Planning Support Statement Station Road, Coleshill - August 2015
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PAP/2015/0525
Planning Support Statement
Station Road, Coleshill NORTH WARWICKSHIRE
BOROUGH COUNCIL
RECEIVED
17/08/2015
August 2015
PLANNING & DEVELOPMENT
DIVISIONContents 1. Introduction 3 2. Site Context and Proposal 4 3. Planning Policy Context 9 4. Employment Land 16 5. Vitality and Viability Assessment 19 6. Sequential Assessment 23 8. Other Planning Matters 35 9. Conclusions 39 Appendix 1: Retail Assessment Tables 41 Appendix 2: Proposed Store Catchment Area 42 Contact Gareth Barton gareth.bartons@turley.co.uk Client ALDI Stores Ltd August 2015
1. Introduction
1.1 This Planning Support Statement is submitted by Turley, on behalf of ALDI Stores
Limited, in support of a full planning application for the erection of a Class A1 discount
foodstore at Station Road, Coleshill.
1.2 The Statement is intended to address the relevant planning policy considerations
associated with the proposed development, but should be read in conjunction with other
documents and drawings submitted in support of this application.
Context
1.3 Whilst the site is located in an out of centre location, the scale of the proposed
development falls below the threshold for (retail) impact assessment (2,500 sq m)
identified at Paragraph 26 of the National Planning Policy Framework (NPPF). Neither
the adopted Core Strategy nor the ‘saved’ policies of the UDP set a different threshold.
At the request of the LPA, a proportionate retail impact assessment has been carried
out, the results of which are addressed in this document. Section 7 of the report
addresses matters concerning effects on trading patterns and impact on centre vitality
and viability, based on information gathered from a centre health check.
1.4 A sequential assessment, consistent with the NPPF and National Planning Policy
Guidance (NPPG) has also been undertaken. The results of the sequential assessment
are set out in Section 6 of this Statement
1.5 The remainder of this Statement is set out as follows:
• Section 2 – Site Context and Proposal;
• Section 3 – Planning Policy Context;
• Section 4 – Employment Land;
• Section 5 – Vitality and Viability Assessment;
• Section 6 – Sequential Assessment;
• Section 7 – Retail Impact;
• Section 8 – Other Planning Matters; and
• Section 9 – Summary and Conclusions.
1.6 It should be noted that Section 2 of this Statement sets out in some detail the nature of
ALDI as an operator in terms of the proposed use and the format of the proposed store.
This is a material consideration in the Local Planning Authority’s (LPA’s) assessment of
this planning application. In the case of retail issues, this is particularly relevant to the
assessment of sequential sites undertaken at Section 6.2. Site Context and Proposal
Site Context
2.1 The application site is located on Station Road, to the north of Coleshill town centre.
The site is located within the defined development boundary, but is considered to be in
an out of centre location in retail planning policy terms.
2.2 The site, which extends to approximately 0.60 ha, comprises a rectangular shaped
parcel of previously developed land. It currently comprises two built structures and a
large area of hardstanding extending to the east. The site was previously occupied by
the Woodall Transport Group before they relocated (within Coleshill) in January 2014.
Only the building fronting Station Road remains in active use, occupied by Ortiga
Communications on a short term let.
2.3 The site is bound by Station Road to the west, employment land uses to the south and
open grassland to the north and east. The northern, eastern and southern boundaries
are formed by a 4.0m high security fence. The western boundary is marked by a picket
fence fronting Station Road. The topography is generally flat and all notable vegetation
is located adjacent to or beyond the site boundary.
2.4 The surrounding area is characterised by existing employment uses to the north and
south, and residential to the west. The area to the east is largely open grassland and
agricultural land, with the River Cole running parallel to the site,
2.5 Access to the site is taken from Station Road. There are existing bus stops situated on
Station Road, approximately 170m and 200m north of the site entrance for the
southbound and northbound bus stops respectively. Pedestrian footways are located
along the western side of Station Road, and in part, along its eastern side. Coleshill
Parkway Station is located approximately 1.1km north of the site,
Proposal
2.6 The application proposes the erection of a 1,735 sq m gross Class A1 discount
foodstore (1,140 sqm net) with ancillary storage, servicing and staff areas and a
dedicated delivery bay and unloading area. The proposals also include a modified
vehicular access from Station Road.
2.7 The scheme provides parking for 87 vehicles, including six parent and child spaces and
six designated spaces for disabled users. Cycle parking (via Sheffield style stands) will
also be provided near the front of the store.
2.8 The loading bay is located at the southern side of the store. The loading bay is located
below the store floor level, which allows stock to be unloaded from the back of the
vehicle directly into the warehouse at the same level. This speeds up the process and
minimises vehicle movements and noise. Waste will be compacted within the internal
warehouse and will be returned via the delivery vehicles.2.9 Hard and soft landscaping is also proposed within the scheme, with new trees and low
level planting (consistent with the nature of the site) provided throughout the site and at
the edge of the car parking areas.
