West Register (Property Investments) Limited

New Hall Hey Retail Park, Rawtenstall

Planning and Retail Statement

August 2014

Ref: 2014-050

Unit 8 Ashbrook Office Park Longstone Road Heald Green M22 5LB

Tel: 0845 362 8202 Fax: 0870 130 5579 [email protected] www.njlconsulting.co.uk

West Register

New Hall Hey Retail Park, Rawtenstall

Planning and Retail Statement

Prepared by: NL/AP

August 2014

Ref: 2014-050

Authorised for and on behalf NJL Consulting

Unit 8 Ashbrook Office Park Longstone Road Nick Lee Heald Green Director M22 5LB

Tel: 0845 362 8202 This report takes into account the particular instructions and requirements of Fax: 0870 130 5579 our client. It is not intended for and should not be relied upon by any third [email protected] party. Any such party relies on this report at their own risk. www.njlconsulting.co.uk © Report copyright of NJL Consulting

New Hall Hey Planning and Retail Statement

Contents

1.0 Introduction ...... 1 2.0 The Site And Its Surroundings ...... 2 3.0 The Proposed Development ...... 4 4.0 The National Planning Policy Framework ...... 7 5.0 The Retail Context ...... 9 6.0 Sequential Site Assessment ...... 11 7.0 Retail Impact Assessment ...... 15 8.0 A Sustainable Development ...... 31 9.0 Conclusions ...... 33

Appendices

Appendix 1: Compliance with Development Plan Policies

Appendix 2: Compliance with Supplementary Guidance

Appendix 3: Catchment Area Plan

Appendix 4: Sequential Site Assessment

Appendix 5: Retail Impact Assessment Tables

Appendix 6: Historic Marketing Details

Reference 2014-050 New Hall Hey Retail Park Planning and Retail Statement

1.0 Introduction

1.1 This Planning Retail Statement has been prepared by NJL Consulting on behalf of West (Property Investments) Limited (West Register) in support of an application to vary and remove conditions attached to planning permission ref: 2007/090 for New Hall Hey Retail Park in Rawtenstall in order to broaden the range of goods that the Retail Park can trade.

1.2 This Statement intends to summarise the nature of the site and the proposed development, its compliance with local and national planning policy, and the need for the proposals.

1.3 Also submitted in support of this application are:

 Transport Assessment prepared by Curtin’s.

1.4 The following drawings have also been submitted in support of the application:

 Site Location Plan (Drawing no: 9447 PL 04 A).

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2.0 The Site And Its Surroundings

The Site

2.1 The application site comprises an existing parade of retail warehouse units at New Hall Hey in Rawtenstall, known as New Hall Hey Retail Park. The parade is split into three units and the site also includes a purpose built car park to the front and HGV servicing area to the rear. The units were constructed in August 2010 and have remained vacant since this time. They comprise 3,817 sq.m gross at ground floor level.

2.2 The site is located 700m to the south west of Rawtenstall Town centre. It is bound by the A682 to the north to the south lies the New Hall Hey mixed use area.

Surrounding Uses

2.3 The New Hall Hey Retail Park sits within the New Hall Hey mixed use area. To the south of the site is a public house and to the west is the New Hall Hey Business Village. Within the wider area is the New Hall Hey Business Centre and Rawtenstall train station.

The Planning History

2.4 The New Hall Hey site has a complex planning history. Set out below is the planning history specifically in relation to the New Hall Hey Retail Park but it does not address the planning history for the wider site.

2.5 Planning permission for the Retail Park was obtained through planning permission ref: 2007/030 for ‘Erection of 3 retail units measuring 3358 sq.m, 1412 sq.m and 1412 sq.m’. This permission includes a number of conditions which impose controls on the range of goods that can be sold from the Retail Park:

1. Condition 3 only permits Units 1A and 2A to be used for the sale of home improvement and garden related products, furniture, floor coverings, soft furnishings, electrical products, household goods, pets, pet food and pet supplies and ancillary goods.

2. Condition 4 does not permit Unit 4A to sell clothing, other than that normally associated with DIY tasks or if sold by a catalogue retailer, or food and drink for human consumption.

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2.6 The application includes a number of pre-commencement conditions and pre- occupation conditions.

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3.0 The Proposed Development

3.1 This planning application seeks permission under Section 73 of the Town and Country Planning Act 1990 for the variation of the conditions attached to planning permission ref: 2007/030 so that 1,162 sq.m of the gross floorspace (Unit A1) can sell all Class A1 goods, including food, drink and clothing, along with ancillary uses. Permission is also sought to allow the remaining floorspace to be used for the sale of all non-food Class A1 goods and ancillary uses. This relates to Units A2, B and C which comprises 5,026 sq.m of floorspace. 2,655 sq.m of this is a ground floor level and 2,371 sq.m at mezzanine level. This will be achieved through the removal of Conditions 3 and 4 and their replacement with a new condition relating to goods controls.

3.2 This application also proposes to remove all pre-commencement and pre-occupation conditions from the permission, along with conditions that do not impose ongoing controls over the use of the development. This includes Conditions 2, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21 and 22.

3.3 The requirements set out in Conditions 21 and 22 have previously been dealt with through Section 106 Agreements and a new Section 106 Agreement will be negotiated as part of the determination process for this application. This will mean that the new permission that is issued under Section 73 of the Town and Country Planning Act 1990 will only include conditions that impose ongoing controls over the operation of the unit.

3.4 Condition 20 imposes restrictions in the maximum level of retail floorspace and a goods restriction. As the variations to Condition 3 and 4 will include floorspace restrictions and goods restrictions it is no longer necessary to include this Condition and so it requested that it is removed.

Context for the Application Proposals

3.5 New Hall Hey Retail Park was constructed in August 2010 and has remained vacant since this time. It has been a casualty of the recession and the associated troubled retail market.

3.6 Permission was gained for New Hall Hey Retail Park by Hurstwood Developments in 2007. Soon after this time the recession hit and the retail market crashed. This was a difficult time for the retail market, with little investor confidence and companies contracting rather than expanding their portfolios. As a result no initial occupiers were found. Hurstwood Developments went into administration in 2008 for New Hall Hey

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Retail Park. KPMG, as administrators to Hurstwood, were responsible for completing the construction of the Retail Park realised in 2010. KPMG sought out occupiers for the site and several names were publicised, although no occupiers ever entered the scheme.

3.7 Retailers have been trading in difficult market conditions or the past 6 years and the retail market continues to struggle to recover. This has effected retailer acquisition decisions so that they now require a greater degree of flexibility in the range of goods that they can sell, so that they can respond to market conditions, if required. Some of the marketing details that have previously been issued by agents in 2008 and 2012 are at Appendix 6. The site has been marketed separately to these documents but details are not available due to changes in the ownership of the site.

3.8 This complex history is important context for the proposals. Firstly, it highlights the difficulties in securing occupiers for this site. The proposals to widen the range of goods that can be sold from the Retail Park will enable a wider range of occupiers to take space, which will significantly increase the potential for securing long term occupiers, at long last.

3.9 It is critically important that an anchor retailer is secured, that will act as the hook to attract other retailers. Anchor retailers often sell a wide range of goods and require the flexibility to adapt their offer to meet market demands. This triggers the requirement for a unit within the Retail Park that can sell all Class A1 goods.

3.10 Allowing the remaining floorspace within the Retail Park to sell all comparison goods, provides retailers with the flexibility required to respond to market demands and will enable the site to attract a wide range of operators.

3.11 Agents marketing the scheme on behalf of West Register have secured genuine interest from an anchor retailer and three further retailers to take space at the Retail Park. These retailers can only trade from New Hall Hey Retail Park, if the conditions associated with planning permission ref: 2007/030 are varied, as requested through this application. The retailers that have confirmed interest are national multiple retailers that will raise the profile of Rawtenstall as a retail destination.

3.12 This application provides a genuine opportunity to secure occupation of a long standing vacant Retail Park, to the benefit of the New Hall Hey area and Rawtenstall in general.

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Why are the application proposals needed? Why now?

1. An anchor retailer is required to attract interest from other retailers. Anchor retailers are high profile national multiple retailers with a strong covenant, that promote linked trips for adjacent retail units. An anchor retailer is critical to the delivery of New Hall Hey Retail Park, as it will drive interest from other retailers for the remaining space. There is confirmed interest from an anchor retailer at this time, which may not be around in a year because of the dynamic nature of the retail market, therefore it is important that the retailer is secured now through approval of this application.

2. An unrestricted Class A1 unit is a requirement of the anchor retailer and therefore this part of the application proposals must be delivered now, to facilitate its occupation.

3. On the back of anchor retailer interest, interest has been secured from other retailers that require unrestricted comparison retail floorspace, therefore this variation is also required at this time.

4. These retailers will not formally agree to occupy space until the anchor retailer is committed and this cannot be achieved without the approval of this application.

5. The site has remained vacant for a number of years and is an eyesore at the entrance to Rawtenstall. The proposals provide a genuine opportunity to bring this site into use in the short term, enhancing the visual perception of Rawtenstall.

6. Bringing this site into use will have resultant benefits for the profile of Rawtenstall, both in general, and as a retail destination. The opportunity of the anchor retailer means that Rawtenstall can start to realise these benefits in the short term.

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4.0 The National Planning Policy Framework

General Aims

4.1 The National Planning Policy Framework (The Framework) was introduced by the Government in March 2012. It was intended to make the planning system less complex and more accessible, to protect the environment and to promote sustainable growth. It is a material consideration in the determination of planning applications.

4.2 The Framework was not intended to be a fundamental over-haul of the planning system; instead it was an attempt at summarising and streamlining existing guidance so that the aims of the planning system were clear.

4.3 These central aims are summarised in the Ministerial foreword of the Framework:

‘The purpose of planning is to help achieve sustainable development.’

4.4 Where proposals are sustainable the Ministerial foreword is clear:

‘Development that is sustainable should go ahead, without delay – a presumption in favour of sustainable development that is the basis for every plan, and every decision.’

4.5 The Ministerial foreword is also clear as to how the planning system can help achieve sustainable development:

‘[P]lanning must not simply be about scrutiny. Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.’

4.6 The Framework, taken as whole, represents the Government’s definition of what constitutes a sustainable development. This definition of sustainable development includes three key roles: an economic role; a social role; and an environmental role. These aims are mutually dependent and should be sought jointly and simultaneously by the planning system.

4.7 An assessment of the proposals against these roles is set out in Section 8.0 of this report.

Main Town Centre Uses

4.8 The Framework requires local authorities to identify an appropriate range of sites for main town centre uses to meet the scale and type of development needed in town centres. The needs should be met in full and not compromised by limited site availability.

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4.9 The Framework requires a sequential test to be applied 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. Priority is given to town centre locations, followed by edge of centre locations. When considering edge of centre sites and out of centre sites preference should be given to sites that are well connected to the town centre (Para. 24). A sequential site assessment has been undertaken for the proposed development and is set out in Section 6.0.

4.10 An impact assessment is required for proposals for main town centre uses outside of town centres that are not in accordance with an up to date Local Plan, if the proposal exceeds 2,500 sq.m or is above a locally set threshold (Para. 26). New Hall Hey Retail Park exceeds this threshold and there is a locally set threshold of 750 sq.m. This application does not propose to increase the floorspace but, as it will widen the range of goods that can be sold, an impact assessment is undertaken for robustness. The impact assessment is set out in Section 7.0 of this Statement.

4.11 The National Planning Practice Guidance (2014) provides more detailed guidance on the application of the sequential approach to site selection and impact assessments. It is a material consideration in the determination of planning applications.

The Development Plan

4.12 The Development Plan for Rossendale comprises the Rossendale Core Strategy 2011 and the ‘saved’ policies of the Rossendale Local Plan (1995). The Council is also in the process of preparing a Town Centre Vision Supplementary Planning Document. This document is in the early stages of preparation and therefore limited weight can be attributed to it in the determination of the planning application.

4.13 Appendices 1 and 2 of this report include a detailed schedule of each policy of the Development Plan, along with an explanation of compliance.

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5.0 The Retail Context

The Catchment Area

5.1 The catchment area for the proposed development comprises the Study Area utilised in the Rossendale Town Centre and Retail Study (2009) (RTRS). This includes the area from Bacup and Whitworth in the east to Haslingden and the southern part of Accrington to the west and Ramsbottom to the south. It includes Rossendale Borough but also Ramsbottom which falls within Bury’s local authority boundary because it has a strong interrelationship with the area.

5.2 It is not considered necessary to widen the catchment area because of the strong retail offer in the wider area. Burnley, Accrington and Blackburn are located to the north and Bolton, Bury and Rochdale to the south. This has the effect of constraining the catchment area to Rossendale Borough, plus Ramsbottom, which falls in between Rawtenstall and Bury.

5.3 Centre’s within the wider area have a strong retail offer including a town centre and retail park offer and therefore operate within their own catchment areas. Rawtenstall is the largest centre in Rossendale but its limited retail offer means that people travel from Rossendale to these larger centres but the return flow of expenditure is limited.

5.4 The Retail Park, as proposed, will primarily be utilised by those within Rossendale and it will act as an enhancement to the local offer rather than drawing trade from competing destinations in the wider area.

5.5 The catchment area was agreed with the Council at pre-application stage and therefore is considered to acceptable.

The Vitality and Viability of Centres

5.6 New Hall Hey is located with Rawtenstall and as it the closest centre to the development and the largest centre in the Borough, it is only considered necessary to review the health of Rawtenstall town centre.

5.7 Rawtenstall Town Centre is focused upon Bank Street. The Town Centre offers a wide range of uses including both retail and service uses to serve the local community. This includes a strong convenience offer and a number of independent bakerys, greengrocers and butchers are located on Bank Street and the surrounding streets.

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These are complemented by clothing, charity and gift shops as well as a number of banks.

5.8 Rawtenstall presents a low vacancy rate and the 2012/13 Annual Monitoring Report indicates that the Centre has an 8% vacancy rate. This is considerably below the national average of almost 14% (GOAD 2014), which is a strong indicator of a healthy centre. A site visit to Rawtenstall in May 2014 indicates that this has not changed significantly.

5.9 The biggest change to Rawtenstall Town Centre in recent times is the demolition of the Valley Centre in 2012. This represents a reduction in Town Centre retail floorspace of 3514 sq.m. Plans for the redevelopment of the Valley Centre, for a scheme more appropriate to Rawtenstall Town Centre, are underway and public consultation has already taken place. It is intended that the new scheme will bring forward 3265 sq.m in small units and will include areas of public open space. This scheme is in progress and is being brought forward by Barnfield Construction, who is also responsible for New Hall Hey Retail Park. Once developed, it will represent a significant enhancement to Rawtenstall Town Centre’s offer and will support the growth of its independent retailers through the provision of small units.

5.10 Rawtenstall is a centre which presents characteristics of strong vitality and viability. It has a low vacancy rate, a vibrant independent retail offer and there is a significant investment project underway.

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6.0 Sequential Site Assessment

The Parameters for the Sites Considered

6.1 The sites considered through the sequential site assessment have been agreed at pre- application stage with Rossendale Borough Council. They have been assessed based on the parameters set out below.

