Units 11A & 11B, Roaring Meg Retail Park, Stevenage, Sg1

UNITS 11A & 11B, ROARING MEG RETAIL PARK, STEVENAGE, SG1 1XN

PLANNING AND RETAIL STATEMENT

JANUARY 2021

CONTENTS

1.0 INTRODUCTION…………………………………………………………….3 2.0 THE SITE AND RELEVANT PLANNING HISTORY…………………….5 3.0 THE PROPOSED DEVELOPMENT……………………………………….8 4.0 PLANNING POLICY OVERVIEW………………………………………..10 5.0 RETAIL CONSIDERATIONS……………………………………………..17 6.0 DEVELOPMENT MANAGEMENT CONSIDERATIONS………………36 7.0 SUMMARY AND CONCLUSIONS……………………………………….38

APPENDICES 1 SITE LOCATION PLAN 2 DECISION NOTICE 99/00097/OP 3 STEVENAGE TOWN CENTRE SEQUENTIAL SITES 4 STEVENAGE OLD TOWN SEQUENTIAL SITES 5 MAJOR OPPORTUNITY AREA SITES 6 STEVENAGE TOWN CENTRE VACANT UNITS (NOVEMBER 2019)

1.0 INTRODUCTION

1.1 This Planning and Retail Statement (PRS) has been prepared on behalf of Stevenage Retail Limited (SRL), in relation to proposals at Unit 11A/11B, Roaring Meg Retail Park, Stevenage, SG1 1XN (the Site). The proposals comprise external alterations and reconfiguration of the existing internal mezzanine floorspace within Units 11A/11B and variation of condition 10 of planning permission 99/00097/OP to allow the units to be used for retail sales under Class E(a) of the Town and Country Planning (Use Classes) (Amendment) Regulations 2020.

1.2 The proposed development is to facilitate the relocation of DFS from the existing accommodation at Unit 18 into Unit 11B, and allow the adjoining Unit 11A to be occupied by Sofology, a sister company within the DFS parent company.

1.3 Following the proposed reconfiguration of the floorspace within the two units, the floorspace will be as follows:

Table 1: Proposed floorspace breakdown Unit 11A Unit 11B

Ground Floor 973sqm 983sqm

Mezzanine 743sqm 743sqm

Total (GEA) 1,716sqm 1,726sqm

Combined Total 3,442sqm (GEA)

1.4 The proposals will meet DFS’s current operational requirements for their DFS brand and also address DFS’s parent company requirement for the retailer’s two key fascia, namely DFS and Sofology, to trade from immediately adjoining units.

1.5 The application is submitted further to pre-application discussions with Stevenage Borough Council (the Council) including a meeting with Officers on 18 December 2020.

1.6 The proposals are progressed as two separate planning applications, one application for the reconfiguration and insertion of additional mezzanine floor within Units 11A/11B and the use of the units for retail sales, and separate application for the external alterations to the units, including new entrances and increased double height glazing on the front elevations and side elevation of Unit 11A. This is to facilitate a phased construction process.

1.7 This PRS sets out the scope of the planning application, identifies the key planning issues, and provides an assessment of the proposals against these key issues. The PRS will focus on the acceptability of the development in land use terms, having regards to the relevant policies of the National Planning Policy Framework (NPPF) and Development Plan Policy.

1.8 The application should be read in conjunction with the other supporting application documents as set out in the accompanying covering letter. The remainder of the Statement is structured as follows:  The Application Site and Relevant Planning History – This section provides an overview of the application Site and summarises the relevant planning history at the Retail Park;  The Proposed Development – This section provides an overview of the development proposals. This section also provides an overview of the proposed occupiers, DFS and Sofology;  Relevant Planning Policy – This section identifies the relevant planning policy at a national and local level which the development proposals will be assessed against. At a local level, this includes the Statutory Development Plan for Stevenage, including The Stevenage Borough Local Plan 2011-2031 (May 2019) and the adopted Proposals Map (2019).  Retail Considerations - Sequential test and impact considerations are assessed within this section of the PRS;  Development Management Considerations – the limited development management considerations, focused on highways and design, are set out within this section;  Summary and Conclusions – Finally we provide a brief summary of the key planning issues and provide conclusions of the assessment. We conclude that the proposed development is fully in line with national and local policy and should therefore be considered favourably.

2.0 THE APPLICATION SITE AND PLANNING HISTORY

2.1 The site is located approximately 1km south of Stevenage Town Centre. As such, the retail park occupies an ‘out-of-centre’ location in terms of planning policy. A Site Location Plan is enclosed as Appendix 1.

2.2 Roaring Meg Retail Park is an established retail destination serving the wider Stevenage area. The Retail Park complements the Town Centre’s retail and leisure offer, and is a significant employer in the local area.

2.3 The Retail Park extends to a total of circa 33,000sqm of retail floorspace. It comprises a number of units including shops, restaurants, cafes and hot food takeaways, including Debenhams, Currys PC World, Tapi, Furniture Village and Oak Furnitureland, and a number of restaurant and coffee operators, including Pizza Hut, Costa Coffee and Harvester pub among others. The majority of these uses now fall within new Class E of the Town and Country Planning (Use Classes) (Amendment) Regulations 2020.

2.4 The application Site comprises Units 11A and 11B, extending to 3,070sqm GEA of Class E(d) floorspace in total, split as follows:

Table 2 – Existing floorspace breaddown Unit 11A Unit 11B

Existing Floorspace

Ground Floor 973sqm 983sqm

Mezzanine Floor 625sqm 489sqm

Total 1,598sqm 1,472sqm

Combined 3,070sqm

2.5 DFS currently occupy Unit 18, within the southern part of the Retail Park. The unit extends to 1,712sqm at ground floor and 74sqm at mezzanine floor (a total of 1,786 sqm).

2.6 The use of Units 11A and 11B falls assembly and leisure uses within Use Class E (d), with

Unit 11A currently occupied by TruGym and Unit 11B occupied by Partyman.

2.7 Part of the Retail Park is located within Flood Zone 2 and Flood Zone 3. Units 11A and 11B are located within Flood Zone 2. The proposals result in no change to the overall building footprint and therefore does not give rise to any flood related issues.

Accessibility

2.8 Vehicular, pedestrian and cycle access to the Retail Park forms off London Road and the A606 Monkswood Way. The A606 provides a primary A road, connecting the Site and wider Stevenage to the A1(M).

2.9 Stevenage is also easily accessible from further afield by train, bus and bike. There are two bus stops located along London Road, approximately 100 metres south-west of the units. Roaring Meg Retail Park Stop A and B provide bus services: 44, 45, 301, 378 and 379.

2.10 A network of cycle lanes serve the site and the wider area, with cycle access via a dedicated cycle lane is provided from London Road and Monkswood Way.

Relevant Planning History

2.11 Planning permission was originally granted for the Retail Park in April 1987 (under permission 2/0048/87). The description of development was for:

‘Sub regional durable goods retail warehouse complex, ice rink and leisure unit, residential flat, licensed restaurant, 2 fast food units, community arts centre and car and coach parking facilities, and improvements to water meadow’.

2.12 Units 11A and 11B were subsequently granted permission on 23 November 2000, under planning permission ref. 99/00097/OP, attached as Appendix 2. The description of the approved development is as follows:

'partial redevelopment involving demolition, extension, and new build, improved internal circulation and adjustment of car parking and landscaping'.

2.13 The permission was subject to 13 conditions. Condition 10 relates specifically to Units 11A and 11B and states:

'Prior to the demolition of the existing leisure unit, identified as a sports centre on drawing reference number MJP1, a replacement leisure building of approximately 1944sqm of gross floorspace shall be constructed and made available for occupation, and it shall be used only for assembly and leisure

purposes, in accordance with Class D2 of the Town and Country Planning (Use Classes) Order 1997.'