The Store Operator - ALDI
2.10 The Company’s aim is to provide high-quality products at discounted prices and within a
pleasant shopping environment. Since arriving in the UK at the start of the 1990’s ALDI
has persistently sought to overcome various negative perceptions associated with
discount food operators, and have now reached the stage where their simple value for
money philosophy is widely understood and accepted. ALDI does not necessarily sell
goods at the lowest possible prices, but rather retail the highest quality goods at the
lowest possible prices. Discounted prices are generally achieved through bulk buying
and economies of scale, limiting the number of lines offered and concentrating on own
label products and maximising efficiency in the operation of the stores.
2.11 Prices are not lower because the quality of goods sold is reduced. Indeed, ALDI
regularly receive widespread recognition of the quality of the own label products,
regularly winning awards including, ‘Which?’ Supermarket of the Year, ‘The Grocers’ –
Discounter of the Year and various blind tasting tests.
ALDI Trading Policy
2.12 ALDI’s function is as a supermarket that can act as either a bulk food shop destination
or a ‘top-up’ shopping convenience store. The emphasis is, however, on providing for
those wishing to carry out a basic weekly shop, which most frequently (according to
most shopping surveys) involves use of the private car. Through their unique retail offer
(involving primarily own label products) ALDI stores also contribute to enhancing the
overall range and choice of convenience goods available within their catchments.
2.13 ALDI stores are modest-scale supermarkets, selling a deliberately restricted product
range consisting of approximately 1,500 lines. This is limited in comparison with other
grocery stores and supermarkets, which normally carry anything between 2,500 and
40,000 product lines, with some superstores carrying up to 60,000 lines. This is the
result of ALDI not stocking numerous types of one product (e.g. petfood, bread ranges
etc), but rather providing one line (and most often one size) of a given product within an
overall range that is carefully chosen to reflect the everyday essentials of the weekly
shop.
2.14 This limited selection of goods includes:
• pre-packed seasonal fruit and vegetable lines;
• general tinned, bottled and pre-packed groceries;
• frozen and chilled goods;
• beers, wines and spirits;
• pre-packed bread, morning goods and cakes;• a limited everyday range of non-food household items.
2.15 ALDI sell only a limited range of branded goods, which are only sold when, in ALDI’s
opinion, the brand offer cannot be ‘bettered’. Local and regional sourcing of products,
particularly for fresh produce and bakery goods, is an important element within the
range.
2.16 ALDI do not sell cigarettes or lottery tickets and stock only a small range of branded
wines and spirits, as well as a limited range of breadlines and a small number of boxed
cakes. The ALDI store format does not include a specialist butcher, fishmonger, bakery,
delicatessen or chemist, which are commonplace with larger supermarket chains.
2.17 This is an important distinction with ALDI and crucial to understanding how stores
operate. This means that, unlike larger supermarket formats, ALDI does not offer a
‘one-stop-shop’. When shopping at ALDI, customers will therefore also have to visit
other shops and services to complete their shopping trip. Stores also have only a
limited amount of non-food floorspace (around 20%), which mostly contains weekly
specials. This is a further difference to larger supermarkets, which can have between
30%-50% non-food floorspace.
2.18 On this basis, ALDI complements, rather than competes with, existing local traders and
generates considerable propensity for linked trips and associated spin-off trade. Store
opening hours are also more limited than traditional convenience shops/newsagents,
which further limits direct competition with such outlets.
2.19 In this way, the introduction of an ALDI offers considerable benefits to the areas a new
store will serve, increasing spin-off trade as well providing as physical and economic
regeneration. Stores will not only increase main food shopping choice in a locality
generally but, by providing an accessible store offering unrivalled value for money, will
specifically help those members of the local community on restricted budgets.
Merchandising Layout, Parking & Store Equipment
2.20 A tried and tested store format is crucial to the ALDI business model. This has been
developed by the enables the Company to enable goods to be handled, displayed and
sold efficiently, thus enabling stores to effectively compete and provide the award
winning offer. Store layouts are eminently practical and reflect the Company philosophy
of offering unrivalled value for money through cost effective management. Whilst the
ambient internal shopping environment is high quality, there is no unnecessary
expenditure on elaborate shop fittings with resultant savings being reflected in low
prices.
2.21 Merchandise is sensibly displayed in specially designed cases to eliminate stocking time
and allow easy and efficient re-stocking. ALDI make enormous efficiency gains in this
area and pass these directly to the customer. Goods themselves are unloaded directly
into the store (approximately 2-3 deliveries per day) via a dock leveller and can be
transferred directly to the shop floor to go on display.
2.22 The internal store layout and operation has been designed to be efficient and practical
for use by customers; these matters are routinely reviewed and monitored andadjustments made to the model as required. Retail is, of course, a constantly evolving
and dynamic sector and ALDI are committed to improving operations and shopping
experience to meet the demands and expectations of customers.
2.23 Features included to facilitate this are:
• long till conveyors that hold a customer’s full shop so as to allow goods to be
unloaded, scanned and then packed quickly by customers.
• level store access, automatic entrance doors, and wide aisles and checkouts for
easy access by all (the design and layout of new ALDI stores also complies with
the requirements of the Disability Discrimination Act).
• gondolas and shelving that allow goods to be easily reached.
• weekday store opening hours of 8am-10pm, and Sunday opening times to enable
general flexibility in choice of shopping (within Sunday trading laws).
