SHP2016 - PSA Retail Assessment

8/15/2019 SHP2016 - PSA Retail Assessment

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STONE HILLPARK LIVE WORK PLAY

A brighter future for

Thanet and East Kent

SHP1-4.4

Planning StatementAddendum:Retail Assessment


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Stone Hill Park Contents

April 2016 gva.co.uk

Contents

1. Introduction................................................................................................................................................... 1

2. Planning Policy Framework ........................................................................................................................ 3

3. Retail Capacity Assessment ...................................................................................................................... 7 4. Health Checks ............................................................................................................................................ 12

5. Impact Assessment .................................................................................................................................... 14

6. Sequential Assessment .............................................................................................................................. 17

7. Conclusions ................................................................................................................................................. 22

Appendices

Appendix 1 Retail Capacity Assessment

Prepared By: Kate Timmis

Checked by: Elle MilimukaStatus: Draft

Draft Date: April 2016

For and on behalf of GVA Grimley Limited


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Stone Hill Park Retail Assessment

April 2016 gva.co.uk 1

1. Introduction

1.1 This Retail Assessment has been prepared in support of a Hybrid Planning Application (‘the

Application’) for comprehensive mixed use redevelopment of the former Manston Airport

(‘the Site’) in Thanet District Counc il. The Application is submitted by Stone Hill Park Limited

(‘the Applicant’).

1.2 The proposed description of development is as follows:

Co m p rehe nsive red eve lop m ent o f the site involv ing the d em ol it ion o f exist ing b uild ing s a nd

struc tures a nd rem ova l of ha rd sta nd ing a nd a ssoc iated infra struc ture, a nd p rovision o f mixed

use d eve lop m ent . Ap p l ic a t ion subm it ted in hyb rid form (pa rt -ou t line a nd pa rt -de ta i led ) .

The o ut line elem ent c om p rises a n out l ine p la nning a p p lic a t ion (w ith a ll m a tters exc ep t Ac c ess

reserved for future d ete rm inat ion) for the p rovision o f :

• Build ing s/ f lo orsp a c e fo r the fol lo w ing uses:

o Em p lo ym e nt (Use C lasse s B1a -c/ B2/B8)

o Reside ntia l (Use C lasse s C3/ C 2)

o Re ta il (Use C la sse s A1-A5)

o Ed uc a tion a nd o the r non-reside ntial inst itut ion s (Use C lass D1)

o Sp ort a nd rec rea tion (Use C lass D2)

o Hot e l (Use C lass C1)

• Op en spa c e/ la nd sc a p ing ( inc lud ing o utdo or sp or t / rec rea t ion fac ilit ies)

o Ca r pa rk ing

o Infrastruc ture (inc luding roa d s a nd uti lit ies)

o Site p rep a ra t ion a nd othe r a ssoc iated wo rks

The fu ll/ d e ta iled e leme nt o f the a p p l ic a t ion c om pr ises:

• Ch a ng e o f Use o f reta ined exist ing b uild ing s

• De ve lop m en t o f Pha se 1 c om p rising fo ur ind ustr ia l units (Use C la ss B1c / B2/ B8) with a nc illa ry

c a r p a rking a nd a ssoc ia ted infra struc ture

• Ac c ess

1.3 The masterplan aspires to deliver a sustainable, mixed use environment which enables people

to work shop and access day-to-day services close to where they live. A fundamental design

principle is the “walkable neighbourhood,” which will encourage residents and visitors to live


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sustainably by providing a range of necessary facilities and amenities within easy distance of

their homes and places of work. To deliver this vision, a new local centre is proposed within the

heart of the community, within 15 minutes’ walk of all proposed residential areas.

1.4 The local centre will comprise a variety of new retail, service and community facilities, focused

around a traditional “High Street”. It is intended that this will include a small/medium-sized

foodstore, cafes/restaurants, GP and pharmacy, community hall, hotel and other leisure

fac ilities. In order to support the day to day needs of the proposed population, the masterplan

includes provision for the following mix and quantum of main town centre uses1:

• Maximum 3,100 sqm (GIA) of retail (Class A1-A5) floorspace. Of which, a maximum of

1,100sqm (net) will be for Class A1 convenience sales floorspace use, and a maximum of

563 sqm (net) will be for Class A1 comparison sales floorspace.

• Maximum 1,700 sqm office (Class B1a) floorspace;

• Maximum of 120 hotel bedrooms (Class C1); and

• Maximum 11,500 sqm (GIA) sports and leisure fac ilities (Class D2), including scope for

provision of small scale sport/recreation facilities to meet the local needs of

residents/workers as well as provision of a regionally significant sports facility (the

applicant’s aspiration is for this to be an indoor swimming pool).

1.5 This Retail Assessment justifies the mix and quantum of main town centre uses proposed and

assesses the proposal against relevant NPPF impact and sequential tests. The report is

structured as follows:

• Section 2 reviews the relevant policy framework with respect to main town centre uses

proposed;

• Section 3 forecasts the additional retail convenience and comparison expenditure which

will be generated by the proposed local population an estimates the available to support

new retail floorspace and service businesses within the masterplan;

• Section 4 provides a health check of local centres in the immediate vicinity of the Site in

order to inform judgements about potential impact;

• Section 5 assesses the proposal in light of the NPPF impact tests;

• Section 6 assesses the proposal in light of the NPPF sequential test; and

• Section 7 concludes that the proposal complies with relevant policy and guidance.

1 Defined by the NPPF as retail development (including warehouse c lubs and fac tory outlet centres); leisure, entertainment

facilities the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs,night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls); offices; and arts, culture and tourism

development (including theatres, museums, galleries and concert halls, hotels and conference fac ilities) (Annex 2).