6.2 This application is being driven partly by the business model requirements of operators with a confirmed interest in acquiring space at New Hall Hey Retail Park. This is alongside changes to the retail market, both locally and nationally and the significant desire for the owners of the Retail Park to achieve an occupied development in the short term.

6.3 In considering the business model approach, it is not possible to name the occupiers at this stage but their requirements are set out below and are the critical factor in determining the suitability of sites. This position has been confirmed through the Tesco v Dundee Supreme Court Judgement (21 March 2012) which states that the key consideration is 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’ (Para. 29). This is supported by the appeal decision for Land at Vulcan Road, Sheffield (Appeal Ref: APP/J4423/A/13/2189893) dated 3 July 2013, which confirms that the business model of the operator can be the key factor in the consideration of whether a site is suitable.

6.4 In this context, the operators have identified the New Hall Hey Retail Park as the location within the catchment area that meets their requirements. They have stated that town centre locations will not be appropriate and therefore it is considered that the application site is the only suitable location for the proposed development in the catchment area. Notwithstanding this consideration, a detailed assessment of the sites provided by the Council has been undertaken in order to be robust. The sites have been assessed against the following parameters:

1. The anchor retailer would like the unit to be trading by Christmas 2014. This is a key requirement of the anchor retailer and New Hall Hey Retail Park is available to meet this requirement, as the structure is already in place. Notwithstanding this requirement, and in order to demonstrate flexibility in accordance with the NPPG (Para: 010, Reference ID: 2b-010-20140306) it is considered that, realistically retailer interest in the scheme would disappear after one year.

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Therefore, this is taken as the maximum timescale for delivery of a development, including acquisition, planning and redevelopment.

2. The site must be able to accommodate at least 746.5 sq.m gross of retail floorspace, as this is the floorplate of the smallest unit in the Retail Park without mezzanine floors. Realistically, the scheme could not come forward without the anchor retailer which requires a floorplate of 1,162 sq.m gross. There is also the option of testing the full quantum of floorspace provided at the Retail Park as this is the floorspace proposed through this application (6,188 sq.m gross). However, utilising the floorspace of the smallest unit provides a robust approach and demonstrates flexibility in format in accordance with the NPPG (Para. 010, Ref ID: 2b-010-20140306).

3. The site must be able to trade all Class A1 goods including food, clothing and bulky goods, as the New Hall Hey Retail Park would trade the full offer. The breadth of the offer means that the site must also include flexibility in terms of display floorspace.

4. The site must be accessible for servicing by HGV. This is a requirement for most national retailers and especially bulky goods retailers that require larger vehicles to transport their goods.

5. An interrelationship with other retailers is required to promote linked trips, which supports the viability of the stores.

6.5 The parameters for the assessment demonstrate flexibility in format and scale in accordance with the NPPG (Para. 010, Ref ID: 2b-010-20140306). This has been achieved in terms of flexibility in the size of the unit that has been assessed and the timescales for delivery. There are however, fixed parameters that are determined by the fact that the development is completed on site and the operators that will be acquiring space also have some fixed requirements.

Sites Assessment

6.6 Set out below are summaries of the sites that were assessed. The full assessments can be found at Appendix 4:

1. Robert Street - The site has ownership complexities which means that it will not be available for redevelopment within the required timescales. The site’s size and location means that it is also not a suitable location for the proposed development.

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2. Rawtenstall Market – The market is to be relocated as part of the Valley Centre proposals that will not commence on site until 2015 and will take approximately a year to deliver. Therefore this site will not be available for redevelopment within the required timescales.

3. Phipps Car Park - The site is a heavily used car park that supports the retail function of the Town Centre, therefore it is not available. The access to the site and constrained size means that servicing by HGV would be difficult and so it is not suitable.

4. The Valley Centre and Rawtenstall Police Station - The site is coming forward for a development that will not commence on site until 2015 and will take over a year to deliver, therefore it is not available within appropriate timescales. The form of retail development proposed through this application does not accord with the Council’s objectives for the Valley Centre. The form of retail floorspace coming forward as part of the scheme does not accord with the retailers requirements as it is too small and does not have appropriate parking or servicing facilities. The only unit that is large enough at the Valley Centre is committed to a specific retailer, therefore it is not available or suitable.

5. Kay Street Car Park - The site is a heavily used car park that is not available to accommodate the proposals. It is also an irregular shape, which renders this site unsuitable.

6. Heritage Arcade - The building is physically constrained and does not meet the requirements of the retailers that want to locate at New Hall Hey in terms of its physical layout and the lack of car parking and servicing facilities, therefore it is not suitable.

7. Former College Site - The site is out of centre and therefore is not sequentially preferable to the application site. This is not to say that it is sequentially inferior, merely that it is not preferable and most likely sequentially equal. The Telford and Wrekin Borough Council and St Modwen Developments Limited v Secretary of State for Communities and Local Government [2013] EWHC 1638 Judgement confirms that this is possible. Furthermore, it is not suitable for the retailers with an interest in New Hall Hey as it is an island site with no connections to existing retail development and it is too small to accommodate the entire development.

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Summary

6.7 As set out above, the business model of those wishing to occupy space at New Hall Hey dictates that New Hall Hey is the only location where they will locate in the catchment area. Notwithstanding this consideration, it is demonstrated that there are no sites in sequentially preferable locations that are available and suitable for the development proposed and therefore the sequential test is passed.

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7.0 Retail Impact Assessment

7.1 Section 7.0 of the Planning and Retail Statement addresses retail impact. It is set out in the following sub-sections:

1. A review of the methodology used for the retail impact assessment.

2. A summary of the changes in retail provision that have taken place since the RTRS was published in 2009 and how these have affected shopping patterns.

3. A summary of the headline findings of the retail capacity assessment and its implications.

4. Consideration of how the proposal will divert trade from existing destinations and opportunities for claw back of expenditure.

5. The implications of the proposal on the vitality and viability of centres in the catchment area.

6. Consideration of the scope for the proposals to impact upon investment in defined centres in the catchment area.

7.2 Tables associated with the retail impact assessment are set out in Appendix 5.

Methodology

7.3 The methodology for the impact assessment was agreed with Rossendale Council at pre-application stage and this is summarised below.

7.4 The RTRS is considered to need updating, as it was prepared 5 years ago. However, retail provision and shopping patterns in Rossendale have not changed significantly during this time and therefore it is possible to simply update the findings of the RTRS to reflect the current position. Furthermore, the RTRS was based on a telephone household survey and therefore provides a robust basis on which to assess shopping patterns in the catchment area.

7.5 This approach accords with the NPPG which states ‘The impact test should be undertaken in a proportionate and locally appropriate way, drawing on existing information where possible’ (Para. 015, Reference ID: 2b-015-20140306).

7.6 In order to update the findings of the RTRS it is first necessary to update the baseline population and retail expenditure data. Up to date population data was obtained from Experian, which takes account of the 2011 census. Convenience and comparison

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expenditure per head data was also obtained from Experian. This provided the Price Base for the impact assessment of 2012.

7.7 2014 was used as the base year for the assessment, as the first occupier intends to open by Christmas 2014. The NPPG (Para. 013, Reference ID. 2b-013-20140306) suggests that impacts should be assessed up to a 5 year period to assess impacts once the development has reached a mature trading pattern. For these purposes 2019 was selected, as the development will have been trading maturely for a number of years by this point. The turnover of destinations, could then be then projected to 2014 and 2019 using floorspace efficiencies set out in Retail Planner Briefing Note 11.

7.8 The RTRS includes shopping patterns based on a telephone household survey undertaken in December 2008. This is an established method for understanding local shopping patterns and therefore provides a robust basis for the assessment. Updated convenience and comparison expenditure was applied to these shopping patterns to establish the turnover of destinations in the catchment area, if there had been no changes to shopping patterns since the RTRS was published. This includes a proportion of in-flow from outside the catchment area.

7.9 The next step is to update the shopping patterns of the catchment area to reflect changes in retail provision that have taken place since the RTRS was published, both within and outside of the catchment area that will have had an effect on shopping patterns. The assumptions that were made are considered in greater detail below. The changes in retail provision to be included in the assessment were agreed with Rossendale Council at pre-application stage.

7.10 Once the baseline is in place, a comparison is made between the benchmark turnover of destinations and the updated survey derived turnover, to understand if there is any retail capacity in the catchment area. This is the approach adopted in the RTRS and is one approach for calculating retail capacity.

7.11 It is then necessary to understand where the proposal may divert trade from. The first step is to calculate the turnover of the proposal. The assessment uses typical sales densities attributable to retailers likely to occupy floorspace at the Retail Park. This ensures that it is a realistic assessment of trade diversion. The convenience and comparison turnovers for the site need to be considered separately, as they will have different trade diversionary impacts. Although the entire site could be used for comparison sales, assessing the effect of the convenience floorspace separately sensitivity tests a higher turnover scenario.

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7.12 The convenience turnover is calculated using an average of the sales density of high end food retailers, having regard to interest expressed in the site. The comparison offer includes a sample of retailers which reflect a wide ranging offer but are similar to those that have expressed an interest in the site, namely TK Maxx, Pets at Home and Currys/PC World (£12.52m in 2014).

7.13 The turnover for the proposal has been calculated based on the position that the New Hall Hey Retail Park is currently unoccupied and therefore has no turnover. An assessment could have been made assuming that the units are occupied by retailers that can trade under current goods restrictions, however the approach that has been taken presents the greatest uplift achievable and therefore represents a worst case scenario in terms of trade diversion impacts. This is a robust position from which to sensitivity test the potential impacts of the proposal and accords with guidance in the NPPG (Para: 018, Reference ID: 2b-018-20140306).

7.14 An assessment of trade diversion resulting from the application proposals was then undertaken. This was based on a number of factors: The size of the store; Location; Brand; Accessibility; Type of offer; and, other market attractions.

7.15 This methodology was agreed with Rossendale Council at pre-application stage and therefore is considered to be acceptable.

Changes to Provision Since the Publication of the RTRS

7.16 Set out below in Tables 1 and 2 is a schedule of the significant changes to retail provision that have taken place since the RTRS was published in 2009. These are changes both inside and outside of the catchment area that have an influence on shopping patterns within the catchment area. Tables 1 and 2 also set out the effects that these changes have had on shopping patterns and the sources of information used to inform the trade diversion assumptions. Once these are factored into the assessment it provides an up to date position on local shopping patterns and the turnover of developments in the catchment area. Details are set out in Tables 6, 8, 13 and 15 of Appendix 5.

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Table 1: Changes to Convenience Provision Since the RTRS was Published

Convenience Changes in Provision

Inside Catchment Area

Morrison’s, Bacup Trade diversion rates taken are from the Planning and Retail Statement submitted with application ref: 2010/692 for the Morrison’s store. They include trade diversion from the main foodstores in the local area because of the similarity in the offer and also Bacup, due to proximity to the store. They also indicate a degree of claw-back of convenience expenditure (£4.43m) from outside of the catchment area from towns located to the west of the area e.g. Todmorden.

Family Bargains Family Bargains trade diversion rates are assumed by NJL. The convenience turnover of Family Bargains is small (£0.27m) and it is considered it will draw trade from the value offer of Tesco and Asda in Rawtenstall and also from the Lidl in Rawtenstall because of the proximity and similarity in offer.

Aldi, Ramsbottom The Bury Retail Study is from 2012 and includes an assessment of where the Aldi in Ramsbottom draws its trade from. It indicates trade diversion from the value offer at Asda and Tesco in Rawtenstall and also from the Lidl in Rawtenstall. The trade draw from Lidl is largely balanced out by a reverse trade draw from Aldi to Lidl.

Lidl, Rawtenstall Lidl in Rawtenstall trade diversion rates are assumed by NJL. It is considered that it will divert trade from the value offer of Asda and Tesco, with a greater emphasis on Asda. A small trade diversion is attributed to Rawtenstall Town Centre because it has a convenience offer, but as they are independent retailers, they have a different market profile and so trade diversion will be limited. It will also divert trade from the Aldi in Ramsbottom because Aldi and Lidl are direct competitors in the market. This is largely balanced out by reverse trade diversion.

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Outside Catchment Area

Tesco, Accrington This is a large store and so it will divert expenditure generated from within the catchment area. The Planning and Retail Statement submitted with application ref: 11/08/0044, for the store sets out trade diversion rates. These were applied to the impact assessment. They suggest a trade diversion from the Asda and Tesco in Rawtenstall and Tesco at Syke Side, as they are either the same fascia or direct competitors in the market. This results in an additional outflow expenditure of from the catchment area.

Asda, Todmorden This is a commitment and trade diversion has been assumed by NJL. Given its proximity to the east of the catchment area it is considered that it will have a marginal effect on shopping patterns in this area. This will primarily be from Bacup District Centre and the new Morrison’s store in Bacup. As it is an Asda store it is considered that there will also be some marginal trade diversion from Asda and Tesco in Rawtenstall from people within the east of the catchment area diverting to the Todmorden store.

Table 2: Changes to Comparison Retail Provision Since the RTRS was Published

Comparison Changes in Provision

Inside Catchment Area

Family Bargains Family Bargains trade diversion rates are assumed by NJL. Given its location within Rawtenstall it is considered that it will primarily divert trade from the comparison offer of the supermarkets and discount stores in Rawtenstall. Similarly, there will be some trade diversion from the comparison offer of Tesco, Syke Side and Morrison’s, Bacup. All trade diversion will be internal to the catchment area.

The Valley Centre The Valley Centre has been demolished and so it currently represents a net loss of retail floorspace in Rawtenstall Town

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Centre. Expenditure has therefore been diverted to other destinations and it is likely that a significant proportion of this will have been directed to other locations in Rawtenstall Town Centre. The remainder is considered to be have been lost to destinations outside of the Borough e.g. Accrington, Burnley, and Bury. This is because the overall attraction of Rawtenstall will have declined, as floorspace is lost, and people will go to higher order centres instead.

It is intended that the Valley Centre redevelopment will commence on site in 2015 and therefore by 2019 there will be an established pattern of trading. This will increase the attraction of Rawtenstall and so claw-back more comparison retail expenditure than was lost through the demolition of the old Centre. The increased attraction of Rawtenstall will mean that it can retain a greater proportion of comparison expenditure that would previously have been spent at nearby higher order centres.

Outside Catchment Area

Tesco, Accrington Because of the size of this store, the comparison offer draws £12.81m of expenditure from the catchment area. The Planning and Retail Assessment submitted with the planning application indicates that a small proportion of this turnover will be diverted from the catchment area, with Rawtenstall and Haslingden being the key destinations because it will directly compete with the Tesco stores in these locations.

Tesco, Accrington has increased the outflow of comparison expenditure from the catchment area.

The Rock, Bury The Rock in Bury is the major change that has taken place for comparison retail floorspace in the local area. Bury is outside of the catchment area for the proposal but the scale of The Rock means that the attraction of Bury has increased significantly which has resulted in a greater degree of outflow of comparison expenditure from the catchment area.