2.24 It is the above core philosophy that underpins ALDI’s operator model and is fundamental
to their store development and profitability. Both the Company’s stores and their
distribution warehouses are laid out to reflect the internal shop layout, which ensures
efficient loading, unloading and stocking of shelves. This requires a consistent
floorspace proportion and layout regardless of store location.
2.25 Although the Company has developed stores of different sizes since arriving in the UK,
with the newer stores being larger than the early generation stores, all ALDI stores have
a consistent proportion and layout. Aldi strives to ensure that all of the stores can stock
the full range of goods (and the Company are currently undertaking a programme of
extending their smaller stores), although the amount of circulation space within some of
the smaller stores is reduced. The key factor is that each store displays its range of
goods in the same way and this is a fundamental efficiency factor in the operation which
enables prices to be kept very low.
2.26 Stores are required to have adjacent car parking facilities. In particular, customers
wishing to undertake a ‘weekly’ shopping trip, or those purchasing large and heavy
items, and less able-bodied customers, must have the opportunity to take their goods
home by car irrespective of the accessibility of the store location via sustainable modes
of transport.
2.27 ALDI recognises the need for flexibility in promoting sites for development and pursue
non-standard stores where this will assist in meeting planning policy requirements.
When considering the scope for flexibility, however, the inherent nature of ALDI’s
operation as a discount food retailer must be borne in mind. Accordingly, there are a
number of key areas where it is not possible to alter the core design of the store; as to
do so would undermine the operational efficiency of the business and hence its viability.
2.28 Specific areas of the design and layout of an ALDI store are as follows:
• Retail sales area: this is the most critical aspect of store building design. A
1,140sq m floor area is required to provide approximately 1,500 product lines, andthe dimensions of the retail area are determined by the need to ensure that
adequate and consistent product display space is provided. The retail sales area
is also specifically designed to enable efficient transfer of products (it has been
demonstrated that a rectangular store design is necessary for appropriate stock
transfer, retail display and security). In view of its central importance to the trading
and operational success of ALDI’s business, the size and proportions of the net
retail floor area is the area where it is not possible for ALDI to depart from their
core design as to do so would undermine trading viability.
• Storage and ancillary non-retail floorspace: where the size and shape of a
particular site requires less than optimal configuration, ALDI can exhibit some
flexibility, such as the location of the service pod and size of the storage area,
although in all cases adequate levels of storage will be required.
• Urban design: ALDI recognises that the external appearance of its buildings
needs to respond to their design context. In appropriate circumstances ALDI is
able to be flexible regarding siting, the exterior design and external finishes.
• Parking: ALDI is committed to ensuring that its stores are accessible by a variety
of modes of transport and seek to locate stores where they are accessible to
pedestrians and by public transport. In recognition of the fact that most
customers will wish to travel by car, and that many customers visit ALDI to carry
out a weekly shop, ALDI normally seeks parking provision in line with local
parking standards, subject to maintaining overall store viability.3. Planning Policy Context
3.1 This Section provides a summary of the key elements of national planning guidance and
local planning policy relevant to the proposed retail development at the application site.
3.2 The Development Plan comprises the ‘saved’ policies of the North Warwickshire Local
Plan (2006) and the North Warwickshire Core Strategy (2014), The ‘saved’ policies of
the Local Plan can only be afforded such weight as is appropriate to their degree of
consistency with the NPPF (Paragraph 215 of Annex 1 of the NPPF). We have
therefore considered the local policy context on this basis. Consideration has also been
given to the emerging North Warwickshire Site Allocations Plan.
National Planning Policy Framework (March 2012)
3.3 The National Planning Policy Framework (NPPF) was published on 27 March 2012 and
forms the planning framework for England. The NPPF superseded the previous national
policy tier comprising PPS/PPG/MPG (as well as Circular 05/2005 and some Chief
Planning Officer letters). The NPPF should be given significant weight in the
assessment of this planning application.
Presumption in Favour
3.4 A ‘Presumption in Favour of Sustainable Development’ is central to the NPPF.
Paragraph 14 of the NPPF states that:
“At the heart of the National Planning Policy Framework is a presumption in favour of
sustainable development, which should be seen as a golden thread running through
both plan-making and decision-taking.”
3.5 Paragraph 14 of the NPPF requires that for decision-taking this means:
• approving development proposals that accord with the development plan without
delay; and
• where the development plan is absent, silent or relevant policies are out-of-date,
granting permission unless:
• any adverse impacts of doing so would significantly and demonstrably outweigh
the benefits, when assessed against the policies in this Framework taken as a
whole; or
• specific policies in this Framework indicate development should be restricted.
3.6 For plan-making this means that:
• local planning authorities should positively seek opportunities to meet the
development needs of their area;• Local Plans should meet objectively assessed needs, with sufficient flexibility to
adapt to rapid change, unless:
• any adverse impacts of doing so would significantly and demonstrably outweigh
the benefits, when assessed against the policies in this Framework taken as a
whole; or
• specific policies in this Framework indicate development should be restricted.”
Retail Guidance
3.7 National policy applying to proposals involving retail development is set out at
Paragraphs 23-27 of the NPPF.
