to economic and financial conditions in considering proposals that could contribute to economic growth’ (para 33). ‘Proactively supporting’ and taking a ‘positive approach’ in current economic conditions translates to a ‘presumption in favour’ of granting planning permission where proposals are proven to contribute to economic growth.
SPP also states that the planning system should support economic development by taking account of the economic benefits of the proposal in development management decisions, and supporting development which will provide new employment opportunities and enhance local competitiveness (para 45). Information has been provided in this letter setting out the employment opportunities that would be created and also, in retail terms, that the store would enhance local competitiveness by, for example, introducing a new entrant to the local market.
The clear economic benefits of the proposed development should therefore be taken into account in the determination of the planning application. On the basis of the information submitted and current economic conditions, particularly in the Motherwell area, there should be a presumption in favour of granting planning permission for the proposed retail development.
Employment of Local People
Sainsbury’s, if approved, would be creating in the region of 300 operational job opportunities in the supermarket, approximately 100 jobs in the construction of the supermarket and will further bolster employment via purchasing from local suppliers to the supermarket (for example, when Sainsbury’s opened in Nairn, it started sourcing from the local Co-op Dairy and also from Ashers Bakery, which is located across the road from the store).
Sainsbury’s aims to ensure that their stores reflect the communities that they serve so whenever possible Sainsbury’s seek to give jobs to people who live locally. It is also expected to ring fence 10 per cent of the available jobs for individuals who we can recruit as part of ‘You Can’ - Sainsbury’s programme to open up recruitment to a wider range of new recruits, such as the long term unemployed or through organisations such as Mencap, Remploy and Job Centre Plus. This programme means that direct contact is made with local people seeking work.
Petition of Support
The petition in support of the Sainsbury’s store has been omitted from the PCR as names and addresses where not provided. We now have the pleasure of enclosing the petition together with further details of local people that support the proposal received in the last seven days. 154 local people have now signed the petition. We trust that you will take time to consider the comments made. 12
We trust that this letter will be circulated to all Members of the Planning Hearings Committee and Full Council and should you wish to discuss any aspect in greater detail please do not hesitate to contact Tim Ferguson of Turley Associates on (0131) 240 5440.
Yours sincerely
\J Turley Associates cc.
Jeff Wilson, Sainsbury’s Supermarkets Ltd (Town Planning Team Lead - Scotland)
Stuart Dodson, BDW Trading / Barratt Homes (Development Director)
Enc.
1. Sainsbury’s Petition of Support 2. Turley Associates, Response to Retail Comments, May 2012
TURLEYASS Slsneme Awl Add2 Tcmn Posta&- I support Sainsbury's Motherwell planning application 11/01231/ful because ... I have to travel outside of 38 Lindum Motherwell if do not want to visit ASDA to shop. I feel Sainbury's have hit the nail on the head. The town will Ar Paul Norris Street Motherwell MLI 3QY benefit by the jobs created, the alternative shopping, and the location of the store is ideal. Ar Alexander Quither 2 Ashwood Wishaw ML2 OFE 61 Comrie I support Sainsbury's Motherwell planning application 11/01231/ful because ...Motherwell has been needing a Ar Graeme Anderson Crescent Hillhouse Hamilton ML3 9QF new development and a reason to draw in people for a long time. As a local resident, I stay Less than 5 minutes from the proposed site, and a trader in the retail industry for the past 8 years Ican only think positive when thinking about you building a store on my doorstep. With 2 ASDA stores a mile either side of the site, it will provide an alternative to the ASDA monopoly we have been landed with for the past 10 - 15 years. As an active member in the local community, Door to Door visits amongst other informationgaining exercises have over 90 of this community supporting Sainsburys. As im sure your already aware, you have great support in this great town, and the amount of jobs you will generate, along with great 18 Brogan products and service you will provide, we feel that this could change the face of this tom, and it's residents for Ar Gary Keys Crescent MotherwellMLI 3HP the better, in the short medium and long term. I am very supportive of Sainsbury's in mothenrvell and live very nearby. can you advise when the store will be Laura Crickett opening. I support Sainsbury's Motherwell planning application 11/01231/fulbecause ... I would be able to walk to the store instead of driving to the Hamilton branch. I would also welcome a Sainsburys petrol station as the price of 8 Gaughan Parkside fuel in the petrol station on Airbles Road is too expensive and there are often queues at the Jet station on Rosemary Mclntyre Quadrant Gardens Motherwell MLI 3FB Hamilton Road. This can often lead to congestion onto the main road. At present I shop at Sainsbury's Hamilton and would welcome Sainsbury's Motherwell as it would save me time and money on fuel. Also, Iwould welcome a petrol station attached to Sainsbury's Motherwell. Sainsbury's offer value for money, good quality food and organic produce most of which is sourced in Scotland which Asda in Motherwell and Tesco in Wishaw often lack. Sainsbury's offer value for money, good quality food and organic produce most of which is sourced in Scotland which Asda in Motherwell and Tesco in Wishaw often lack. I also appreciate Sainsbury's "Brand Match" with price deals against Asda and Tesco. You are never overcharged and can cash in the "Brand Match" voucher and Nectar points towards your shopping which is a bonus. Sainsbury's 698 Glasgow in Motherwell would also give employment, full and part-time to so many people which is very much needed in Catherine Quither Road Wishaw ML2 TTL this area. All in all, Sainsbury's Motherwell has my vote. 31 Lochnager I support Sainsbury's Motherwell planning application 11/01231/ful because ... it will support the local COInmUnity Charlene Allan Road Motherwell MLI 2PG & I would like to shop instore. I support Sainsbury's in Motherwell as i have lived there for over 30 years and feel a company such as sainsbury's can offer jobs, in an area which is badly in need of job opportunities, choice of supermarkets within the Motherwell area as there are currently none, with Asda having the monopoly on this. It would also attract 8 Brogan shoppers and people into the Motherwell area who have not previously shopped in Motherwell and the location Helen Atlan Crescent MotherwellMLI 2HR for it i feel, is absolutely perfect for all. 187 Hamilton M Yaqub Road Motherwell MLI 3DR 22 Kethers I support Sainsbury's Motherwell planning application 11/01231/ful because ... I enjoy shopping in Sainsburys Janice Marshall Street Motherwell MLI 3HF and it is near to where I live I support Sainsbury's Motherwell planning application 11/01231/ful because new employment opportunities are 18 Howson so needed in our area. It is an ideal location, just off the motorway and it would be nice to have an alternative to Anne Cavinue Lea MotherwellMLI 2JQ ASDA. Iwould welcome a Sainsburys in Motherwell very much. 68 Empire I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will bring fairer competition, jobs W Gibbs Way Motherwell MLI 3FQ and more choice to motherwell 34 Pimmill I support Sainsbury's Motherwell planning application 11/01231/ful because ...i feel asda has a monopoly in this Allyson Doran Avenue Motherwell MLI 3PU area. We need another major superstore in the area 53 Kirkland It's vital we attract new investment into our town, this new development will provide consumers with more choice Greg Barrie Street Motherwell MLI 3JW re. supermarket shopping. sumerne Add1 Add2 Tm Pdcodecommerrt I support Sainsbury's Motherwell planning application 11/01231/ful because it will bring a high quality retailer to a town which is regarded as down at heel. Their plans are sympathetic to the local environment, will improve a 46 The dangerous and busy junction on Airbles Road and give a much needed facelift to a highly visible but derelict area 11 Steven Ross Loaning MotherwellMLI 3HE of town. 104 Crawford It will bring jobs. The Sainsbury's brand will help the town and it would be good to have another local 1 Fraser Pattison Street MotherwellMLI 3BN supermarket option. I can walk to it in 2 minutes! I support Sainsbury's Motherwell planning application 11/01231/ful because it would mean another major supermarket in the town, instead of having to travel to the nearest one in Hamilton. Also, its painfully obvious that 51 Belhaven there should be more than one supermarket in an iconic town such as Motherwell. It would encourage most 1' Ross Watson Terrace Wishaw ML2 7AY Motherwell residents not to travel far. 19 Melvinhall ML11 1 lan Road Lanark 7AU 2 Helmsdale I support Sainsbury's Motherwell planning application 11/01231/ful because ... The old traction house site has 2 Ewan Rodgers Avenue Blantyre G72 9NY been an eyesore for years, and it will give customers a choice of where to shop ,and create more local jobs. 46 The I support Sainsbury's Motherwell planning application 11/01231/ful because ... Motherwell needs another better 2 Suzanne Ross Loaning MotherwellMLI 3HE supermarket than adds, also it will enhance the area and provide jobs. I support Sainsbury's Motherwell planning application 11/01231/ful because ...the town centre in Motherwell is an embarrassment and has been allowed to run into neglect by the current owners. They have opposed the plans by Sainsburys out of sheer bloody mindedness as they have clearly lost any sense of reality. What Motherwell needs is an influx of new investment from leading retailers to lift its profile and in doing so, attract similar sized businesses which would elevate the town to levels which the parochial Owners of the town centre can only 13 Chestnut dream of. If we lose Sainsburys Ifear they will only locate elsewhere leaving the town devoid of a genuine 2 Gary Leitch Grove MotherwellMLI 3JF commercial attraction and much needed jobs. In my view, the plan must succeed. Good luck I feel that having a local Sainsburys will bring much needed competition with Asda.Also it could possibly provide a job for myself, i have 20 years customer service experience in food retail and yet finding it impossible to find 2 Catherine Kerr work in north Lanarkshire. Ithink it will be a real benefit to Motherwell town centre and also bringing forward jobs for local people which it 423 Merry what is really needed just now there are not enough company's out there willing to put back into the local 2 Leanne Duncan Street MotherwellMLI 4BP community.. North lanarkshire residents should be allowed to have a choice of more supermarkets than just tesco. We have 3 Speybum to make a ten mile trip to south lanarkshireto have any choice of supermarket other than tesco or asda. If a large 2 John Matthew Place Airdrie ML6 6GF company want to invest in our county in these testing evonomic times then they should be allowed to do so. I support Sainsbury's Motherwell planning application 11/01231/ful because ...It is time north lanarkshire had a quality supermarket. The store will mot only bring- employment to motherwell but will also support large number 2 Alison Meggitt 3 Lanton Path Chapelhall Airdrie ML6 8GY of jobs in distribution centre in east kilbride 30 Jerviston I support Sainsbury's Motherwell planning application 11/01231/ful because having choice to shop in different 2 LYn Mullen Street MotherwellMLI 4BL supermarket instead of Asda 35 Brogan I support Sainsbury's Motherwell planning application 11/01231/ful because we shop in Sainsburys in Hamilton 2 Donald Laing Crescent MotherwellMLI 3HT almost every week. Why shouldn't our own town have a quality supermarket. I support Sainsbury's Motherwell planning application 11/01231/ful because ... The only major Supermarket ASDA is so complacient with a could not care less attitude that we waste fuel shopping at Sainsbury's or Morrisons each week, The Motherwell town centre is an embarassment with little more than pawnbrokers, 33 Elvan charity shops and boarded up unused shops, Primark is the only Nationwide known outlet and they sell only 2 Ars Rosslyn Kirkpatrick Tower Motherwell MLI 3EN what other big city Primark shops cant sell Sainsbury's for Motherwell -- YES 135 New Stevenston 3 Naules Road Carfin llle MName sumerne Add1 Add2 Tarm Poslcodecamment I support Sainsbury's Motherwell planning application 11/01231/ful because ... I am disgusted at the petty small mindedness of North Lanarkshire Council and local shop keepers trying to keep a decent store out of Motherwell while, at the same time they are actively seeking to bring in more cheap stores. There is nothing at that end of 18 Stirling Motherwell and, given the bad weather of recent years, people from there struggle to get to ASDA. Also, I don't 3 Michelle Crosby Street Motherwell MLI IAT see why ASDA should have the monopoly within Motherwell. I support Sainsbury's Motherwell planning application 11/01231/ful because ... I am an existing Sainsburys customer and look forward to being able to walk to the new Sainsbury instead of having to drive to Hamilton to do my shopping. I also think the proposed new store will create a very good impression at the entrance to Motherwell. I am very pleased Motherwell Town Centre is doing well, however I feel residents deserve a wider range of choice than is available at the moment. Motherwell Planners - you cannot reject this opportunity for 22 lmlach Parkside Motherwell to at last compare with Hamilton and East Kilbride in the retail market place and keep North 3 Jacqueline Jeffrey Place Gardens Motherwell MLI 3FD Lanarkshire money in North Lanarkshire. I support Sainsbury's Motherwell planning application 11/01231/ful because I feel that Motherwell needs Sainsbury's more than Sainsbury needs Motherwell. This could be the start of a regeneration of Motherwell 5 Tolemount Colvilel albeit outside the town centre. Lots of people staying in Motherwell shop outwith Motherwell this may keep some 3 tlr Tom Bow Crescent Gardens MotherwellMLI 2QX of the lost revenue in Motherwell. 