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The Bury Retail Study 2012 was undertaken after The Rock was constructed (2010), therefore it provides an indication of the post development attraction of Bury Town Centre from the catchment area. It indicates that the development of The Rock has resulted increased trade diversion from Rawtenstall and Haslingden.

Asda, Todmorden This is a commitment and trade diversion has been assumed by NJL. It is a small Asda store and therefore will have only a small amount of comparison retail floorspace (£4.78m turnover). It is therefore considered that it will only draw trade from Bacup, as this is the neighbouring town to Todmorden and this will most likely be from the Morrison’s because they are direct competitors.

7.17 In summary, the effect of the changes in provision that have taken place since the RTRS was published are:

1. It has led to an increase in the outflow of convenience retail expenditure, mainly due to the Tesco store in Accrington.

2. It has resulted in an increase in the outflow of comparison retail expenditure, primarily due to The Rock in Bury, although this will be helped, in part, by the Valley Centre coming forward.

Turnover of the New Hall Hey Retail Park, As Proposed

7.18 The turnover for the application proposal is based on the type of retailers that have a confirmed interest in acquiring space at New Hall Hey Retail Park. This ensures that the assessment of trade diversion is accurate. Table 3 sets out the calculation for the turnover of the proposal and Table 4 provides a summary of the turnover at 2014 and projected to 2019.

Table 3: Turnover of the Application Proposal

Gross Floorspace Net Floorspace Sales Density Turnover Unit Type of Goods (sq.m) (sq.m) (£/sq.m) (£m) Unit A1 Conv/Comp 1162 929.6 11856.50 11.02 Unit A2 Comp 2235.5 1788.4 2390.00 4.27 Unit B Comp 1297.5 1038 2172.00 2.25 Unit C Comp 1493 1194.4 5104.00 6.10 Total 6188.00 4950.40 23.65

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Table 4: Turnover of the Application Proposal Projects to 2014 and 2019

Convenience T/O 2014 Comparison T/O 2014 Convenience T/O 2019 Comparison T/O 2019 11.02 12.63 11.06 12.67

Findings of the Updated Retail Capacity Assessment

7.19 There is no longer a policy requirement to demonstrate need for retail floorspace as part of a planning application. The NPPG retains the requirement for Council’s to assess need in Plan making but in terms of decision taking there is only a requirement to pass the sequential and impact tests and need is removed as a consideration. However, for the purposes of this application it provides the baseline from which an assessment of trade diversion impacts can be undertaken and it is set out through the update to the RTRS.

7.20 The NPPG suggests a ‘no development scenario’ should be assessed (Para. 017, Ref ID: 2b-017-20140306). The retail capacity assessment that has been undertaken to update the RTRS represents this scenario, as it assesses the current and future need for additional retail floorspace in the catchment area, factoring in recent changes to the local retail market and commitments for new floorspace. It therefore sets out the up to date position without trade diversion associated with the application proposal.

7.21 The headline findings of the retail capacity assessment, as updated, are:

1. There is capacity for additional convenience retail floorspace in the catchment area. A comparison between the expenditure generated in the catchment area (£191.1m) and the turnover of convenience retail destinations (£137.11) clearly highlights that at 2014 there is £53.99m of convenience retail expenditure that is generated within the catchment area but spent outside of it.

2. Growth in convenience retail expenditure (£13.3m) and comparison retail expenditure (£63.1m) from 2014 to 2019 is sufficient to accommodate the application proposals.

3. There is therefore scope to claw-back some of this £53.99m of convenience retail expenditure that is spent outside of the catchment area.

4. There is an even greater proportion of comparison capacity for additional retail floorspace. At 2014, out of a total of £320.1m of comparison retail expenditure

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that was generated within the catchment area, only £66.12m was spent within it. This represents an outflow of £253.98m of comparison retail expenditure.

5. This highlights that there is significant scope for the claw-back of further comparison retail expenditure that is spent outside of the catchment area, to enhance Rawtenstall as a comparison retail destination.

6. The RTRS compares survey derived turnovers with national benchmark turnovers. This methodology, does not take account of the local differences in the retail market and also includes the out of centre foodstores in the assessment. As these foodstores are not policy protected, their performance is not a relevant consideration in the determination of planning applications. therefore can be easily challenged. A comparison of the catchment area’s convenience retail expenditure with benchmark turnovers suggests that there may not be capacity. But this does not take account of the significant outflow of expenditure. For comparison retail floorspace, a comparison between the survey derived turnovers and benchmark turnovers suggests that there is some comparison retail capacity (£27.4m in 2014), which is sufficient to accommodate the application proposal.

7. The level of convenience and comparison retail expenditure that is available in the catchment area has increased since the RTRS was published. This is reflective of the 2012 figures from Experian stating that convenience and comparison retail expenditure per head has increased, which has a resultant impact on overall expenditure.

8. The catchment areas retention rate for convenience goods expenditure is 53% in 2014 and 58% in 2019. For comparison goods expenditure it is 20% in 2014 and 18% in 2019. These are low retention rates, which indicates scope for retention of a greater proportion of retail expenditure.

7.22 It is considered that realistically a combination of these factors will come into play to accommodate the application proposal, with a focus in claw-back of trade to increase the retention rate of the catchment area.

Trade Diversion Impacts of the Proposal

7.23 An assessment has been undertaken of the potential for the application proposal to divert trade from existing retail destinations within the catchment area. This includes an assessment of where claw back of expenditure that is generated within the

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catchment area but spent outside of it. This is a sensitivity test of a worst case scenario as, realistically, the growth in convenience and comparison retail expenditure and comparison retail capacity will absorb some of the turnover of the proposal. Tables 19 and 20 of Appendix 5 contain the detailed analysis but some of the sources of information and assumptions made in the assessment are discussed below for transparency.

Convenience Trade Diversion Assumptions

7.24 The convenience trade diversion assumptions used are based on actual interest in the application site from a high end food retailer. The assessment of potential turnover and likely trade diversion is based robustly upon future occupation by this type of food retailer.

7.25 It is considered that the proposals would result in some trade diversion from the main food retailers within the catchment area, as a result of the ‘Finest’ range in Tesco, the ‘Extra Special’ range in Asda, ‘M Signature’ range in Morrison’s, which aim to compete with the likes of M&S Simply Food, Waitrose and Booths. These stores are not within defined centres are therefore are not policy protected:

 Asda, Rawtenstall would have the greatest degree of trade diversion to the New Hall Hey Retail Park due to its close proximity and that it is the largest store in the area. Asda presents a turnover of £42.10m and the application proposal will divert 3.54% of this (£1.43m).

 Tesco, Rawtenstall would also have a degree of trade diversion because it is close in proximity to New Hall Hey and is a main food store. It has a turnover of £13.39m and the application proposals will divert £0.88m which represents 6.59% of its turnover.

 Tesco, Haslingden is a larger Tesco store, with a wider catchment area but is further from New Hall Hey. The store turns over £26.06m and the proposal will divert £0.88m which is 3.38% of its turnover.

 Morrison’s in Bacup is a smaller store and more remote from New Hall Hey. The application proposals will divert £0.33m of the store’s £11.41m turnover (2.90%).

7.26 It is considered that the differences between the offer of high end food retailers and that of Tesco, Asda and Morrison’s, which are currently located within the catchment area, means that the proposal will also divert a significant proportion of the proposal’s

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turnover from other similar retailers outside of the catchment area. The high levels of outflow of convenience expenditure from the catchment area also indicate that there is significant scope for claw-back of some of this expenditure. Destinations from which there is potential for trade to be diverted to a foodstore at New Hall Hey are Accrington, Burnley, Bury and Rochdale. There will also be limited trade diversion from Blackburn and Bolton. t

7.27 None of the locations nearby include a Waitrose or Booths.

7.28 Trade diversion from these destinations will comprise 66% of the New Hall Hey Retail Park’s convenience retail turnover. This represents £7.27m of convenience goods expenditure that is generated within the catchment area but currently spent outside of it. Accrington will experience the greatest trade diversion at £4.41m but this only represents 18.63% of the current outflow of expenditure from the catchment area to Accrington. Trade will be mainly drawn from those at the west of the Borough. Accrington includes an M&S, so as well as the claw-back of trade from the Tesco store there will also be a diversion of trade from those that live at the west of the Borough because of the presence of a high order food retailer in closer proximity.

7.29 In summary, the proposals will claw back £7.27m of expenditure that is currently spent outside of the catchment area. It will also increase the convenience expenditure retention rate from 53% to 68%.

Comparison Trade Diversion

7.30 The comparison trade diversion assumptions set out in Table 20 of Appendix 5 are based on the assertion that the remainder of the New Hall Hey Retail Park can be occupied by a range of comparison retailers from clothing to bulky goods retailers. A focus has been placed on the likelihood of some of the floorspace being used for the sale of clothing, as this will have the greatest level of trade diversion from defined centres and therefore it represents a sensitivity test of a worst case scenario.

7.31 The size of the units proposed at New Hall Hey Retail Park will attract national multiple retailers. The centres within the catchment area contain few of these types of retailers and therefore residents travel to higher order centres outside of the catchment area for these stores. This is evidenced by the outflow of comparison retail expenditure is in the region of £264.6m, compared to only £64.84m being retained in the catchment area (20% retention rate).

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7.32 It is therefore clear that a significant proportion of New Hall Hey Retail Park’s comparison turnover will be diverted from the higher order centres outside of the catchment area, which will result in claw back of expenditure into the catchment area.

7.33 The trade diversion rates that are applied are informed by shopping patterns set out in the RTRS, as updated, and from the Bury Retail Study 2012, along with consideration of the size of the store, location, brand, accessibility, type of offer and other market attractions.

7.34 It is considered that there will be trade diversion from Accrington, Blackburn, Bolton, Burnley, Bury, Manchester, Rochdale and other nearby centres. This diversion will be as a result of those within the catchment area undertaking some of their comparison shopping trips at New Hall Hey Retail Park as an alternative to centres outside of the catchment area. It is considered that trips for comparison retail shopping to New Hall Hey Retail Park from those living outside of the catchment area will be limited because of the higher order offer in centres outside of the catchment area. The greatest proportion is from Bury because of a combination of the established shopping linkages between the areas and the development of The Rock, which recently increased outflow. As the change is recent, there is scope to claw-back a proportion of this outflow of comparison expenditure.

7.35 Given the proximity of New Hall Hey Retail Park to centres within Rossendale, there will be a degree of trade diversion from these centres. Although it is likely to be limited because they include primarily independent retailers in smaller units that will complement the offer at New Hall Hey rather than compete with it. Rawtenstall has a turnover of £57.35m and it is anticipated that the proposal will divert £1.13m trade (1.98%), a proportion of which will be from the comparison offer of the Asda and Tesco stores, which will more closely compete with the offer of New Hall Hey. It is not considered that this will alter significantly once the Valley Centre comes forward, although the trade diversion will be split between existing retailers and those at the Valley Centre, with £0.38m being diverted from the Valley Centre in 2019 (3.88% of its £9.80m turnover). The Valley Centre proposals include units that are significantly smaller than those proposed for New Hall Hey and therefore they will attract a different type of retailer that will complement the New Hall Hey proposals, similarly to existing retailers in Rawtenstall Town Centre. Furthermore, both scheme are being brought forward by Barnfield Construction that will not want to prejudicially impact upon either scheme.

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7.36 Trade diversion from Bacup will be limited because of the small scale and independent nature of the District Centre offer and Morrison’s has a smaller comparison offer than other major supermarket chains. It is anticipated that there will be a £0.13m trade diversion from a turnover of £3.84m which represents 3.29%. There is also anticipated to be some limited trade diversion from the comparison offer at the Tesco in Haslingden (£0.25m, which represents 2.69% of its £9.38m comparison turnover).

7.37 In summary, the proposals will claw-back £10.89m of comparison retail expenditure that is currently generated in the catchment area but spent outside of it. This will increase the retention rate from 20% to 28%.

Impact on the Vitality and Viability of Centres

7.38 The NPPF (Para. 26) requires consideration to be given to whether the proposals will have a significant adverse impact on the vitality and viability of defined centres in the catchment area. New Hall Hey Retail Park comprises units of 750 sq.m and above, in a retail warehouse format. This differs significantly to the offer in the defined centres in the catchment area, which comprise units of generally 300 sq.m or less in traditional high street units, with limited options for expansion or flexibility. The differences between the offer means that New Hall Hey Retail Park is complementary to the offer in defined centres.

7.39 New Hall Hey Retail Park will be occupied by national multiple retailers. Such retailers have specific requirements, with the size of the unit being a critical component. They also require flexibility in terms of the offer they can trade, to respond to market demands. As a result they also require flexibility in the format of retail units, so that display floorspace can be easily adapted to reflect these changes in offer. New Hall Hey Retail Park comprises retail warehouse units that are perfectly situated to meet these requirements, which cannot be met within existing centres in the catchment area.

7.40 The centres in the catchment area have a strong independent retail offer. This is particularly prevalent in Rawtenstall, which is the closest centre to the application site. Independent retailers generally require smaller units and proximity to other similar retailers is preferable. Rawtenstall and the other defined centres in the catchment area meet this requirement which, does not compete with New Hall Hey. Furthermore, the proposals for the Valley Centre are to extend this offer and therefore Rawtenstall town centre will be strengthened over the coming years.

7.41 It is therefore clear that the offer proposed for New Hall Hey Retail Park would complement the existing offer rather than compete with it. This is reflected in the level

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of trade diversion which is minimal. Rather, New Hall Hey Retail Park will compete with existing out of centre foodstores and will claw back trade from higher order centres outside of the catchment area.

7.42 Tables 19 and 20 of the retail impact assessment (Appendix 5) consider the likely trade diversion from destinations in the catchment area and opportunities for claw back of expenditure currently spent outside of the catchment area. They demonstrate that the impacts resulting from both convenience and comparison trade diversion from defined centres in the catchment area are minimal and will not have a significant adverse impact on the vitality and viability of the centres.

7.43 The attraction of New Hall Hey Retail Park, as proposed, will encourage more local people to shop within the catchment area. It is considered that 66% of convenience turnover and 87% of the comparison turnover of New Hall Hey Retail Park will derive from clawing back expenditure that is generated within the catchment area but currently spent outside of it. This will relate to approximately £7.27m of convenience expenditure and £10.98m of comparison expenditure that will be brought back into the local area, which will marginally increase the catchment area’s retention rate for both convenience and comparison expenditure. It will also have resultant benefits for defined centres through linked trips (on foot and by car) and the presence of national multiple retailers will raise the profile of Rawtenstall as a shopping destination.

7.44 Furthermore, the assessment undertaken in Tables 19 and 20 of the retail impact assessment (Appendix 5) represents a sensitivity test of a worst case scenario, as the retail capacity assessment indicates that there is sufficient comparison retail capacity within the catchment area to accommodate the proposals. It is therefore reasonable to assume that a proportion of the comparison turnover of the store will be absorbed by the identified retail capacity, which will further reduce trade diversion impacts. It is also important to highlight that both convenience and comparison expenditure between 2014 and 2019 can more than accommodate the proposals.