3.8 Paragraph 24 of the NPPF confirms that (in line with PPS4, now superseded) Local
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. Such proposals are required to be located in town centres, then edge-of-
centre locations, and only if suitable sites are not available should out-of-centre sites be
considered. The NPPF advises that in considering edge and out-of-centre sites,
preference should be given to sites that are accessible and well connected to the town
centre.
3.9 Town centres are defined in the NPPF as city, town, district and local centres, but
exclude small parades of shops of purely neighbourhood significance. The relevant
area is to be defined on the Local Authority proposals map, including the Primary
Shopping Area (PSA) and areas predominantly occupied by main town centre uses
within or adjacent to the PSA.
3.10 Paragraph 26 of the NPPF confirms that when assessing retail proposals outside town
centres, local planning authorities should require an impact assessment if the
development is over a proportionate, locally set floorspace threshold. If there is no
threshold, the NPPF confirms that the default threshold is 2,500 sq m. The adopted
Core Strategy does not set its own threshold.
3.11 Where impact assessments are required, policy relating to retail impact has been
simplified in the NPPF to reference two criteria only:
• The impact on existing, committed or planned public and private investment in a
centre, or centres, in the catchment area; and
• The impact on town centre vitality and viability, including local consumer choice
and trade in the town centre and wider area, up to 5 years from the time the
application is made. For major schemes where the full impact will not be realised
in five years, the impact should also be assessed up to ten years from the time
the application is made.
3.12 To inform the Council’s consideration of this application, a proportionate updated retail
impact assessment has been undertaken.Economic Development Guidance
3.13 The NPPF (at Annex 2) defines economic development as:
“Development, including those within the B Use Classes, public and community uses
and main town centre uses (but excluding housing development)”.
3.14 This means that the NPPF recognises the contribution of retail development to
economic growth and employment creation and, importantly, does not seek to make a
distinction between employment arising from retail development and ‘traditional’
employment arising from B-class uses.
3.15 As such, it follows that the third ‘core planning principle’ set out at Paragraph 17 of the
NPPF is applicable to retail development as well as other types of development falling
under the heading of economic development. That core planning principle states that
the planning system should “proactively drive and support sustainable economic
development to deliver the homes, business and industrial units, infrastructure and
thriving local places that the country needs”. As well as being required to objectively
identify the level of need for development and then to meet those needs, LPA’s are
required to “respond positively to wider opportunities for growth”.
3.16 The theme of government support for development that achieves economic growth is
reinforced in Paragraphs 18 to 20 of the NPPF which relate to the building of a strong,
competitive economy.
3.17 In respect of land proposed for employment use, Paragraph 22 states that:
“Planning policies should avoid the long term protection of sites allocated for
employment use where there is no reasonable prospect of a site being used for that
purpose. Land allocations should be regularly reviewed. Where there is no reasonable
prospect of a site being used for the allocated employment use, applications for
alternative uses of land or buildings should be treated on their merits having regard to
market signals and the relative need for different land uses to support sustainable local
communities.”
Planning Practice Guidance (NPPG)
3.18 The National Planning Practice Guidance (NPPG) confirms that when applying the
sequential test in decision-taking, due regard must be paid to the requirement
demonstrate flexibility. The NPPG also confirms that the impact test should be
undertaken in a proportionate and locally appropriate way. As a guiding principle,
impact should also be assessed on a like-for-like basis in respect of that particular
sector as retail uses tend to compete with their most comparable competitive facilities.
Development Plan
3.19 The Development Plan comprises the adopted Core Strategy (2014), together with
‘saved’ policies from the adopted Local Plan (2006). A Site Allocations Plan will also
form part of the North Warwickshire Local Plan (formerly the Local Development
Framework). The Pre-Submission Site Allocations Plan was consulted on in June 2014.Once adopted the Site Allocations Plan will replace the ‘preferred allocated sites’ from
the saved Local Plan.
North Warwickshire Core Strategy (2014)
3.20 Section 4 of the Core Strategy sets out nine Strategic Objectives. Other policies in the
Core Strategy are intended to flow from these objectives. Strategic Objective 1 aims to
“secure a sustainable pattern of development reflecting the rural character of the
Borough”. To do so, priority will be given to:
“re-using previously developed land and buildings within Market Towns and Local
Service Centres, recognising regeneration opportunities; as well as reducing the overall
need to travel, limiting exposure to flood risk and protecting the Borough’s
environmental character”.
3.21 Strategic Objective 4 aims to “maintain and improve the vitality of the Market Towns”.
This will be achieved by making the best use of land and buildings, facilitating
regeneration and building on their historic strengths.
3.22 Policy NW1 sets out the Council’s approach to following the presumption in favour of
sustainable development. It states that planning applications that accord with the
policies of the Core Strategy will be approved without delay, unless material
considerations indicate otherwise. Where there are no relevant policies, or the policies
are out of date, the Council will grant permission unless material considerations indicate
otherwise.
3.23 Paragraph 2.3 of the Core Strategy recognises the importance of Coleshill as one of
three market towns in North Warwickshire. It notes that it is important to the health of
the surrounding rural economy as it provides many services and facilities to the outlying
hinterland.