2.14 Therefore, whilst the existing and proposed uses both fall within Class E, the effect of Condition 10 above is to restrict the use of the units to Class E(d). In other words, were it not for Condition 10, the units could be used for retail sales (and other uses within Class E) without the need for planning permission.

3.0 THE PROPOSED DEVELOPMENT

3.1 The development proposals comprise the variation of condition 10 of planning permission 99/00097/OP which currently restricts the use of the Units 11A and 11B to assembly and leisure uses within Class E(d), the reconfiguration and insertion of additional floorspace at mezzanine floor, and associated external alterations, to allow the unit to be used for Class E(a) retail uses.

3.2 The proposals will facilitate the occupation of the units by DFS and Sofology, furniture and sofa retailers within the DFS group of companies.

3.3 The proposed reconfiguration of the internal floorspace will result in the following breakdown of floorspace within the units:

Table 3: Proposed floorspace breakdown Unit 11A Unit 11B Sofology DFS

Ground Floor 973sqm 983sqm

Mezzanine 743sqm 743sqm

Total (GEA) 1,716sqm 1,726sqm

Combined Total 3,442sqm (GEA)

3.4 The proposals result in a minor increase of floorspace of 372sqm, with the total combined floorspace within Units 11A/11B increasing from 3,070sqm to 3,442sqm GEA.

3.5 The proposed external alterations comprise amendments to the front elevations including increasing the glazing to mezzanine level, additional glazing on the side elevation of Unit 11A, removing the dated portico features and canopies, and introducing new signage zones.

3.6 Additionally, the proposals seek to increase the height of the parapet with metal cladding to match the design of recently refurbished units at the Retail Park. There will be no increase in the height of the roof.

3.7 Further details of the proposed design and materials to be used are included within the Design and Access Statement and application drawings prepared by Mountford Pigott.

The Proposed Occupiers- DFS and Sofology

3.8 Units 11A and 11B are to be occupied by Sofology and DFS respectively. The two prospective retailers are part of the same parent company, DFS Furniture.

3.9 Furniture shopping tends to be a “comparison” shopping trip. When customers are looking to buy a big-ticket item, such as furniture, they will generally shop around comparing different products before making a purchase. For a furniture item like a sofa, this is most likely to be in-store, so customers can try out the product for comfort, fabric choices, etc. For this reason, whilst online sales of furniture is growing, the majority of purchases are still made in-store.

3.10 Typically, furniture retailers, particularly those selling a similar range of goods or complimentary products (such as home furnishings), like to locate close to one another to allow customers to make linked trips (e.g. to view a range of different products offered by different retailers in a single visit). The benefits of these type of retailers locating close to one another goes beyond those for the retailers.

3.11 Given the bulky nature of the products sold, most furniture retailers are located in large format stores in edge or out-of-centre locations. Locating similar retailers close to each other therefore reduces the number of trips customers have to take to ‘test-run’ products prior to making a purchase.

3.12 For DFS and Sofology, which are operated under the same parent company (Sofology as a subsidiary of the DFS Furniture parent company), this co-location strategy has the additional benefit of being able to share resources, such a servicing, where possible. Although under the same parent company, DFS and Sofology generally have different price points and target markets. As such, although there will be a degree of competition between the two stores, they will complement each other, offering greater choice and competition within the local market.

3.13 Currently, DFS and Sofology trade either alongside one another or in close proximity in 25 locations and presently there are plans for a further 20-25 dual locations.

4.0 PLANNING POLICY OVERVIEW

4.1 This section sets out a planning policy overview relevant to the consideration of this pre- application. We consider national policy contained in the National Planning Policy Framework 2019 (NPPF) and the accompanying guidance contained in the Planning Practice Guidance (PPG).

4.2 At a local level, we consider the statutory development plan to include Stevenage Borough Local Plan 2011-2031 (May 2019) and the adopted Proposals Map (2019). The Local Plan forms the part of the Development Plan for Stevenage and replaces the previous District Plan (2004).

National Planning Policy

4.3 The National Planning Policy Framework (NPPF) states that the purpose of the planning system is to contribute to the achievement of sustainable development - performing economic, social and environmental roles. The three roles are interdependent and need to be mutually supported.

4.4 Paragraphs 8-11 confirm that at the heart of the NPPF is a presumption in favour of sustainable development. The planning system should therefore promote sustainable development solutions.

Economic Growth

4.5 Paragraphs 80-82 state that planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. Planning decisions should also recognise the specific locational requirement of different sectors.

Town Centres

4.6 Paragraphs 85-90 of the NPPF seek to ensure the vitality of town centres and requires that planning policy should provide a framework to assess proposals for main town centre uses, such as retail, which cannot be accommodated in or adjacent to town centres. Paragraph 86 requires proposals to demonstrate compliance with the sequential test, and paragraph 89 to demonstrate that the proposals will not have a significantly adverse impact on any designated local centres.

4.7 LPA’s should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. That is to say that main town centre uses should be located in town centres, then in edge of centre locations and only if suitable sites are not available (or expected to become available within a reasonable

period) should out of centre sites be considered. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale, and the sequential test should be considered in light of the latest NPPF policy, which confirms that when considering availability, it is necessary to consider sites which may become available within a reasonable period.

4.8 Details of how this policy should be applied are contained in the NPPF Planning Practice Guidance 2019 as well as relevant Secretary of State decisions, which are explored in more detail later in this Statement.

4.9 The application of the sequential test should be proportionate and appropriate for the given proposal. The following considerations should be taken into account in determining whether a proposal complies with the sequential test (Paragraph 011 of Planning Practice Guidance):

With due regard to the requirement to demonstrate flexibility, has the suitability of more central sites to accommodate the proposal been considered? Where the proposal would be located in an edge of centre or out of centre location, preference should be given to accessible sites that are well connected to the town centre. It is important to set out any associated reasoning clearly.

Is there scope for flexibility in the format and/or scale of the proposal? It is not necessary to demonstrate that a potential town centre or edge of centre site can accommodate precisely the scale and form of development being proposed, but rather to consider what contribution more central sites are able to make individually to accommodate the proposal.

If there are no suitable sequentially preferable locations, the sequential test is passed.

4.10 Paragraph 012 of the PPG guidance further states that the implementation of the sequential test should reflect the specific characteristics of the development proposals:

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

4.11 With regards to retail impact, the PPG confirms:

The impact test only [our emphasis] applies to proposals exceeding 2,500 square metres gross of floorspace unless a different locally appropriate threshold is set by the local

planning authority. In setting a locally appropriate threshold it will be important to consider:  the scale of proposals relative to town centres  the existing viability and vitality of town centres  cumulative effects of recent developments  whether local town centres are vulnerable  likely effects of development on any town centre strategy  impact on any other planned investment

As a guiding principle impact should be assessed on a like-for-like [our emphasis] basis in respect of that particular sector (e.g. it may not be appropriate to compare the impact of an out of centre DIY store with small scale town-centre stores as they would normally not compete directly). Retail uses tend to compete with their most comparable competitive facilities. Conditions may be attached to appropriately control the impact of a particular use.

Transport

4.12 Transport issues should be considered from the earliest stages of development proposals. In assessing specific applications for development, it should be ensured that:

 Appropriate opportunities to promote sustainable transport modes can be taken up, given the type of development and its location;  Safe and suitable access to the site can be achieved for all users; and  Any significant impacts from the development on the transport network or on highway safety can be cost effectively mitigated and acceptable to a degree.