4 Wellview This will save me a lot of travel as Sainsbury is my supermarket of choice but as an elderly lady, I find travelling 33 AS Sheila McGrory Drive MotherwellMLI 3ET difficult. 51 This will save me a lot of travel as Sainsbury is my supermarket of choice but as an elderly lady, I find travelling 3 IS Sarah Moffat Cakdergrove Motherwell difficult. 31 IS Ann Hamilton 26 Ross Drive Motherwell MLI 3BD I support Sainsbury's Motherwell planning application 11/01231/ful because ..we have too many cheap rubbish shops in motherwell and we are being dictated to by a glasgow consortium who have their own agenda. i have lived in motherwell many years and can remember when we had stores including the co op bairds goldbergs and 3 AS Gillian Clark 8 Staig Wynd Motherwell bhs. lets bring quality shopping back to motherwell. we no longer want to be the poor relation of lanarkshire. I support Sainsbury's Motherwell planning application 11/01231/ful because ...Motherwell needs a quality retailer such as Sainbury's, not in the congested town centre, Hamilton Road would be perfect ...... should Sainbury's 42 Carbams fail to get permission to build this new store ...... my wife and I will continue to shop in Sainsbury's Hamilton 3( Ir Eddie MacDonalc East Wishaw ML2 ODG ...... and not some second rate store in the town centre with no parking ...... 23 Brogan 3' IS Laura Prentice Crescent Motherwell It would be handy to have a sainsburys in motherwell 23 Brogan 41 IS Pauline Prentice Crescent Motherwell We shop in hamilton and live in motherwell 3 Viewpark 4 rlr Tom Watson Place Motherwell I would like to shop in motherwell 3 Viewpark 4: 6 May Watson Place Motherwell 20 Hillhead WE THINK IT WOULD BRING MOTHERWELL IN LINE WITH MOST OTHER TOWNS IN NORTH 4: IS lsobel Cowan Crescent Motherwell MLI 4AE LANARKSHIRE TO HAVE TWO MAJOR SUPERMARKETS IN THE TOWN 3 Harvest ML12 I support Sainsbury's Motherwell planning application 11/01231/ful because ...it would provide another option for 41 IS Clare McKay Drive Motherwell 2RT shopping on my doorstep 65 Arran I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will bring more jobs to the town 4! dr John Campbell Road Motherwell and give more of a choice where to shop I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will bring much needed 12 Lawson investment Into Motherwell and will also reduce the exodus of shoppers from Motherwell to other areas outside 4( Ir Stephen OMara Avenue Motherwell North Lanarshire. 49 Sannox I support Sainsbury's Motherwell planning application 11/01231/ful because ... it will be better for the residents 4 IS Evonne Moffat Drive Motherwell of the town, creating jobs and giving people choice of where to shop 49 Sannox I support Sainsbury's Motherwell planning application 11/01231/ful because ... The town needs another 4r Ir Kenny Moffat Drive Motherwell supermarket and petrol station as the current one's are holding the town to ransome!!! Sumeme Add1 136 Hamilton 49 k3 Jeanette Nolan Road Motherwell Lanarkshin MLI 3DG I support the Sainsburys Motherwell planning application so that we have more supermarket choice 39 Crawford 50 4s Clare Beattie St Motherwell MLI 3AF I support Sainsbury's Motherwell planning application 11/01231/ful because it would benefit the town very much 202 Burnside I support Sainsbury's Motherwell planning application 11/01231/ful because ...it gives us more choice since at 51 Ar David Amott Road Newarthill MLI 5BS the moment we only have only one large supermarket. 202 Burnside 52 As Nanette Amott Road Newarthill MLI 5BS I support Sainsbury's Motherwell planning application 11/01231/ful because ...it is a really good supermarket. 15 I support Sainsbury's Motherwell planning application 11/01231/ful because ... i think motherwell will benefit from Cunningham the addition of a premium retailer like sainsburys and it will be a good use the land which will be an improvement 53 Ar Mark Milligan St Motherwell on the previous use as a bus depot. 5 Henderson I support Sainsbury's Motherwell planning application 11/01231/ful because ... It's a joke that motherell only had 54 Ar Martin McGuire Court Motherwell one supermarket I support Sainsbury's Motherwell planning application 11/01231/ful because we need a Supermarket that gives 5 Tolmount Colville value for money and that also sells good quality food products. It will also enhance the derelict area that has 55 AB Christine Bow Crescent Gardens Motherwell MLI 2QX been lying vacant for many years and create jobs in the local community Motherwell needs good quality shops. 6 Shirley I shop at Sainsbury's Hamilton and it would much closer to my home in Motherwell. It would also create jobs in 56 Ars Margaret MacClure Quadrant Motherwell Motherwell which is very important in these very difficult economic times. I support Sainsbury's Motherwell planning application 11/01231/ful because ... It would give Motherwell shoppers 6 Shirley more choise and keep money in the town as lots of people go to Hamilton and further to shop. It is also very 57 Ar Jim MacClure Quadrant Motherwell important to ensure we do not lose the jobs to some other area I support Sainsbury's Motherwell planning application 11/01231Rul because Motherwell desperately needs another supermarket and a full service one at that. We do not need a "convenience" size store in the town centre but one that allows shopping, cafe facilities and petrol. The poor shopping choice in the town centre is a separate issue. Motherwell is the only town round about that has only one supermarket. The people of Motherwell are long overdue a choice of where they shop. People should be encouraged to spend their disposable income in Motherwell and not do what I and many others do - shop elsewhere due to lack of choice and facilities. Yes, there will be traffic issues but there are long-standing traffic management issues in 235 Airbles Motherwell and these should not stop inward investment - especially in times of a recession. Sainsbury's in 58 Justine Main Street MotherwellMLI 1x2 Motherwell anonly be a good thing. 4 Wellview Will save me so much time and fuel getting my shopping from my favourite store. Jobs potential for town a boost 59 Ar John McGrory Drive MotherwellMLI 3ET as well. This is fantastic for Motherwell. Not only will it bring new job opportunities to the people in this area but also healthy competition for Asda. They've had it all their own way for a very long time. Also eventually getting rid of this eyesore of overgrown scared for land is a great welcome. You have the full support of our family. I support Sainsbury's Motherwell planning application 11/01231/ful because ... it brings job stability into our local area and brightens up the entrance to our town from leaving the motorway. Also saves me a trip to Hamilton for shopping. 60 Sarah Connell I support Sainsbury's Motherwell planning application 11/01231/ful because ... It will bring a much needed jobs 2 Primrose boost to the area and a greater choice of grocery shopping (currently limited to Asda if you live in town centre 61 MdY Laing Crescent MotherwellML1 2RF and don't drive) I support Sainsbury's Motherwell planning application 11/01231/ful because ... Motherwell needs another supermarket. The town center is an Absolute Joke,and wee need more choice for the consumer. I dont care if i have to walk to the Hamilton Road supermarket because "Quality is not in motherwell town Center, and if i need 62 Thomas Welsh to travel to buy quality products, i will. 11 Catrine MLI A Sainsbuv's store would provide an alternative to ASDA and improve our ability to shop for items lacking in 63 Catherine Dick Crescent Motherwell 2BW Motherwell town centre 11 Catrine MLI I support Sainsbury's Motherwell planning application 11/01231/ful because it will provide us with shopping not 64 Cameron Dick Crescent Motherwell2BW available in Motherwelltown centre 10 Dorian I support Sainsbury's Motherwell planning application 11/01231/ful because ... It brings new jobs to the area and 65 David Brown Wynd Motherwell MLI 2QT giving us more choice in the supermarkets we shop in. ltle Town PoskodeComment i support Sainsbury's Motherwell planning application 11/01231/ful because ... of the jobs it will create and the 8 Broomside choice it will offer. Currently motherwell has Asda and no other choice of supermarket, no other town is restricted 6( Linda Mairs Street Motherwell in that way. I support Sainsbury's Motherwell planning application 11/01231/ful because ...It is the only supermarket to offer a good selection of organic fruit, veg and groceries. Asda offers none of this and so we have to journey to 6 Amy Cartwright Hamilton in the car for our weekly shop - this would cease with a Motherwell store providing choice for shoppers I support Sainsbury's Motherwell planning application 11/01231/fulbecause it would bring jobs to the area and provide competition to Asda which dominates the town centre. The town centre is dying and there is no point in waiting till we have no other shopping alternatives and wishing we had backed the Sainsburys application. At present that land has been derelict for at least 5years with houses having been the original idea for replacing the 77 North bus depot. This has never come to fruition and it makes sense that while the house building industry is suffering Lodge in this economy that we should put this land to good use and bring employment to the area. Perhaps if the jobs 6; Sarah Cartwright Avenue Motherwell are primarily offered to local residents this would be a positive step in the right direction. 18 John Muir I enjoy the Sainsburys shopping experience and feel it is a nonsense that I need to travel to Hamiltoqwhen 6 Anne Cartwright Way Motherwell Sainbuys are able and willing to build Motherwell's only rival to Asda, a store where Organic produce is a rairity. I support Sainsbury's Motherwell planning application 11/01231/ful because ...There is an urgent necessity to 18 John Muir provide a quality supermarket...p roviding for example organic produce. Further I find it strange that Planners who 71 Robert Cartwright Way Motherwell sanctioned the hideous 'Asda Box' should object to anything. I support Sainsbury's Motherwell planning application 11/01231/fully because it would bring significant employment to Motherwell during a period of economic downturn. The shopping centre in Motherwell is a disgrace as there is an inordinate number of pound shops and shops that lack quality of produce. The town planners exertions would be better served in improving the carbuncle that they have allowed Motherwell Town Centre to become. In Addition, they seem to be obsessed with improving the roads and pavements around the cross which will turn the area into nothing more that a glorified bus station!! I like many folks in Mothewell personally do not shop in Motherwell and prefer to shop in Hamilton as the shopping experience is far superior. The proposed site of the Motherwell Sainsbury's is the first impression visitors to Motherwell are exposed to and it is currently nothing more than a eyesore. Having a Sainsbury's on that site would be ideal and would be a 75 Parkneuk welcoming gateway to the town. 7 Peter McCrossar Street Motherwell MLI 1BY 29 Cunningham 7 Christine Macmillan Street MotherwellMLI 3EP Because it will bring much needed jobs to the town I support Sainsbury's Motherwell planning application 11/01231/ful because ... There is only 1 Supermarket in 5 Herald Motherwell and Sainsbury's would give people options where to shop and also creating 300 jobs which is good 7 lain Somerville Grove MotherwellMLI 2sL news for the area. I support Sainsbury's Motherwell planning application 11/01231/ful because ...What is the council thinking of that site is just an eye sore!! I would love to be able to walk over to Sainsbury's and buy good quality food at an affordable price. Motherwell is a ghost town and needs a new development to inject some lie back into it. There are a lot of good people in the local area that want to increase employment in the area and help the younger people have more opportunities to go out and learn and improve their people skills. I say yes yes yes to 32 Wellview Sainsbury's developing on that site and myself and my family fully support this opportunity. Alison Thomson 7 Alison Thomson Drive Motherwell MLI 3ET I am speaking on behalf of my mum who has lived in this area for over 40 years although elderly she still has an opinion and has noticed a deterioration over a number of years in the area, my mum, family and i who still live 37 Wellview MLI locally fully support the Sainsbury's development. A massive welcome to the area not only to improve the 7 Ars Kirkland Drive Motherwell 23ET outlook but to inject much needed jobs to local youngsters. 31 Ladywell 7 John Crow Road Motherwell 1 support Sainsbury's Motherwell planning application 11/01231/ful because ... it will employ locals swnenw, Awl Add2 T' PoskodeComment I support Sainsbury's Motherwell planning application 11/01231/ful because I believe it will be an asset to the community, create extra jobs and help to bring more customers into the area. I live in Motherwell for many years and although the council has started to improve (modernise) the overall look of the town centre in recent times with success, the actual high street shopping facilities in terms of smaller boutique-style shops is still lacking. I 54 Bruce dont see Sainsburies as a threat to the economy of Motherwell, rather a bonus. Maybe their move to Motherwell 7 Kerstin Devine Avenue MOtherwel MLI 3LB will encourage other retails such as Deichman, Next, etc. to look at our high street spaces as well. As a full time mother of 2 kids under 3 this site is within walking distance to me, I do shop in sainsburys (hamilton & online) & think it would be an asset to the local area & the amount of jobs it would generate would give the area a boost especially for mothers like myself that cannot work a 9-5 job giving people a chance to get back out 50 Grainger to work doing shifthightime work I find this very exciting as I would like this opportunity myself & if this goes 7 Laura Watt Way Motherwell MLI 3GY ahead as soon as jobs are advertised I will apply. 