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2. Planning Policy Framework

2.1 Section 38(6) of the Planning and C ompulsory Purchase Act (2004) requires planning

applications to be determined in accordance with the Development Plan unless material

considerations indicate otherwise.

National Planning Policy Framework (NPPF) 2012

2.2 The National Planning Policy Framework (NPPF) was published on 27th March 2012 and is a

material consideration in the determination of planning applications. It sets the planning

policies for England and how these are expected to be applied.

2.3

The NPPF continues to advocate a ‘town centre first’ approach and requires planning policiesto positively promote competitive town centre environments. The policy framework aims to

ensure the vitality of town centres, and encourages LPA’s to ‘recognise town centres as the

heart of their communities and pursue policies to support their vitality’, and ‘to promote

competitive town centres that provide customer choice and a diverse retail offer and which

reflect the individuality of town centres’ (para 23).

2.4 When setting out policies for promoting sustainable transport, the NPPF encourages a balance

of land uses so that people can be encouraged to minimise journey lengths for employment,

shopping, leisure, education and other activities (para 37). For larger scale residential

developments in particular, the NPPF encourages the promotion of a mix of uses in order to

provide opportunities to undertake day-to-day activities. Where practical, key facilities such as

primary schools and local shops should be located within walking distance of most properties

(para 38).

2.5 Paragraphs 24 and 26 set out the criteria for assessing applications against the sequential and

impact tests. When considering applications for main town centre uses that are not in an

existing centre and not in accordance with an up-to-date Local Plan, the NPPF states thatLPAs should:

• apply a sequential test – directing applications to main town centre uses to town centres,

then in edge-of-centre locations and only if suitable sites are not available should out-of-

centre sites be considered. When considering edge of centre and out of centre

proposals, “…preference should be given to accessible sites that are well connected to

the town centre” (para 24). Applicants and LPAs should demonstrate flexibility on issues

such as format and scale.


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• require an impact assessment – if the development is over a proportionate, floorspace

threshold (2,500 sq. m if not set lower by the Local Authority). This should include

assessment of:

o the impact of the proposal on existing, committed and planned public and private

investment in a centre or centres in the catchment area of the proposal; and

o the impact of the proposal on town centre vitality and viability, including local

consumer choice and trade in the town centre and wider area. For major schemes

where the full impact will not be realised in five years, the impact should be assessed

at five and ten years from the time the application is made (para 26)

2.6 Where an application fails to satisfy the sequential test or is likely to have a “significant adverse

impact” on one or more of the above fac tors, it should be refused (para 27).

Adopted and Emerging Local Plan

Retail

2.7 The Thanet District Local Plan was adopted in 2006. A number of policies were saved in 2009

(pre-publication of the NPPF). Paragraph 4.14 sets out the Councils approach to sustainable

retailing, and states that the Counc il will seek to improve the quality of life for residents through

providing a range of quality retail and leisure facilities within the district which will contribute to

the local economy, generate additional jobs and reduce the need for residents to travel.

2.8 Paragraph 4.18 of the 2006 Local Plan recognises that new retail development brings other

development which assists in supporting the local economy. Without the retail investment,

these other development opportunities are not created or catered for elsewhere and result

therefore in non-mixed economy.

2.9 Saved Local Plan Policy TC1 relates to ‘New Retail Development’, and sets out the sequential

approach to new retail development. The preference is for new development to be located

within the core areas of Margate, Ramsgate, Broadstairs and Westwood. Retail proposals

outside these locations should:

• Demonstrate an identified need;

• Be in a sequentially preferable location;

• Be of an appropriate scale;

• Have no unacceptable impact on the vitality and viability of existing centres; and

• Be accessible.


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2.10 The Local Plan is considerably out of date and the weight which should be attached to Saved

Policies will be limited to their consistency with the NPPF. The NPPF removes the requirement for

applications to demonstrate ‘quantitative need’ (a previous requirement of PPS4). The test

relating to appropriate scale of new development remains, however only in so far as it relates

to consideration of impact. The retail element of the proposal should therefore be determined

in accordance with the impact and sequential tests set out in the NPPF.

2.11 The emerging Loca l Plan will hold limited weight as it has not been independently tested by

an Inspector. Proposed Policy E05 carries forward the established retail hierarchy, and states

that proposals for main town centre uses should be located within the designated town

centres of Margate, Ramsgate, Broadstairs and Westwood. Where this is not possible due to

size, format and layout, town centre uses should be located on the edge of town centres or

on employment land designated for flexible uses. Outside these areas applicants should

demonstrate that there is no sequentially preferable location within the catchment of the

proposed development. It proposes a 280sqm threshold for proposals for main town centre

uses in rural areas, above which assessment of impact will be required. We note that

proposed a llocations for strategic housing sites include scope for provision of small scale

convenience retail provision required to accessible serve day to day needs of development.

Office

2.12 There are no Saved Policies in the 2006 Local Plan or emerging Preferred Options Local Plan

relevant to assessment of proposed office uses. This element of the proposal should therefore

be assessed in accordance with the NPPF retail impact and sequential tests.

Hotel

2.13 There are no Saved Policies in the 2006 Local Plan relevant to hotel uses. Proposed Policy E07

of the Preferred Option Local Plan supports new serviced tourist accommodation where it

relates to existing built development, is of an appropriate scale, is accessible by range of

means of transport, is respectful of landscape character/nature conservation value and anyincrease in recreation pressure on designated nature conservation sites is mitigated.