4.13 Paragraph 109 of the NPPF confirms that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

4.14 All developments that will generate significant amounts of movement should be required to provide a Travel Plan and the application should be supported by a transport statement or transport assessment to enable the likely impacts of the proposal to be assessed.

Sustainability

4.15 Paragraph 148 of the NPPF confirms that the planning system should support the transition to a low carbon future in a changing climate, including encouraging the re-use of existing resources, such as the conversion of existing buildings.

Local Planning Policy

4.16 Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that planning applications must be determined in accordance with the Development Plan unless material considerations indicate otherwise.

4.17 The statutory development plan for Stevenage Borough Council consists of the following:

 Stevenage Borough Local Plan 2011-2031 (2019); and  Stevenage Borough Local Plan 2011-2031 Policies Map (2019).

Site Designations

4.18 Figure 1 provides an extract from the Council’s adopted Policies Map (2019).

Figure 1: Extract from Stevenage Borough Local Plan Policies Map (2019)

4.19 As identified from the above policies map the Retail Park is located within a Flood Risk Area. Aside from this, the Site has no specific allocations. The relevant policies are set out below, against which the emerging development proposals should be assessed.

Relevant Local Plan Policies

4.20 Policy SP1 relates to Sustainable Development, and the Council’s positive approach to consider development proposals in favour of sustainable development. This states that the Council will work proactively with applicants to find solutions that will allow proposals to be approved where possible. Additionally, the Council will secure development that improves social, environmental and economic conditions in the area.

4.21 Policy SP4 relates to Stevenage’s Town Centre and retail facilities. The policy states that the Council will make provision for the type and range of retail facilities that are required to support Stevenage’s role, following the sequential test and the Borough's retail hierarchy. The Council seek to maintain the below retail hierarchy:

i. Stevenage Town Centre; ii. High street, Major Centre; iii. Poplars, District Centre; iv. Seven Local Centres; and v. Seven Neighbourhood Centres.

4.22 Chapter 7 of the Local Plan relates to Stevenage’s Town Centre. Policy TC1 identifies the extent of the town centre as defined on the Policies map. For the purposes of paragraph 23 of the NPPF, the town centre is defined as follows:

 The Town Centre Shopping Area (TCSA);  The Southgate Park, Central Core and Station Gateway MOAs in their entirety; and  That part of the Northgate MOA south of Fairlands Way and that part of the Marshgate and Gardens MOA west of St George’s Way.

4.23 Chapter 7 goes on to identify six Major Opportunity Areas within the Stevenage Central Area. These include Southgate Park, Centre West, Station Gateway, Central Core, Northgate and Marshgate. Individual policies are included within the Local Plan for each of these Major Opportunity Areas identifying specific redevelopment requirements for each of the areas.

4.24 Policy TC9 relates to the High Street Shopping Area (HSSA), as defined on the policies map, which encompasses the Old Town High Street. Policy TC10 goes on to identify the High Street Primary and Secondary Frontages, setting out the need for development to benefit the overall vitality and viability of the High Street.

4.25 The Local Plan sets out a number of generic retail policies relating to retail development proposals. Policy TC11 is of particular relevance and refers to provision of new retail floorspace. The policy states that new Class A1 retail floorspace provision will be expected to follow the sequential test and the Borough's retail hierarchy.

4.26 Policy TC13 relates to Retail Impact Assessments. The policy states that proposals for main town centre uses should be located in the Town Centre, then in edge-of-centre locations and only if suitable sites are not available will out-of-centre sites be considered. When considering edge-of-centre and out-of-centre sites, preference will be given to accessible sites that are well connected (preferably by multi-modal means) to the Town Centre.

4.27 An impact assessment will be required for any proposals in excess of 300sqm for main town centre uses outside the Town Centre. This should include an assessment of:

i. The impact of the proposal on existing, committed and planned public and private investment in centres in the catchment area; and

ii. The impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the Town Centre and wider area, up to five years from the time that the application is made. For major schemes, where the full impact will not be realised in five years, the impact should also be assessed up to ten years from the time that the application is made.

4.28 Proposals will be permitted unless they fail the sequential test, or are likely to have a significant adverse impact on one or both of the above factors.

4.29 Reflecting the Site’s out of centre location and that the proposed development is for a retail store, this statement will consider the effect of the development against Policy TC11 and TC13.

Summary of Planning Policy

4.30 In the context of the scale and type of development proposed, it is our opinion that the proposals should be considered against the following:

 Are the proposals for a scale of retail development appropriate? The proposed development is located within an established retail destination, and relates to the re- use of existing commercial units, with the minor increase in mezzanine floorspace. The proposals reflect the specific requirements of the identified operators. The proposals are therefore of an appropriate scale to its location as an established retail destination.

 Is the proposed development appropriate to the character and appearance of the site and the surrounding built environment? The proposed development comprises the refurbishment and upgrade of Units 11A/11B, providing increased double height glazing along the front elevation as well as the side elevation of Unit 11A. The proposed external alterations will modernise the existing units, and will reflect the refurbishment of other retail units at the Retail Park. Therefore we conclude that the proposals are fully compliant in this regard.

 Is the proposed development easily accessible, or capable of being made easily accessible, by a choice of means of transport, including by public transport, walking and cycling? The application site forms part of an existing retail destination that is accessible by bus, walking and cycling as well as by private vehicles. The site benefits from strong cycle path linkages with Stevenage Town Centre, as set out within the enclosed Transport Statement. Therefore, we conclude that the proposals are fully compliant in this regard

 Will the proposals comprise sustainable economic development? The development will deliver an improvement on the existing building, secure the long term occupation of the site, maintain and enhance employment opportunities and generally meet sustainable economic development objectives. Therefore, we conclude that the proposals are compliant in this regard

 Will the proposals have a significant detrimental impact on the vitality and viability of Stevenage Town Centre? The proposal relates to bulky goods furniture and sofa retailers which are typically located in large format retail warehouse units in out of centre locations. There is therefore considered to be limited overlap between the proposals and the retail offer of Stevenage Town Centre. A consideration of impacts of the proposed development is set out within Section 5 of this PRS.

 Are there any sequentially preferable sites? A sequential assessment has been undertaken and is set out within Section 5 of this PRS. The assessment has been undertaken on the basis of the specific occupier-led floorspace and business model requirements, including the specific need for co-location.

5.0 RETAIL CONSIDERATIONS

5.1 This section of the report sets out the considerations relating to the implementation of the sequential and retail impact tests in accordance with national and local planning policy.

The Sequential Test

5.2 This section of the PRS assesses the proposed development against the provisions of Paragraphs 86-87 of the NPPF, namely whether there are sequentially preferable sites that have the potential of accommodating the floorspace associated with the application.

5.3 Paragraph 86 of the NPPF states that Local Planning Authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan. It is important to note that the Units 11A/11B are currently occupied for town centre uses, and the proposal do not therefore introduce additional town centre uses.

5.4 The proposed development comprises a town centre use in an out–of-centre location. This section of the assessment therefore provides an assessment of the sequential test in accordance with the requirements of paragraph 86 of the NPPF.

5.5 We make the following general observations which set the context for this sequential assessment:

 It is intended for Units 11A and 11B to be occupied by Sofology and DFS respectively.  The proposed use of the units as furniture and sofa retailers requires appropriate large format floorplate, with additional mezzanine floorspace at mezzanine level for the display of goods. Mezzanine floors are typically used for the display of goods within room settings and are not as intensively traded as ground floor areas.  Currently, the units are in Class E (d) use. This use is also a Town Centre use that would be subject to the retail NPPF tests (e.g. sequential test).  The proposed reconfigured units will result in two units extending to a total floorspace of 1,716sqm within Unit 11A and 1,726sqm within Unit 11B, including the reconfigured and additional mezzanine floorspace.  The proposed use requires suitable servicing arrangements and an appropriate level of surface level customer car parking.