18 Morris I support Sainsbury's Motherwell planning application 11/01231/ful because it would mean that I am closer to my 7 Catherine Srirangan Crescent Motherwell MLI 5NH favourite supermarket than I am at the moment with the Hamilton Sainsbury's. I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will create alot of jobs for local a Tessa Howie 26 Bums Way Newarthill MotherwellMLI 5EQ people and another choice for food shopping instead of just asda as far as large supermarkets are concerned. 74 Kethers I support Sainsbury's Motherwell planning application 11/01231/ful because ...The people of Motherwell deserve 8 Andrew McRoberts Street Motherwell to have a choice of supermarket within the town and not have to travel to other towns for this choice. 26 Orchard 8 Hugh O'Donnell Street Motherwell MLI 3JD I use the local Sainsburys at my work and would like to be able to do so at home. 26 Orchard I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will bring much needed 8 Janice Bayne Street Motherwell MLI 3JD employment to the area and an alternative to ASDA. 6 West Thomlie Thomlie 8 Mike Dwyer Manse Street Wishaw ML2 7AR I want to see big companies move to the area and invest as this will drive further investment. 29 Murdostoun 8 Kathleen Falconer Gardens Wishaw MU7JL I want more choice so having sainsbury's will give us this I support Sainsbury's Motherwell planning application 11/01231/ful because it will give more choice when 6 West shopping and bring jobs to the area. It also an how's people want to invest in the area which will bring other Thomlie Thomlie investors to the area. a Alison Falconer Manse Street Wishaw ML2 7AR I support Sainsbury's Motherwell planning application 11/01231/ful because it will create more jobs in the area and will increase competition between Tesco and Asda. a Lorna Ross 3 Ellis Way Motherwell I support Sainsbury's Motherwell planning application 11/01231/ful because ... it bring a freedom of choice for supermarket shopping in Motherwell. a Drew Brown 13 King Court Motherwell ML1 3FW I love shopping in Sainsburys and also feel that the jobs boost for the local economy is vital. 24 Northfield I support Sainsbury's Motherwell planning application 11/01 231/ful because ...it.will.benefit.motherwell.al1.round. a Neil Toal Street Motherwell shopping.wise I support Sainsbury's Motherwell planning application 11/01231/ful because ... Every shopper deserves freedom of choice. I, like many others, was lured to a large new build family home in Carfin with the promise of" new village" and " substantial investment" in the area instead of which we have Ravenscraig almost at a standstill albeit with a stunning new sports facility but like Aquatec with nowhere for adults to have a swim. In addition to this we have the likes of local employer Terex slashing jobs yet in astonishment you have responsible retailers E Liz Clark 2 Peach Court Carfin Motherwell MLI 5FE and employers you are dismissing without due survey of the residents of Motherwell. I support Sainsbury's Motherwell planning application 11/01231/ful because I'm interested in quality of 45 Brogan supermarkets. At the moment I have to drive to Hamilton whenever I need proper food (currently Supermarket in E Tauras Valevicius Crescent Motherwell MLI 3HT Motherwell's centre is not great). Add2 T
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10 1 sunerne Awl Add2 Tawn PostcodeComment I support Sainsbury's Motherwell planning application 11/01231/ful because ...it is a chance for Motherwell to 1)provide employment for the local community (construction and in-store) 29 Douglas 2)attract shoppers from outwith Motherwell who may also decide to shop in the town centre 118 Linda Timlin Street MotherwellMLI 1JQ 3)provide the local community with a greater selection of shopping experiences I support Sainsbury's Motherwell planning application 11/01231/ful because ...more jobs to the area, better 41 Kirkland variety for the local community and a choice for individuals in motherwell other than the usual supermarket 119 Andrea Galloway Street Motherwell brands, without having to travel to another town. 29 Cunningham I support Sainsbury's Motherwell planning application 11/01231/ful because I don't think it would have a negative 120 Colin Macmillan Street MotherwellMLI 3EP impact on the town centre and it would improve the derelict site I support Sainsbury's Motherwell planning application 11/01231/fulbecause ... Ifind the road system & parking in Motherwell town centre a nightmare. At present I shop in Sainsburys and Morrisons in Hamilton as do most of 5 Kay my friends & neighbours. This means many people born & brought up in Motherwell are taking our money away 121 Ars M Bulloch Gardens Motherwell from our home town as our needs are not being met here. I support Sainsbury's Motherwell planning application 11/01231/ful because ...the site has been vacant for so long and Sainsbury's supermarket is a very reputable company. The store will offer job opportunities in the area. 15 Sandilands I may even be interested myself in applying for a post. I live in an estate that overlooks the piece of land and look 122 Audrey Robertson Crescent Motherwell MLI 2AX forward to the store being there for handiness and to make use of the land 123 John Hutton 4 Earl View Motherwell MLI 4LA We need some competion as we have a monoply at the moment. 33 Ross I support Sainsbury's Motherwell planning application 11/01231/ful because Motherwell needs a supermarket like 124 Margaret Kerr Gardens Mothewell ML1 3BE Sainsbury. I would rather spend my money in North Lanarkshirethan travel to South Lanarkshire to shop. I support Sainsbury's Motherwell planning application 11/01231/ful because ... I always shop in sainsburys and it would be only appropriate that the people of Motherwell have a good supermarket like other areas of Lanarkshire
It will also bring jobs to the area which we really need to give the area a boost and encourage people outside 69 Harvest North Motherwell to visit. 125 Lorraine Sherry Drive Lodge MotherwellMLI 2RT The positionjust off the motorway is ideal 69 Harvest North I support Sainsbury's Motherwell planning application 11/01231/ful because ... We need jobs and inward 126 Alan Sherry Drive Lodge MotherwellMLI 2RT investment for young people in the area Sainsburys new build wil offer this 6 Centurion I support Sainsbury's Motherwell planning application 11/01231/fulbecause ... it would encourage me to stay in 127 Alan Brown Place Motherwell MLI 3DZ MLI 3FS Motherwell to shop rather than going to nearby Hamilton (South Lanarkshire) I support Sainsbury's Motherwell planning application 11/01231/ful because a) It would save a regular journey into Hamilton for shopping. b) It would provide greater choice for shoppers in Motherwell c) We do not have a supermarket petrol station in Motherwell and this would be a boon to motorists in these difficult economic times. d) The siting of this supermarket is perfect for visitors to the town and would clear up an eyesore at a major entrance to Motherwell. e) For these reasons and a host of others, this could only be a great benefit to the town and Iwould urge the 12E Ben Swinburne 3 Wooddale Beechwood Motherwell town planners to get their heads out of the sand and support this exciting development. 12s Mary Swinburne 3 Wooddale Beechwood Motherwell This is a great opportunity to raise the profile of Motherwell and provide greater choice for all shoppers. I support Sainsbury's Motherwell planning application 11/01231/ful because ...we really do need a quality supermarket other than ASDA. The towm badly needs the jobs. It would improve the entrance to the town by 20 Neilsland developing the eyesore of the bus garage site. I don't believe that it would take trade away from the town Centre - 13C Nancy Wardrop Drive Motherwell MLI 3DZ I currently go out of Motherwell to shop as I know many others do. Please don't throw away this opportunity. John and 10 Viewpark I support Sainsbury's Motherwell planning application 11/01231/ful because ...for the size of our Town we need 131 Rae Hunter Road MotherwellMLI 3EY another good Supermarket and take vehicle congestion away from the Town centre which is overrun already. 44 Gemini I support Sainsbury's Motherwell planning application 11/01231/ful because ...it will create more jobs for the 132 Fiona Crawford Grove Holytown Motherwell MLI 4SP motherwell area and give the local people more choice of supermarkets Mle lawn poetocrdecomment general supermarket shopping in Motherwell is currently limited to Asda and Lid1 reducing choice for residents. At present I travel out of Motherwell to shop in Sainsburys in Hamilton as do many of my neighbours. At a time where jobs are limited in the area the new store would create jobs. A new store would also improve the derelict 133 Wendy Bennett 1 Easterbrae MotherwellMLI 2ET site at the gateway into Motherwell which is becoming a worse eyesore as time goes by. 40 Morven 1 Support Sainsbury's Motherwell planning application 11/01231/ful because it will create jobs in the area and 134 Celine Clarke Drive MotherwellMLI 2TT provide choice for consumers. I support Sainsbury's Motherwell planning application 11/01231/ful because ...THE TOWN COULD DO WITH A BETTER QUALITY SUPERMARKET, AND IT WILL BRING EMPLOYMENT. MOTHERWELL TOWN CENTRE IS ALWAYS VERY CONGESTED WITH TRAFFIC &YOU CAN'T GET PARKED AT ASDA ON A SATURDAY 3 Wellview AFTERNOON.THE PROPOSED NEW STORE WOULD BE MUCH MORE CONVENIENT FOR MY FAMILY. MY 135 Patricia Chambers Drive MotherwellMLI 3ET NEIGHBOURS & I FULLY SUPPORT THE APPLICATION. I support Sainsbury's Motherwell planning application 11/01231/ful because ...I drive to Sainbury's in Hamilton. 38 Jerviston Motherwell town centre is awful, it would improve Motherwell to have a more upmarket store instead of all the 136 Gareth Lindsay Street Motherwell MLI 4BL bargain stores. I support Sainsbury's Motherwell planning application 11/01231/ful because ... i stay on the loaning which is a 41 The dose Street to the site of the proposed sainsbury's site, and this would be a great help in my day to day life. i 137 Grant Finnigan Loaning MotherwellMLI 3HE would also like to apply for a job in the store and im sure more people would feel the same. I support Sainsbury's Motherwell planning application 11/01231/ful because currently I do all my shopping in either Hamilton or Wishaw and it would be nice to shop locally in a store I like. Motherwell dramatically needs a 11 Lochnager facility like Sainsburys to boost revenue to the town and create additionaljobs as well as offer choice to the 138 Linda Duddy Road MotherwellMLI 2PG town's residents. 67 Wood I support Sainsbury's Motherwell planning application 11/01231/ful because ...i think it would be a good 139 Angela Mitchell Crescent MotherwellMLI 1HN opportunity for motherwell, and the jobs that will be available, would only be a good thing. 152 Muirfoot ML11 I support Sainsbury's Motherwell planning application 11/01231/ful because ...i like sainsburys and i know 140 Kirsteen Kyle Road Rigside Lanark 9NE someone who works for them 27 Morven I support Sainsbury's Motherwell planning application 11/01231/ful because it would enhance the reputation of 141 Dave Biggans Drive Motherwell MLI 2TT the town and create employment 4 Parkside 142 Mrs Margaret Dalziel Road Motherwell MLI 3DY because ... it will be handy for people who stay at this end of the town 1 Greenacres I support Sainsbury's Motherwell planning application 11/01231/ful because ...It brings jobs,choice and much 143 Graeme Smillie View Motherwell MLI 3BG needed competition in the area Asda have the monopoly so I welcome Sainsburys with open arms 4 Greenacres I support Sainsbury's Motherwell planning application 11/01231/ful because ...We need more choice and value 144 Diane Dempster View MotherwellMLI 3BG for money also creates jobs I support Sainsbury's Motherwell planning application 11/01231/ful because I strongly feel that we need more choice in Motherwell. Also I am a pensioner and can't drive so this store would be much more accessible for me. 58 Viewpark Currently I have to get buses to stores in other towns eg wishaw, Bellshill, Lanark. I cannot stress how 145 Mrs Janet Gillespie Road Motherwell MLI 3HB disappointed Iwas to hear that sainsburys application was being declined. I support Sainsbury's Motherwell planning application 11/01231/ful because ...We need investment,jobs and 2 Greenacres choice in Motherwell I started shoping in Hamilton a few years ago because it has choice we have asda !!! I will 146 George Taylor Mew Motherwell MLI 3BG revert to motherwell again if Sainsburys gets the go ahead I am vet upset that this has not been aproved I support Sainsbury's Motherwell planning application 11/01231/ful because IT WOULD BRING MORE JOBS TO 13 Duke THE AREA AND OFFER SOME HEALTHY COMPETITION TO ASDA WHO SEEM TO HAVE IT ALL THERE 147 Stuart Gray Street Motherwell OWN WAY AT THE MOMENT, AND GIVE CUSTOMERS MORE CHOICE. 157 Ladywell I support Sainsbury's Motherwell planning application 11/01231/ful because ... we have only one supermarket - 148 Winnie ONeill Road Motherwell Asda quality and parking is very poor- Sainsburys offers better quality and I like the proposed location. 35 Neilsland I support Sainsbury's Motherwell planning application 11/01231/ful because ...it would bring much needed extra 149 Mrs I Christie Drive Motherwell shopping facilities plus the bonus of jobs to the area I support Sainsbury's Motherwell planning application 11/01231/ful because ... i work for the company and know 150 Rory Stannage 13 Emily Drive Motherwell ML 2SH how much we will bring to the motherwell and North Lanarshire area 8 Laith I support Sainsbury's Motherwell planning application 11/01231/ful because ... It will enhance Motherwell and Nicola Mackie Avenue Motherwell ML 2QU provide jobs ntle MN8me sumerne Add1 Add2 lawn PoBkodecomment 30 Carfin I support Sainsbury's Motherwell planning application 11/01231/ful because, it will create more jobs for locals 15; Jillian McDowall Road Newarthill MotherwellMLI 5AB and will be good for local businesses in the area. I support Sainsbury's Motherwell planning application 11/01231/ful because apart from the obvious number of jobs created, it will also encourage people from surrounding towns and villages to shop in Motherwell who otherwise would not. And if they shop in Sainsbury's then they would probably make use of other facilities that Motherwell has to offer eg Strathclyde Country Park, local hotels and restaurants etc thus increasing revenue to local businesses. The building itself would improve the appearance of the currently derelict land which in the current recession will probably lie in its present state for many years to come.