3.24 This is reflected in Policy NW2, which sets out the settlement hierarchy for North
Warwickshire, identifying Coleshill as a ‘Category 2’ settlement – Green Belt Market
Town. The policy states that
““Within the development boundary of Coleshill, the Green Belt Market Town,
development for employment, housing (including affordable housing), services and other
facilities will be permitted.”
3.25 Paragraph 6.7 states that retail proposals will “be expected to accord with the settlement
hierarchy and be proportionate to the size and scale of the settlement”.
3.26 Policy NW9 states that “all employment land will be protected unless it can be
demonstrated that there is no realistic prospect of the site being used for employment
purposes. Evidence would need to demonstrate that:
o The site is no longer commercially viable; and
o It has been marketed for an appropriate period of time, usually no less than 12
months; ando There are no alternative employment uses that could use the site.”
3.27 Paragraph 7.40 of the Core Strategy does, however, recognise that existing
employment land cannot always be protected from alternative uses. It continues by
stating that proposals for a change of use from employment uses (Class B) to non-
employment uses should be supported by evidence to show that the existing buildings
and land are not suitable or cannot be viably reused for another employment use.
3.28 Policy NW10 sets out the main development considerations that should be met,
including:
• Be targeted at using brownfield land in appropriate locations reflecting the
settlement hierarchy.
• Provide for proper vehicular access, sufficient parking and manoeuvring of
vehicles.
• Encourage sustainable forms of transport focusing on pedestrian access and
provision of bike facilities.
• Avoid and address unacceptable impacts upon neighbouring amenities.
3.29 Policy NW11 states that new development will be expected to be energy efficient in
terms of its fabric and use. Major development will be required to provide a minimum of
10% of its operational energy requirements from a renewable energy source subject to
viability.
3.30 Policy NW12 sets out five factors development must respond to in order to deliver
quality development.
3.31 Policy NW13 states that the quality, character and local distinctiveness of the natural
environment will be protected and enhanced.
3.32 Policy NW15 relates to nature conservation and states that development should help
ensure that there is a net gain of biodiversity and geological interest by avoiding adverse
impacts first, then providing appropriate mitigation measures and finally seeking positive
enhancements wherever possible.
3.33 Policy NW17 relates to economic regeneration, stating that “the delivery of employment
generating uses, including the redevelopment of existing employment sites and farm
diversification, should reflect the need to broaden the employment base, improve
employment choice and opportunities for local people.”
3.34 Policy NW20 states that proposals that would have a detrimental impact on the viability
and vitality of town centres will not be permitted. Town centres will be the focus for new
retail development.
3.35 Paragraph 7.92 of the Core Strategy states that “retail uses will be focussed towards the
Market Towns to help maintain their viability and vitality”.North Warwickshire Local Plan (2006)
3.36 The adopted Core Strategy supersedes some of the policies contained in the adopted
Local Plan (2006). The following ‘saved’ policies are, however, relevant to the
consideration of this planning application.
3.37 A number of policies relating to the natural and built environment remain ‘saved’. These
relate to trees and hedgerows (Policy ENV4), safeguarding water resources and
protecting development from floodwater (Policy ENV8), air quality (Policy ENV9), urban
design (Policy ENV12), building design (Policy ENV13) and access design (Policy
ENV14).
3.38 Policy ECON1 identifies a number of existing industrial estates that are designated for
local employment purposes, including Coleshill Industrial Estate. The policy states that
the quantum of development arising from any expansion, conversion or redevelopment
of existing premises will be limited to that provided for by Classes B and D (Part 8,
Schedule 2 to the Town and Country Planning (General Permitted Development) Order
1995.
3.39 Policy ECON3 states that existing employment sites and buildings within the
development boundaries of the Market Towns will be retained for employment purposes,
unless:
• Redevelopment or reuse is proposed as a mixed use scheme within a defined
town centre; or
• There would be no negative impact on the range and quality of employment sites
available in the settlement concerned.
3.40 The above policies were conceived in a context where there was deemed to be an
‘oversupply’ of employment land within the Borough relative to requirements set out in
the Warwickshire Structure Plan (now rescinded). They were also prepared in the
context of an evidence base dating from 2001. These factors limit the weight that can be
afforded to these policies.
3.41 Paragraph 5.30 of the Local Plan recognises that the retention of suitable sites for
continued employment use should not be perceived as an obstacle to redevelopment
and/or the qualitative improvement of such sites. It continues by stating that the Council
encourages redevelopment and improvement of sites within the constraint of not adding
to the supply of employment land.
3.42 Paragraph 5.31 states that it is not the intention of Policy ECON3 to retain all
employment sites within the development boundaries of the Main Towns, the Green Belt
Market Town and Local Service Centres. It is recognised that there may be instances
where the loss of an employment use would not have a harmful impact on the portfolio
of sites available in a particular settlement, or where the site may be better suited to
meet an identified need for community facilities or services.
3.43 Policy ECON5 states that proposals for additional retail floorspace will only be permitted
if they are located within the town centre boundary and are less than 1,000 sq m. Giventhat the Council currently has no up-to-date retail evidence base the requirement for
retail units to be less than 1,000 sq m must be given limited weight.