Sport and Recreation

2.14 The NPPF confirms that pursuing sustainable development involves seeking positive

improvements in the quality of the built, natural and historic environment, as well as in

people’s quality of life, including improving the conditions in which people take leisure (para

9). It states that planning policies should plan positively for the provision of sports venues and

confirms that opportunities for sport and recreation can make an important contribution tothe health and well-being of communities. It promotes development of local services and

community facilities in villages, including sports venues (para 28).


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2.15 Saved Policy T1 of the 2006 Local Plan states that planning permission will be granted for

development which would extend or upgrade the range of tourist facilities in the district,

increase the attraction of tourists to the area or extend the season.

2.16 The Preferred Options Local Plan identifies one long-term primary sports venue for Thanet

(J ackey Bakers, south of Westwood Cross); however it is silent on the assessment of

applications for additiona l sports and leisure facilities elsewhere in the district.


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3. Retail Capacity Assessment

3.1 A retail capacity assessment has been undertaken to inform the quantum and scale of new

retail (convenience and comparison goods) floorspace proposed to serve the likely needs of

the masterplan population. The assessment is based on a 20 year build out period, and

projects total capacity up to 2034 (the latest date for which forecasts are available). The

detailed modelling is provided in Appendix 1.

3.2 Whilst ‘need’ is no longer a policy requirement, it provides a useful indication of the likely

demand for new local shops and services which will be generated by the proposed

population and helps to inform judgements about impact.

Catchment Area

3.3 The proposal will include a local centre. Its principal purpose is to meet needs of the proposed

masterplan population. For the purpose of our assessment we have therefore assumed that

the catchment area for the proposed local centre will principally comprise the boundary of

the proposed masterplan. This is robust and corresponds to the Applicant’s aspiration to

create a sustainable mixed use community where people can live, work and play.

Population Forecasts

3.4 The masterplan includes provision for up to 2,500 dwellings. We have assumed that these will

be delivered at an average of 250 dwellings per annum from 2018 to 2034 (the last forecast

date by Experian). The total forecast residential population which will be generated by the

proposed masterplan is summarised in Table 3.1 below.

Table 3.1: Population Growth

2016 2021 2026 2031 2034

Number of homes 0 625 1,406 2,188 2,500

Total resident population 0 1,400 3,150 4,900 5,950

Source: Table 1, Appendix 1

3.5 When fully implemented, the masterplan is expected to generate a resident population of

around 5,950 people.


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Expenditure Forecasts

3.6 For the purpose of this assessment, we have assumed that masterplan residents will have a

similar average per capita income to existing Thanet residents in the local area and have

therefore adopted average per capita estimates of expenditure for residents of Zone 6 of the

Thanet District Council Retail Study (2012). This is considered c onservative, bearing in mind the

calibre of the proposed masterplan and the aspiration to attract new-skilled labour to the

area.

3.7 Expenditure per capita is grown over the assessment years drawing on the latest advice

published by Experian Retail Planner Briefing Note (October 2015). In accordance with

standard approaches, we have made an allowance for ‘special forms of trading’ (SFT) to

account for non-store purchases (such as mail order and internet shopping) which would not

be available to support the proposed local centre. Experian forecasts show that SFT accounts

for 3.0% of average convenience goods expenditure per capita levels in 2016, increasing to

6.3% by 2034. For comparison goods expenditure, SFT accounts for 12.4% of average

expenditure in 2016 and is forecast to increase to 14.4% by 2034.

3.8 Per capita estimates of convenience and comparison goods expenditure are summarised in

Table 3.2 below.

Table 3.2: Retail Expenditure Forecasts (2014 prices), £ per person

2016 2021 2026 2031 2034

Stone Hill Park

Convenience £2,315 £2,298 £2,292 £2,287 £2,281

Comparison £3,569 £4,011 £4,686 £5,511 £6,071

Source: Table 2, Appendix 1.

3.9 Together, the figures in Tables 3.1 and 3.2 are used to estimate the total available

convenience and comparison goods expenditure which will be generated by the forecast

residential masterplan population. As shown in Table 3.4 below, the proposed masterplan

population will generate an additional £13.6m of convenience expenditure and £36.1m of

comparison expenditure by 2034 which will be available to support existing and proposed

shops and services within the local area.


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Table 3.3: Total Available Retail Expenditure (2014 prices) £ million

2016 2021 2026 2031 2034

Stone Hill Park

Convenience £0.0 £3.2 £7.2 £11.2 £13.6

Comparison £0.0 £5.6 £14.8 £27.0 £36.1

Total £0.0 £8.8 £22.0 £38.2 £49.7


3.10 In reality, not all of the retail expenditure generated by the proposed masterplan population

will be retained within the proposed local centre. We have therefore made assumptions

regarding the proportion (or ‘market share’) of available convenience and comparison goods

expenditure within the catchment area that new retail floorspace the proposed local centre

could reasonably draw.

3.11 In our judgement, the local centre will need to be anchored by a small/medium sized food

supermarket. This is required to help generate the necessary level of day-to-day trips,

expenditure and linked trips to other shops and facilities to help underpin the centre’s overall

vitality and viability. This store will therefore need to have the necessary critical mass of

floorspace and product offer to serve the day-to-day needs of the local community. Subject

to provision of a reasonably sized foodstore, we estimate that the proposal has the potential

to retain approximately 80% of convenience expenditure generated by the local population. This is considered reasonable bearing in mind the scheme objective to create a sustainable

mixed use environment for residents and visitors to live sustainably by providing a range of

necessary facilities and amenities within easy distance of their homes and places of work. It

also allows for a reasonable 20% ‘leakage’ of shopping trips and expenditure to larger

foodstores in the wider catchment area.