Also, most towns have more than one major supermarket store to offer to its population and competition breeds rivalry therefore shoppers should be in a win-win situation as stores compete for their custom. 15: Mrs Alexis Watson 18 Boyd Drive Motherwell MLI 3HX 101 Bellshill I support Sainsbury's Motherwell planning application 11/01231/ful because there is currently only one major 154 Matt Alexander Road MotherwellMLI 3SJ supermarket in the town. In addition, it would regenerate a derelict site. ... 15! 15( 15 15; SAINSBURY'S SUPERMARKETS LTD & BDW TRADING LTD
PROPOSED SUPERMARKET
FORMER FIRST BUS DEPOT, HAMILTON ROADlAlRBLES ROAD, MOTHERWELL
PLANNING APP REF. 11/01231/FUL
RESPONSE TO RETAIL COMMENTS
MAY 2012 CONTENTS
1. Introduction 1
2. North Lanarkshire Council 2
3. Glasgow and Clyde Valley Strategic Development Planning Authority (GCVSDPA) 16
4. Dundas & Wilson / ASDA Stores Ltd 18
5. Douglas Stevens I Montagu Evans on behalf of Chester Properties I Columbus Capital 29
6. Conclusion 36
Appendix 1: ASDA Linked Trip Analysis
TA Ref: SAIE2030
LPA Ref: 11/01231/FUL
Office address: 115 George Street Edinburgh EH2 4JN
Telephone: 0131 240 5440
Date of Issue: 18* May 2012
TU R LEYA S S 0C IAT E S 1. Introduction
1. The purpose of this report is to respond to retail planning comments made by:
North Lanarkshire Council (email dated 5‘h April 2012)
Glasgow and Clyde Valley Strategic Development Planning Authority (GCVSDPA) (letter dated 17‘h February 2012)
Dundas and Wilson on behalf of ASDA Stores Limited (letter dated 6th March 2012)
Douglas Stevens / Montagu Evans on behalf of Chester Properties / Columbus Capital (letters dated 1Oth and 29* February 2012).
2. We are aware that there have also been third party objections that comment on retailing planning policy. It is considered that these points will be covered within the response to the four representations noted above.
3. The Retail Assessment (RA) (November 2011) was submitted on behalf of Sainsbury’s Supermarkets Ltd and BDW Trading Ltd to assist the Council in their assessment of the planning application for a proposed supermarket on the Former First Bus Depot, Hamilton Road / Airbles Road, Motherwell.
4. This response should be read in conjunction with the RA and Planning Statement (PS) submitted to accompany the planning application. The validity of both documents still stand despite the comments made within the comments to the application.
5. The correspondence received from North Lanarkshire Council sets out points of clarity rather than objection and relates to the: ‘Quantitative Assessment‘, ‘Turnover of Asda, Motherwell’, ‘Sequential Approach’ and ‘Town Centre Health Checks’.
6. The GCVSDPA mainly focuses on the interpretation of planning policy within the structure plan with the representations made by ASDA, Chester Properties / Columbus Capital as well as some of the third parties categorised as being objections to the application. The majority are considered commercial objections.
1 TURLEYASSOCIATES 2. North Lanarkshire Council
2.1 An email was received from North Lanarkshire Council on 5‘h April 2012 which outlined a number of points of clarity the Council would like addressed prior to concluding their review of the proposal. An overview of comments made by the Council are outlined below together with the appropriate response.
Quantitative Assessment
Comment C1
2.2 Clarity on calculation of quantitative capacity within the catchment to enable appropriate review of Strategic Policy 9.
Response Rl
2.3 The proposal’s compliance with Strategic Policy 9 is provided in detail within the ‘Planning Statement’ (refer to paras517 to 5.54). The assessment of the proposal against the relevant criteria is still valid.
2.4 We note the Council’s comment, which states that the applicant should demonstrate that there is a quantitative need for the development both in terms of convenience and comparison retailing. While clarity can be provided on this point, there is no specific requirement within Strategic Policy 9(A) or other related policy that requires the demonstration of “need” in order for the proposal to be considered acceptable.
2.5 SPP2010 in particular requires those promoting development to assess how any proposal would help address identified quantitative deficiency. It does not require there to be an exact equilibrium between catchment expenditure and turnover.
2.6 The ‘test’ is in understanding what deficiency exists but to then take this forward and assess whether the individual and cumulative impact on any town centre (as a whole) is significant or not.
2.7 Although not referenced specifically it is understood, the Council’s principal query relates to part ‘A of Strategic Policy 9, which seeks to understand expenditure compared to turnover (including additional identified development).
2.8 While the Council cross references Chapter 9 and 13 of the ‘Retail Assessment‘ (RA), it should be noted that the exercise of comparing expenditure and turnover and any related deficiencies has also been referenced within Chapter 7 and 8. It
2 TURLEYASSOCIATES provides commentary on the leakage and overtrading levels within the catchment. This then provides an indication of the resultant deficiency or “need”.
2.9 Chapter 9 provides more insight into the quantitative analysis, and provides commentary on the Total Available Expenditure (TAE) and turnover within the catchment with all detailed analysis contained within the retail model (Appendix 4).
2.10 While it is recognised that the structure plan and adopted local plan has undertaken capacity analysis, it is not directly comparable (due to differing assumptions/catchment etc) and is now somewhat out of date (having been undertaken back in 2006).
2.1 1 The Council’s latest position on retail capacity matters is contained within GCVSP Technical Report TR7/06. It notes with regard to the ‘Bellshill/MotherwelI’ area, that there is a ‘surplus of turnover‘ (or negative turnover) of some f15.92 million. This figure relates to 201 1 but does not provide for the growth in expenditure over the next five years. It should be noted that the analysis indicates that f41.98 million is ‘lost’ from the catchment. This is expenditure that should be retained and forms part of local deficiency/capacity in the area.
2.12 The equivalent figure in relation to comparison goods is noted as showing a shortfall of some f14.53 million, and that necessary steps should be taken to address this. It again should be highlighted that a significant f62.90 million is ‘lost’ from the catchment. This too forms part of local retail deficiency that should be addressed by greater provision locally.
2.13 The analysis undertaken by Turley Associates makes reference to the current position at 2011 but then forecasts this to a design year of 2015 using the appropriate methodology. To provide further clarity, Tables 1 to 3 of this report outline the relevant deficiencies highlighted by the Sainsbury’s quantitative assessment.
3 TURLEYASSOCIATES Table 1: Indicative Convenience Goods Capacity Analysis (assuming constant market share)
Total Available Expenditure TAE fm 210.90 217.03
Catchment Area Market Share % I 97.4% I 97.4%
Survey Derived Turnover f m 205.34 21 1.31
Benchmark Turnover f m 199.37 199.49
Convenience Capacity f m 5.97 11.82
Leakage f m 1 5.56 5.72
Capacity + Leakage fm 11.53 17.54
Total Available Expenditure TAE fm 444.54 457.39
Catchment Area Market Share % 95.3% 95.3%
Survey Derived Turnover f m 423.50 435.74
Benchmark Turnover f m 430.19 430.45
Convenience Capacity f m -6.69 5.29
Leakage f m 21.04 21.65
Capacity + Leakage f m 14.35 26.94
4 TURLEYASSOCIATES Table 2: Indicative Comparison Goods Capacity Analysis (assuming constant market share)
Total Available Expenditure TAE fm 280.45 341.26 I I I I 1 Catchment Area Market Share % 1 52.8% 1 52.8%
Survey Derived Turnover fm 147.94 180.02
Benchmark Turnover f m 178.34 189.28
Comparison Capacity fm -30.40 -9.26
Leakage f m 132.51 161.24
Capacity + Leakage f m 102.11 151.98
Total Available Expenditure TAE fm 599.45 729.27
Catchment Area Market Share % 58.1% 58.1%
Survey Derived Turnover fm I 348.53 1 424.01
Benchmark Turnover f m 371.07 393.84
Comparison Capacity f m -22.5 30.17
I Leakagefm I 250.92 I 305.26
Capacity + Leakage fm 1 228.37 I 335.43
5 TURLEYASSOCIATES 9
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6Z'8SS SE'16P 2.14 Tables 1 to 3 above have identified the relevant deficiencies within the primary and catchment as a whole. They show, in convenience terms (Table l), an indicative primary catchment deficiency (capacity + leakage) level of some f17.54 million at the design year (2015) rising to some f26.94 million when considering the catchment as a whole.
2.15 While not directly comparable (as acceptable levels of impact require to be factored) the predicted convenience turnover (from catchment) of the Sainsbury’s store stands at some f39.36 million.
2.16 In comparison terms (Table 2) the indicative primary catchment deficiency (capacity + leakage) stands at some f151 -98million at the design year, which then rises to significant f335.43 million in the entire catchment. Again, while not entirely comparable for reasons stated previously, the level of comparison turnover by the proposal (from catchment) is f12.99 million at the design year.
2.17 SPP2010 requires assessment of the impacts on town centres as a whole and, as such, the combined deficiencies have been outlined within Table 3. It shows a combined primary catchment deficiency (capacity + leakage) of f169.52m at the design year, which then grows to f362.37m when taking the catchment as a whole. The combined (catchment) turnover of the proposed Sainsbury’s stands at some f52.35million.
2.18 The analysis has identified a growing level of quantitative retail deficiency within the catchment. The proposal would assist in addressing this, as advocated by SPP2010 and the Development Plan.
Turnover of ASDA, Motherwell Town Centre
Comment C2
2.19 The second comment raised by the Council relates to the turnover of the ASDA store in Motherwell Town Centre. In doing so, reference is made to two recent Retail Impact Assessments (RIA) for proposals in close proximity to Motherwell.