7.45 It is therefore demonstrated that there is no scope for the application proposals to have a significant adverse impact on the vitality and viability of defined centres, and there is even scope for some benefits to result from the proposals. The application therefore accords with the provisions of the NPPF (Para. 26).

Qualitative Impacts

7.46 The application proposals will bring four new national multiple retailers into Rawtenstall. This will enhance the profile of Rawtenstall as a retail destination.

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7.47 It will also improve the choice of goods available for local people. As set out above the offer available will differ from the independent offer available in town centres and therefore will widen choice.

7.48 For the convenience offer, it will bring a high order food offer into the catchment area, which has not previously been available. This will benefit the local population and mean that people do not need to travel considerable distances to buy certain goods.

7.49 Overall, the proposals for New Hall Hey Retail Park will diversify the retail offer of Rawtenstall and the catchment area without diluting or diverting the offer that is available within defined centres.

Impact on Investment

7.50 The NPPF (Para. 26) requires a consideration of the impacts that the proposal may have on existing, committed and planned investment in defined centres. The only significant town centre investment in the catchment area is the redevelopment of the Valley Centre. An assessment of the likelihood for the application proposals to impact upon the Valley Centre development highlighted the following key points:

1. Both the Valley Centre and New Hall Hey are being brought forward by Barnfield Construction. Barnfield Construction is a local developer, based in Lancashire that has a vested interest in both of these schemes realising there full potential. Therefore, if it was considered that one would harm the other, it would not be bringing both proposals forwards and most definitely not in within close timescales, as is the case here.

2. The proposals for the Valley Centre are at a relatively advanced stage and have undergone public consultation (Plan at Appendix 5). The proposals include 12 units of between 140 sq.m and 325 sq.m and one larger ‘anchor’ unit of 930 sq.m. The entire scheme is designed to act as an extension to the existing retail offer of the town centre and to provide space for further independent retailers.

3. The smaller units proposed have no scope to compete with New Hall Hey Retail Park. The difference in size between these units and the ones at New Hall Hey means that they will attract attention from a different section of the retail market. The adjacent car parking and large servicing areas provided at New Hall Hey, further differentiates the offer.

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4. The single larger unit (930 sq.m) at the Valley Centre is to act as an anchor for the development. This unit has similar characteristics to the smaller units, in that there is no adjacent car parking and servicing areas are more constrained, which means that it will attract different retailers. Also, retailers that occupy retail park floorspace have preferred named retailers that they want to occupy space next too. The type of retailers that will occupy floorspace at the Valley Centre will not fall within such requirements and therefore the larger unit at the Valley Centre will not compete with New Hall Hey. Furthermore, Barnfield Construction has confirmed interest from a retailer to occupy this anchor unit that has stated it would not want an out of centre location, therefore the proposals for New Hall Hey will not delay the occupation of this unit.

5. Table 20 of the retail impact assessment sensitivity tests a worst case scenario that the New Hall Hey proposals would result in some trade diversion from the Valley Centre by 2019 despite the differences in the offer. Even if this were the case, it is would only have a 3.88% impact on the turnover of the Valley Centre, which is minimal and would not result in significant adverse impacts e.g. closure.

7.51 It is therefore demonstrated that New Hall Hey Retail Park will act as a complementary retail destination to Rawtenstall Town Centre, including the Valley Centre. Both New Hall Hey and the Valley Centre will, together, enhance the attraction of Rawtenstall as a retail destination, and claw back some of the retail expenditure that is currently lost to destinations outside of the catchment area.

7.52 The differences between the proposals in terms of location, size, servicing areas and car parking means that they will attract wholly different retailer interest and will not compete. In this context it is clear that the proposals for New Hall Hey will not have an adverse impact on the delivery or success of the Valley Centre scheme.

Summary

7.53 It is demonstrated that the application proposals will not have a significant adverse impact on the vitality and viability of defined centres in the catchment area and will not impact upon investment in these centres. The proposals therefore pass the NPPF impact test (Para. 27).

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8.0 A Sustainable Development

An Economically Sustainable Development

8.1 The application proposal is economically sustainable for the following reasons:

1. The application is submitted to allow specific operators to occupy New Hall Hey Retail Park and therefore will bring a site that has remained vacant since it was constructed 2010, into use. As a prominent site, at the gateway to Rawtenstall, it is vitally important that this site is brought into use, as it will enhance the overall perception of the town. This is also a key objective of the Core Strategy, as the Key Issues section (Page 25) identifies the improvement of New Hall Hey as one of the key regeneration objectives for the Borough. The application proposals will therefore deliver one of the Core Strategy’s key objectives. The regeneration benefits of the proposal are a material consideration in favour of the application.

2. The occupation of the site by national multiple retailers will raise the profile of Rawtenstall and increase its attraction as a retail destination. The proposals will also claw back retail expenditure that is generated within the local area but currently spent in higher order centres outside of the catchment area, demonstrating that the proposals are not dependent upon trade diversion from existing retailers and will actually bring retail expenditure back into the local economy.

3. It is demonstrated that the proposals can come forward without having a significant adverse impact on the vitality and viability of defined centres or future investment in those centres.

4. The proposals will bring forward approximately 125 Full time Equivalent1 employment positions. This is in large part due to the convenience floorspace which presents a higher sales density than comparison retail floorspace in retail park units.

5. Investment in New Hall Hey Retail Park and the enhanced profile of the local area will also have associated benefits for retailers in defined centres, and in particular Rawtenstall Town Centre.

6. The Sequential Site Assessment confirms that there are no sites within or on the edge of centres within the catchment area that could accommodate the proposals. The application site is therefore required to support growth and meet needs identified by national multiple retailers for a presence in Rawtenstall.

1 Employment Densities Guide - Offpat and HCA 2010

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A Socially Sustainable Development

8.2 The proposals represent a socially sustainable development in that they:

1. Will improve the choice and range of goods available in the local area so that it is not restricted by limited site availability.

2. The New Hall Hey Retail Park is in a genuinely accessible location, being located within Rawtenstall urban area and adjacent to the A682. Therefore all members of the community can benefit from enhanced choice. It is also highly accessible to those working within the commercial units at New Hall Hey and therefore will significantly enhance their access to retail services. Further details in relation to the accessibility of the site are provided in the Transport Assessment that is submitted with this application.

An Environmentally Sustainable Development

8.3 The application proposals are environmentally sustainable for the following reasons:

1. They will bring into use a vacant building in a prominent gateway location. This will make a positive contribution to the regeneration of the New Hall Hey area and also enhance the perception of Rawtenstall in general, which is a material consideration in the determination of the application.

2. The proposals will bring forward a retail development in a location which is accessible by sustainable forms of transport. Further details are set out in the Transport Assessment submitted with the application.

3. The catchment area is deficient in high order food provision and also comparison national multiple retailers. The application proposal will means that residents of the catchment area do not need to travel to higher order centres for these goods, which significantly reduces travel distances. It will therefore promote a more sustainable pattern of movement.

4. The building is already in place and the proposals will simply enable it to be occupied. There are therefore no concerns about the exterior of the building or its siting in this location, as these factors have already been established.

5. The proposals represent an efficient use of land as they will bring into use a vacant building, rather than developing a new building.

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9.0 Conclusions

9.1 New Hall Hey Retail Park was constructed in 2010 and has remained vacant since this time. This application proposes variations to the conditions associated with the planning permission for the Retail Park, so that it meets the requirements of retailers with a confirmed interest in acquiring space at the Retail Park. It therefore represents a genuine opportunity to bring this vacant and prominent site into use.

9.2 An anchor retailer is critical to the delivery of the scheme, as it raises the profile of the site and triggers interest from other retailers. An anchor retailer has currently been secured for New Hall Hey Retail Park, which has triggered interest from other retailers, that is dependent upon the anchor retailer coming forwards. The anchor retailer cannot trade from the site without widening the goods restrictions and so the approval of this application is critical to it being able to trade from the site.

9.3 The proposals form part of West Register’s strategy to bring forward and complete developments across the New Hall Hey area. West Register is committed to creating a successful commercial destination at the New Hall Hey area and will be investing considerably in this objective.

9.4 The proposals form part of the regeneration objectives of the Core Strategy in that they will enhance to New Hall Hey, and given the prominent gateway location of the site, will also contribute to the overall perception of Rawtenstall as a retail destination. This is a material consideration in favour of the application proposals.

9.5 This Statement demonstrates that the proposed development comprises sustainable development in accordance with the Framework. In summary:

 Economically Sustainable Development: It will bring forward the occupation of a long term vacant Retail Park, create employment opportunities, support wider regeneration objectives and not impact upon the economic performance of town centres.

 Socially Sustainable Development: It will enhance choice and competition in an accessible location.

 Environmentally Sustainable Development: It will enhance the perception of Rawtenstall, bring an existing building into use, has no environmental issues and promotes the use of sustainable forms of transport and linked trips.

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9.6 Widening the range of goods that can be sold from the Retail Park triggers the requirement to address the Framework tests of the sequential approach to site selection and impact. This Statement demonstrates that there are no sites in sequentially preferable locations in the catchment area that can accommodate the proposals, by virtue of their availability, suitability or viability and therefore this gateway test is passed.

9.7 The impact assessment confirms that there is sufficient expenditure capacity within the catchment area to accommodate the additional turnover generated by the proposals. In addition to this assessment, it is demonstrated that trade diversion from existing destinations in the catchment area would not have an impact upon the vitality and viability of those destinations. It is also confirmed that the proposals will not upon impact town centre investment.

9.8 This Statement demonstrates that the application proposals are compliant with the Development Plan and national guidance. They comprise sustainable development and therefore in the absence of any material considerations which indicate otherwise planning permission should be granted in accordance with Section 38(6) of the Planning and Compulsory Purchase Act 2004 and the Framework (Para. 14).

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APPENDIX 1: COMPLIANCE WITH LOCAL PLAN POLICIES

POLICY AIM COMPLIANCE

ROSSENDALE CORE STRATEGY 2011 The application site falls within the urban boundary of Rawtenstall and therefore is in an appropriate location. New Hall Hey Retail Park has been vacant since it was constructed in 2010. Occupiers with a confirmed interest in the Seeks to focus the Retail Park are now ready to occupy the site and greatest amount of the application proposals will allow them to do development in this, therefore it will make best use of the Rawtenstall, within the buildings by bringing vacant buildings into active defined urban boundary. It use. should be of a size and The size of the development is fixed by the Policy 1 nature appropriate to the existing units on site and the proposals will not size and role of the alter this. settlement. Development The impact assessment submitted with the should make best use of application confirms that the proposals will not under-used buildings and have an adverse impact on centres in the maximise access by public catchment area and they will actually contribute transport. to maintaining Rawtenstall’s role as the dominant centre within Rossendale. The site lies within 300m of Rawtenstall train station and numerous bus stops and therefore it is accessible by public transport. The application site is within 300m of Rawtenstall train station and numerous bus Requires all new routes pass by the site, on the A682. It is development to be located Policy 9 therefore in an accessible location for travel by close to the main public sustainable forms of transport. This is transport corridors. considered further in the Transport Assessment submitted with the application.

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POLICY AIM COMPLIANCE

ROSSENDALE CORE STRATEGY 2011 A sequential site assessment has been Directs retail development undertaken which confirms that there are no to defined centres. sites with Rawtenstall Town Centre that are Rawtenstall is defined as a available and suitable to accommodate the Town Centre and is at the proposed development and therefore the top of the retail hierarchy. sequential test is passed. The Council wants to The application site is within Rawtenstall urban create a quality retail area and, as the proposals cannot be located in development at the Valley the Town Centre, it represents the most Centre with ancillary retail appropriate location for the scale of retail in other centres. development proposed. Rawtenstall is the focus for New Hall Hey is an area which is a focus for medium and large scale Policy regeneration in Rawtenstall. In particular, the retail development. 11 application site is a vacant Retail Park in a Proposals for convenience prominent gateway location for Rawtenstall retail development in Town Centre. The proposals will bring this site excess of 200 sq.m and into use and therefore will have significant outside of the PSA must regenerative benefits, as well as enhancing the pass the sequential test, overall perception of Rawtenstall Town Centre. meet the Council’s An impact assessment is undertaken in support regeneration objectives of this application, as the site exceeds 750 sq.m. and must not impact upon This demonstrates that the proposals will not vitality and viability. have a significant adverse impact on defined The local impact threshold centres in the catchment area or existing, for Rawtenstall is 750 planned or committed investment and therefore sq.m. the impact test is passed. An impact assessment has been undertaken which demonstrates that the proposals will not have an adverse impact on the scope to bring Policy Prioritises the regeneration forwards the Valley Centre proposals within the 12 of the Valley Centre. planned timescales. This site was also considered as part of the sequential site assessment and was discounted. The impact assessment that has been undertaken demonstrates that the proposals will Seeks to retain and not have an adverse impact on defined centres Policy enhance smaller retail in the catchment area, which includes the 13 centres and markets. markets. Rawtenstall Market was assessed as a potential sequential site and it was discounted. New Hall Hey Retail Park is a gateway site for those arriving at Rawtenstall from the west. The site has remained vacant since it was Seeks to enhance gateway constructed in 2010 and the application Policy locations and key proposals represent a genuine opportunity to 23 approach corridors. secure occupiers for the development. This will significantly enhance this gateway location which will have a resultant positive impact on Rawtenstall as a whole.

Reference 2014-050 Page 36 New Hall Hey Retail Park Planning and Retail Statement

POLICY AIM COMPLIANCE

ROSSENDALE CORE STRATEGY 2011 An impact assessment has been undertaken Seeks: which demonstrates that the application 1. The redevelopment proposals will not have an adverse impact on the of the Valley delivery of the Valley Centre. Centre; The application proposals will secure occupiers 2. Improved for the New Hall Hey Retail Park. This will pedestrian links to increase footfall between the Town Centre and Rawtenstall the site. It is in a location which is accessible by Railway Station; public transport, as it is within 300m of 3. The retention and Rawtenstall train station and numerous bus enhancement of stops. the diversity of An impact assessment has been undertaken shops in which demonstrates that the proposals will not Rawtenstall Town have an adverse impact on the diversity of shops AVP 4 Centre; in Rawtenstall Town Centre. 4. The location of new New Hall Hey currently has permission for the developments near sale of bulky goods. Under this restriction, the to public transport; site has been vacant for 4 years. It is therefore 5. Safeguarding New clear that there is not market demand for this Hall Hey for bulky form of retail development in this location. The goods retail and application proposals will widen the range of business use goods that can be sold from the site and these The Monitoring and changes are proposed to allow specific operators Implementation part of this that have a confirmed interest in occupying policy requires the Council space at the Retail Park. It therefore represents to work with developers to a genuine opportunity to bring this site into use overcome barriers to as it has been demonstrated that there is not development. market demand for bulky goods floorspace in this location.