3.12 For comparison goods it is clear that the proposed local centre will have a more limited role,

which reflects the proximity of attractive comparison goods retail destinations and its likely

status in the retail hierarchy. For the purpose of this assessment, we have assumed that non-

food retailing in the local centre could attract around 10% of available comparison goods

expenditure from masterplan residents.

3.13 We anticipate that the local centre will also attract an element of expenditure from visitors

who live outside of the masterplan area. To account for this, we have estimated that inflow

from existing local residents in the area could account for an additional 10% of retail

expenditure in both convenience and comparison goods, as could trade from businesses and

employees in the proposed employment area. We consider that this is reasonable bearing in

mind the location of the local centre in relation to existing facilities and the capacity for linked


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trips with other proposed facilities (including employment area, schools, GP surgery, regional

sports facilities, etc.).

Retail Floorspace Capacity Forecast

3.14 For convenience floorspace, we have assumed that the turnover of any additional

convenience goods floorspace in the local centre would be around £5,000/sqm for

discounters or smaller independent units, or around £11,000/sqm for major foodstore. These

figures are then applied to the total available expenditure in order to derive the capacity for

new convenience goods floorspace in the centre up to 2034. The detailed results for

convenience goods floorspace capacity are summarised in Table 3.4 below.

Table 3.4: Total Floorspace Capacity (2014 prices) (sqm net) – Convenience

2016 2021 2026 2031 2034

Proposed Local Centre

If Foodstore 0 282 635 985 1,193

If Smaller/Discount Retailer 0 621 1,396 2,166 2,625


3.15 The results demonstrate that the proposal will generate sufficient demand to sustain a

foodstore of 1,100 sqm (net) convenience floorspace. Although our model shows that there

will not be sufficient local expenditure to sustain the maximum quantum of convenience

floorspace proposed until the later stages of the development, this is not unusual and does

not prec lude the foodstore from being provided earlier in the development programme. This

only means that, in reality, any foodstore operator would be likely to trade below expected

company benchmark until the masterplan is built out. If the maximum quantum of main

foodstore floorspace is not built, the model demonstrates that there will be additional

capacity to support small scale/discount foodstore provision at a rate of 2.2 (sqm) to 1.

3.16 The detailed results of the expenditure and floorspace capac ity forecasts for comparison

goods floorspace is summarised in Table 3.5 below.

Table 3.5: Total Floorspace Capacity (2014 prices) (sqm net) - Comparison

2016 2021 2026 2031 2034

Proposed Local Centre

Comparison floorspace 0 122 291 483 609



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3.17 As shown, we estimate that there will be sufficient capacity for the 563 sqm (net) of

comparison goods floorspace proposed by 2033. We would expect that the comparison retail

floorspace will primarily comprise smaller shop units of between 100 and 150 sqm (net). Again,

although our model shows that there will not be sufficient local expenditure to sustain the

maximum quantum of comparison floorspace proposed until the later stages of the

development, this would only mean that retailers are likely to trade below expected company

benchmark until the masterplan is fully built out.

3.18 We also estimate that approximately one third of the of the total floorspace in the local centre

will comprise supporting retail and business services, including Class A2 Uses (banks and

financial services) and C lass A3/A4/A5 Uses (cafes, restaurants and takeaways), launderettes,

hairdressers, estate agents, etc. On this basis we estimate that the local centre could support

820 sqm (net) or 1,250 sqm (GIA) of additional A2-A5 service in the centre. We would expect

that these are delivered in units of between 100 and 150 sqm (GIA).

3.19 The key findings of the retail capac ity assessment are summarised in Table 3.6 below.

Table 3.6: Local Centre – Total Floorspace Estimates (sqm net)

2016 2021 2026 2031 2034

Convenience Floorspace

If Foodstore 0 282 635 985 1,193

If Small /Discount Retailer0 621 1,396 2,166 2,625

Comparison Floorspace 0 122 291 483 609

A2-A5 Floorspace 0 444 592 740 887

TOTAL FLOORSPACE 0 848 1,518 2,207 2,689


3.20 Based on the population and expenditure growth forecasts and our robust assumptions

regarding market share, the capacity assessment demonstrates that there is capacity for atleast 2,689 sqm (net) of total retail (Class A) floorspace in the local centre. Adopting an 80%

net to G IA ratio, this translates to capacity for a total of 3,362 sqm (G IA) retail (Class A)

floorspace. The application seeks consent for a total of 3,100 sqm (GIA), and is therefore an

appropriate quantum and mix to support the masterplan population.


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4. Health Checks

4.1 As demonstrated in Sec tion 3, the proposed loc al centre is appropriate in terms of its scale,

uses and offer to principally meet the day-to-day needs of masterplan residents. Given the

limited scale and type of retailing proposed for the Masterplan area, we do not consider that

it will result in any significant trade draw or impact on the larger centres, or its main shops and

stores. Likewise, it will not therefore have the c ritical mass of retailing or turnover to jeopardise

any planned investment in the other local centres or harm their overall vitality and viability.

Nevertheless, we have undertaken health check of the following local centres in order to

verify our judgements about potential impact – Minster, Monkton, Manston, Cliffsend and

Acol.

Monkton

4.2 Monkton village has no shops or commercial services other than a public house. There are no

doctor, dentist or leisure facilities in the village, which suggests that there is some reliance on

Minster (to the east) for these requirements. The extent to which the proposal will have the

potential to adversely impact the vitality and viability of Monkton Local C entre will therefore

be extremely limited.

Manston

4.3 Manston is a small village and has no shops or commercial services other than a public house.

There is no doctor or dentist surgery. The village contains a c luster of small industrial units, and

other business being mostly local farms. The extent to which the proposal will have the

potential to adversely impact the vitality and viability of Manston Local Centre will therefore

be extremely limited.