2.20 Reference is also made to commentary made by the agent for ASDA, Dundas & Wilson, on a similar point.
Response R2
2.21 Starting with the two RIA referenced by the Council and without going into the accuracy of these reports they were ultimately not informed by up-to-date and
7 TURLEYASSOCMTES recent household shopper surveys. They therefore do not provide detail on the ‘actual’ shopping patterns across the catchment, and specifically the level of expenditure attributable to the ASDA store in question.
2.22 An understanding of ‘actual’ turnover levels is required to allow a clear picture as to whether stores such as ASDA are trading at, above, or below, the considered ‘average’ level. Beyond this, the RIA in question do not outline the full extent of the catchment for the ASDA store and, as a result, only denotes part of the store’s turnover ignoring further inflow to the store from beyond the catchment noted in the RIA.
2.23 The Sainsbury’s RA has identified both the ‘average’ and ‘actual’ turnover levels of the ASDA store and has captured all the expenditure that is directed to this store. The ‘average’ turnover level denoted within the Sainsbury’s analysis was achieved by applying the relevant sales floorspace to the latest turnover ratio for the operator. The source is the ‘UK Food & Grocery Retailers 2011’ produced by Verdict. This source is ‘goods based’ as opposed to ‘business based’ (eg. Retail Rankings) and considered the most accurate source as it divides out the turnover ratio by goods type.
2.24 Table 2 of the retail model shows that the ASDA store is expected to have an ‘average’ convenience turnover of f39.23 million at the design year (2015)and a comparison turnover of some f15.61 million (2015). This turnover is considered to relate to the figure highlighted by the Council and by others in historic RIA.
2.25 This ‘average’ turnover for the ASDA store is only an indication of what the store should be trading at in order for it to achieve a healthy operational return. Anything beyond this is generally considered to be ‘overtrading’, which can provide a sign of local deficiency eg. lack of competition.
2.26 ‘Average’ turnover data is useful in benchmarking the performance of retailers; it is not, however, the most accurate way in ascertaining how individual retailers are actually performing.
2.27 Ascertaining the ‘actual’ turnover requires the use of household surveys. The survey analysis allows the available expenditure identified within the catchment to be apportioned to the existing destinations based on where people say they undertake the convenience and comparison shopping. This then allows an understanding of how individual stores are actually trading against their expected ‘average’ or benchmark turnover.
8 TURLEYASSOCIATES 2.28 It also allows further analysis to be undertaken into the final effect a new store may have on existing destinations. For example, if a store is shown to be trading well in excess of its ‘average’ level it is better able to absorb the trade diversion.
2.29 We note the Council’s cross reference to commentary made by ASDA that the denoted turnover level within the Sainsbury’s RA is an over estimate.
2.30 We accept that turnover data may be commercially sensitive, but note that ASDAs assertion is unsupported by actual evidence. In contrast, our methodology is completely transparent.
2.31 In relation to overtrading, we have visited the ASDA store at both on and off-peak times and witnessed key indications of overtrading (eg. queues at checkouts, congested car park, produce in lobby etc). Beyond this, feedback at the community consultation event has noted that the ASDA store is extremely busy due to lack of competition in the Motherwell area.
2.32 The use of commissioned household surveys enables us to understand exactly where the identified catchment expenditure is going. ASDA has not provided any detail as to exactly where they believe the trade is going (if it is not to their store).
2.33 From visiting the catchment on a numerous occasions and witnessed the trading conditions of all the main supermarkets, we believe that the identified level of expenditure flowing to the ASDA store is accurate on the basis of the evidence provided by the household survey.
2.34 Model table 10 shows that, once the ‘actual’ main food and top-up turnover is totalled, the ASDA store will achieve an annual convenience turnover (at 2015) of some f57.86 million (includes visitor turnover). The equivalent figure for ‘actual’ comparison turnover stands at some f11.80 million which when combined provides a total turnover at the design year of f69.66 million (on basis of no new floorspace being put in place between 201 1-2015).
2.35 When one compares the ‘actual’ turnover with the ‘average’ turnover this shows that the store will be trading above benchmark by some f18.63 million for convenience goods and trading some f3.81 million under benchmark for comparison goods. Combined it shows the store to be trading (in total) some f14.82 million above its ‘average’ level.
2.36 This level of ‘overtrading’ is an indication of ASDA’s dominant market share in Motherwell. Sainsbury’s would counter this by providing the appropriate competition and choice. We would suggest that the Council make visits to the two
9 TURLEYASSQCIATES ASDA stores in close proximity to the subject site (Motherwell and Hamilton) at on and off peak times and carefully consider the points made in the RA.
2.37 Competition and choice are widely recognised as being a key requirement to ensuring maximum affordability to the local consumer.
2.38 We maintain that there is deficiency in both convenience and comparison retailing within the Motherwell catchment, which the proposal would seek to address.
Sequential Approach
Comment C3
2.39 The Council have sought clarity on why a site known as ‘Brandon Parade East‘ was not identified within the sequential approach undertaken by Sainsbury’s.
ResponseR3
2.40 Turley Associates sent an RA scoping report to North Lanarkshire Council on 17‘h May 201 1, which was then followed up on a number of occasions regarding sites to be reviewed as part of the sequential approach. The sites agreed to be reviewed are those noted within Section 6 of the RA and repeated below:
Former Dalziel Workspace site
0 Former Asda, Brandon Street
0 Council Buildings, Park Street
0 Ravenscraig
2.41 The reasoning for discounting each of the sites on suitability or availability grounds is clearly outlined within the RA and still stands. Turley Associates, at the time, were not made aware of any potential site fronting ‘Brandon Parade East’.
2.42 We are now aware of the commentary made by Montagu Evans (ME) and Douglas Stevens (DS) on behalf of their client@), but to date have not received any development particulars on the site in question nor detail on the overall deliverability of a supermarket on this site within a reasonable time period (eg. three years)
2.43 Having investigated further, we consider that the aforementioned agents are referring to the termination of all lease agreements for units fronting Brandon
10 TURLEYAS SOCIATES Parade East; demolishing the units in question; and connecting this land with the public car park to the rear which in itself has a number of development issues.
2.44 A review of the site gives rise to significant availability and suitability concerns, in particular:
No evidence on the type of ownership/lease agreements in place for the existing retail units. Therefore, there is uncertainty on the availability of the lands for any future supermarket development.
The site is not large enough to accommodate the proposed development in its current form. A key sequential test as confirmed by a recent Supreme Court (SC) (Tesco v Dundee City Council, UKSC 13) decision. The key extract (para. 38&39) of this decision reads:
The words “the proposal” which appear in the third and fifth of the list of the criteria which must be satisfied serve to reinforce the point that the whole exercise is directed to what the developer is proposing, not some other proposal which the planning authority might seek to substitute for it which is for something less than that sought by the developer. It is worth noting too that the phrase “no suitable site is available” appears in Policy 46 of the local plan relating fo commercial developments. Here too the context indicates that 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 to which Lord Reed refers in para 28, above, 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 doing so.
For these reasons which I add merely as a footnote I agree with Lord Reed, for all the reasons he gives, that this appeal should be dismissed. I would afirm the Second Division’s interlocutor.
The scale of development on this site is compromised by the fact that the usable area within the site is significantly smaller than the site boundary suggests, largely due to the site topography. There is a significant level change from Menteith Road down to the site, meaning that embankments encroach into the developable area. In addition, the triangular form of the site means that it is extremely difficult to make any practical use of some parts of the site, particularly the acute corner to the south-east of the site.
11 TURLEYASSOCIATES The triangular shaped site lies between a railway line, a main road and a part pedestrianised street. Given that opportunities for vehicular access to the site are extremely limited, there would seem to be fundamental conflicts between retailing requirements (store facing car park) and urban desigdplanning requirements (store facing main street). Since the new car park will have to be accessed from the existing vehicular access to the site, it seems impossible to satisfy these competing requirements in a manner which is likely to make a meaningful design contribution to this part of the urban townscape.
As noted above, the site has very limited opportunity for vehicular access due to site topography. Indeed, it is likely that the only sensible solution would be to utilise the existing site access off of Menteith Road for both private and service vehicles. The preference at this location would be to provide a roundabout or signalised access, neither of which could be readily designed to provide sufficient capacity for a supermarket due to topographical constraints and the nearby bridge structure on Menteith Road. Careful consideration would have to be given to both the gradient and geometry of the access road to meet the requirements of delivery vehicles. This is likely to further reduce the developable site area.
Options for providing acceptable level access by non car modes, especially from the east and west are constrained by the site levels in relation to the adjacent road and by the railway line.
The site is unlikely to provide the level of parking which will be required by either Sainsbury’s or North Lanarkshire Council.
The size of the site does not offer any opportunity to include a PFS.
The urban context of the site means that either (a), the supermarket faces onto Brandon Parade East with the back of the store facing the car park; or (b), the store faces the car park with the service yard facing onto Brandon Parade East. Neither of these solutions are likely to be acceptable in retailing terms. Moreover, it seems unlikely that the local authority would be supportive of a scheme which positioned a service yard along a primary pedestrian circulation route. Therefore, in site planning terms, the site is not suited to this use.
Whilst consideration could be given to a raised store (‘store-on-stilts’), this has the same problems as noted above. Even allowing for a raised store with the entrance on Brandon Parade East, this means that shoppers would have to drive under the service yard at the rear of the building to access the undercroft car parking area. It is unlikely that such a proposition would be either
12 TURLEYASSOCIATES commercially viable or practically possible, given the level issues relating to service access. A raised store, at circa 16 metres high is unlikely to be a sensitive insertion into this part of Motherwell and will also have a poor relationship with Brandon Parade East at street level.
2.45 The points raised above therefore provide the reasoning as to why the site in question should be discounted.
Town Centre Health Checks (TCHC)
Comment C4
2.46 The Council note within their representation that they seek further justification on the health of Wishaw and Bellshill Town Centres.
ResponseR4
2.47 As noted previously a RA scoping paper was sent to the Council where the content of the TCHC was made known. Commentary stated that the focus would be on Motherwell Town Centre with some commentary also on the centres of Wishaw and Bellshill. This is considered to have been agreed by the Council.
2.48 The town centres in question were not the focus of the TCHC but were visited together with other secondary centres to gain a greater understanding as to their overall vitality and viability. The TCHC analysis on the overall health of Wishaw and Bellshill Town Centres is outlined below.
Wishaw
2.49 Wishaw Town Centre falls within ‘Zone 2’ of the catchment to the south of Motherwell. It plays a largely local role in terms of shopping provision. Commentary is provided within the report on the wide range of retail provision within the town centre and that it has strong levels of accessibility. It is noted as having a robust health, based on a site visit to the centre, but it is also recognised that it is in need of further investment. It is also noted that the centre would possible benefit from consolidation. In short, we believe the centre is robust in terms of health as:
0 Given the local catchment the centre has variety of retail, service and leisure uses present
13 TU RLEY AS S QCIATES 0 It has a good mix of national and independent retailers present which is further supported by the Tesco and Morrisons supermarkets
0 It has good levels of footfall in the core retail area with the role of secondary retail areas in need of review
It has good accessibility by modes other than the private car.
2.50 It is not known whether the Council will undertake a TCHC for Wishaw and Bellshill, but ultimately it will be for the authority to determine the health of these centres and the significance of the impact associated with the proposed development.
2.51 The test for the Council is to assess the level of impact created by the proposal against the overall health of the town centre. In this case, the test relates to the town centre as whole and the level of impact for goods combined. Model Table 14 of the Sainsbury’s RA shows the relevant combined impact on Wishaw Town Centre to be 2.52%. This is not considered to be significant and will not threaten the vitality and viability of the centre.
Bellshill
2.52 Bellshill Town Centre is significantly smaller than Wishaw, but unlike Wishaw has the two main supermarkets of Tesco and Morrisons within its boundary. The more compact nature of this centre appears to be to its advantage and is more in line with the demand place upon it by the local population. While a detailed health check has not been undertaken a site visit to the centre leads us to believe that it would score more highly than Wishaw when tested against the relevant health check indicators.
2.53 The centre falls within ‘Zone 4’ to the north of Motherwell and like Wishaw plays a largely local role in terms of shopping provision. Commentary within the RA noted the range of retail provision including: Tesco, Morrisons, M&Co, Boots etc which is further complemented by local independents. The centre has strong levels of accessibility with only limited vacancies witnessed. Strong footfall was also witnessed within the core retail area (Main Street).