 The application site forms part of an existing retail park, located within an established retail and leisure destination in Stevenage, serving the wider needs of the local catchment area; and  The proposals will facilitate the occupation of the units by identified occupiers DFS and Sofology. DFS who are already trading Unit 18 at Roaring Meg Retail Park, and it is not therefore a speculative application.

5.6 Furniture retailers, which retail larger household items including sofas, beds and dining room furniture, typically occupy large out-of-centre warehouse units due to the nature of goods they sell, the requirement to display goods in a room setting, and requirements for premises that cannot typically be located within town centres.

5.7 It should be noted that although the proposed units are to be occupied separately by DFS and Sofology, they are operated under the same parent company, DFS Furniture. The proposals are progressed on the basis of the two units trading alongside each other, and the commercial benefits that this will deliver to the parent company. Splitting the two units into separate units in different locations will not satisfy the operator’s requirement for this co-location. The proposals are therefore assessed on the basis of the total floorspace within the two units.

5.8 The Planning Practice Guide makes clear that the Government does not seek the arbitrary subdivision of proposals splitting operations into separate sites beyond the flexibility of a business model. Therefore, individual retailers should not be required to separate the sale of categories of products onto separate sites.

5.9 The approach to disaggregation and suitability of sequential sites has been clarified in a number of Judgements and Secretary of State decisions.

5.10 The Dundee judgement (Tesco Stores Limited v Dundee City Council (Scotland), 21 March 2012), establishes the key principles of site ‘suitability’ in respect of the sequential test. It is important to note that whilst the Dundee case was a Scottish case, the Supreme Court’s decision applies in England as well as Scotland.

5.11 In considering alternative sites as part of the sequential test, Paragraph 20 of the Dundee judgement states that key considerations in assessing the suitability of a sequential site are:

“...whether an alternative site is suitable for the proposed development, not whether the proposed development can be altered or reduced so that it can be made to fit an alternative site”.

5.12 Paragraph 38 of the Dundee judgement goes on to state:

“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”. (our emphasis)

5.13 The findings of the inspector in the consideration of the Rushden Lakes Inquiry (Ref. APP/G2815/V/12/2190175) and proposals for a Next store in Sheffield (Ref. APP/J/4423/A/13/2189893), are also pertinent to the considerations in this instance, in considering disaggregation, the Inspector at the Rushden Lakes Inquiry stated at paragraph 2.68:

“There is no longer any such requirement stated in the NPPF. Had the Government intended to retain disaggregation as a requirement it would and should have explicitly stated this in the NPPF. It is too large a point to rest on implication. If it has been intended to carry on with the requirement then all that would have been required is the addition of the word “disaggregation” at end of NPPF [24]”. (our emphasis)

5.14 In considering the proposals for a Next store in Sheffield, the Inspector stated at paragraph 35:

“What needs to be established is whether an alternative site is suitable for the development proposed, not whether the proposed development can be altered or reduced so that it can be made to fit an alternative site”. (our emphasis)

5.15 These findings are reinforced by the findings of Scunthorpe judgement (Zurich Assurance Limited V North Lincolnshire Council) focusing the considerations of the sequential test on the real world, with corresponding commercial realities to be given due consideration:

“It is important to mark that developers, and planning authorities work in the real world” (our emphasis)

5.16 The implementation of the sequential test was further considered by the Secretary of State for a retail proposal in Tollgate (APP/A1530/W/16/3147039). Paragraph 12.3.20 states:

“The sequential test therefore means that whilst a sequentially preferable site need not be capable of accommodating exactly the same as what is proposed, it must be capable of accommodating development which is closely similar to what is proposed.”

5.17 It is therefore clear that there is no requirement to disaggregate proposals into its smaller constituent parts when implementing the sequential test, and when considering sequential sites, these need to be able to be suitable for the development proposed as a whole, and not an alternative hypothetical smaller version of the proposal.

5.18 The proposed development is based on a clear understanding of the form and size that is required for DFS and Sofology's established business model.

5.19 Any compromises to the retailer’s business model would result in the occupier not being able to fully implement its established retail model, and would result in the retailer not proceeding with the site.

5.20 In considering the sequential test in relation to the development proposals, we would set out the following relevant considerations.

 Format: The scale of the development has been driven by the size of the existing unit and the requirements of both retailers for a large floorplate with appropriate mezzanine floorspace for the display and sale of the occupiers’ full product range. Should the proposed floorspace at the Site be any smaller, it would be unable to accommodate both DFS and Sofology business models, and would therefore have an unacceptable commercial impact on the viability of the stores to operate;

 Parking/Servicing: The proposed use requires appropriate and easily accessible customer car parking ; and

 Location: It is key to the business model of the retailer that the proposed stores should be located where it is accessible to its customer base. Given the nature of the products sold by DFS and Sofology, the store must be served by a range of transport modes, including the private car. It is also important for it to be located close to stores selling similar ranges of goods.

5.21 Units 11A and 11B, to be occupied by Sofology and DFS respectively, will extend to a total of 3,442sqm GEA floorspace (1,716sqm and 1,726sqm).

5.22 To demonstrate flexibility for the purposes of undertaking the sequential test, we have searched for units of between 3,098sqm and 3,786sqm floorspace. This demonstrates a flexible interpretation of the sequential test, with sites 10% smaller and larger than the application site considered as part of the assessment.

5.23 Given that the proposals relate to existing retail units, and the operator’s immediate requirement

to relocate into Units 11A/11B, for a site to be considered genuinely available, it needs to be currently vacant, or be available in the immediate short term. Sites which require redevelopment to facilitate occupation cannot be considered genuinely available in the context of the application proposals.

Stevenage Town Centre – Existing Opportunities

5.24 Stevenage Town Centre is located approximately 1km to the north of the application Site and is the dominant retail centre within the Borough. Located directly north of the Town Centre is Stevenage Old Town, also known as the High Street Shopping Area (HSSA).

5.25 Stevenage Town Centre and Stevenage Old Town therefore represent the appropriate focus for the sequential test given their role and function within the local retail hierarchy, and is consistent with the recently approved proposals at Monkswood Retail Park.

5.26 Given the current Government guidance on the closure of non-essential retail in addition to travel restrictions, for the purposes of this sequential test, a desktop survey has been undertaken. This takes into consideration the findings and the fieldwork undertaken in support of planning application 20/00111/S106 at Monkswood Retail Park.

5.27 The desktop survey identified a total of 21 vacant units within Stevenage Town Centre and 5 vacant units within Stevenage Old Town. The vast majority of these were very small with only 4 vacant units larger than 1,000sqm. The table below identifies the largest vacant sites within the Town Centre and Old Town, as well as other sequential sites assessed below. An overview of the relevant sequential sites is set out below.

5.28 Whilst a number of vacant sites of below 300sqm were identified within Stevenage Town Centre, these have not been included below, given the quantum of floorspace to which the application relates. A plan identifying sites 1-7 is enclosed at Appendix 3 & Appendix 4.