Cliffsend

4.4 There is one community run convenience shop which also contains a post office, together

with a garage shop and public house. There is no doc tor or dentist surgery. Local businesses

include catering, pet service and a small cluster of business units at Little Cliffsend Farm. The

extent to which the proposal will have the potential to adversely impact the vitality and

viability of Cliffsend Local Centre will therefore be extremely limited.

Acol

4.5 There are no shops or commercial services other than a public house and no doctor or dentist

surgery. This suggests that use is made of shops and health facilities at Birchington-on-Sea and


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Minster village. There are a small number of businesses. The extent to which the proposal will

have the potential to adversely impact the vitality and viability of Acol Local Centre will

therefore be extremely limited.


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5. Impact Assessment

5.1 This section assesses the impac t of the main town centre uses proposed in accordance with

the criteria set by para 26 of the NPPF.

Retail

5.2 A fundamental design principle of the proposed development is the “walkable

neighbourhood,” which will encourage residents and visitors to live sustainably by providing a

range of necessary facilities and amenities within easy distance of their homes and places of

work. To deliver this vision, a new local centre is proposed within the heart of the community

within 15 minutes’ walk of all proposed residential areas.

5.3 The quantum of Class A1 retail floorspace proposed is derived from a retail capac ity

assessment which forecasts that additional convenience and comparison expenditure could

be ‘retained’ by the proposal bearing in mind the overall masterplan aspiration to create a

sustainable new mixed use c ommunity.

5.4 The retail capac ity assessment confirms that there will be sufficient population and

expenditure growth to support a new local centre of at least 3,362 sqm (GIA) by 2034,

assuming a maximum foodstore of 1,100 sqm (convenience).

5.5 Although the capacity assessment indicates that there will not be sufficient expenditure

capacity to support the full extent of floorspace proposed until later stages of the

development programme, this is not unusual and does not preclude floorspace from coming

forward earlier in the development programme. The proposed main town centre uses would

not have a disproportionately more significant impact on existing centres and stores outside of

the proposal prior to the occupation of all proposed residential dwellings because the share

of expenditure ‘diverted’ to the proposal from the catchment area is not linked to occupation

of the residential units. Rather, it is normal for first phase retail uses to trade below companybenchmarks until such time as the development is fully completed and able to sustain

expected trading levels.

5.6 The quantum of retail floorspace proposed is designed to sustain the requirements of the

proposed development, not draw in local expenditure from beyond. Overall, we estimate

that 20% of the turnover of proposed retail floorspace could come from residents outside of

the proposal. Of this, a large proportion of this would be from employees of the manufacturing

area and drive-by traffic. Impact (in terms of trade diversion) would be diversified across a

wide geographical area and is therefore unlikely to result in any significant impact on any

local centres. With respect to comparison floorspace, we estimate that the majority of local


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residential expenditure will be absorbed by higher order centres within the district, resulting in

a significant positive benefit to existing town centres in the district.

5.7 Local expenditure which is not attributed to the local shops within the local centre will be

spent in existing shops and services within the local area. Overall, the impact of the proposal

on local centres is expected to be positive as the proposed population will generate

additional spend/patronage which will not be entirely retained within the proposed local

centre. Likewise, the proposal will not prejudice any existing or planned investment within town

centres within the area. Indeed, it will create new local demand which will not fully be realised

by the proposed local centre, which will be capable of being absorbed by existing local

centres, stores and services in the local area.

Hotel

5.8 The proposed hotel has been designed to serve the future requirements of the proposed

masterplan population. It will:

• Support the operational requirements of the proposed employment area;

• Sustain the viability and attractiveness of proposed regional significant leisure facility

(namely, the ‘wave garden’); and

• Provide visitor overflow (e.g. those visiting residents of the masterplan)

5.9 The proposed hotel is therefore designed to meet locally specific needs which cannot be met

by existing hotels elsewhere in the District. The scale of the proposal is driven by operator

requirements and is not of sufficient scale to trigger potential for adverse impacts. Indeed, by

encouraging visitors and employees to stay in the local area longer, the proposed hotel will

increase the propensity for visitors to visit other local attractions. The proposal will therefore not

have any significant adverse impact on any town centres.

Office

5.10 A maximum of 1,700 sqm (GIA) of floorspace is proposed to diversify the proposed

employment offer on Site. The proposal is designed to meet locally specific needs arising from

the masterplan and sustain the creation of a genuine, mixed-use sustainable community. The

scale of proposed office floorspace is minimal relative to the total quantum of employment

floorspace proposed (5%) and not sufficient to trigger a potential adverse impact on any local

centre surrounding the proposal.


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Sports and Leisure

5.11 The proposal includes provision for up to 11,500 sqm (GIA) sports and leisure facilities (Class

D2), intended to include regionally significant leisure facilities including a wave garden and

50m indoor swimming pool (forming a new ‘East Kent Sports Village’). These uses will anc hor

the eastern end of the local centre, compatible with surrounding land uses and well-

connec ted to the major transportation network.

5.12 The proposal will deliver regionally significant sports and leisure facilities, one of which is not

currently not provided for in Kent (50m swimming pool) and one which will be entirely new to

the England (wave garden). The proposal will introduce something entirely new to the district

and therefore not direc tly ‘compete’ with existing facilities. This element of the proposal

creates a significant opportunity to increase the number of tourists who visit the District,

enhancing the length of their stay (through provision of the hotel), and increasing the

potential or linked trips to local centres. This will have positive benefits to the entire area,

attracting a new tourist base to town centres and other major tourist attractions

Summary

5.13 The quantum and mix of main town centres proposed as part of the local centre is designed

to serve the needs of the masterplan population and will not trigger significant impacts on

town centres in the district. Indeed, the proposed population will generate demand for new

local shops and services which will not be ‘captured’ within the proposed local centre and will

therefore be available to support existing shops and services in existing centres within the

district.