2.54 It is noted as being a healthy centre given its scale and purpose. In short we believe the centre:
0 Has a good variety of retail, service and leisure uses
Has a good mix of national and independent retailers
14 TURLEYASSOCIATES 0 Has good levels of footfall in the core retail area
0 Has a relatively low vacancy rate
0 Has good accessibility by modes other than the private car.
2.55 It is not understood whether the Council will undertake a TCHC for Bellshill but ultimately it will be for the authority to determine the health of these centres and the significance of the impact created by the proposed development.
2.56 The test for the Council is to assess the level of impact created by the proposal against the overall health of the town centre. In this case the test relates to the town centre as whole and the level of impact for goods combined. Model Table 14 of the RIA shows the relevant combined impact on Bellshill Town Centre to be 6.89%.
2.57 The primary reasoning for the impact being greater than Wishaw, despite it being smaller, is because the two Bellshill supermarkets are classified within the town centre. It is questionable whether these destinations, in particular Tesco, are perceived to be located within the town centre as there is little interconnectivity between the store and Main Street. Morrisons occupies a similar freestanding position. If the two supermarket where to be excluded from the town centre the impact would reduce to 2.26%. Neither of the impacts noted are significant and will in no way threaten the vitality and viability of the centre.
15 TURLEYASSOCIATES 3. Glasgow and Clyde Valley Strategic Development Planning Authority (GCVSDPA)
3.1 The comments from the Strategic Development Plan Manager are contained in a letter dated 17’ February 2012 and relate to the following main areas: interpretation of the Proposed Strategic Development plan (SDP Proposed Plan), and, in terms of the retail assessment, trade draw, growth rates, turnover values, trade diversion assumptions and finally, impact.
Strategic Development Plan
Comment C5
3.2 Interpretation of SDP Proposed Plan. The comment is made on the basis that paragraph 3.25 of the retail assessment is not a proper interpretation of the Proposed Plan.
Response R5
3.3 This matter is addressed in the submitted PS (December 201 1). In summary our response is:
Bellshill is not identified as a strategic centre in the Proposed SDP, unlike Motherwell, Ravenscraig and Wishaw. This must mean that Bellshill has a different and lesser role as a centre than these other three centres and reduces its relative importance in the Network of Centres generally. It is not really a matter open to interpretation.
0 The Proposed SDP accepts the ‘extended timescales for delivery’ for Ravenscraig where it sets out in a Table the role and function of the strategic centres.
0 The same table also recognises that ‘retail contraction’ is a challenge facing Wishaw and Motherwell that warrants action to diversify their roles. This can mean looking at displacing retail and / or looking at uses other than retail.
3.4 Since the planning application was submitted the Reporters have completed their examination of the Glasgow Proposed Strategic Development Plan and have issued their recommendations to Scottish Ministers. The Reporters’ findings and recommendations to Ministers do not change our views.
16 TURLEYASSOCIATES Retail Assessment
3.5 The relevant response to the retail matters raised by the GCVSDPA has been addressed elsewhere in this report.
17
TU RLEYAS SOC l ATES 4. Dundas & Wilson / ASDA Stores Ltd
4.1 Dundas and Wilson (D&W) lodged an objection to the above proposal on behalf of their client, ASDA Stores Limited, on 6* March 2012. The objection can be categorised under the following headings:
0 Rationale for Proposed Development
0 Town Centre Health Checks
0 Retail Capacity & Impact
0 Sequential Assessment
0 Impact on Residential Amenity
4.2 ASDA has a dominant role locally. It commands a significant convenience market share of some 79% with regard to Motherwell (Zone 1). Retailers will always seek to protect their market share and ASDAs objection must be viewed against this background. Comments that have been raised, together with the relevant responses are outlined below.
Rationale for Proposed Development
Comment C6
4.3 D&W has questioned the accuracy of the surveys which informed the quantitative analysis.
Response R6
4.4 The surveys used to inform the retail model where undertaken by NEMs, an independent market research company. The results provided by the company reflect the responses provided to them by the residents interviewed. The analysis and sample size gained is completely statistically robust. D&W have provided generic commentary on the validity of the quantitative analysis with no evidence to counter the conclusions being made.
18 TURLEYASSOCIATES Comment C7
4.5 D&W reiterate that ASDA is within Motherwell Town Centre and that it is considered a significant anchor with strong benefits to the town centre.
Response R7
4.6 We do not consider that the ASDA store acts as crucial anchor to Motherwell Town Centre. We believe that the Primark store is the key anchor tenant in this centre. ASDA previous premises on Brandon Parade would have also been considered a key anchor as it was situated within the core retail area and attracted consumers to the shopping streets within the inner ring road.
4.7 The current ASDA store does not do that as it is located on the opposite side of the main ring road with very poor pedestrian connectivity between it and the core retail area. One of the main reasons for the movement of the ASDA store will have been to ensure that the consumer can enter and leave the site more easily by car. There is little to no encouragement for consumers to link their shopping trip with the store. This is demonstrated in the orientation of the building facing away from what is considered to be the ’traditional’ Motherwell Town Centre.
4.8 While we recognise that the ASDA store has been allocated within the town centre boundary the reality is that the store does not function as part of Motherwell Town Centre and provides little spin-off benefit to the other retailers within the centre.
4.9 The survey analysis has shown (refer to Appendix 1 survey cross tabulation) that of those that visit the ASDA store for main food shopping 78% do not combine this with a trip to Motherwell Town Centre. The results of the same question but this time for top-up food shopping shows that 86% of those interviewed do not combine their trip to ASDA with other shopping in Motherwell Town Centre.
4.10 This level of response would typically be expected from an out-of-centre supermarket and, as such, provides the evidence to demonstrate that ASDA does not play a key role in the vitality of Motherwell Town Centre.
Comment C8
4.11 D&W note that Sainsbury’s have entirely relied upon the household survey to ascertain ‘actual’ turnover levels and that this should not be relied upon in determining the application.
19 TURLEYASSOCIATES Response R8
4.12 One is a little confused as to what D&W suggest as being the more accurate alternative to ascertaining the likely turnover of this store?
4.13 The quantitative analysis has identified the level of available expenditure within the catchment and using the surveys of local consumers shown where those people are undertaking their convenience and comparison shopping. If the expenditure is not being directed to ASDA it would simply mean that it would be flowing to another destination. However, given the lack of choice within the Motherwell area we believe the survey results to be accurate and robust.
4.14 Further commentary on this issue has been addressed previously (refer to R2).
Comment C9
4.15 D&W note that the level of impact on the ASDA store will be significant and will have concerning implications for Motherwell Town Centre as a whole.
Response R9
4.16 In relation to the impact on ASDA and the proposition that an ‘actual’ impact of 23% is significant and unacceptable, we would make a number of observations. The first would be to note the ‘combined’ / ‘actual’ impact. The impact as shown within Model Table 14 is some 15%, which rises to 21% taking account of committed development (that may or may not come forward by the design year).
4.17 The residual ‘actual’ (combined) turnover of the ASDA is some f54.96 million even after accounting for committed development. This compares with the store’s ‘benchmark’ turnover of some f54.84 million. In effect, the proposed Sainsbury’s is diverting the level of turnover that is considered to be ‘overtrading’ within the ASDA store, at the design year (2015).
4.18 The test in understanding the significance of the proposal’s impact is not on individual retailers but the overall impact on the town centre (refer to SPP2010, para. 64). In this regard Model Table 22 (accounting for commitments) denotes a town centre ‘actual’ impact of some 12% with residual turnover levels continuing to be above the relevant ’benchmark’ turnover level for Motherwell Town Centre. It is therefore believed that the proposal will not have a significant impact on the town centre nor the ASDA store.
20 TURLEYAS SOC IATES 4.19 D&W imply that the impact on the ASDA store is the same as that on Motherwell Town Centre as a whole. This is not the case. The impact on the town centre as a whole is significantly less than that on the ASDA store.
Comment C 7 0
4.20 D&W assert that national policy should not support competition and choice created by retail provision found beyond the town centre.
Response R70
4.21 We disagree with the comment being made by D&W. It fails to take into account the general principles of why competition and choice should be encouraged in every local area (so long as it does not significantly damage town centres).
4.22 As we have shown in our sequential assessment and R3 above there are no sites currently available or suitable to provide the appropriate competition to the dominant ASDA store and therefore sites beyond the town centre must be considered. We believe that ASDA will have left their previous store on Brandon Parade as part of responding to this very point (ie. growing dominance of large supermarkets in Hamilton).
4.23 SPP2010 advocates that local retail deficiencies must be met by the development plan but in no way states that this would fail to be the case should the appropriate competition not fall within a town centre location. The comment being made by D&W is therefore unfounded.
Town Centre Health Checks
Comment C7 7
4.24 D&W raise issue with regard to the overall health of Motherwell and other centres located beyond. Cross reference is also made to comments by the GCVSDPA on the role of these centres.
Response R7 7
4.25 The majority of the response to the points raised has been addressed previously in R4 and R5. The renewal of Motherwell and Wishaw Town Centres is for those with the relevant ownership rights. Significant investment in the public realm is already taking place in the centres such as Motherwell as is investment in smaller sites,
21 TURLEYASSOCIATES such as, the Dalziel Workspace site and the former ASDA on Brandon Parade South.
4.26 This appropriate investment will continue even with the proposed Sainsbury’s supermarket in place.
4.27 Contrary to D&W assertions, there is no part of the PS or RA that states that the proposal is justified on the basis of planned contraction within some of the catchment town centres. This has not been suggested by Turley Associates in the documents produced. The proposal is justified against the tests set out within the relevant planning policies, which have been addressed in detail both within the PS, RA and this response.
Retail Capacity & Impact
Comment C72
4.28 Within D&W ‘Adverse Town Centre Impacts’section there is an attempt to replicate the retail model to support the critique of the quantitative analysis.
Response RI2
4.29 We would like to make clear that the D&W preamble reviews the ‘combined’ impacts on identified town centres, as SPP2010 requires, but then alters the figures to highlight the ‘convenience’ impacts not a continuation of the ‘combined’ impacts on the town centres in question. Therefore a ‘like for like’ overview is not being reported by D&W in their statement.
4.30 In relation to their comment on Table 18 of the RA, this table provides a simple overview of the findings. Indeed, ASDA has been extracted from the town centre to demonstrate the difference in terms of impact on the proposal’s main competitor and to that of the remainder of the ‘traditional’ town centre. That said the table still concludes by combining the two and shows that the ‘combined’ impact on the denoted town centre.
4.31 D&W imply that the ‘convenience’ impact on the stand alone ASDA store is the same as the impact on the town centre as whole. This is inaccurate as D&W do not highlight the ‘combined’ impact, but focus on the ‘convenience’ impact. The
imDact reDortinaI is therefore flawed and not reflective of Dolicv reauirements.
22 TURLEYASSOCIATES 4.32 As Table 18 shows, the ‘combined’ impact on Motherwell Town Centre is some 9%, with all other centre impacts falling below this level. No impact is considered significant, including the impact on the ASDA store.
4.33 The assertion that the impacts on ASDA are going to seriously risk the viability of small local retailers in places such as Wishaw is without foundation in our view.
4.34 D&W support their comment by noting that the Wishaw local shops would lose a quarter of their business (under sensitivity 2 tests). This statement is once again inaccurate and not focused on the tests required by retail planning policy.
4.35 Reference to Model Table ST 22 shows that the ‘combined’ town centre turnover of Wishaw is some f49.24 million, which then reduces to f47.59 million as a result of the proposed development and commitments (if built out by the design year). This is a reduction of some f1.64 million or 3% of the town centre’s turnover. We do not consider this impact to be unsustainable.
4.36 We also do not accept the comments made on the significance of impact on individual retailers. D&W raise the example of the Co-op in Holytown/New Stevenson. If one refers to Model Table ST22 (which is considered the worst case scenario) in relation to this store it can be seen that it has ‘combined’ turnover of f1.87 million, which is some f0.63 million above its’ identified trading ‘benchmark’ (f1.24 million).