Table 4: Summary of Sequential Survey

Site Address Floorspace

1 Former BHS Store, 7 The Forum, 2,340sqm

2 Former Office Outlet, Unit 11, 1,625sqm (ground floor). Fairlands Way Amenity block mezzanine of 37sqm,

3 Former Waitrose Store, 74 High 1,370sqm (two units with Street – Now split into 2 units floorspace of 758sqm and 612sqm)

4 Park Place, Stevenage, SG1 1DP 1,950sqm (two units of 975sqm)

5 85 - 103 Queensway, Stevenage, Floor space ranging from SG1 1EA 113sqm – 789 sqm

6 SG1 Development Site Up to 151sqm

7 Matalan Retail Park, Danesgate Up to 454sqm

8 Major Opportunity Areas N/A

9 Local / Neighbourhood Centres N/A

1. Former BHS Store – Unit 7, The Forum Shopping Centre

5.29 The unit extends to 2,340sqm across the ground floor (the unit extends across the ground floor only), and was previously occupied by BHS. The store closed on 20th August 2016 and has remained vacant since that time. The store is currently subject of a planning application for its redevelopment for predominantly residential uses (application ref. 19/00647), with a ground floor retail unit.

5.30 The retail element within the proposed application, at circa 520sqm is significantly below the identified minimum floorspace threshold of 3,098sqm and would not therefore be able to accommodate the development proposals.

5.31 The site does not provide immediately adjoining customer car parking, and does not therefore reflect the fundamental business model requirements of the prospective tenants of Units 11A and 11B.

5.32 It is therefore concluded that the unit is not a suitable or genuinely available site for the proposed development, and the vacant unit is dismissed as a sequentially preferable site.

2. Former Office Outlet - Unit 11, Fairlands Way

5.33 Unit 11, Fairlands Way extends to 1,625sqm at ground floor, and a small amenity mezzanine block of circa 37sqm, and was previously occupied by Office Outlet. The store closed in 2019.

5.34 The minimum flexible floorspace threshold of the proposed development is of 3,098sqm, which is significantly greater than the existing floorspace within the former Office Outlet.

5.35 Whilst the unit could be split into two separate units of circa 812sqm at ground floor, this would be circa 15% smaller than the ground floor of Units 11A/11B. Mezzanine cover of over 90% would be needed within each unit to reach the identified minimum floorspace threshold of 3,098sqm within each unit. Whilst a small staff amenity mezzanine floor exists within the unit, it is not clear whether the unit (internal height clearance, building frame etc) is able to facilitate the necessary mezzanine floorspace identified. It is important to note that even with 100% full mezzanine cover (i.e. providing circa a total of 3,250sqm within the unit), this does not provide the quantum of floorspace that is subject of the proposals (3,442sqm).

5.36 Notwithstanding the above, the site provides limited and constrained car parking spaces located around the perimeter as well as the rear of the site, with relatively limited car parking provided at the front of the unit. The unit does not therefore provide convenient customer parking. This is one of a number of factors which has contributed to the unit remaining vacant since the closure of the Office Outlet unit in January 2019.

5.37 The site is located in a stand-alone and isolated position in retail terms, with no other comparison goods retailers in immediate proximity of the site. The location does not provide a sufficient critical mass of retail floorspace to attract sufficient numbers of potential shoppers to this isolated location to be commercially viable to the operators. The proposals subject of the application relate to an established retail park location, where existing occupiers benefit from having a range of retailers, attracting an appropriate customer base.

5.38 The former Office Outlet store is therefore dismissed as a sequentially preferable site on the basis of suitability from a site selection perspective and viability relating to the commercial implications of the prospective tenants trading from a compromised bulky goods retail location.

3. Former Waitrose, 74 & 74A High Street, Stevenage Old Town

5.39 74 & 74A High Street previously extended to a total of 1,370sqm, split between circa 612sqm and 758sqm, was formerly occupied by Waitrose. The store closed on 27th October 2019 and has

remained vacant since. The two units are in two separate ownerships and the marketing particulars confirm that the units are being let separately, with both units previously under offer, and no longer being marketed.

5.40 The development proposals relate to a proposed combined floorspace of 3,442sqm. The former Waitrose Unit, at a combined floorspace of 1,370sqm is significantly small than the floorspace threshold of the proposed development, and can be dismissed on the basis of suitability.

5.41 The former Waitrose store is therefore not considered available as the two units are under offer or suitable for the proposed development and is dismissed as a sequentially preferable site on this basis.

4. Park Place, Stevenage, SG1 1DP

5.42 The retail space at Park Place (planning permission ref. 16/00511/FPM) is divided into two retail blocks of 975sqm each, totalling a combined floorspace of 1,950sqm across the ground floor, with no opportunity to provide mezzanine floorspace.

5.43 The retail units within Park Place fall significantly below the identified minimum floorspace threshold, and the site is therefore dismissed on the basis of suitability.

5. 85 - 103 Queensway, Stevenage, SG1 1EA

5.44 The proposed commercial and retail units 85-103 Queensway associated with planning permission 18/00268/FPM are proposed to be sub-divided into 10 retail units (ranging from Use Class A1-A4) and a gym (Use Class D2) of circa 3,600sqm floorspace.

5.45 These units range in floorspace from 113sqm – 790sqm, and are therefore materially smaller than the identified minimum floorspace threshold of the proposed development of 3,098sqm and can be dismissed as not sequentially preferable site on the basis of suitability and viability.

5.46 Whilst it may be possible to amalgamate the units to satisfy the minimum floorspace threshold of 3,098sqm, this would in effect require the amalgamation of all 10 units, as it is not possible to install mezzanine floors within these units. This would clearly be contrary to the aspirations for the Queensway site, seeking to provide a range of mixed retail, commercial and leisure uses within a range of differently sized units.

5.47 The site cannot therefore be considered as genuinely suitable in the context of the proposals for bulky goods retail floorspace.

6. SG1 Development Site, Town Centre Stevenage

5.48 Planning committee resolved to approve an application (ref. 19/00743/FPM) for the comprehensive mixed use SG1 development in October 2020. The detailed elements of the hybrid planning application include the Phase 1 planning application for Plots A and K.

5.49 Within these two plots 760 residential units and 151sqm of retail/ restaurant (Class A1/A2/A3) floorspace is proposed. The quantum of retail / leisure floorspace within the development is too small to accommodate the proposed development.

5.50 The provision of a large format furniture store would not be consistent with the aspirations for the redevelopment of the site to deliver a high quality mixed use residential led scheme, and the site is not therefore considered suitable or available on this basis.

7. Matalan Site, Danestrete

5.51 The site is located on the corner of Danestrete and Danesgate, to the south of identified primary shopping area. On 19 October 2017 an application for outline permission (ref. 14/00559/OPM) was granted for the demolition of existing buildings and redevelopment of the site for up to 526 residential apartments and commercial units Class A1 (retail) A2 (professional and financial) A3 (restaurant) and A4 (drinking establishments) and A5 (hot food take away) uses.

5.52 A Reserved Matters application (20/00643/RMM) was submitted to the Council in November 2020 and is currently under consideration. The proposals include for 526 residential units and ancillary commercial and community floorspace. The plans show two separate commercial / retail units of 454sqm and 311sqm, and two additional smaller commercial / community units of 210sqm and 137sqm on the ground floor. The proposed retail units within the residential led development are therefore too small to accommodate the development proposals.

5.53 The site is allocated in the Local Plan within Southgate Park Major Opportunity Area Policy TC2. The policy states that planning permission will be granted for “high density Use Class C3 residential units, new multi-storey or basement car parking, new Use Class D1 civic hub, a linear park running east-west parallel to Six Hills Way and a new primary school on the Eastgate car park.”

5.54 The proposal for a large format furniture and sofa retail units would therefore be contrary to the site's allocation included within Policy TC2 for mixed use development.

5.55 The site is therefore dismissed as unavailable and unsuitable.

8. Major Opportunity Areas (MOAs)

5.56 Six MOAs are identified within the Stevenage Central Area, and policies TC3, TC4, TC5, TC6 and TC7 make reference to the provision of new Use Class A1 (now Class E (a) retail uses. Each MOA is assessed in further detail below. A map identifying the opportunity areas is enclosed as Appendix 5.