Reference 2014-050 Page 37 New Hall Hey Retail Park Planning and Retail Statement

APPENDIX 2: COMPLIANCE WITH SUPPLEMENTARY PLANNING DOCUMENTS

DOCUMENT/COMPLIANCE REQUIREMENT

Rawtenstall Town Centre Vision SPD This document aims to improve the Consultation Draft (Feb 2012). Town Centre’s accessibility and create opportunities for investment whilst This document has not yet been finalised conserving and enhancing its and so limited weight can be attributed to distinctive character. it in the determination of the application. Four priority investment locations are An impact assessment has been identified at the Valley Centre, undertaken which demonstrates that the Rawtenstall Market, Rawtenstall Bus application proposals will not have a Station and Bury Road/Bacup Road. significant adverse impact on Rawtenstall Town Centre. In particular it will not affect investment in key locations. The sequential site assessment demonstrates that the sites identified as priority investment locations are not available or suitable for the application proposals. Bury Road/Bacup Road was not assessed as it identified for public realm improvements rather than redevelopment.

Reference 2014-050 Page 38 Appendix 3 Key

Zone 1

Zone 2

Zone 3

Zone 4

Rossendale Retail and Town Centre Study

Study Area

Rossendale Borough Council

06/11/08

1:100,000 @ A4

MAr

GIS40540-14

GIS Reference: S:\MA40540 - Rossendale Retail Study\MA40540 - Rossendale Retail and Town Centre Study - Study Area - 15.10.09.mxd Appendix 4 Appendix 4

1. Robert Street

Site Details

Site Area 3585 sq.m

Location Located at Robert Street, Rawtenstall. It is bound to the east by Burnley Road.

Site Description An industrial estate in use by multiple occupiers. It is mostly occupied.

Site Constraints

Planning Policy The site has no site specific allocations. It is located outside of the Town Centre boundary and 180m to the north of the Primary Shopping Area (PSA), making it an edge of centre site. However, it has poor accessibility and visibility to the PSA.

Adjacent Uses Immediately to the south is a mill building that has been converted to the Kingfisher Business Centre. Across Burnley Road, to the east, is the Rawtenstall cemetery and to all other sides is terraced residential development.

Site Access The site is accessed from Roberts Street or Kenyon Street off Burnley Road.

Availability

• A search of the title register (appended) has highlighted that this site is subject to multiple ownerships and a number of different lease arrangements. • A site visit confirmed that it is in use by a number of occupiers. • The multiple ownerships and occupiers would make acquiring this site time consuming. Factoring this into the timescales for the planning process, demolition and redevelopment, it means that it would take over a year for the site to be complete, at best. This means that it would most definitely not be available within the preferred timeframe of Christmas 2014 and also not within a year, which is a requirement for the development. It is therefore not available.

Suitability

• The site is only large enough to accommodate one of the retail units and associated car parking. This is not the preferred situation, as it would be preferable for all of the units to come forward together. • The site does not relate to other retail uses, as it is separated from the town centre, with no out of centre provision nearby. Therefore there is no scope for the site to benefit from an interrelationship with other retailers, which is a requirement of the development.

Viability

• N/A

Summary

• The site has ownership complexities which means that it cannot be brought forward for redevelopment within the required timescales and so it is not available. • The site’s size and location means that it is not a suitable for the proposed development.

2. Rawtenstall Market

Site Details

Site Area 3951 sq.m

Location Fronting Newchurch Road, within Rawtenstall Town Centre.

Site Description The site comprises Rawtenstall Market and includes an open air market, public toilets, an indoor market building and an associated car park.

Site Constraints

Planning Policy The site is allocated as a Market in the Core Strategy Proposals Map. It is within the Town Centre but outside of the PSA. At 40m to the north of the PSA it is an edge of centre site.

Adjacent Uses To the west is a Listed public house, to the east a parade of shops, to the north is Rawtenstall cemetery and to the south is the Town Centre.

Site Access The site is accessed from Newchurch Street.

Availability

• The site is in use as a market which is an important service for the local community. The market would therefore have to be relocated before the site could be redeveloped. • It is understood that this will form part of the proposals for the Valley Centre. The Valley Centre redevelopment is not due to commence until 2015 and will be brought forward in a number of phases. This will take over a year to complete and therefore the site will not be available within the required timescales.

Suitability

• The site is not large enough to accommodate the all of retail units with associated car parking and servicing and therefore it is not ideal. • The site lies adjacent to a Grade II Listed public house. The retail warehouse form of development proposed would not appropriately protect and enhance this building and therefore the site is not suitable.

Viability

• N/A

Summary

• This site cannot be available within the required timescales and therefore it is not available. • The site is not suitable for the entire retail park development and the form of development does not fit with the conservation area status of the site, therefore the suitability of this site is not ideal.

3. Phipps Car Park

Site Details

Site Area 3000 sq.m

Location The car park is located off Bank Street and is bound to the west by St Mary’s Way.

Site Description A car park that is un active use.

Site Constraints

Planning Policy Within the Town Centre boundary and partly within the PSA, as defined in the Core Strategy Proposals Map. It is within the Town Centre Conservation Area. It has no site specific designations.

Adjacent Uses To the north and south are retail units that front Bank Street. To the west across St Mary’s Way is an Asda supermarket.

Site Access The site is accessed from Bank Street.

Availability

• The site is in use as a car park and at the time of the site visit it was busy. It is understood that there is not a Council programme of car park consolidation and this car park clearly provides a valuable service to support the Town Centre, therefore the site is not available for redevelopment .

Suitability • It would not be possible to incorporate the quantum of car parking currently on the site along with the application proposal, therefore redevelopment of this site would result in a net loss of car parking spaces, which would have a negative impact on the centre as a whole. • As the site fronts Bank Street, it would be difficult to service the site with a HGV, due to the narrow street, sharp angle of access and the fact that it would block the entire street whilst servicing was taking place. This would have a negative impact on other retailers in the centre. • The retail warehouse form of development proposed would not preserve and enhance the Conservation Area in which it is located, rendering this location unsuitable.

Viability

• It would not be viable to relocate the car park to facilitate the redevelopment of this site.

Summary

• The site is a heavily used car park that supports the retail function of the Town Centre, therefore it is not available. • Servicing by HGV would be difficult and so it is not suitable and it would not be viable to relocate the car park to another site.

4. Valley Centre and Rawtenstall Police Station

Site Details

Site Area Approximately 1 ha

Location Bound to the north by Bank Street and Kay Street and the south by James Street, in Rawtenstall Town Centre.

Site Description The former Valley Centre and adjacent buildings. The majority of the site has been cleared and landscaped as a temporary public square before redevelopment takes place in 2015. The Police Station building remains intact.

Barnfield Construction is bringing forward both the Valley Centre and New Hall Hey Retail Park. We therefore have a detailed insight into the delivery of the proposals.

Site Constraints

Planning Policy Within the Primary Shopping Area and Town Centre on the Core Strategy Proposals Map. Core Strategy Policy AVP4 allocates the Valley Centre as a priority for redevelopment for a mixed use scheme to complement its Conservation Area location. Adjacent Uses To the north is Bank Street and the retail uses that comprise the Town Centre. To the south are mixed commercial uses.

Site Access Vehicular access to the site is from Kay Street or James Street.

Availability

• The site is allocated for mixed use regeneration in the Core Strategy (Policy AVP4). Proposals for redevelopment of the site are underway and a public consultation has been held. It is understood that the development is programmed to commence in 2015 and will come forward in phases. The development will take over a year to complete and therefore the site is not available within the required timescales. • Only the largest unit in the Valley Centre proposals is of a suitable size to accommodate any of the New Hall Hey units, at 929 sq.m. Barnfield Construction has confirmed that this unit is committed to a specific retailer and therefore is not available to accommodate the application proposal.

Suitability

• The largest unit proposed as part of the Valley Centre redevelopment is 929 sq.m. This is too small to accommodate the anchor retailer for New Hall Hey. The development could not come forward without the anchor unit and therefore the site is considered to be unsuitable. • It is understood that the proposals for the Valley Centre are at a relatively advanced stage and although there may be minor alterations, there will not be any more large units included within the development as these do not accord with the character of the development that the Council wishes to achieve. There will therefore not be any available units of a suitable size within the development. • The servicing arrangements are not suitable for the large scale HGV’s that deliver for bulky goods retailers. Such vehicles are required because of the size and nature of the goods sold and it is a requirement of the application proposal that the site must be able to sell all goods within Class A1. • A retail warehouse development on this site does not accord with the Conservation Area status of the area and would not reflect the Council’s objectives for a development that will extend the existing Town Centre and be similar in character (Core Strategy Policy AVP4).

Viability

• N/A

Summary

• The site is coming forward for a development that will not be delivered within the required timescales and the only larger unit is committed to a specific retailer, therefore it is not available. • The form of retail floorspace coming forward as part of the scheme does not accord with that required by the retailers wishing to locate at New Hall Hey, therefore it is not suitable.

5. Kay Street Car Park

Site Details

Site Area 2770 sq.m

Location Located within Rawtenstall Town Centre, to the north of the Valley centre redevelopment site.

Site Description A car park that is in active use.

Site Constraints

Planning Policy Within the Town Centre, as defined in the Core Strategy proposals map. It is an edge of centre site.

Adjacent Uses Bound to the east by Rawtenstall Cricket Club, to the south by residential and commercial uses fronting Kay Street, to the west by Rawtenstall’s Post Office and to the north by an area of public open space.

Site Access The site is accessed from Kay Street.

Availability

• The site is in active use as a car park and was busy at the time of the site visit. This performs a valuable role in supporting town centre businesses and the vitality and viability of the centre. There is no known strategy of car park consolidation, therefore it is not considered to be available.

Suitability

• The site could only accommodate a single retail unit, which is not the preferred situation. • It is in a low profile location, behind existing commercial properties and therefore would not benefit from an interrelationship with other established retailers. • The site is an irregular shape that could not accommodate a retail warehouse type unit, rendering it unsuitable. • This car park is performing a valuable role supporting town centre retailers and therefore the vitality and viability of the centre. The site could not accommodate the car parking currently on site along with the retail unit, therefore there would be a net loss of car parking if it was redeveloped. There is no known programme of car park consolidation and there is a risk loss of the car parking spaces could adversely affect the vitality and viability of the centre, rendering it unsuitable.

Viability

• N/A

Summary

• The site is a heavily used car park that is not available to accommodate the proposals. • It is an irregular shape and is in a low profile location, therefore the site unsuitable.

6. Heritage Arcade

Site Details

Site Area 1000 sq.m

Location Fronting Bacup Road and adjacent to Rawtenstall Bus Station.

Site Description A vacant building which was originally a cinema that opened in 1920. It has a prominent façade which has local significance.

Site Constraints

Planning Policy Within the Town Centre and Conservation Area as defined in the Core Strategy Proposals Map. The building is not Listed but it is understood that the Council values it architectural qualities and considers that it contributes to the Conservation Area.

Adjacent Uses To the east of the site is Rawtenstall Bus Station. To the west are commercial units that front Bacup Street, to the south is a Family Bargains retail warehouse unit and to the north is the Valley Centre redevelopment site.

Site Access The site is accessed from Bacup Road.

Availability

• The site is vacant and being actively marketed, therefore it is considered to be available.

Suitability

• It is understood that the Council wishes to retain this building. In its current form it does not meet the requirements of the retailers interested in New Hall Hey which require modern, retail warehouse units that provide flexible accommodation. • It would only be able to accommodate a single retail unit which is not the preferred situation. • The site does not include adjacent car parking and it does not have a servicing area to enable servicing by HGV. It is therefore not suitable for the type of retailer that wishes to locate at New Hall Hey.

Viability

• N/A

Summary

• The building is physically constrained and does not meet the requirements of the retailers that want to locate a New Hall Hey in terms of its physical layout and the lack of car parking and servicing facilities, therefore it is not suitable.

7. Former College Site

Site Details

Site Area 0.8ha

Location Located 300m from the PSA, to the south of Rawtenstall Town Centre.

Site Description A cleared site that formerly comprised Rawtenstall College.

Site Constraints

Planning Policy The Core Strategy indicates that this site should come forward as a hotel. The site falls outside of the Town Centre and at 330m from the Town Centre is an out of centre site that is not sequentially preferable to the application site.

This is not to say that the college site is sequentially inferior to New Hall Hey Retail Park and the Telford and Wrekin Borough Council and St Modwen Developments Limited v Secretary of State for Communities and Local Government (2013 EWHC 1638) confirms that sites can be considered to be sequentially equal and given the similarities in the accessibility of the locations, it is considered that this may be the case here.

Adjacent Uses To the north is residential development. To the south is Rawtenstall Train Station and New Hall Hey.

Site Access The site is accessed from the A682 junction at the north east of the site.

Availability

• The site is cleared and appears to be ready for redevelopment. • It is understood that historic planning permissions for a hotel, public house and apartments on the site has expired. • The site is in control of the West Register. An alternative scheme for this site is currently being prepared, based on market interest that does not include retail floorspace and therefore it will not be coming forward for a form of development that could accommodate the application proposal.

Suitability

• The site is too small to accommodate the full development with associated car parking and servicing areas and could most likely only accommodate one retail unit which is not ideal. • The site does not relate closely to existing retail development and therefore it would not benefit from an interrelationship which is a requirement for the proposals.

Viability

• N/A

Summary

• The site is out of centre and therefore is not sequentially preferable to the application site. • It is not suitable as it is an island site with no connections to existing retail development and will shortly be coming forward for a scheme that does not include retail floorspace. It is also too small to accommodate the entire development.