4.37 Of this it is estimated that the proposed Sainsbury’s would divert f0.20 million (which falls within the confines of turnover above ‘benchmark’). The ‘actual’ impact stands at some 11%. The analysis then factors in the committed development and shows that the turnover of the store reduces to f1.48 million. In total, the diversion stands at f0.39 million or 21% in ‘actual’ terms, but it should be noted that the residual turnover of this store is some f0.24 million above the operator’s ‘benchmark’ of f1.24 million. This therefore provides comfort that the impact is not significant. The same goes for the impact on other retailers within identified local centres.
4.38 In relation to the comment that the turnover ratio for the small supermarket at Bell Quadrant is not sourced (and is too low), we would clarify that the figure was sourced from the RIA undertaken in support of the proposal. Moreover, the location and scale of this store means that it is likely to lend itself to a more discount or local retail operator (eg. Aldi / Spar / Co-op). The turnover ratio of these supermarkets is likely to be in the region of f3,500to f6,000 per sqm. As such, the rate quoted is considered more than robust in reflecting the likely turnover level.
23 TURLEY AS SOCIATES 4.39 Similarly, with regard to the Ravenscraig proposal, the source of the turnover ratio for this proposal has been based on the supporting RIA. Moreover, the prospect of this proposal coming forward by the design year is low. This proposal is designed to serve the Ravenscraig area only. The analysis undertaken by Sainsbury’s has taken into consideration the entire proposal but not all the housing it seeks to serve. Therefore it should be recognised that all the available expenditure created by new housing within Ravenscraig has not been factored into the analvsis. The impacts noted therefore are likely to be an over estimate.
4.40 Table 4 below outlines the turnover of the town/local centres in question together with the level of diversion/impact caused by the proposed development. The information denoted has been extracted from Model Table 14.
Table 4: Town Centre Impact
Motherwel I f 158.45m f 14.13m I 9%
Wishaw f49.24m f 1.24m I 3%
HolytownlN Stevenson f6.85m 40.20m 13%
Bellshill 1 f106.46m f 7.34m I 7%
Uddingston f2.59m €Om 10%
Blantyre f58.63m f 1.57m I 3%
I Hamilton I f283.70m I €6.67ml2%
Larkhall f32.92 f0.79m 12%
4.41 Table 4 quite clearly shows the level of diversion that the proposal will have on identified town centres within the catchment. No one impact can be considered as being significant or a threat to the vitality and viability of that centre.
24 TURLEYASSOCIAPES 4.42 The analysis to justify the scale of the proposal is fully documented. In relation to planning policy, support is given to out of centre stores where it can be demonstrated that the sequential approach has been met and that no significant impact will be caused to identified town centres. The proposal has addressed these two key tests asked of it.
Comment C13
4.43 D&W consider the scale of the proposal to be excessive.
Response R13
4.44 The RA in support of the Sainsbury’s store has demonstrated that it is justified in relation to its scale. In addition, the need to be of a scale to trade alongside the main competition stands as a valid one. A smaller store would not be attractive as one providing a wider range of goods and therefore would mean it more difficult to attract or spread custom in order to reduce overtrading and uncomfortable shopping environments witnessed at the ASDA and Tesco stores.
Comment C14
4.45 D&W believe that the capacity highlighted within the RA does not exist and that overtrading is unsubstantiated.
Response R14
4.46 We have provided the relevant response to this comment within R1 above. The analysis identifies the level of available expenditure and relates this to where it flows in the form of turnover. The identified ‘overtrading’ and ‘leakage’ then enables a clearer picture on the level of deficiency or capacity within the identified catchment.
4.47 The RA shows retailers that are both overtrading and under-trading when related to their defined benchmark, so we are unclear as to D&Ws view that Table 14 of the retail model distorts the analysis to indicate that all retailers are overtrading. This once again fails to take consideration the full facts of the catchment’s trading characteristics and what will and will not be affected by this proposal.
4.48 A significant number of retailers within the catchment will be unaffected by the proposed development due to lack of similarity of offer or due to other factors such as distance. We emphasise that any overtrading denoted by the retail model is
25 TURLEYASSOCIATES substantiated by the use of the detailed and independent household shopper surveys. ASDA has not provided any other evidence that would be considered more accurate than the analysis undertaken and presented by Turley Associates.
Sequential Assessment
Comment C15
4.49 D&W make a comment under the heading of 'Sensitivity Analysis' that states there should be consideration of the former ASDA building on Brandon Parade South and other centres within the catchment.
Response R15
4.50 The sequential assessment within the RA has addressed the reasoning as to why the site that ASDA vacated was not sequentially preferable. One unit is currently leased to Home Bargains with our understanding being that the remaining unit is about to be taken up by a furniture and electrical retailer.
4.51 The focus of locating the proposed store is on Motherwell not any other location. Notwithstanding this, visits to all the relevant centres within the catchment had been undertaken and we are confident that no sequentially preferable site, that could accommodate the proposed development, exists within those centres.
4.52 While there is an extensive catchment outlined for this assessment, not all of it has a relationship with the proposed development. As explained within the RA, the reason for the extensive catchment was to ensure the analysis picked up a complete picture of those that may look to Motherwell for their shopping needs. A significant proportion of the catchment does not interact with the Motherwell area, as shown within the expenditure flow analysis.
Impact on Residential Amenity
Comment Cl6
4.53 D&W assert that the proposal will have a detrimental impact on residential amenity.
26 TURLEYASSOCIATES Response R16
4.54 This matter has been addressed in supporting documents and summarised in the planning statement, Design and Access Statement and Noise Impact Assessment. Planning policy seeks that supermarkets are convenient to where people live in order to reduce unsustainable travel patterns. Supermarket development within close proximity to residential dwellings is to be supported in principle.
4.55 We do not accept that the proposal is incompatible with its setting. For example, the site was formerly used as an industrial I bus depot and, as such, the proposal represents an improvement on previous uses for the site.
4.56 Extensive consultation and technical work has been undertaken by Sainsbury’s to fully understand any development constraints and to ensure that the proposal ‘fits’ within the area it is set. This has resulted in amendments to the proposal as described in the planning statement. Many of these were in response to residential amenity concerns including the relocation of the store and service yard from the eastern edge to the western side of the site.
4.57 Sainsbury’s has also agreed to further enhance the rear elevation of the store in order to subscribe to the desire of a ‘gateway’ building on the site. Beyond this; the development sits lower than the level of Hamilton Road; is separated from residential properties by the existing road network and, with the use of boundary landscaping, will blend sympathetically with its surroundings.
4.58 The Design and Access Statement (DAS), Noise Assessment (NA) and the many other supporting documents lodged with the application provide evidence that the proposed development would not harm the residential amenity of the area.
4.59 The site has been vacant and an ‘eyesore’ to local residents for many years and a great deal of comments made by local people welcome the redevelopment of this long term redundant brownfield site.
4.60 D&W make reference to the Reporter’s examination into the forthcoming local plan. We are aware of the comments made by the Reporter and would point out that the thrust of comments made relate to the lack of supporting documentation (at that time) to allow a supermarket on the site. It does not mean that no supermarket development would be allowed on this site. The Reporter states: in the event that the sequential approach requirements of Scottish Planning Policy could be satisfied, it may be that a retail proposal for the site could be brought forward.
27 TURLEYASSOCIATES 4.61 This evidence has now been provided and demonstrates the acceptability of the development against all key planning policy. No evidence has been provided by D&W to support their comments on residential amenity.
28 TURLEYASSQCIATES 5. Douglas Stevens / Montagu Evans on behalf of Chester Properties / Columbus Capital
5.1 Two separate objection letters have been received on behalf of Chester Properties. We are also aware of the same objector lodging a further objection via the planning portal. We intend treating all three as the one objection by Chester Properties.
5.2 The first letter was made by Montagu Evans (ME) on loth February 2012 on behalf of ‘Chester Properties Asset Management No 3 Ltd’ which provides opinion on how the proposal is considered to be contrary to Development Plan and National Planning Policy. The submission on the planning portal is made by the same consultant and repeats much of what is said in the letter.
5.3 The second letter was made by Douglas Stevens Chartered Surveyors (DS), the joint letting agent for ‘Chester PropertieslColumbus Capital’. Their objection covers more specific operational considerations.
5.4 We will endeavour to minimise repeating any points that have already been stated. We intend to address points made under the following headings:
Contrary to the Development Plan
0 Scottish Planning Policy
Commercial Considerations
Contrary to the Development Plan
Comment C17
5.5 ME, within their letter, cover a variety of topics in relation to the proposal’s compliance with the Development Plan.
Response R17
5.6 The majority of the points are not accepted with our position on how the proposal addresses the relevant planning policies clearly outlined within the PS.
Glasgow and Clyde Valley Structure Plan
5.7 We acknowledge the Structure Plan’s aspiration is to direct investment to town centres, but it must also be acknowledged that it is not always possible to do so. It
29 TURLEYASSOCIATES should be highlighted that there are numerous policies within the Structure Plan that support economic development / inward investment and job creation not just within identified town centres.
5.8 Sainsbury‘s understand the relevant policy tests given that the application site is in an out of centre location. The answers to the relevant Structure Plan tests are provided within Chapter 5 of the PS. When a development is not in a preferred location (eg. town centre) there are then other related policies that require to be addressed. If those tests are met then the proposal cannot be considered as being contrary to the structure or local plan for that matter.
5.9 In relation to the Structure Plan’s retail floorspace requirements we do not believe that the full and up to date position on capacity has been provided. It has not fully considered the ‘actual’ trading patterns of the catchment nor projected forward the relevant capacity to the design year of 2015.
5.10 Beyond this capacity analysis should only ever be used to inform an understanding of the potential deficiency within a specific catchment. Further comment on this has been provided within R1 above.
5.1 1 Commentary on the potential development opportunity at Brandon Parade East and other sequential assessment matters has been detailed within R3 above.
5.12 ME state that the allowance of this proposal would run counter to Strategic Policy 1 as it would adversely impact on the future investment in the town centre. If this were to be believed then North Lanarkshire Council would not have received a number of significant financial offers for their Dalziel Workspace site (with the understanding that this will be become a new Aldi supermarket) and Chester Properties would have not have entered into a lease agreement with regard to the vacant unit at the former ASDA supermarket on Brandon Parade South.
5.13 These town centre transactions have taken place well after the announcement that Sainsbury’s propose a new supermarket on Hamilton Road and assist in drawing the conclusion that the proposal will not significantly impact on future investment in Motherwell Town Centre.
5.14 The proposal seeks to address the needs of Motherwell and the surrounding area. It is important to recognise the shopping characteristics of the area and not just look at the urban area of Motherwell which is being suggested by Montagu Evans in their critique of Schedule G(c)(ii).
5.15 ME’s review is an over simplistic way of assessing the role and purpose of retailing in the area. We would imagine that ME’s client (owners of Brandon Parade) would
30 TURLEYASSOCIATES not limit themselves to attracting expenditure from Motherwell residents only. They, like any other commercial retailer, operate within a market context where competition and choice is to be encouraged within a particular catchment (subject to no significant impacts being caused on identified town centres).
5.16 ME, like D&W, seek to limit the focus of this assessment and ignore the significant levels of overtrading and leakage that currently occurs within the catchment. Simplistic retail capacity studies that do not take account of the ‘actual’ trading characteristics of a catchment should not be given any weight in determining the acceptability of this or any other proposal. This viewpoint is shared in the conclusion of the Scottish Government‘s Retail Methodology paper.
5.17 The overtrading noted is a simple overview of the ‘actual’ turnover of stores, identified by the surveys, against the ‘average’ turnover of the stores in question. The analysis has shown that in some cases, such as ASDA, some of the dominant retailers are trading above that defined ‘average’. This, when taken together with the significant leakage levels, is a sign of local deficiency or need for further retail provision. For ME and D&W to say that Turley Associates has not provided any evidence for this is unfounded as it is clearly outlined within the retail model.
5.18 The applicant’s quantitative analysis is not inflated as being suggested by ME. The analysis has identified the level of available expenditure within the catchment and with the use of the household surveys identified where that expenditure is flowing in ‘actual’ terms. The only inflation involved is rolling the analysis forward from the current to the design year given that the proposal will not be operational for some time. This is standard practice in undertaking quantitative analysis of this nature.