5.57 Policy TC3 (Centre West MOA) seeks to include the provision of a new 'de minimus (by volume) Use Class A1 shop units', which specifically relates to serving the day-to-day convenience retail needs of the residents of Centre West. On this basis the Centre West MOA cannot be considered a suitable sequentially preferable site.

5.58 Policy TC4 (Station Gateway MOA) includes the provision of new Use Class A1 and A3 restaurant and café uses. The policy sets out the aspirations to significantly regenerate and redevelop the area to act as a quality landmark gateway environment for all rail visitors. Although the policy includes the provision of new Use Class A1 uses, the focus of the MOA is to facilitate the extension and regeneration of the train station, with complementary commercial and leisure use. The proposed large format bulky goods retail uses cannot be considered an appropriate element of the redevelopment of the site, and therefore dismissed on this basis.

5.59 Policy TC5 (Central Core MOA) includes for new Use Class A1, A3, and A4 shop, bar, restaurant and café uses. Specifically, the policy sets out the provision of a southern extension to the Westgate Centre, containing in the order of 4,700m2 additional comparison floorspace, facing onto an enlarged Town Square. The proposals for large format bulky goods floorspace would not be consistent with the aspirations of the policy to improve the retail offer within the Town Centre. The application proposals relate to total bulky retail floorspace of 3,442sqm, representing nearly 75% of the additional comparison floorspace within this MOA. The Central Core MOA is not therefore considered an appropriate sequentially preferable site, and can be dismissed accordingly.

5.60 Policy TC6 (Northgate MOA) includes the provision of new Use Class A1, A3 and A4 uses. The supporting text of Policy TC6 refers to the Tesco Extra Store being dated in terms of external appearance and does not meet the operator’s current format expectations. The MOA therefore includes for the provision of a replacement foodstore. The initial ‘in principle’ discussions with Tesco, as set out within the supporting text of the Policy TC6, suggest that this site is unlikely to come forward until the end of the plan period, transitioning into the post 2031 period. The site is therefore dismissed as a sequentially preferable site on the basis of availability, and the intention to provide a foodstore rather than bulky goods comparison goods on the site.

5.61 Policy TC7 (Marshgate MOA) states planning provision will be granted for new high density residential units, new Use Class D1 and D2 leisure uses, new Use Class A1, A3 and A4 shop, bar, restaurant and cafe uses, in addition to a new multi-storey / basement car park.

5.62 There are currently no timescales associated with the redevelopment of this MOA. Given that the proposals relate to an immediate commercial requirement, the site cannot be considered genuinely available within a reasonable timeframe in this instance.

9. Stevenage 2007 Town Centre Regeneration Development

5.63 On 22 November 2007 an application for outline permission (ref. 07/00810/OP) was submitted to the Council for a comprehensive redevelopment for a mix of uses to include the full range of retail uses (Class A1, A2, A3, A4 and A5), housing (Class C3), hotel (Class C1), leisure (Class D2), offices (Class B1), voluntary services (Class D1), magistrates court, replacement bus station, together with ancillary and associated developments, pedestrian and cycle circulation and open space, car parking, vehicular access, servicing facilities, highway works, plant and machinery, landscaping and enabling works, the demolition of existing buildings and structures, the closure and alteration of highways and cycleways and the internal and external alteration and change of use of buildings to be retained, engineering works and construction of new buildings and structures.

5.64 Planning Committee resolved to grant permission in January 2012, subject to the applicant entering into and completing the S106 Agreement. However, as far as we understand, the development partnership is not progressing with the development. The approved scheme cannot therefore be considered genuinely available for the purposes of this sequential assessment.

10. Local and Neighbourhood Centres

5.65 Policy HC1 of the Local Plan relates to district, local and neighbourhood centres and confirms the borough's 7 Neighbourhood Centres, 7 Local Centres and 1 District Centre as shown on the Council’s policies map.

5.66 Policy SP4 relates to town centres and the Borough's retail hierarchy and allocates 500sqm of convenience floorspace within two Local Centres in the north and west of Stevenage respectively, and 500sqm of convenience floorspace within the Neighbourhood Centre in the south-east of Stevenage.

5.67 The proposals comprise bulky goods furniture and sofa retailers extending to a total of 3,442sqm GEA existing floorspace, and would not therefore satisfy the aspirations for local convenience provision to serve the localised catchments of the local and neighbourhood centres.

5.68 Given the scale and nature of the proposals for large format bulky goods floorspace, it is not considered appropriate to consider local and neighbourhood centres, which focus on top-up shopping provision serving the immediate areas within which the centres are located.

Summary of Sequential Test

5.69 In this section we have considered whether there are any available sites in Stevenage Town Centre which are suitable for the development proposals. The assessment has concluded that there are no suitable, available or viable sequentially preferable sites which can accommodate the development proposals.

5.70 In the absence of any suitable town centre sites, the application site is considered to be an appropriate location for the use proposed by this application. As such, we conclude that the sequential test has been passed.

Town Centre Impact Considerations

5.71 In this section we consider the acceptability of the proposed development against other relevant national and local planning policy, including town centre / retail impact sustainable development, and transport.

5.72 Policy TC13 of the Local Plan requires an assessment of impacts to be undertaken where a proposal for a town centre use over 300sqm is proposed outside of the designated Town Centre. It is important to note from the outset that the proposed development relates to existing units in a town centre use (i.e. former Class D2 now Class E (d)) within an established retail destination. The principle of retail use has therefore been accepted within this location.

5.73 At a principle level, the proposed development will have limited town centre impact implications given the bulky nature of the goods sold and the proposed tenants. The proposals will facilitate the relocation of DFS from their existing accommodation at Unit 18, and also allow for its sister company, Sofology, to trade alongside in the adjoining unit. The proposals will therefore maintain an existing tenant on the retail park, and introduce a new fascia, focusing on the sales of bulky comparison goods.

5.74 Given the particular circumstances of the proposal, the following observations are made:

o The implementation of the impact test will be undertaken on the accepted principle of like affects like, where the proposal would have the largest impact on similar type of retail provision, in accordance with paragraph 15 of the PPG (Reference ID: 2b-015/20190722).

o In this instance, given that the proposals comprise a relocation of DFS and the introduction of only Sofology as a new fascia, this would result in the majority of the impact from the development experienced by other large format furniture and sofa stores, including retailers currently trading at the retail park, including ScS, Furniture Village and Furniture Outlet, as well as the Dunelm store located to the south of the Retail Park.

o Sales densities for the prospective tenant will be derived from Mintel Retail Rankings, an accepted industry source, where available.

o The assessment will set out the anticipated impacts of the proposals on any relevant centres. In this instance, the proposals will focus on Stevenage Town Centre as the relevant designated retail centre.

5.75 In order to understand the potential impact of the proposed development, it is necessary to identify the likely turnover that the proposal will generate. Limited trading information is provided for furniture and sofa retailers within the Mintel Retail Rankings 2020 Report. No sales densities are provided for DFS, whilst a sales density figure of £2,480/sqm is identified for Sofology in 2017/2018. This is broadly consistent with other comparable retailers, such as ScS (£2,475/sqm), Sofa Workshop (£3,781/sqm) and Harveys/Steinhoff (£1,894/sqm) for the same time period.

5.76 To provide a robust assessment, we have therefore assumed the 2017/18 sales density of £2,480/sqm for Sofology, and an average sales density based of the above furniture retailers (i.e. Sofa Workshop, ScS and Harveys/Steinhoff) of £2,717/sqm at 2017/28 for the DFS unit.