Appendix 5 Table 1: Study Area Population Growth

Change Sub Zone 2014 2019 14-19 1 Haslingden 21,797 22,430 633 2 Rawtenstall/Waterfoot 28,257 29,252 995 3 Bacup 23,083 23,945 862 4 Ramsbottom 22,973 23,821 848 TOTAL 96,110 99,448 3,338

Notes: ONS based Population Projections from Experian MMG3 (Post 2011 Census) (2012) Experian data is in 2012 Prices

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 2a: Convenience Retail Expenditure Growth per Person

Convenience Spending per Person (£) Growth (£) Zone 2014 2019 14-'19 1 Haslingden 1,947 2,013 66 2 Rawtenstall/Waterfoot 1,986 2,052 66 3 Bacup 1,887 1,950 63 4 Ramsbottom 2,175 2,248 73

Notes: 2012 Prices SFT deducted using Retail Planner Note 11 Appendix 3 SFT - 2.1% 2012, 2.5% 2013, 2.7% 2014, 3% 2015, 3.2% 2016, 3.5% 2017, 3.8% 2018, 4% 2019 Retail exp per head grown by Retail Planner Note 11 Figures 1a and 1b Retail Growth per head - 2012 -0.6%, 2013 -0.6%, 2014 -0.3%, 2015 0.1%, 2016-2019 0.8%

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 2b: Comparison Retail Expenditure Growth per Person

Comparison Spending per Person (£) Growth (£) Sub Zone 2014 2019 14-'19 1 Haslingden 3,174 3,672 498 2 Rawtenstall/Waterfoot 3,308 3,827 519 3 Bacup 2,928 3,388 460 4 Ramsbottom 3,912 4,526 614

Notes: SFT deducted using Retail Planner Note 11 Appendix 3 SFT- 10.5% 2012, 10.8% 2013, 11.6% 2014, 12.3% 2015, 13% 2016, 13.8% 2017, 14.5% 2018, 15.1% 2019 Retail exp per head grown by Retail Planner Note 11 Figures 1a and 1b Retail Growth per head - 3.1% 2012, 3.2% 2013, 2.3% 2014, 2.8% 2015, 3.0% 2016-2019

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 3a: Total Convenience Retail Expenditure and Growth in Catchment Area

Spending Power (£million) Sub Zone 2014 2019 14-'19 1 Haslingden 42.4 45.2 2.7 2 Rawtenstall/Waterfoot 56.1 60.0 3.9 3 Bacup 43.6 46.7 3.1 4 Ramsbottom 50.0 53.5 3.6 TOTAL 192.1 205.4 13.3

Notes: Tables 1 and 2a

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 3b: Total Comparison Retail Expenditure and Growth in Catchment Area

Spending Power (£million) Sub Zone 2014 2019 14-'19 1 Haslingden 69.2 82.4 13.2 2 Rawtenstall/Waterfoot 93.5 111.9 18.5 3 Bacup 67.6 81.1 13.5 4 Ramsbottom 89.9 107.8 17.9 TOTAL 320.1 383.2 63.1

Notes: Tables 1 and 2b

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 4: Convenience Shopping Penetration Rates- From RTRS

Centre/Facilities Zone 1 Zone 2 Zone 3 Zone 4 Rawtenstall/ Haslingden Bacup Ramsbottom Inflow Waterfoot Asda, Rawtenstall 16% 48% 26% 12% 5% Tesco, Rawtenstall 2% 20% 15% 4% 5% Other Rawtenstall 1% 5% 1% 1% 2% Bacup 0% 0% 20% 0% 2% Haslingden 10% 2% 0% 0% 2% Waterfoot 0% 5% 1% 0% 2% Local Centres 0% 1% 6% 1% 2% Tesco, Sykes Lane 35% 14% 2% 10% 5% Other Rossendale 3% 0% 0% 0% 2% Rossendale Sub-Total 67% 95% 71% 28% 27% Ramsbottom 0% 0% 0% 29% Catchment Area Total 67% 95% 71% 57% Outflow from Catchment Area Bury 1% 0% 0% 31% Accrington 28% 0% 0% 1% Rochdale 0% 1% 15% 0% Burnley 1% 3% 8% 0% Outside of study area 3% 1% 6% 11% Expenditure Outflow 33% 5% 29% 43% Total 100% 100% 100% 100% 27%

Notes: Source: Rossendale Retail and Town Centres Study Update 2009 - Table 4F Table 5: Convenience Retail Turnover 2014- Based on Shopping Patterns from RTRS- Baseline

Expenditure (£m) Centre/Facilities Zone 1 Zone 2 Zone 3 Zone 4 In-Flow Total

Rawtenstall/ Haslingden Bacup Ramsbottom Waterfoot

Expenditure 2014 42.4 56.1 43.6 50.0

Asda, Rawtenstall 6.79 26.94 11.32 6.00 2.23 53.27 Tesco, Rawtenstall 0.85 11.22 6.53 2.00 0.89 21.50 Other Rawtenstall 0.42 2.81 0.44 0.50 0.07 4.24 Bacup 0.00 0.00 8.71 0.00 0.15 8.86 Haslingden 4.24 1.12 0.00 0.00 0.09 5.46 Waterfoot 0.00 2.81 0.44 0.00 0.05 3.29 Local Centres 0.00 0.56 2.61 0.50 0.06 3.74 Tesco, Sykes Lane 14.85 7.86 0.87 5.00 1.25 29.83 Other Rossendale 1.27 0.00 0.00 0.00 0.02 1.29 Rossendale Sub-Total 28.43 53.31 30.93 13.99 4.82 131.48 Ramsbottom 0.00 0.00 0.00 14.49 14.49 Catchment Area Total 28.43 53.31 30.93 28.48 145.97 Outflow from Catchment Area Bury 0.42 0.00 0.00 15.49 15.91 Accrington 11.88 0.00 0.00 0.50 12.38 Rochdale 0.00 0.56 6.53 0.00 7.09 Burnley 0.42 1.68 3.48 0.00 5.59 Outside of study area 1.27 0.56 2.61 5.50 9.94 Expenditure Outflow 14.00 2.81 12.63 21.49 50.93 Total Expenditure Generated in CA 42.44 56.12 43.56 49.97 196.90

Notes: Source: Tables 3a, 4 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 5F

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 6: Convenience Retail Turnover 2014 - Updated to reflect changes since RTRS was published

Inside Catchment Area Outside Catchment Area Asda, Todmorden Total Centre/Facilities Total Morrisons, Bacup Family Bargains Aldi, Ramsbottom Lidl, Rawtenstall Tesco, Accrington Commitment

Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion (£m)

Expenditure 2014 T/O (£m) £13.06 T/O (£m) £0.29 T/O (£m) £6.03 T/O (£m) £2.49 T/O (£m) £47.02 T/O (£m) £11.00 % £m % £m % £m % £m % £m % £m Asda, Rawtenstall 53.27 38% 4.96 50% 0.14 8% 0.48 60% 1.49 8% 3.76 3% 0.33 42.10 Tesco, Rawtenstall 21.50 22% 2.87 35% 0.10 5% 0.30 30% 0.75 8% 3.76 3% 0.33 13.39 Other Rawtenstall 4.24 1% 0.02 4.21 Lidl, Rawtenstall 2.49 15% 0.04 4% 0.24 2.20 Family Bargains 0.29 0.29 Rawtenstall Sub-Total 81.78 60% 7.84 100% 0.29 17% 1.03 91% 2.26 16% 7.52 6% 0.66 62.19 Bacup 8.86 5% 0.65 5% 0.55 7.65 Morrison's, Bacup 13.06 15% 1.65 11.41 Bacup Sub-Total 21.92 5% 0.65 20% 2.20 19.06 Haslingden 5.46 5.46 Waterfoot 3.29 3.29 Local Centres 3.74 1% 0.13 3.61 Tesco, Sykes Lane 29.83 8% 3.76 26.06 Other Rossendale 1.29 1.29 Ramsbottom 14.49 69% 4.16 10.33 Aldi, Ramsbottom 6.03 9% 0.22 5.81 Ramsbottom Sub-Total 20.52 69% 4.16 9% 0.22 16.14 Catchment Area Total 167.83 66% 8.62 100% 0.29 86% 5.19 100% 2.49 24% 11.28 26% 2.86 137.11 Outflow from Catchment Area Bury 15.91 14% 0.84 15.07 Accrington 12.38 12.38 Rochdale 7.09 7.09 Burnley 5.59 5.59 Outside of study area 9.94 9.94 Tesco, Accrington 47.02 47.02 Asda, Todmorden 11.00 11.00 Total Outflow 108.94 24% 11.28 26% 2.86 123.08 Claw-back into Catchment Area 34% 4.44 14% 0.84 5.28 Total Expenditure Retained in CA 167.83 13.06 0.29 5.19 2.49 -11.28 -2.86 142.39

Notes: Source: Tables 3a, 4 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 5F Morrison's, Bacup trade diversion taken from Table 2 of Planning and Retail Statement submitted with application Tesco, Accrington trade diversion taken from Table 7a of the Retail Statement submitted with application ref:11/08/0044 Lidl Rawtenstall T/O from RTRS Table 3A Aldi, Ramsbottom T/O from Bury Retail Study Convenience Retail Assessment Table 9 Floorspace efficiencies updated using Retail Planner Briefing Note 11 Tables 4a and b 2009-2011 floorspace efficiencies obtained from Retail Planner Note 8.1 Tables 4a and b Pre-2009 floorspace efficiencies assumed to be 0% in accordance with RTRS Table 9F Family Bargains trade diversions based on size of store, location, brand, accessibility and type of goods Morrisons, Bacup trade diversions based on Planning and Retail Statement submitted with application- Table 2 Aldi, Ramsbottom based on Bury Retail Study Table 9 Total T/O of Changes Since 2008 takes account of claw-back and outflow of expenditure T/O directed to destinations- Morrisons total takes account of outflwo and clawback Total T/O column deducts outflow of expenditure 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 7: Convenience Retail Turnover 2019 - Based on Shopping Patterns from RTRS

Centre/Facilities Expenditure (£m) Zone 1 Zone 2 Zone 3 Zone 4 In-Flow Total

Rawtenstall/ Haslingden Bacup Ramsbottom Waterfoot

Expenditure 2019 45.15 60.03 46.69 53.55

Asda, Rawtenstall 7.22 28.81 12.14 6.43 2.23 2.21 59.03 Tesco, Rawtenstall 0.90 12.01 7.00 2.14 0.89 0.88 23.82 Other Rawtenstall 0.45 3.00 0.47 0.54 0.07 0.05 4.58 Bacup 0.00 0.00 9.34 0.00 0.15 0.13 9.61 Haslingden 4.52 1.20 0.00 0.00 0.09 0.07 5.88 Waterfoot 0.00 3.00 0.47 0.00 0.05 0.03 3.55 Local Centres 0.00 0.60 2.80 0.54 0.06 0.04 4.04 Tesco, Sykes Lane 15.80 8.40 0.93 5.35 1.25 1.23 32.97 Other Rossendale 1.35 0.00 0.00 0.00 0.02 0.00 1.38 Rossendale Sub-Total 30.25 57.02 33.15 14.99 4.64 140.07 Ramsbottom 0.00 0.00 0.00 15.53 15.53 Catchment Area Total 30.25 57.02 33.15 30.52 155.59 Outflow from Catchment Area Bury 0.45 0.00 0.00 16.60 17.05 Accrington 12.64 0.00 0.00 0.54 13.18 Rochdale 0.00 0.60 7.00 0.00 7.60 Burnley 0.45 1.80 3.74 0.00 5.99 Outside of study area 1.35 0.60 2.80 5.89 10.65 Total Outflow 14.90 3.00 13.54 23.03 54.47 Total Expenditure Generated in CA 45.15 60.03 46.69 53.55 210.06

Source: Tables 3a, 4 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 5F Morrison's, Bacup trade diversion taken from Table 2 of Planning and Retail Statement submitted with application Tesco, Accrington trade diversion taken from Table 7a of the Retail Statement submitted with application ref:11/08/0044 Lidl Rawtenstall T/O from RTRS Table 3A Aldi, Ramsbottom T/O from Bury Retail Study Convenience Retail Assessment Table 9 Floorspace efficiencies updated using Retail Planner Briefing Note 11 Tables 4a and b (2014 -1.2%, 2015 -0.7% and 2016-20 0%) Historic floorspace efficiencies obtained from Retail Planner Note 8.1 Tables 4a and b Pre-2009 floorspace efficiencies assumed to be 0% in accordance with RTRS Table 9F Family Bargains trade diversions based on size of store, location, brand, accessibility and type of goods Morrisons, Bacup trade diversions based on Planning and Retail Statement submitted with application- Table 2 Aldi, Ramsbottom based on Bury Retail Study Table 9

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 8: Convenience Retail Turnover 2019 - Updated to reflect changes since RTRS was published

Centre/Facilities Changes Since 2009 - Outside Catchment Changes Since 2009 - Inside Catchment Area Area Total Total Morrisons, Bacup Family Bargains Aldi, Ramsbottom Lidl, Rawtenstall Tesco, Accrington Asda, Todmorden Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion (£m) Expenditure 2019 T/O (£m) 13.04 T/O (£m) 0.27 T/O (£m) 6.01 T/O (£m) 2.47 T/O (£m) 34.06 T/O (£m) 10.99 % £m % £m % £m % £m % £m % £m Asda, Rawtenstall 59.03 38% 4.93 50% 0.13 8% 0.48 60% 1.48 8% 2.72 3% 0.33 48.96 Tesco, Rawtenstall 23.82 22% 2.90 35% 0.09 5% 0.30 30% 0.74 8% 2.72 3% 0.33 16.74 Other Rawtenstall 4.58 1% 0.02 4.56 Lidl, Rawtenstall 2.47 15% 0.04 4% 0.24 2.19 Family Bargains 0.27 0.27 Rawtenstall Sub-Total 90.18 60% 7.82 100% 0.27 17% 0.17 91% 2.25 16% 5.45 6% 0.66 73.56 Bacup 9.61 5% 0.65 5% 0.55 8.41 Morrison's, Bacup 13.04 15% 1.65 11.39 Bacup Sub-Total 22.65 5% 0.65 20% 2.20 19.80 Haslingden 5.88 5.88 Waterfoot 3.55 3.55 Local Centres 4.04 1% 0.13 3.91 Tesco, Sykes Lane 32.97 8% 2.72 30.25 Other Rossendale 1.38 1.38 Ramsbottom 15.53 69% 4.15 9% 0.22 11.16 Aldi, Ramsbottom 6.01 6.01 Ramsbottom Sub-Total 21.54 69% 4.15 9% 0.22 17.17 Catchment Area Total 182.20 66% 8.61 100% 0.27 86% 4.32 100% 2.47 24% 8.17 26% 2.86 155.51 Outflow from Catchment Area Bury 17.05 14% 0.84 16.21 Accrington 13.18 13.18 Rochdale 7.60 7.60 Burnley 5.99 5.99 Outside of study area 10.65 10.65 Tesco, Accrington 34.06 34.06 Asda, Todmorden 10.99 10.99 Expenditure Outflow 99.51 6% 0.74 14% 0.84 24% 8.17 26% 2.86 112.13 Claw-back into Catchment Area 34% 4.43 4.43 Total Expenditure Retained in CA 182.20 13.04 0.27 5.16 2.47 -8.17 -2.86 159.94

Notes: Source: Tables 3a, 4 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 5F Morrison's, Bacup trade diversion taken from Table 2 of Planning and Retail Statement submitted with application Tesco, Accrington trade diversion taken from Table 7a of the Retail Statement submitted with application ref:11/08/0044 Lidl Rawtenstall T/O from RTRS Table 3A Aldi, Ramsbottom T/O from Bury Retail Study Convenience Retail Assessment Table 9 Floorspace efficiencies updated using Retail Planner Briefing Note 11 Tables 4a and b 2009-2001 floorspace efficiencies obtained from Retail Planner Note 8.1 Tables 4a and b Pre-2009 floorspace efficiencies assumed to be 0% in accordance with RTRS Table 9F Family Bargains trade diversions based on size of store, location, brand, accessibility and type of goods Morrisons, Bacup trade diversions based on Planning and Retail Statement submitted with application- Table 2 Aldi, Ramsbottom based on Bury Retail Study Table 9 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 9: Convenience Benchmark Turnovers

2014 2019 Asda, Rawtenstall 50.28 50.26 Tesco, Rawtenstall 29.55 29.52 Other Rawtenstall 2.66 2.64 Lidl, Rawtenstall 2.78 2.75 Family Bargains 0.91 0.89 Rawtenstall Sub-Total 86.18 86.06 Bacup 2.29 2.27 Morrisons, Bacup 18.07 18.05 Bacup Sub-Total 20.37 20.32 Haslingden 4.41 4.39 Waterfoot 3.65 3.63 Local Centres 7.34 7.32 Tesco, Sykes Site 43.21 43.18 Other Rossendale 0.00 0.00 Ramsbottom 39.67 40.55 Aldi, Ramsbottom 6.60 6.58 Ramsbottom Sub-Total 46.27 47.13 TOTAL 211.44 212.02