5.19 In relation to qualitative deficiencies it is clear, from speaking with many people that attended the Sainsbury’s exhibitions, that Motherwell lacks choice and competition in terms of main food provision. We are not aware of a detailed qualitative analysis undertaken by the GCVSDPA recently and therefore question ME’S assertions that no qualitative deficiencies exist. The leakage and overtrading identified in both convenience and comparison retailing clearly identifies local retail deficiencies.
5.20 While it is recognised that the proposal is not within Motherwell Town Centre it will attract people back and bring new consumers into the town. The site has strong public transport links between it and the town centre and we are confident that linked trips between the two destinations will occur. Moreover, Sainsbury’s often forge lasting relationships with town centre associations for the overall benefit of the town.
31 TURLEYASSOCIATES 5.21 The assertion that the proposal has not taken into consideration comparison impacts on Motherwell town centre and the product lines that exist is completely unsubstantiated. Numerous visits to Motherwell town centre were undertaken to gauge the level of similarity in product offer and to allow a professional judgement thereafter.
5.22 In relation to the breakdown of Motherwell Town Centre we would refer to Table 5 of the RA which shows that comparison retail units make up less than half (45%) of Motherwell town centre with not all being in direct competition with the proposal.
5.23 The RA does not confirm that there will be a significant impact on town centres as alluded to by ME. What the RA does recognise is that there will be an impact on town centres but that it is well within the realms of acceptability and cannot be considered significant.
5.24 There is recent evidence showing that new transactions/investment continue to take place within Motherwell Town Centre (eg. North Lanarkshire Council public realm improvements, sale of Dalziel House, lease agreement for retail unit at former ASDA etc). The news of potential investment by a major retail operator, such as Sainsbury's, is considered to have boosted confidence in Motherwell as a place in which to do business.
Southern Area Local Plan & Emerging North Lanarkshire Local Plan
Comment C 18
5.25 ME appear to take the position that if a development is not within a town centre then it does not meet retail planning policy outlined by the adopted or forthcoming Local Plan and should be refused. It also asserts the allocation of the site within the emerging Local Plan prohibits retail use.
Response R18
5.26 The assessment of the proposal against local plan policy is contained within the PS. It is recognised that the first preference is to direct retail development to town centres but national and development plan policy also recognise that this is not always possible and other appropriate locations must be considered.
5.27 This is the case with regard to the proposed development. The PS addresses Policy RTL4 of the adopted Local Plan and Policy RTC 3 of the draft Local Plan. We do not intend to repeat what has already been stated within the PS or
32 TURLEYASSOCIATES previously within this response. The proposal has; addressed the sequential approach; demonstrated that local deficiencies exist and that there will be no significant impact on any town centre. These are the key tests asked within local plan policy and to which the proposal complies with.
5.28 We do not accept ME reporting that the Local Plan Reporter has rejected retail development on the subject site. A response has been provided to Policy HCF 1 ‘Residential Amenity’ within the planning statement and RI4 above.
5.29 Sainsbury’s had no involvement in the Examination process and has subsequently provided the necessary evidence to support retail development on the site. Further supporting documentation (eg. Design and Access Statement) also address the relevant residential amenity requirements.
5.30 ME has failed to highlight the Reporter’s comment that in the event that the sequential approach requirements of Scottish Planning Policy could be satisfied, it may be that a retail proposal for the site could be brought forward.
Scottish Planning Policy, 2010 (SPP)
Comment C7 9
5, I ME state that the proposal does not satis,; the relevant sequential assessment criteria outlined by SPP2010.
Response Rl9
5.32 We would stand by our assessment of SPP Policy as outlined within the PS. Contrary to ME assertions the proposal has fully addressed the requirements set down with paragraph 64 and others of SPP2010. No detail has been provided by any of the objectors on the economic benefits of the proposal which is a strong focus of SPP2010 and should not be ignored in the determination of this application.
Commercial Considerations
Comment C20
5.33 DS make a number of commercial and operational points of objection within their letter. Much of these relate to the sequential assessment of town centre sites and comparison impact on the Motherwell Town Centre.
33 TU R LEYAS S 0 C IAT E S Response R2O
5.34 We would respond to the comments by make the following observations:
0 Investment is taking place within Motherwell Town Centre. This has included public realm improvements by the Council and the recent announcement of a retailer taking up a vacant unit at the former ASDA and the recent sale of Dalziel House.
0 The vacant units that currently exist within Motherwell town centre are not of a scale or configuration to attract the main stream comparison retailers.
Vacancies are on par with the UK and like many towns have been the victim of the recent recession.
Any approach made to Sainsbury’s for the Brandon Parade East was after the retailer had entered into a contract with the landowner of the former depot site. This, together with the analysis previously regarding the sequential approach and development potential of the site, is the reason why the site is not suitable and also potentially not available to Sainsbury’s.
DS appear to be using a selection of retailers’ names to support their letter. It is not understand if they have gained the authority to make such comments and indeed if they can be substantiated with proper evidence.
0 It is understood that Aldi are ready to invest in Motherwell Town Centre. Retailers of this nature largely trade side by side with the main stream supermarkets such as Sainsbury’s. This is due to a differing offer being provided. We do not believe that the proposed Sainsbury’s is stopping further investment by Farmfoods and Iceland.
0 The DS interpretation of non-food floorspace within the proposed store is misleading and not to be taken as fact. The focus of this assessment is the sales area and the space from which the products will be sold. The proposed comparison sales floorspace is 1,951 sq.m. Even if one were to account for non-durable goods the ‘non-food’ floorspace would be no more than 2,500sq.m. This is some 1,000sq.m.less than that being propositioned by DS.
0 The non-food floorspace within the proposed Sainsbury’s represents nearly half the Primark Store or 13% of non-food floorspace within Motherwell Town Centre. Their comments on the excessive scale of the non-food offer should, in our opinion, be ignored when testing the proposal against the relevant policy tests.
34 TURLEYASSOCIATES DS appear to quote different levels of non-food floorspace throughout their letter. On differing occasions they note 40% and then 45%. The analysis undertaken within the RA is based on the definition of comparison goods and is 35% of the sales floorspace.
The 4% impact on non-food operators as a whole is considered accurate when one considers not all non-food retail in the town centre will be affected by this proposal. It also takes due cognisance of the scale of the non-food provision in the centre which is extends to some 18,344sq.m.
The economic investment that the proposal will bring to the Motherwell area is a strong material consideration and one that Sainsbury’s seek to deliver.
The accusation that jobs may be lost is again unsubstantiated. Employment levels will increase as a result of the Sainsbury’s proposal. The investment that Sainsbury’s seeks to bring to Motherwell will not go unnoticed and will indeed bolster North Lanarkshire as a strong place in which to invest.
Comparison deficiency within the catchment currently stands in the region of f 152 million which is higher than convenience goods. Motherwell Town Centre cannot meet this demand in full and is the reasoning why it continues to grow and leak to centres such as Hamilton and Glasgow. Appropriate out of centre opportunities should be considered in helping to address the significant non- food deficiencies.
35 TU R LEYA S S 0 C I AT E S 6. Conclusion
6.1 This retail response addresses queries raised by North Lanarkshire Council and the numerous points of objection raised by third parties. It provides clarity on the relevant matters which should be taken into account when coming to a conclusion on the acceptability of the proposal and those that should be ignored due to them not being a clear material consideration. Reference should be made to other documents that accompany the planning application including the planning statement.
6.2 The interpretation of retail impact requires careful consideration not least when related to how it may alter the vitality and viability of a designated town centre. It is important to appreciate that an impact on the turnover of an individual store, whether it is within or outwith the town centre, is not the relevant policy test to determine whether a proposal is acceptable or not.
6.3 The key issue in retail planning terms is the impact which the development will have on the vitality and viability of the town centre as a whole. The assessment has provided an overview of Motherwell Town Centre and others and has shown that all centres will continue to trade well following the identified impacts. It shows a combined ‘actual’ impact on Motherwell Town Centre of some 9% with all other town centre impacts falling well below this level.
6.4 This therefore provides the necessary comfort that the proposed Sainsbury’s store will not have a significant impact upon the vitality and viability of catchment town centres and that it complies with the relevant policy tests outlined within SPP (2010) and the Development Plan.
6.5 The parties that have raised objections to the application have all failed to provide a balanced representation. There is no mention of the positive impacts the proposal would have for the Motherwell area. It is essential that the Council has the full facts prior to making any decision on the application.
6.6 We stand by the acceptability of the proposal. For instance:
0 The household survey undertaken to inform the retail model is accurate as are the findings denoted within the retail model.
0 The identification of how existing stores are trading against their relevant ‘benchmark‘ is wholly acceptable and enables greater judgement on the effect of the ‘actual’ impacts outlined.
36 TURLEYASSQCIATES 0 The qualitative deficiency in retail provision is clear in the current expenditure leakage and overtrading conditions that exist, particularly within the ASDA store in Motherwell. The demand for further competition and choice was outlined strongly by those who were involved in the public consultation exercise.
0 The assessment was conservative and did not account for the increase in demand as a result of new housing and took into consideration development unlikely to be open at the design year (ie. Ravenscraig supermarket).
0 The advocacy of having more stores to create appropriate competition and choice is one that Sainsbury’s promote despite ASDAs and others view on the matter.
0 The diversion from the ASDA store to the Sainsbury’s store will have little to no effect on the trading conditions on the remainder of Motherwell Town Centre. in fact, they are likely to increase as more people get drawn into Motherwell as a result of the first Sainsbury’s in North Lanarkshire.
0 ASDA made a commercial decision to disjoin itself from the ‘traditional’ town centre by relocating to the other side of a busy ring road. While it is accepted that the site falls within the town centre boundary we strongly believe the location and orientation of ASDAs existing supermarket adds little value to those retailers within the core retail area (ie. Brandon Parade).
The level of linked trips between ASDA and the ‘traditional’ town centre are more in line with an out of centre location and provide evidence that it does not play an important role in the vitality of Motherwell Town Centre.
0 Tackles identified qualitative deficiencies in retail provision by being of a scale that increases choice and competition, addresses over-trading levels in some stores and responds to public opinion.
0 The assessment addresses identified quantitative deficiencies in retail provision by primarily redistributing expenditure considered to be leaking beyond Motherwell and overtrading with existing stores.
0 The proposal has shown to comply with the sequential approach as there are no alternative sites in or on the edge of the town centre that are suitable or available in accommodating the proposed development.
0 Sainsbury’s will be capable of co-existing with Motherwell Town Centre and the other secondary town/local centres. Most local impact will be felt by the ASDA
37 TURLEYASSOCIATES Motherwell store which is considered to be trading well in excess of the identified benchmark level.
0 The first Sainsbury’s in North Lanarkshire will assist in attracting new trade to Motherwell and increase the likelihood of associated linked trips with the town centre.
0 The proposal will not impinge on further investment in Motherwell Town Centre as demonstrated by the recent transactions within the centre.
0 Significant local employment opportunities in the construction and operation of the Sainsbury’s store will be created as a result of this development.
0 The proposed development has been assessed and complies with relevant residential amenity I design policies.
0 The proposal has been assessed against relevant planning policy and other material considerations. The evidence provided gives clear reasoning as to why North Lanarkshire Council should support this planning application.
38 TU RLEYAS SOCIATES
48. When you do your main food and grocery shopping do you visit Motherwell Town Centre? Zone Base: Main shoppers at Asda, 1 2 3 4 5 6
Nurn % Num % Num % Nurn % Nurn % Num % Nurn % Base: Main shoppers at Asda, Watson 207 100.0% 142 100.0% 9 100.0% 46 100.0% 2 100.0% 6 100.0% 2 100.0% Street I No 162 78.3% 115 81.0% 6 66.7% 34 73.9% 1 50.0% 4 66.7% 2 100.0% lYes I 44 21.3% 27 19.0% 3 33.3% 11 23.9% 1 50.0% 2 33.3% 0 .O%
Zone Base: Top-up shoppers at Asda, 1 2 3 4 6 7 Watson Street Num % Nurn % Nurn % Num % Num % Num % Nurn % Base: Top-up shoppers at Asda, 63 100.0% 49 100.0% 1 100.0% 10 100.0% 1 100.0% 1 100.0% 1 100.0% Watson Street IN0 54 85.7% 40 81.6% 1 100.0% 10 100.0% 1 100.0% 1 100.0% 1 100.0% IYm I 9 14.3% 9 18.4% 0 .O% 0 .O% 0 .O% 0 .O% 0 .O%