5.14 The quantum of Class D2 uses will accommodate regionally significant leisure fac ilities on site,

intended to comprise a 50m swimming pool and wave garden. These fac ilities are not

currently represented within the region and (when proposed alongside the hotel) will have the

potential to significantly improve the tourist industry by encouraging those who visit to stay inthe local area longer and visit other local attractions (including the local centres).


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6. Sequential Assessment

6.1 Paragraph 24 of the NPPF confirms that local planning authorities should apply a sequential

test to planning applications for main town centre uses that are not in an existing centre and

are not in accordance with an up-to-date Local Plan.

6.2 When considering applications for main town centre uses that are not in an existing centre

and not in accordance with an up-to-date Local Plan, the NPPF states that LPAs should apply

a sequential test. That is, LPAs should require applications for main town centre uses to be

located in town centres, then in edge-of-centre locations and only if suitable sites are not

available should out-of-centre sites be considered.

6.3 The Dundee High Court Decision2 has provided clarification on the application of the

sequential test, and confirms that the issue of suitability is directed to the developer’s

proposals and not some alternative scheme which might be suggested by the local planning

authority. The Applicant’s proposal is to deliver a sustainable mixed use development, and a

fundamental component of this is delivery of a local centre with a sufficient mix and quantum

of main town centre floorspace required to provide for day-to-day shopping, business and

leisure needs of the proposed population. The proposed retail, hotel and office uses proposed

respond to defined need arising from the masterplan population and are therefore location

specific. Locating these uses elsewhere would fundamentally contradict the developer’s

aspiration to deliver a sustainable, mixed use environment on the Site. Nevertheless, we

consider compliance with the sequential approach in further detail below.

Retail

6.4 The purpose of the proposed retail floorspace is to enable the creation of sustainable “walking

neighbourhoods” which provide access to necessary facilities and services within close

proximity of proposed and existing residents. The location retail floorspace within the local

centre is designed to serve location-specific needs, which could not be met by provision on

alternative sites elsewhere in the District. The proposal is therefore compliant with sequential

approach to site selection.

Hotel

6.5 The proposed hotel element has a location specific requirement to be in an accessible

location in close proximity of the regionally significant leisure uses and proposed employment

area (which it is intended to serve). Its purpose is to serve visitors to the Site, and encourage

2 Tesco Stores Limited vs. Dundee City Counc il (21 March 2012).


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them to stay in the area longer, supporting the overall viability of the proposition. This

requirement could not be met by provision on alternative sites elsewhere in the District. There

are therefore no sites in or at the edge of existing centres which are considered suitable to

accommodate the proposed development. The proposal is therefore compliant with

sequential approach to site selection.

Office

6.6 The proposed office floorspace within the local centre is designed to help diversify the mix of

uses in the local centre and serve location-specific needs which could not be met by

provision on alternative sites elsewhere in the district. This could not be met by provision on

alternative sites elsewhere in the district. There are therefore no sites in or at the edge of

existing centres which are considered suitable to accommodate the proposed development.

The proposal is therefore compliant with sequential approach to site selection.

Sports and Leisure

6.7 The proposal includes provision for up to 11,500 sqm (GIA) sports and leisure facilities (Class

D2). This element of the proposal will allow provision of regionally significant leisure fac ilities

including a wave garden and 50m indoor swimming pool (forming a new ‘East Kent Sports

Village’). These uses will anchor the eastern end of the local centre, in order to benefit from

colocation with proposed outdoor sports facilities/trails and well connected to the major

transportation network.

6.8 Although the aspiration is that masterplan residents will also use the proposed fac ilities, since

this floorspace is intended for regionally significant leisure facilities there is no ‘locally spec ific’

requirement for this element of the proposal. We have therefore considered whether there are

any sequentially preferable sites within the district which are suitable and available to

accommodate the proposed development.

Scale and Format

6.9 The proposed Class D2 uses are intended to help form a new ‘East Kent Sports Village’. This is

intended to include a 50m swimming pool, wave garden, supported by a network of

supporting outdoor sports pitches and running trails. As such, we do not consider there is

scope for further disaggregation of the proposed regional leisure facilities. Nevertheless, in

order to demonstrate flexibility on format and scale, and for the purposes of the sequential

assessment, we have assessed whether there are any preferable sites in the district which

could accommodate the 50m swimming pool and wave garden excluding the surroundingoutdoor fac ilities proposed (equating to a requirement for a site of 1.8ha).


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Area of Search

6.10 For the purposes of the sequential approach we have considered whether there are any

preferable sites in or at the edge of the following centres:

• Westwood Cross;

• Margate;

• Ramsgate;

• Broadstairs;

• Cliftonville;

• Westgate;

• Birchington-on-Sea; and

• Minster.

Site Assessment

In-Centre

6.11 Aside from a number of small-scale vacant shop units (regarded as unsuitable to

accommodate the proposed development by virtue of scale), we did not identify any

potential sites within the centres identified within the catchment area.

Edge of Centre

6.12 The only edge-of-centre site within the district which we identified was Arlington Square. This

1.8ha site sits to the west of Margate town centre next to the Dreamland site opposite the sea

front, and comprises a covered arcade of shops (the majority of which are derelict) as well

Arlington House block of flats.