5.77 We have adopted a density growth rate of 3.6% in both 2019 and 2.6% 2020, as set out within Table 3b of the Experian Retail Briefing Note 17 (February 2020) with the corresponding average sales subsequently increasing to £2,636/sqm for Unit 11A (Sofology) and £2,888/sqm for Unit 11B (DFS) at 2021.

5.78 It is a generally accepted position that the sales densities of mezzanine floors trade significantly below the company average, as the mezzanine floor areas are typically used for the display of items in larger room settings, and do not therefore trade as intensively as ground floor floorspace. We have therefore assumed that the sales density of mezzanine floorspace will be approximately 50% of the average sales density adopted for the ground floor sales area.

5.79 The estimated turnover of the proposed development is summarised below:

Table 5 – Proposed Estimated Turnover, 2021 Unit 11A – Unit 11B - DFS Sofology Ground Floor Floorspace 973sqm 983sqm

Ground Floor Sales Density £2,636/sqm £2,888/sqm

Mezzanine Floorspace 743sqm 743sqm

Mezzanine Floor Sales £1,318/sqm £1,444/sqm Density Ground Floor Turnover £2.56m £2.84m

Mezzanine Turnover £0.98m £1.07m

Total Turnover £3.54m £3.91m

Combined Turnover £7.46m

5.80 The Council’s Retail Study was prepared in October 2014 by Applied Planning (alongside additional research by CACI). The Study adopts a benchmark sales density of £5,000/sqm for comparison goods floorspace within the Town Centre, and circa £10,000/sqm for convenience goods floorspace. Whilst the Study is out of date with regard to capacity projections, the adopted benchmark sales densities for convenience and comparison floorspace are a reasonable assumption and broadly reflect the turnover that can be anticipated across the convenience and comparison goods sectors.

5.81 The Stevenage Town Centre GOAD Report (December 2018), the most up to date report available for the centre, identifies a total of 32,800sqm comparison goods and circa 14,625sqm convenience floorspace within the Town Centre. Adopting the sales density growth figures set out within ERPBN 17, this therefore equates to a town centre comparison goods turnover of circa £164m at 2018, and increasing to £171m in 2021. This is higher than estimated comparison turnover of the Town Centre set out in the Council’s Retail Study (Table 7 of Applied Planning 2014, Appendix 1), as the comparison goods floorspace has increased from circa 27,000sqm in 2014 to 32,800sqm in 2018.

5.82 The estimated turnover of Stevenage Town Centre convenience goods turnover of £146m at 2018 and decreasing marginally to £144.5m in 2021. The Council’s Study does not provide a

figure for the Town Centre, and includes a number of out of centre superstores within its calculations.

5.83 The anticipated total comparison and convenience goods turnover within Stevenage Town Centre is therefore estimated to be approximately £315m in 2021. This turnover does not include the significant redevelopment proposals that are being brought forward within the Town Centre, which will contribute positively to the overall performance and function of Stevenage Town Centre. The limited scale of the proposals is therefore apparent.

5.84 Assuming a completely unrealistic scenario whereby the whole of the proposed development’s turnover is derived from Stevenage Town Centre, this will have an impact of just 2.4% on the total turnover of the Town Centre, which cannot be considered significantly adverse.

5.85 In reality, the proposed development will not draw all of its trade from the Town Centre, but instead draw trade from large format furniture stores across the catchment, including the retailers already present at Roaring Meg Retail Park, including ScS, Furniture Village and Furniture Outlet, and other furniture retailers serving the Stevenage catchment, including the Dunelm store located to the south of the Retail Park.

5.86 It is anticipated that some 70% of the turnover of the Sofology unit will be drawn from other retailers at Roaring Meg Retail Park, including ScS, Harveys, Furniture Village, Affordable Furniture Outlet and Oak Furnitureland, which all carry sofa ranges.

5.87 Some 10% of the turnover will be drawn by other furniture retailers within Stevenage, such as Dunelm (located in an out of centre location) and to a lesser extent B&M store (located within The Forum). On this basis, given that there are a limited number of large format and sofa retailers within Stevenage Town Centre, the potential impacts of the proposal on Stevenage Town Centre would be 0.24% - assuming that 10% of the draw trade associated with Stevenage will be from town centre locations. This represents a robust assessment of impacts. The identified level of impact cannot be considered materially adverse.

5.88 It is also estimated that 20% of the proposal’s turnover likely to be clawed back from existing furniture and sofa retailers outside of the Stevenage area, with customers now able to undertake heir shopping needs more locally.

5.89 It is important to highlight that the unit is currently occupied by alternative Town Centre uses, which will have a draw on expenditure and consumer spending. Whilst the existing uses relate to leisure based uses and associated expenditure, the proposal will ‘free-up’ this leisure consumer expenditure, which could be diverted to facilities within Stevenage Town Centre, and could therefore result in a positive impact on the performance of the centre.

5.90 The proposal will clearly not have any perceptible impact on the vitality and viability of a well performing and established centre such as Stevenage Town Centre, and will not have any discernible impact on existing shopping patterns by virtue of its limited scale.

Stevenage Town Centre Healthcheck Overview

5.91 The Council’s 2014 Retail Studies prepared by CACI and Applied Planning identified a number of strengths, opportunities as well as potential weaknesses within Stevenage Town Centre.

5.92 The CACI report identified the strengths of Stevenage Town Centre including a low vacancy rate (14.36% at the time of the survey in 2012 against a national average of 12.22% in number of units), good accessibility as well as affluent catchments and worker population within the Town Centre. The identified weaknesses include poor environment and lack of character within parts of the Town Centre.

5.93 The Studies identify St Albans, Milton Keynes and Luton as having a stronger premium and mass market retail and leisure offer which draw shoppers from the localised Stevenage catchment area, whilst Stevenage Town Centre provided a particularly strong value-focused offer.

5.94 The Studies conclude that whilst Stevenage Town Centre has been successful in establishing the value offer, in order to compete with established Town Centre which impact the catchment, such as St Albans and Milton Keynes, the retail and leisure mix should be improved to make Stevenage Town Centre an attractive destination for a wide range of local residents.

Retail Composition & Diversity of Uses

5.95 The retail and service mix of Stevenage Town Centre is set out in Table X below, as derived from the Experian GOAD December 2018 report.

Table 6: Mix of Uses in Stevenage Town Centre (December 2018)

Category Number of % of Total UK Average (%) Units Outlets

Comparison Goods 84 35.75 28.03

Convenience Goods 20 8.51 9.14

Retail Service 27 11.49 15.44

Leisure Service 37 15.74 24.49

Financial & Business 28 11.91 9.42 Service

Vacant Retail & Service 39 16.60 13.26 Outlets

5.96 The table demonstrates a wide and varied mix of services and retail provision within Stevenage Town Centre. The mix of uses reflects the conclusions of the Council’s Retail Study that the leisure service, including food and beverage operators are under-represented against the national average, and that addressing this shortage forms one of the elements for the Council’s long-term strategy for the Town Centre.

Vacancy Rate

5.97 The 2018 Goad Report identified 39 vacant units, reflecting a vacancy rate of 16.6%, against a slightly lower national average of 13.26% at the time of the report. This is marginally higher than the 32 vacant units (amounting to 14.36%) identified within the 2012 Council Study.

5.98 In part, the higher vacancy rate reflects the number of redevelopment sites within which Stevenage Town Centre, requiring site assembly, and the closure of some units to facilitate the wider redevelopment of the site.

5.99 Montagu Evans undertook and assessment of the vacant sites in November 2019. Taking into consideration the site assembly associated with redevelopment of sites within the Town Centre, a total of 21 vacant sites were identified, representing a vacancy rate of 8.4%. This is considered to be a strong vacancy rate.