3.44 Policy TPT1 requires the submission of a Transport Assessment and Travel Plan to
support applications for new food retail uses over 1,000 sq m. Other transportation
matters covered by the ‘saved’ policies include, traffic management and travel safety
(Policy TPT2), access and sustainable travel and transport (Policy TPT3), public
transport improvements (Policy TPT4) and parking (Policy TPT6).
Emerging North Warwickshire Local Plan
3.45 The adopted Core Strategy forms part of the wider emerging Local Plan. As part of this
process, the Council consulted on the Pre-Submission Site Allocations Plan in June
2014. This plan seeks to identify sites consistent with meeting the requirements set out
in the adopted Core Strategy.
3.46 Paragraph 2.7 states that areas such as the Station Road/Gorsey Lane employment
estates “will continue to be identified and protected for employment uses”. The
emerging Development Management Policies document will not, however, identify these
areas as ‘allocated employment’ sites as they have already been developed. Control
will be applied over their potential redevelopment for both employment and other uses
such as housing.
3.47 Policy EMP1 states that the existing employment sites identified on the Proposals Map
will be safeguarded for general employment uses, including Classes B1, 2 & 8. It
continues by stating that redevelopment proposals for non-employment related
development will be resisted unless clear evidence and justification is provided that:
• the redevelopment proposed is appropriate; and
• the loss of the employment use/land will not impact detrimentally on choice,
availability and the economic viability/vitality, character and well-being of the
employment estate.
Retail Evidence Base
3.48 There is no independent Borough–wide retail study forming the Council’s retail evidence
base. There is, however, reference on the Council’s website to a ‘Planning Policy and
Retail Appraisal’ report relating to Coleshill prepared by Roger Tym and Partners (RTP)
in April 2009. This was prepared on behalf of Limes Developments Limited in
connection with a proposed edge-of-centre foodstore on land at Birmingham Road and
Park Road, Coleshill. The store was granted planning permission in June 2010 (LPA
ref: PAP/2009/0154) and is currently occupied by a 1,007 sq m net Morrison’s
supermarket. The RTP assessment is more than five years’ old and of limited relevance
as a basis for assessing the ALDI store proposal at Station Road. It also relates to a
specific proposal and therefore cannot be considered as an evidence base to underpin
the retail policies of the development plan.4. Employment Land
4.1 The application site forms part of a large mixed industrial estate located on the northern
edge of Coleshill. The industrial estate, which is centred on Station Road and Gorsey
Lane, is located within the defined ‘development boundary’ and is identified as an
‘existing employment area’ on the adopted Local Plan Proposals Map.
4.2 Given the existing use and location of the application site, it is necessary to consider the
proposals against the relevant policies contained in the adopted Local Plan and Core
Strategy. As set out in Section 3 of this Statement, relevant policies include Policy NW9
and NW17 of the Core Strategy and Policy ECON3 of the adopted Local Plan.
4.3 Policy NW9 states that employment land will be ‘protected’ unless it can be
demonstrated that there is no realistic prospect of the site being used for employment
purposes. Evidence is required to demonstrate that the site is no longer commercially
viable; it has been marketed for an appropriate period of time; and there are no
alternative employment uses that could use the site. Paragraph 7.40 of the Core
Strategy does, however, recognise that employment land cannot always be protected
from alternative uses.
4.4 Policy ECON3 of the adopted Local Plan states that existing employment sites within
the development boundary of Coleshill will be retained for employment purposes unless:
• Redevelopment or re-use is proposed as a mixed use scheme within a defined
town centre; or
• there would be no negative impact on the range or quality of employment sites
available in the settlement concerned.
4.5 Paragraph 5.31 of the Local Plan establishes that it is not the intention of Policy ECON3
to retain all employment sites within the development boundary of Coleshill. It continues
by stating that there may be cases where the loss of an employment use would not have
a harmful impact on the portfolio of sites available in a particular settlement, or where
the site may be better suited to meet an identified need for community facilities or
services.
4.6 Reference to the North Warwickshire Employment Land Review Update (September
2013) establishes that the application site forms part of a wider industrial estate that
extends to approximately 63.78 ha. The ELR Update notes that the industrial estate
includes a wide range of accommodation, from larger warehouse units to smaller
industrial units and small office suites. It continues by stating that “the size, type and
quality of the premises vary considerably”.
4.7 Whilst the wider estate is identified as being generally successful, the ELR Update notes
that “there is a level of vacancies of 10-20%, mainly amongst the older premises”.
Given the high vacancy levels, the ELR Update notes that older stock “would benefit
from investment in refurbishment or redevelopment”. The application site itself is
located on Station Road and comprises relatively small scale industrial/office buildings
and a large area of hardstanding. The application site is older stock lesser quality.4.8 The site accommodated the Woodall Transport Group until the business relocated in
January 2014. The previous occupant has advised that the business relocated due to
limitations of the application site to accommodate modern industrial/distribution uses.
Concerns included the age and quality of the existing buildings, limited warehousing
space and the ability to operate a 24 hour distribution business in close proximity to
residential uses. Woodall Transport Group remained within Coleshill, relocating to
Gorsey Lane.
4.9 The limitation of the application site for modern Class B employment uses is illustrated
by the relocation of the Woodall Transport Group. It also demonstrates that the
variation in quality of stock within the wider Coleshill Industrial Estate. Following the
relocation of the previous occupier, the majority of the application site has remained
vacant. During this 20 month period it has only been possible to let one of the existing
buildings on a short term basis. The current occupier is, however, due to relocate to
new premises.