6.13 At its meeting on 15 June 2011 Planning Committee resolved to grant planning permission (ref.

F/TH/10/1061), subject to a legal agreement and safeguarding conditions for the erection of

retail superstore (approx. 750 sq. m gross internal floorspace) parking, access road, service

ramp and delivery area, external alterations to Arlington House comprising staining of

concrete, render, lighting, new windows and doors and extension of ground floor to include

A1, A2, A3 or A5 uses following demolition of 1-50 Arlington Square together with an outline

application for 2, 3 and 4 storey buildings for use classes A1-A5 and hotel, including means of

access and landscaping.


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6.14 Demolition work pursuant to the extant consent started in spring 2016 and is in preparation for

redevelopment by the current leaseholder (Freshwater). The intended anchor tenant is yet to

be released.

6.15 The approved development is currently under-construction and therefore not available for the

proposed development. Furthermore, as the Site is at the edge of Margate Town Centre, it is

considered more appropriate for the retail uses for which it is being redeveloped.

Out-of-Centre

6.16 The only potential out of centre sites which we identified were:

• Eurokent Mixed Use Area;

•

The Lido;

• Winter Gardens/Rendezvous Coach Park.

6.17 The NPPF states that when considering out-of-centre sites, preference should be given to

accessible sites that are well connected to the town centre. We consider these sites in further

detail below.

Eurokent Mixed Use Area

6.18 This site is allocated as one of the District’s four strategic employment locations and includes

19.85ha of remaining developable land. The Saved Local Plan restricts uses here to traditional

employment (Class B). The site is therefore not available to accommodate the proposed

regional leisure facilities. Furthermore, the site is not in a more accessible location and would

not materially increase the propensity for linked trips to town centres. The site is therefore

dismissed for the purpose of the sequential assessment.

The Lido

6.19 The Lido leisure complex is a long, thin, 0.73ha site on the seaward side of Ethelbert Terrace, on

the cliff face close to the Winter Gardens. Saved Local Plan Policy T5 identifies the site for ’an

appropriate mix of tourism, leisure and housing uses subject to consideration being given to

the potential loss of sea views from Ethelbert Terrace and design being sympathetic to the

character of the area.

6.20 The site is inadequate to accommodate the scale of the proposal, even demonstrating

flexibility. The shape of the site is inappropriate for the proposed use. The site is therefore not

suitable to accommodate the proposed development and is therefore dismissed for the

purpose of the sequential assessment.


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Winter Gardens/Rendezvous Coach Park

6.21 This site is 2.2ha and located on the seafront, to the north east of Margate town centre. The

Winter Gardens are designated as Public Open Space in the Thanet Local Plan Proposals Map

(under Policy SR10). Development will only be permitted here in very exceptional

circumstances.

6.22 The site is too small to accommodate the proposed development, even when demonstrating

flexibility. It is protected open space and therefore unavailable. The proposal would generate

potentially significant impacts on views along the coast, and would therefore be unsuitable.

The site is therefore dismissed for the purpose of the sequential assessment.

The Proposed Site

6.23 The proposal will increase the number of tourist visitors to the local area and (by virtue of the

complementary facilities propose) encourage them to stay longer in the local area. The

Application Site is in a highly accessible location, with good connections to surrounding local

centres, and will therefore have the propensity to encourage linked trips.

6.24 The Site benefits from excellent existing vehicular access and connections to the neighbouring

towns, major towns of Kent and the south east region. Manston Road (B2190) provides

connections to the A253 and A28 via the A254. The A253 runs east to west connec ting

Ramsgate and Canterbury. The A28 runs east to west connecting Margate and the M2

leading to Gillingham. The A256 which is accessed to the south of the site runs north to south

connecting Ramsgate and Dover.

6.25 The Site is also served by three bus lines: two routes (no. 11 and 38) have existing stops along

the B2050 and provide services to Birchington-on-Sea, Acol, Manson Village, Westwood Cross,

Ramsgate; and a third (no. 9) provides regional services from Ramsgate to Canterbury via

Hengist Way (A299).

Summary

6.26 In summary, this sec tion demonstrates that there are no sequentially preferable sites to

ac commodate the regionally significant leisure fac ilities within the defined area of search,

even demonstrating flexibility. Accordingly the proposed development satisfies the

requirements of paragraph 24 of the NPPF.


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7. Conclusions

7.1 Based on the population and expenditure growth forecasts, and our market share

assumptions, we conclude that there will be sufficient population and expenditure growth

within the proposed development to support the retail floorspace. The quantum and mix of

retail, leisure and office floorspace is considered appropriate to support the creation of a

sustainable and vibrant mixed use community. The proposal will not generate any significant

adverse impact on any town centres. Indeed, it will help generate a new local population

with expenditure which will be able to sustain new shops and services in the proposed

masterplan as well as elsewhere in the District. The proposal therefore accords with paragraph

26 of the NPPF.

7.2 With respect the sequential test, the Applicant’s proposal is to deliver a sustainable mixed use

development, and a fundamental component of this is delivery of a local centre with a

sufficient mix and quantum of main town centre floorspace required to provide for day-to-day

shopping, business and leisure needs of the proposed population. The proposed retail, hotel

and office uses proposed respond to defined need arising from the masterplan population

and are therefore location specific. Locating these uses elsewhere would fundamentally

contradict the developer’s aspiration to deliver a sustainable, mixed use environment on the

Site.

7.3 With respect to the regionally significant leisure fac ilities, the assessment demonstrates that

there are no sequentially preferable sites to accommodate the regionally significant leisure

fac ilities within the defined area of search, even demonstrating flexibility. Accordingly the

proposed development satisfies the requirements of paragraph 24 of the NPPF.