Notes: Ramsbottom T/O from Bury Retail Study Convenience Goods Assessment Table 10 Rawtenstall, Bacup, Haslingden, Waterfoot, Local Centres, Tesco Sykes Site, Tesco Rawtenstall, Asda Rawtenstall floorspace from RTRS Table 1A Sales densites for centres from RTRS Table 1A Aldi Ramsbottom floorspace obtained from Bury Retail Study Conveniece Retail Assessment Table 13 Morrison's, Bacup floorspace from Planning and Retail Statement submitted with application Foodstore sales densities from Verdict 2013 unless otherwise specified inc Co-op's in centres Family Bargains sales density from Mintel Retail Rankings 2012 Family Bargains floorspace from Planning and Retail Statement submitted with planning application (Para. 6.12) Lidl, Rawtenstall floorspace from Committee Report for Ap ref: 2007/665 para. 3.1 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 10: Summary of Convenience Retail Performance 2014 to 2019

Centre 2014 2019

Available Expenditure Asda, Rawtenstall 42.10 48.96 Tesco, Rawtenstall 13.39 16.74 Other Rawtenstall 4.21 4.56 Lidl Rawtenstall 2.20 2.19 Family Bargains 0.29 0.27 Rawtenstall Sub-Total 62.19 73.56 Bacup 7.65 8.41 Morrison's, Bacup 11.41 11.39 Bacup Sub-Total 19.06 19.80 Haslingden 5.46 5.88 Waterfoot 3.29 3.55 Local Centres 3.61 3.91 Tesco, Sykes Site 26.06 30.25 Other Rossendale 1.29 1.38 Ramsbottom 10.33 11.16 Aldi Ramsbottom 5.81 6.01 Ramsbottom Sub-Total 16.14 17.17 Total 137.11 155.51 Benchmark Turnover Asda, Rawtenstall 50.28 50.26 Tesco, Rawtenstall 29.55 29.52 Other Rawtenstall 2.66 2.64 Lidl Rawtenstall 2.78 2.75 Family Bargains 0.91 0.89 Rawtenstall Sub-Total 86.18 86.06 Bacup 2.29 2.27 Morrison's, Bacup 18.07 18.05 Bacup Sub-Total 20.37 20.32 Haslingden 4.41 4.39 Waterfoot 3.65 3.63 Local Centres 7.34 7.32 Tesco, Sykes Site 43.21 43.18 Other Rossendale 0.00 0.00 Ramsbottom 39.67 40.55 Aldi Ramsbottom 6.60 6.58 Ramsbottom Sub-Total 46.27 47.13 Total 211.44 212.02 Expenditure Deficit/Surplus Asda, Rawtenstall -8.18 -1.30 Tesco, Rawtenstall -16.16 -12.78 Other Rawtenstall 1.55 1.92 Lidl Rawtenstall -0.58 -0.57 Family Bargains -0.63 -0.62 Rawtenstall Sub-Total -23.99 -12.50 Bacup 5.36 6.14 Morrison's, Bacup -6.66 -6.66 Bacup Sub-Total -1.30 -0.52 Haslingden 1.05 1.49 Waterfoot -0.36 -0.07 Local Centres -3.74 -3.41 Tesco, Sykes Site -17.14 -12.94 Other Rossendale 1.29 1.38 Ramsbottom -29.34 -29.39 Aldi Ramsbottom -0.80 -0.57 Ramsbottom Sub-Total -30.14 -29.96 Total -74.33 -56.52

Notes: Source: Tables 6, 8 and 9 2012 Prices Table 11: Comparison Shopping Patterns - From RTRS

Centre/Facilities Zone 1 Zone 2 Zone 3 Zone 4 Rawtenstall/ Haslingden Bacup Ramsbottom In-Flow Waterfoot Rawtenstall 10% 32% 17% 7% 5% Bacup 0% 1% 5% 0% 2% Haslingden (Inc Tesco, Skye Side) 10% 4% 1% 1% 5% Waterfoot 0% 1% 1% 0% 2% Local Centres 0% 0% 3% 0% 2% Rossendale Total 20% 38% 27% 8% Ramsbottom 0% 0% 0% 6% Catchment Area Total 20% 38% 27% 14% Outflow from Catchment Area Accrington 27% 5% 2% 2% Blackburn 16% 4% 1% 0% Bolton 2% 2% 1% 8% Burnley 4% 16% 17% 1% Bury 12% 16% 5% 52% Manchester 10% 11% 8% 15% Rochdale 1% 2% 31% 0% Other outside of study area 8% 6% 8% 8% Total Outflow 80% 62% 73% 86% Total Market Share 100% 100% 100% 100%

Notes: Source: Rossendale Retail and Town Centres Study Update 2009 - Table 3G Table 11: Comparison Shopping Patterns - From RTRS

Centre/Facilities Zone 1 Zone 2 Zone 3 Zone 4 Rawtenstall/ Haslingden Bacup Ramsbottom In-Flow Waterfoot Rawtenstall 10% 32% 17% 7% 5% Bacup 0% 1% 5% 0% 2% Haslingden (Inc Tesco, Skye Side) 10% 4% 1% 1% 5% Waterfoot 0% 1% 1% 0% 2% Local Centres 0% 0% 3% 0% 2% Rossendale Total 20% 38% 27% 8% Ramsbottom 0% 0% 0% 6% Catchment Area Total 20% 38% 27% 14% Outflow from Catchment Area Accrington 27% 5% 2% 2% Blackburn 16% 4% 1% 0% Bolton 2% 2% 1% 8% Burnley 4% 16% 17% 1% Bury 12% 16% 5% 52% Manchester 10% 11% 8% 15% Rochdale 1% 2% 31% 0% Other outside of study area 8% 6% 8% 8% Total Outflow 80% 62% 73% 86% Total Market Share 100% 100% 100% 100%

Notes: Source: Rossendale Retail and Town Centres Study Update 2009 - Table 3G Table 12: Comparison Retail Turnover 2014

Centre/Facilities Expenditure (£m) Zone 1 Zone 2 Zone 3 Zone 4 In-Flow Total

Rawtenstall/ Haslingden Bacup Ramsbottom Waterfoot

Expenditure 2014 69.2 93.5 67.6 89.9

Rawtenstall 6.92 29.91 11.49 6.29 2.44 57.05 Bacup 0.00 0.93 3.38 0.00 0.07 4.39 Haslingden (Inc Tesco, Syke Side) 6.92 3.74 0.68 0.90 0.54 12.77 Waterfoot 0.00 0.93 0.68 0.00 0.03 1.64 Local Centres 0.00 0.00 2.03 0.00 0.03 2.06 Rossendale Total 13.84 35.52 18.25 7.19 3.11 77.90 Ramsbottom 0.00 0.00 0.00 5.39 5.39 Catchment Area Total 13.84 35.52 18.25 12.58 83.30 Outflow from Catchment Area Accrington 18.68 4.67 1.35 1.80 26.50 Blackburn 11.07 3.74 0.68 0.00 15.48 Bolton 1.38 1.87 0.68 7.19 11.12 Burnley 2.77 14.96 11.49 0.90 30.11 Bury 8.30 14.96 3.38 46.73 73.37 Manchester 6.92 10.28 5.41 13.48 36.09 Rochdale 0.69 1.87 20.95 0.00 23.51 Other outside of study area 5.53 5.61 5.41 7.19 23.74 Total Outflow 55.35 57.95 49.34 77.29 239.93 Total Expenditure Generated in CA 69.18 93.47 67.59 89.87 323.22

Notes: Source: Tables 3B, 11 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 3G

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 13: Comparison Retail Turnover 2014 - Updated to reflect changes since RTRS was published

Centre/Facilities Changes to Provision Inside Catchment Area Changes to Provision Outside Catchment Area Amount of CA Total Total Directed Expenditure Asda, Todmorden to Destinations Directed to Family Bargains Valley Centre Demolition Tesco, Accrington The Rock Commitment Destinations in 2014 (£m) Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion (£m)

T/O (£m) 3.11 T/O (£m) -5.27 T/O (£m) 12.81 T/O 119.32 T/O 4.78 % £m % £m % £m % £m % £m Rawtenstall 57.05 75% 2.33 50% 2.64 57.35 Family Bargains 3.11 3.11 Valley Centre Demolition -5.27 -5.27 Rawtenstall Sub-Total 54.88 75% 2.33 50% 2.64 5% 0.64 5.74% 6.85 47.70 Bacup 4.39 10% 0.31 5% 0.24 3.84 Haslingden (Inc Tesco, Syke Side) 12.77 15% 0.47 5% 0.64 1.91% 2.28 9.38 Waterfoot 1.64 1.64 Local Centres 2.06 2.06 Ramsbottom 5.39 9.54% 11.38 -5.99 Catchment Area Total 81.13 3.11 2.64 1.28 20.51 0.24 64.84 Outside of Catchment Area Accrington 26.50 10% 0.53 25.98 Blackburn 15.48 15.48 Bolton 11.12 11.12 Burnley 30.11 10% 0.53 29.58 Bury 73.37 20% 1.05 72.32 Manchester 36.09 36.09 Rochdale 23.51 23.51 Other outside of study area 23.74 10% 0.53 23.21 Total Outflow 239.93 50% 2.64 10% 1.28 20.51 0.24 264.60 Claw-back Total Expenditure Retained in CA 81.13 64.84

Notes: Source: Tables 3B, 11 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 3G Family Bargains trade diversions based on size of store, location, brand, accessibility and type of goods Tesco, Accrington 2010 turnover adjusted by floorspace efficiencies to 2014 using Retail Planner Briefing Note 11 Appendix 3 Family Bargains Turnover obtained from Planning and Retail Statement submitted with application ref: 2011/0538 The Valley Centre has been demolished and so is shown as a loss of floorspace in 2014 Valley centre floorspace obtained from application from for application ref: 2011/0570 and sales density fo £3,000/sq.m applied Valley Centre vacancy rate assumed to be 50% at time of Retail Study as it is not stipulated Valley Centre trade diversion rates are assumed, based on shopping patterns in RTRS There are no figures available for the turnover of the Asda, Todmorden and so a benchmarke T/O has been applied Floorspace efficiencies obtained from Retail Planner Briefing Note 11 Table 4b 2009-2011 floorspace efficiencies obtained from Retail Planner Briefing Note 8.1 Table 4b Pre-2009 floorspace efficiencies assumed to be 0% in accordance with RTRS Table 9F Changes Since 2008 are both located in Rawtenstall 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 14: Comparison Retail Turnover 2019

Centre/Facilities Expenditure (£m) Zone 1 Zone 2 Zone 3 Zone 4 In-Flow Total

Rawtenstall/ Haslingden Bacup Ramsbottom Waterfoot

Expenditure 2019 82.4 111.9 81.1 107.8

Rawtenstall 8.24 35.82 13.79 7.55 2.48 67.87 Bacup 0.00 1.12 4.06 0.00 0.11 5.29 Haslingden (Inc Tesco, Syke Side) 8.24 4.48 0.81 1.08 0.58 15.18 Waterfoot 0.00 1.12 0.81 0.00 0.07 2.00 Local Centres 0.00 0.00 2.43 0.00 0.07 2.51 Rossendale Total 16.47 42.54 21.90 8.63 92.85 Ramsbottom 0.00 0.00 0.00 6.47 6.47 Study Area Total 16.47 42.54 21.90 15.09 99.32 Accrington 22.24 5.60 1.62 2.16 31.61 Blackburn 13.18 4.48 0.81 0.00 18.47 Bolton 1.65 2.24 0.81 8.63 13.32 Burnley 3.29 17.91 13.79 1.08 36.08 Bury 9.88 17.91 4.06 56.06 87.91 Manchester 8.24 12.31 6.49 16.17 43.21 Rochdale 0.82 2.24 25.15 0.00 28.21 Other outside of study area 6.59 6.72 6.49 8.63 28.42 Total Outflow 65.89 69.41 59.22 92.72 287.24 Total 82.36 111.95 81.13 107.81 386.56

Notes: Source: Tables 3b, 11 Rounding errors may occur

2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 15: Comparison Retail Turnover 2019 - Updated to reflect changes since RTRS was published

Centre/Facilities Change to Provision Inside Catchment Changes to Provision Outside Catchment Area Total Area Total Expenditure Family Bargains Valley Centre Tesco, Accrington The Rock Asda, Todmorden Directed to Destinations in Trade Diversion Trade Diversion Trade Diversion Trade Diversion Trade Diversion 2019 (£m) (£m)

T/O (£m) 3.15 T/O (£m) 9.80 T/O (£m) 12.85 T/O 119.36 T/O 4.82 % £m % £m % £m % £m % £m Rawtenstall 67.87 75% 2.36 50% 4.90 5% £0.64 6% £6.85 53.12 Family Bargains 3.15 3.15 Valley Centre Redevelopment 9.80 9.80 Rawtenstall Sub-Total 80.82 75% 2.36 50% 4.90 5% £0.64 6% £6.85 66.06 Bacup 5.29 10% 0.31 4.98 Haslingden (Inc Tesco, Syke Side) 15.18 15% 0.47 5% £0.64 2% £2.28 5% £0.24 11.54 Waterfoot 2.00 2.00 Local Centres 2.51 2.51 Ramsbottom 6.47 10% £11.38 -4.91 Catchment Area Total 99.32 100% 3.15 50% 4.90 10% £1.28 17% £20.52 5% £0.24 69.23 Outside of Catchment Area Accrington 31.61 20% 1.96 29.65 Blackburn 18.47 18.47 Bolton 13.32 13.32 Burnley 36.08 36.08 Bury 87.91 20% 1.96 85.96 Manchester 43.21 43.21 Rochdale 28.21 28.21 Other outside of study area 28.42 10% 0.98 28.42 Total Outflow 287.24 10% £1.28 17% £20.52 5% £0.24 309.28 Claw-back 50% 4.90 4.90 Total Expenditure Available 99.32 74.13

Notes: Source: Tables 3B, 11 Rounding errors may occur Inflow based on proportional increase in expenditure across Zones 1 to 4 from RTRS Table 3G Family Bargains trade diversions based on size of store, location, brand, accessibility and type of goods Tesco, Accrington 2010 turnover adjusted by floorspace efficiencies to 2014 using Retail Planner Briefing Note 11 Appendix 3 Family Bargains Turnover obtained from Planning and Retail Statement submitted with application ref: 2011/0538 Valley centre floorspace obtained from application from for application ref: 2011/0570 and sales density of £3,000/sq.m Valley Centre vacancy rate assumed to be 50% at time of Retail Study as it is not stipulated There are no figures available for the turnover of the Asda, Todmorden and so a benchmark T/O has been applied Floorspace efficiencies obtained from Retail Planner Briefing Note 11 Table 4b 2009-2011 floorspace efficiencies obtained from Retail Planner Briefing Note 8.1 Table 4b Pre-2009 floorspace efficiencies assumed to be 0% in accordance with RTRS Table 7G The Rock trade diversion assumed to be proportional to Shopping Patterns set out in Table 13 of the Bury Retail Study 2012 The Rock- Rawtenstall and haslingden split 75/25 to reflect proximity of centre to Bury and offer 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 16: Comparison Benchmark Turnovers