Multiple and Independent Retail Representation

5.100 The 2018 GOAD report identifies a total of 120 multiple retailers within the Town Centre. Whilst a number of these have since closed, such as the Carphone Warehouse, the centre has maintained a relatively strong national multiple offer.

5.101 Westgate Shopping centre includes a number of national brands, including H&M, The Entertainer, River Island and The Works. The Forum Shopping Centre includes national multiples such as Sports Direct, Next, TK Maxx and Home Bargains.

5.102 Where there have been closures of stores such as Marks and Spencer store in 2015, or the BHS store in 2016, the redevelopment of the sites coming forward to provide a mix of uses and unit sizes which addressing the overall conclusions of the Council’s Retail Study for a need to improve and widen the retail and leisure offer within the Town Centre. The redevelopment of these vacant sites would therefore contribute positively to the overall performance of Stevenage Town Centre, and reflect the long term strategy for the Town Centre.

Public and Private Town Centre Investment

5.103 The Council are currently progressing a number of ambitious and wide ranging regeneration projects within the Town Centre, reflecting the evolving role and function of Town Centres as leisure, residential and retail destination. The Stevenage Better comprises a 20-year programme with an investment of over £1bn into the Town Centre.

5.104 A number of projects have already been completed, including the Park Place development, including over 200 new homes, as well as smaller town centre projects such as at Market Place, providing improved play space and street furniture to make visits to Stevenage more attractive and welcoming, as well as other smaller scale streetscape and public realm improvements.

5.105 A number of significant projects are currently underway, including Queensway North, a mixed use redevelopment of the former Marks and Spencer store. The scheme includes nearly 100 new homes, with a variety of commercial, leisure and retail facilities at ground floor.

5.106 Further projects are due to commence shortly, including the SG1 / Norther Quarter site, comprising over 1,700 new homes, new public space, complementary ground floor retail and restaurant uses and a public services hub.

5.107 There are therefore a number of significant projects being brought forward by the Council in partnership with Mace and Reef Group, which will contribute significantly and positively to the performance and function of Stevenage Town Centre as a mixed use hub, with a significant residential element. The proposals will have no impact on these planned investments.

Summary

5.108 Stevenage Town Centre continuities to be a relatively vital and viable centre, with a good mix of national and independent retailers, with a strong national multiple offer. The Town Centre does

not rely on large format retailing as a contributor to its strong vitality and viability.

5.109 The December 2018 GOAD vacancy rate was slightly above the national average (+3.3%), however, this included a number of sites being assembled for redevelopment, such as Park Place. A more up to date assessment in November 2019 identified a total of 21 vacant units accounting for known development sites, representing a vacancy rate of 8.4%.

5.110 The Council’s strategy for the investment in the Town Centre reflects the findings of the Council’s Retail Studies, which highlight the need for an improved variety in the retail and leisure offer within the Town Centre. The regeneration schemes being progressed by the Council also respond positively to reports such as The Grimsey Review, identifying the need for Town Centres to be mixed use hubs with strong focus on residential accommodation.

6.0 DEVELOPMENT MANAGEMENT CONSIDERATIONS

6.1 In this section we set out an overview of the development management issues. These are considered to be modest, and predominantly focus on design and highways matters. The proposals relate to the repurposing and reconfiguration of existing buildings, and there are therefore limited development management considerations.

Transport and Highways Considerations

6.2 The application is supported by a Transport Statement, prepared by TTP Consulting, which considers the potential impact of the proposals on accessibility and transport issues. The Statement confirms that the Site is accessible by a range of different transport modes, including public transport, private car and by bike.

6.3 In terms of car parking, the proposals do not include any changes to the parking layout or numbers. It is anticipated that there would be a reduced demand for parking during the week associated with the proposals compared with the existing leisure uses, with a potential increase in demand on Saturday afternoon. However it is concluded that the proposals would not materially alter the demand for parking.

6.4 The Statement therefore concludes that the development proposals would not result in a noticeable change on the local or wider highway and transportation network and as such are deemed acceptable in highways and transportation terms.

Socio Economics Benefits

6.5 The proposed development will deliver material socio-economic benefits. The existing tenants are currently on short-term leases, and it is unclear whether the existing occupiers will be able to re-open following the lifting of COVID related restrictions.

6.6 The proposed occupiers will ensure the long term occupation of the two units, delivering significant and secure employment opportunities available to the local community. The proposed development will result in the creation of 6no additional employment opportunities within the Sofology store, and 2 additional positions within the supply chain. Staff within the existing DFS store will transfer to new accommodation at Unit 11B.

6.7 The proposed development will also result in a significant investment into the local economy by way of the external alterations, refurbishment works, and mezzanine works proposed within the two units.

Flood Risk

6.8 The Site is partly located within Flood Zone 2, which indicates having between a 1 in 100 and 1 in 1,000 annual probability of river flooding, with a culvert running to the south-west of the Site. As such, the application is supported by an appropriate Flood Risk Note.

6.9 The Flood Risk Note acknowledges the proposals relate to existing buildings and do not increase the building footprint. Therefore, given that the development will not increase the likelihood of flooding at the Site, it is concluded that a full Flood Risk Assessment is not required to support the application.

Design

6.10 The proposals include alterations to the external façade of the units in order to update and enhance the appearance of the building and bring in line with future occupier requirements.

6.11 The proposals seek to remove the out-dated features of the existing building, including the porticos and canopies to the entrance of the units. Furthermore, the scheme seeks to increase the glazing on the front elevation of the units, as well as side elevation of Unit 11A.

6.12 The parapet is also proposed to be increased in height to align with Unit 4 at the Retail Park.

6.13 Further details on the proposed design, elevation treatment and materials are included within the Design and Access Statement, prepared by Mountford Pigott.

7.0 SUMMARY AND CONCLUSIONS

7.1 This PRS has been prepared in support of an application to vary the prevailing goods condition controlling the use of Units 11A and 11B, alongside associated external alterations, to allow the units to be occupied by national furniture retailers, DFS and Sofology.

7.2 The proposed development will facilitate the relocation of DFS from existing accommodation at Unit 18, to a modern unit with a new mezzanine floor which will meet the operator’s business model requirements. The proposal will also allow Sofology, a sister company within the same retail group, to trade in an immediately adjoining unit, reflecting the retailer’s evolving business model requirements for co-location.

7.3 This PRS has considered the acceptability of the proposal against the relevant policies contained in the NPPF and in local Development Plan policy, and concludes the following:

 The Site is an established out-of-town retail destination in Stevenage;  The proposals are progressed to secure the long term viability of Roaring Meg Retail Park as the premier out of centre retail destination within the Stevenage area, complementing the retail and leisure focus of Stevenage Town Centre.  The proposed development will deliver significant investment into the local economy by way of new employment opportunities, as well as investment into the local economy by way of the repurposing and enhancement works proposed;  Notwithstanding the out-of-centre location of the site, the sequential assessment concludes that there are no sequentially preferable sites within Stevenage Town Centre capable of accommodating the development, and the application site is therefore the most sequentially preferable location.  The proposal will not have any adverse impacts on the performance and vitality and viability of Stevenage Town Centre.  The development presents sustainable development, resulting in the enhancement and occupation of existing retail units, in an accessible location;  The proposal will deliver material socio-economic benefits, by securing the long- term occupation of the two units, providing secure employment opportunities to the local community.  The proposed development is acceptable in all other respects.

7.4 Accordingly, we conclude that the application fully accords with both national and local planning

policy, and should therefore be considered favourably by the Council.

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