4.10 Returning to the relevant adopted Core Strategy and Local Plan policies, it is clear that
there is a considerable amount of alternative local quality employment land within the
Coleshill Industrial Estate, Gorsey Lane and Station Road area. As such, the loss of the
application site to retail use will have no negative impact on the range or quality of
employment sites available to meet the future needs for industrial development within
Coleshill or North Warwickshire.
4.11 The application site itself comprises poor quality, older stock, and is vacant with the
exception of one building let on a short term basis. The ELR Update establishes that
the stock within the wider industrial estate is of varied quality, with vacancy levels
reaching 10-20% for older premises. This reflects the difficulties of letting older, poorer
quality stock such as the application site.
4.12 The definition of ‘economic development’ in the NPPF (Annex 2) should also be taken
into account when considering the acceptability of redeveloping the site for retail uses.
The NPPF recognises the important contribution of retail development to economic
growth and employment creation. Importantly, the NPPF makes no distinction between
employment arising from retail development and ‘traditional’ employment arising from
Class B uses.
4.13 The policies of the adopted Local Plan and Core Strategy refer to retaining existing
sites for ‘employment purposes’. In doing so, it should be recognised that retail
development constitutes an employment use and is an important form of job creation.
This is demonstrated by the number of jobs expected to be generated by the new Aldi
foodstore – up to 40 new jobs, of which around 35 positions will be locally sourced. This
compares favourably to the number of staff currently employed at the site, which is
approximately 10 people. It is also relevant that the proposals will require around 100
construction operatives during the construction phase.
4.14 Policy NW17 of the adopted Core Strategy relates to economic regeneration, referring
specifically to ‘the delivery of employment generating uses’. National planning guidance
makes it clear that retail uses should be classed as valuable ‘employment generating
uses’.4.15 In conclusion, the application proposals will have no harmful impact on the portfolio of
sites available in Coleshill, would result in considerable investment in an existing
brownfield site within the defined development boundary and will generate up to 40 new
jobs. The development will result in an older, lesser quality Class B employment site,
being brought back into a commercially viable employment generating use – thereby
contributing to the economic regeneration of the area in line with Policy NW17. The loss
of the application site from Class B employment uses to a retail foodstore is therefore
considered acceptable.5. Vitality and Viability Assessment
5.1 To assist in determining the likely economic impact of the proposed development, this
section of the report establishes the baseline health of the defined centres within the
agreed catchment area, namely:
• Coleshill Town Centre; and
• Water Orton Local Centre;
Coleshill Town Centre
5.2 Coleshill is identified as one of three market towns in the Borough. The defined town
centre boundary is centred around High Street and Church Hill. The ‘Core Shopping
Frontage’ is focused solely on the High Street.
Diversity of Uses
5.3 The defined town centre comprises a mix of comparison and convenience retail,
together with a range of other complementary service uses. There are also a number of
food and beverage uses including cafes, restaurants, public houses and takeaways.
5.4 Table 5.1 (below) identifies the mix of retail and service uses found in Coleshill in June
2015.
Table 5.1: Diversity of Uses
Use No. of Units %
A1 convenience 2 3.39
A1 comparison 17 28.81
Services 20 33.89
Vacant 1 1.69
Other 19 32.20
Total 59 100
5.5 As Table 5.1 demonstrates, the total number of retail units within the district centre in
June 2015 totalled 59. The centre offers a good range of facilities across the
convenience, comparison and service sectors.
5.6 Convenience goods provision is limited to two retail units – The Co-operative and Tesco
Express. This is below the national average. An edge of centre Morrison’s foodstore is
located on Birmingham Road/Park Road.5.7 Comparison good units are reasonably well represented, comprising a reasonable mix
of independent operators, including various clothing shops, furniture/hardware stores, a
bike shop, flower shop and gallery.
5.8 Turning to services, Table 5.1 demonstrates that the town possesses a good range of
other uses for local residents including:
• A large number of cafés, restaurants and public houses (Green Man, Swan Hotel,
Balti Cottage, Indian Lounge, Café & Tea Rooms, Brownies Coffee Shop,
Coleshill Fish Bar, Rajrani, Conisours Sandwiches, Polash, Tao Tao, L’Maiz)
June’s Café);
• Banks (HSBC, Lloyds, Barclays, The Coventry);
• Solicitors (Waters & Co, Garner Canning, Evans Derry) Estate agents (Miller
Briggs & Co, First Choice Property Centre, House and Home Property Centre,
Bristow Eves, Waters & Co);
• A Post Office;
• Hair & Beauty Salons (Miracles, Heads Of Coleshill, Pacific Nails, Blades, Le
Hair and Beauty, Well Being Therapy Centre);
• Medical and Pharmacies (Hazelwood Group Practice, Lloyds Pharmacy)
• A library.
5.9 Whilst the centre’s retail offer is considered to be in keeping with a centre of this scale,
the centre does contain a large number of café//restaurant/takeaway uses and service
uses.