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gva.co.uk

Appendix I

Retail

Capacity

Assessment


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Stone Hill Park Retail Ca acit Assessment

Table 1Population Growth

2016 2021 2026 2031 2034

Stone Hill Park Masterplan

Number of homes 0 625 1,406 2,188 2,500

Total resident population 0 1,400 3,150 4,900 5,950

Table 2Retail Expenditure Forecasts (2014 prices), £ per person

2016 2021 2026 2031 2034

Stone Hill Park Masterplan

Convenience £2,315 £2,298 £2,292 £2,287 £2,281Comparison £3,569 £4,011 £4,686 £5,511 £6,071

Source: Experian Micromarketer (January 2016).

Table 3

Total Available Retail Expenditure (2014 prices), £ million

2016 2021 2026 2031 2034

Stone Hill Park

Convenience £0.0 £3.2 £7.2 £11.2 £13.6

Comparison £0.0 £5.6 £14.8 £27.0 £36.1 Total £0.0 £8.8 £22.0 £38.2 £49.7

Source: Tables 1 & 2.

Notes: Assumes delivery of 250 dwellings per annum as part of masterplan from 2018 to 2034 (the last forecast date by

Experian). Population estimates for planned housing growth taken from Environmental Statement (ref. SHP1-13).

Notes: Assumes masterplan residents will have same average per capita inc ome as residents in Zone 6 of latest Thanet

District Counc il Retail Study (2012) which the Site lies within. Per capita growth rates and allowance for SFT taken from


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Table 4

2016 2021 2026 2031 2034

Stone Hill Park residents

Available Expenditure (£m): £0.0 £3.2 £7.2 £11.2 £13.6

Forecast Market Share (%): 80% 80% 80% 80% 80%

Expenditure Ava ilable to Support New

Convenience (£m):£0.0 £2.6 £5.8 £9.0 £10.9

Inflow

+10% £0.0 £0.3 £0.6 £0.9 £1.1

Trade from Employment Area

+10% £0.0 £0.3 £0.6 £0.9 £1.1

Total £0.0 £3.1 £6.9 £10.8 £13.0

Table 5

2016 2021 2026 2031 2034

Total Available Expenditure Capacity £0.0 £3.1 £6.9 £10.8 £13.0

Foodstore

Estimated Average Sales Density of New

Floors ace (£ er s m): £11,000 £10,945 £10,923 £10,923 £10,923

Capacity for convenience floorspace

(sqm net) 0 282 635 985 1,193

OR Smaller/discount convenience store

Estimated Average Sales Density of NewFloorspace (£ per sqm): £5,000 £4,975 £4,965 £4,965 £4,965

Capacity for convenience floorspace

(sqm net) 0 621 1,396 2,166 2,625

Source: Estimated average sales density of new foodstore and smaller/discount retailer floorspace taken as GVA

estimate.

Notes: Turnovers grown to 2034 using efficiency rates set out in Experian Briefing Note 13 (October 2015).

Local Centre - Estimated Available Convenience Expenditure (2014 prices), £m

Notes: forecast retention rate for convenience expenditure reflects masterplan aspiration to create a sustainable new

community and relative attrac tiveness and proximity of local centre to proposed residents. Inflow and business trade

taken as GVA estimate.

Local Centre - Estimated Turnover of Convenience Floorspace (2014 Prices), £m


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Table 6

2016 2021 2026 2031 2034

Stone Hill Park residents

Available Expenditure (£m): £0.0 £5.6 £14.8 £27.0 £36.1

Forecast Market Share (%): 10% 10% 10% 10% 10%

Expenditure Ava ilable to Support New

Comparison (£m):£0.00 £0.6 £1.5 £2.7 £3.6

Inflow

+10% £0.0 £0.1 £0.1 £0.3 £0.4

Trade from Employment Area

+10% £0.0 £0.1 £0.1 £0.3 £0.4

Total £0.0 £0.7 £1.8 £3.2 £4.3

Table 7

2016 2021 2026 2031 2034

Total Available Expenditure Capacity £0.0 £0.7 £1.8 £3.2 £4.3

Estimated Average Sales Density of New

Floorspace (£ per sqm): 5,000 5,510 6,077 6,710 7,120

Capac ity for comparison floorspace (sqm

net) 0 122 291 483 609

Local Centre - Estimated Share of Comparison Expenditure (2014 prices), £m

Notes: forecast retention rate for comparison expenditure reflects tendancy for comparison goods floorspace to be

concentrated to higher order centres. Inflow and business trade taken as GVA estimate.

Local Centre - Estimated Turnover of Comparison Floorspace (2014 Prices), £m

Source: Available c omparison expenditure taken from Table 3. Sales density of new c omparison floorspace taken as

GVA estimate and grown to 2034 using effic iency rates set out in Experian Briefing Note 13 (October 2015).


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Table 8Local Centre - Total Floorspace Capacity (sqm net)

2016 2021 2026 2031 2034


if Foodstore 0 282 635 985 1,193

if Smaller/Discount Retailer 0 621 1,396 2,166 2,625


A2-A5 Floorspace 0 444 592 740 887

TOTAL FLOORSPACE

(assuming 1,100 sqm (net) foodstore)0 848 1,518 2,207 2,689

Table 9Local Centre - Total Floorspace Proposed (sqm net)2016 2021 2026 2031 2034


Foodstore 0 0 1,100 1,100 1,100


A2-A5 Floorspace 0 0 273 547 820

Notes: Adopts 80% net to GIA ratio for new floorspace. Assumes small foodstore will be brought forward post 2021, with

comparison and A2-A5 floorspace delivered in phases from 2026 onwards.

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