2014 2019

Rawtenstall 16.93 16.97 Family Bargains 4.94 4.98 Valley Centre -5.27 9.80 Rawtenstall Sub-Total 16.60 31.75 Bacup 2.83 2.87 Haslingden (Inc Tesco, Syke Side) 6.63 6.67 Waterfoot 1.08 1.12 Local Centres 2.71 2.75 Ramsbottom 8.88 8.92 TOTAL 38.72 54.08

Notes: Family Bargains floorspace and based on the Planning and Retail Statement submitted with the application paras. 6.15 and 6.12 Family Bargains sales density from Mintel Retail Rankings 2013 Valley centre floorspace obtained from application from for application ref: 2011/0570 and sales density of £4,000/sq.m applied as used in the RTRS Table 3A. Assumed to trade consistently at £4000/sq.m Floorspace for all centres (unless otherwise specified) taken as £3,000/sq.m for Rawtenstall and £2,000/sq.m for all other centres Sales density for Rawtenstall taken to be £4,000sq.m which accords with RTRS Tables 3A or the Valley Centre Sales density for all other centres assumed to be £2,000sq.m to reflect the scale of the centre and type of offer Ramsbottom floorspace and sales density taken from Bury Retail Study 2012 Table 17 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 17: Summary of Comparison Retail Performance 2014 to 2019

Centre 2014 2019

Available Expenditure Rawtenstall 57.35 53.12 Family Bargains 3.11 3.15 Valley Centre -5.27 9.80 Rawtenstall Sub-Total 55.19 66.06 Bacup 3.84 4.98 Haslingden (Inc Tesco, Syke Side) 9.38 11.54 Waterfoot 1.64 2.00 Local Centres 2.06 2.51 Ramsbottom -5.99 -4.91 Total 66.12 82.18 Benchmark Turnover Rawtenstall 16.93 16.97 Family Bargains 4.94 4.98 Valley Centre -5.27 9.80 Rawtenstall Sub-Total 16.60 31.75 Bacup 2.83 2.87 Haslingden (Inc Tesco, Syke Side) 6.63 6.67 Waterfoot 1.08 1.12 Local Centres 2.71 2.75 Ramsbottom 8.88 8.92 Total 38.72 54.08 Expenditure Deficit/Surplus Rawtenstall 40.43 36.16 Family Bargains -1.84 -1.84 Valley Centre 0.00 0.00 Rawtenstall Sub-Total 38.59 34.32 Bacup 1.01 2.10 Haslingden (Inc Tesco, Syke Side) 2.75 4.87 Waterfoot 0.56 0.88 Local Centres -0.65 -0.24 Ramsbottom -14.86 -13.83 Total 27.40 28.10

Notes: Source: Tables 15, 17 and 18 2012 Prices Inclusive of VAT where applicable, unless otherwise stated Table 18: Turnover of the Proposal

Table 20A: Proposed Turnover

Unit Type of Goods Gross Floorspace (sq.m) Net Floorspace (sq.m) Sales Density (£/sq.m) Turnover (£m) Unit A1 Conv/Comp 1162 929.6 11856.50 11.02 Unit A2 Comp 2235.5 1788.4 2390.00 4.27 Unit B Comp 1297.5 1038 2172.00 2.25 Unit C Comp 1493 1194.4 5104.00 6.10 Total 6188.00 4950.40 23.65

Table 20B: Turnover 2014 and 2019 (£m)

Convenience T/O 2014 Comparison T/O 2014 Convenience T/O 2019 Comparison T/O 2019 11.02 12.63 11.06 12.67

Notes: 2012 Prices Unit A1 sales density from Verdict 2013 Sales densities from Mintel Retail Rankings 2013 unless otherwise specified Table 20A: Unit A1 sales density taken as an average of Waitrose and M&S Simply Food Unit A2 sales density is TKMaxx, Unit B Pets at Home and Unit C Currys/PC World Table 19: Convenience Trade Diversion

T/O of Existing Impact on T/O of Existing Impact on Available Available Trade Diversion Trade Diversion Destinations Existing Trade Diversion Trade Diversion Destinations Existing Expenditure 2014 Expenditure 2019 Centre/Facilities Post-Application Destination Post-Application Destination % of Proposal £m of Proposal % of Proposal £m of Proposal £m £m % £m £m % T/O T/O T/O T/O Asda, Rawtenstall 42.10 13.00 1.43 40.67 3.40 48.96 13.00 1.44 47.52 2.94 Tesco, Rawtenstall 13.39 8.00 0.88 12.50 6.59 16.74 8.00 0.89 15.85 5.29 Other Rawtenstall 4.21 1.00 0.11 4.10 2.62 4.56 1.00 0.11 4.45 2.43 Lidl, Rawtenstall 2.20 2.20 2.19 2.19 Family Bargains 0.29 0.29 0.27 0.27 Rawtenstall Sub-Total 62.19 22.00 2.42 59.77 12.61 72.71 22.00 2.43 70.27 10.65 Bacup 7.65 7.65 8.41 Morrison's, Bacup 11.41 3.00 0.33 11.08 2.90 11.39 3.00 0.33 11.06 2.91 Bacup Sub-Total 19.06 3.00 0.33 18.73 2.90 19.80 3.00 0.33 11.06 2.91 Haslingden 5.46 5.46 5.88 5.88 Waterfoot 3.29 5.46 3.55 3.55 Local Centres 3.61 3.61 3.91 3.91 Tesco, Sykes Lane 26.06 8.00 0.88 25.18 3.38 30.25 8.00 0.89 29.36 2.93 Other Rossendale 1.29 1.29 1.38 1.38 Ramsbottom 10.33 1.00 0.11 10.22 1.07 11.16 1.00 0.11 11.05 0.99 Aldi, Ramsbottom 5.81 5.81 6.01 6.01 Ramsbottom Sub-Total 16.14 1.00 0.11 16.03 1.07 17.17 1.00 0.11 17.06 0.99 Catchment Area Sub-Total 137.11 34.00 3.75 133.36 19.95 154.65 34.00 3.76 150.89 17.48 Other Destinations (Outflow) Bury 15.07 8.00 0.88 14.19 5.85 16.21 8.00 0.89 15.33 5.46 Accrington (Inc Tesco) 23.67 40.00 4.41 19.26 18.63 21.35 40.00 4.43 16.93 20.73 Rochdale 7.09 5.00 0.55 6.54 7.77 7.60 5.00 0.55 7.05 7.27 Burnley 5.59 8.00 0.88 4.71 15.77 5.99 8.00 0.89 5.10 14.78 Other outside of catchment area 9.94 5.00 0.55 9.39 5.54 10.65 5.00 0.55 10.09 5.20 Asda, Todmorden 2.86 10.99 Outflow of Expenditure from CA 64.23 66.00 7.27 54.09 53.56 72.79 66.00 7.30 54.50 53.44 Table 20: Comparison Trade Diversion

T/O of Exising Impact on T/O of Existing Impact on Available Available Trade Diversion Trade Diversion Destinations Existing Trade Diversion Trade Diversion Destinations Existing Expenditure 2014 Expenditure 2019 Centre/Facilities Post-Application Destination Post-Application Destination % of Proposal £m of Proposal % of Proposal £m of Proposal £m £m % £m £m % T/O T/O T/O T/O Rawtenstall 57.35 9.00 1.14 56.22 1.98 53.12 6.00 0.76 52.36 1.43 Family Bargains 3.11 1.00 0.13 2.98 4.07 3.15 1.00 0.13 3.02 4.03 Valley Centre -5.27 -5.27 9.80 3.00 0.38 9.42 3.88 Rawtenstall Sub-Total 55.19 10.00 1.26 53.93 6.05 66.06 10.00 1.27 64.80 9.34 Bacup 3.84 1.00 0.13 3.71 3.29 4.98 1.00 0.13 4.85 2.55 Haslingden (Inc Tesco, Syke Side) 9.38 2.00 0.25 9.13 2.69 11.54 2.00 0.25 11.29 2.20 Waterfoot 1.64 1.64 2.00 2.00 Local Centres 2.06 2.06 2.51 2.51 Ramsbottom -5.99 -5.99 -4.91 -4.91 Catchment Area Total 66.12 13.00 1.64 64.48 12.03 82.18 13.00 1.65 80.53 14.08 Other Destinations (Outflow) Accrington (Inc Tesco) 27.26 12.00 1.52 25.74 5.56 30.94 13.00 1.65 29.29 5.32 Blackburn 15.48 8.00 1.01 14.47 6.52 18.47 8.00 1.01 17.45 5.49 Bolton 11.12 5.00 0.63 10.49 5.68 13.32 5.00 0.63 12.69 4.75 Burnley 29.58 11.00 1.39 28.20 4.69 36.08 11.00 1.39 34.68 3.86 Bury 72.32 23.00 2.90 69.41 4.02 85.96 23.00 2.91 83.04 3.39 Manchester 36.09 15.00 1.89 34.19 5.25 43.21 15.00 1.90 41.31 4.40 Rochdale 23.51 8.00 1.01 22.50 4.30 28.21 8.00 1.01 27.20 3.59 Other outside of study area 23.21 5.00 0.63 22.58 2.72 28.42 4.00 0.51 27.91 1.78 Outflow of Expenditure from CA 238.57 87.00 10.98 227.59 38.73 284.61 87.00 11.02 273.59 32.58 Appendix 6 Investment For Sale

..", . --., ~'"~,--

New Hall Hey " Retail Park, Rawtenstall New Hall Hey, Rawtenstall

,,-~ ~.~~ "-

Tenure

The property is held freehold Market Commentary

Retail warehousing provision in Rawtenstall is weak. A 2,849.80 sq m (30,675 sq ft) Focus DIY store is located approximately 450 metres to the west, opposite a Tesco supermarket. There are no other retail warehouse operators in the immediate area. The subject park will therefore be the main focus for retail warehousing in the town. We believe the prospects for the operators to trade well from this location are excellent with the potential for rental growth in the future. VAT

;>- Our clients have elected to charge VAT; hence the sale will attract VAT. However we envisage the " sale will be dealt with as a ''Transfer of a Going Concern".

Proposals

We are instructed to seek offers of £12,000,000 (Twelve million pounds) exclusive of VAT and subject to contract for the freehold interest in the property. A purchase at this level reflects a net initial yield of 5.74% assuming purchaser's costs of 5.75%. Investment Considerations

We are of the opinion that the property offers the following benefits to a purchaser.

. Brand New Retail Park.

. Excellent location on the A682 bypass.

. Let to established retailers / restaurants.

. The only retail warehouse park in Rawtenstall.

. 100% of income has an unexpired lease term of 15 years or more.

. 67.5% of income has an unexpired lease term of 20 years.

n New Hall Hey, Rawtenstall

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For further information or to arrange an inspection please contact:-

Russell Hall Chris Con nor DTZ DTZ 1 Marsden Street 1 Marsden Street Manchester Manchester M2 1HW M2 1HW Tel: 0161 2358981 Tel: 0161 4553768 Fax: 0161 455 3799 Fax: 0161 4553799 [email protected] [email protected]

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Property Misdescriptions

1) Misrepresentation Act 1967: DTZ for themselves and for the vendor(s) of this property, whose agent they are, give notice that:

i. the particulars are set out as a general outline for the guidance of intending purchasers and do not constitute, not constitute part of, an offer or contract;

ii. all descriptions, dimensions, floor areas, photographs, reference to condition and necessary permission for use and occupation and other details are given without responsibility and any intending purchasers should not rely on them as statements or representations of fact, but must satisfy themselves by inspection or otherwise as to the correctness of each of them;

iii. The vendor(s) or lessor(s) do not make or give nor any person in the employment of DTZ has any authority to make or give, any representation or warranty whatever in relation to this property;

2) Finance Act 1989: All negotiations are on a subject to contract and exclusive of VAT basis, unless specifically stated to the contrary;

3) Property Misdescriptions Act 1991: The particulars are believed to be correct at the time of compilation but may be subject to subsequent amendment.

Plans

The plans are published for convenience of identification only, and although believed to be correct, their accuracy is not guaranteed and does not form part of any contract.

Date of Particulars: May 2008

[ n: Tenancy Schedule

Tenant "Size Lease Rent,PA Comments SqM Terms (£psf) 'cc (SaFU cc, '" ,cc""

Unit A1 Homebase Ltd 2,322.50 20 year FR&llease from £362,500 PC expected at the end of June 2008. (25,000) PC with 5 yearly reviews (£14.50)

743.20 Unit A2 Pets @ Home Ltd 15 year FR&llease from £128,000 PC expected at the end of June 2008. (8,000) PC with 5 yearly reviews (£16.00) (

743.20 £128,000 Unit A3 Argas Ltd 20 year FR&llease from PC expected at the end of June 2008. (8,000) PC with 5 yearly reviews (£16.00)

Unit C1 Kentucky Fried 176.51 20 year FR&llease from £47,500 Tenant's break at the end of the 15thyear. Chicken (GB) Ltd (1,900) PC with 5 yearly reviews (£25.00)

Unit C2 City Centre 329.80 25 year FR&llease from £62,125 T/AFrankie and Benny's. Tenant's break at the Restaurants (UK) Ltd (3,550) PC with 5 yearly reviews (£17.50) end of the 15thyear. "" " " ,', 4,315.21 Total" £728,125 (46,450) ','"

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TO LET RETAIL WAREHOUSE

UNIT A1, NEW HALL HEY RETAIL PARK, NEW HALL HEY, RAWTENSTALL

\ New retail warehouse. AVAILABLE SPACE 2,399m² (25,790 sq ft) \ Planning consent for bulky goods/DIY. \ Adjacent to two smaller retail warehouses at the entrance to Rawtenstall.

LOCATION RATEABLE VALUE

New Hall Hey is a mixed use retail/employment park The property has yet to be assessed for rating purposes. located on the A682 at the entrance to the town of Rawtenstall.

VAT Rawtenstall is approximately 15 miles to the north of

Manchester and has access to the national motorway Prices and rental are exclusive of VAT if chargeable. network via the A682 and M66.

DESCRIPTION TERMS

The property comprises a single storey retail warehouse The property is available on a leasehold basis. clad in profile metal sheeting. The premises have an entrance lobby to the front and space for a garden centre Rents available upon request. and storage to the rear. Internally the premises has a main shop area with ancillary facilities to the rear. The eaves LEGAL COSTS height is 6.68m. Each party to be responsible for their own legal costs The premises have been measured in accordance with the incurred in the transaction. RICS Code of Measuring Practice with the following gross internal floor area:- VIEWING Floor area 2,399m2 (25,790sq.ft.) By prior arrangement with the agents: Externally the premises share a car park with two adjacent retail units. Eddisons

File Ref / 709.1589a

Tel / 0113 241 0940

Email / [email protected]

JANUARY 2012 SUBJECT TO CONTRACT

0113 241 0940