Proportion of Vacant Street Level Property
5.10 In June 2015 there was only one vacant unit in Coleshill. This is clearly a low level of
vacancies.
Pedestrian Flows and Accessibility
5.11 The High Street is the main shopping area of Coleshill Town Centre. The High Street
benefits from pedestrian walkways and various forms of pedestrian crossings, which
makes it relatively easy for pedestrians to navigate through the centre.
5.12 Whilst we are not aware of any recent footfall surveys, it is evident from our own
observations that Coleshill is relatively busy.
5.13 The public main car parks serving Coleshill are located at Parkfield Road and Church
Hill. Both are free of charge. Additional parking is also available at the Morrison’s
supermarket on Birmingham Road/Park Road. Public parking is available for up to three
hours. From our site visit, these car parks appeared to be well used.5.14 The town is well served by public transport. Table 5.2 identifies the principal bus
services running to and from Coleshill.
Table 5.2: Coleshill Principal Bus Services
Number From/To Frequency
70 Birmingham Argos – 2 per hour (Mon to Sat); 1
Solihull (via Coleshill) per hour (Sun)
75 Sutton Coldfield – 1 per hour (Mon to Sat)
Birmingham International
115 Tamworth – Coleshill 1 per hour (Mon to Sat)
5.15 Coleshill Parkway Railway Station is located to the north of the town centre.
Environmental Quality
5.16 The majority of shop fronts are reasonably well maintained and the public realm is
dominated by pavements that are in reasonable condition and also comprise adequate
street furniture and bins at regular intervals. The Lych Gate leads to St Peter and St
Paul’s Church to the rear of the High Street. A large recreational area is situated to the
west of Parkfield Road.
Perception of Safety and Occurrence of Crime
5.17 The centre is generally well lit, which enhances the perception of safety for its visitors.
Summary and Conclusion
5.18 The centre’s retail offer is considered to be in keeping with a centre of this scale and
there are areas. It is a traditional market town with a good level of environmental quality
and pedestrian accessibility and low vacancy rate. Overall we conclude that the centre
is reasonably vital and viable but, like all centres, could benefit from investment.
Water Orton
5.19 Water Orton is a local centre, focused on a small parade of shops located to the north of
Birmingham Road. Three additional units are located to the south of Birmingham Road.
The centre comprises a mix of retail and services uses, and is anchored by a Tesco
Express. The centre also includes food and drinks and hair/beauty uses. There were
no vacant units at the time of our site visit (June 2015). The centre benefits from free
off-street parking and is situated adjacent to the Water Orton train station. At the time of
visiting the car parking was heavily used.Conclusion
5.20 In summary, Coleshill Town Centre and Water Orton Local Centre are considered to be
performing relatively well. It is noted, however, that Coleshill has a relatively limited
range of convenience retail units within the town centre boundary. We conclude that all
centres are meeting their roles within the retail hierarchy and are both vital and viable to
varying degrees.6. Sequential Assessment
6.1 As set out in Section 3, the NPPF requires LPAs to apply a sequential test to planning
applications for main town centres uses that are not in an existing centre and are not in
accordance with an up-to-date Local Plan. A sequential assessment has been
undertaken for this development proposal given that it proposes a main town centre use
in an accessible, but ‘out of centre’ location.
Overview & Approach to Assessment
6.2 The Planning Practice Guidance (Paragraph 010) sets out a checklist that should be
taken into account in determining whether a proposal complies with the sequential test.
This is summarised as follows:
• “With due regard to the requirement to demonstrate flexibility, has the suitability
of more central sites to accommodate the need or demand which the proposal is
intended to meet been considered? Where the proposal would be located in an
edge of centre or out of centre location, preference should be given to accessible
sites that are well connected to the town centre. Any associated reasoning
should be set out clearly;
• Is there scope for flexibility in the format and/or scale of the proposal? It is not
necessary to demonstrate that a potential town centre or edge of centre site can
accommodate precisely the scale and form of development being proposed, but
rather to consider what contribution more central sites are able to
makeindividually to accommodate the proposals;
• If there are no suitable sequentially preferable locations, the sequential test is
passed.”
6.3 In applying the sequential approach, it is therefore important to reflect upon the nature of
the proposed development. In this case a retail development for a discount foodstore is
proposed. In considering potential sequentially preferable sites, we have considered the
proposed format and scale of the development, as well as the scope for disaggregation
of the scheme, and have taken a flexible and proportionate approach to the amount of
floorspace and associated back up space, servicing and parking required.
6.4 In considering the sites we have applied the ‘Dundee’ principle to our assessment
below, and we would emphasise the importance of the meaning of ‘suitable’ from the
perspective of the applicant, as clearly underlined by this Judgment.
6.5 This case is material to the operation of the sequential approach. This is a decision of
the Supreme Court (21 March 2012) and as such has currency in England and Wales,
although it relates on an appeal by Tesco Stores Limited in Scotland. This appeal was
lodged in relation to a planning permission granted to Asda and MacDonald Estates in
Dundee.
6.6 Although focusing on the question of deficiency, the case considered the application of
the sequential test and the meaning of ‘suitable’ in relation to need and alternative sites.It was held in the Judgment that ‘suitable’ means ‘suitable for the development proposed
by the applicant’, subject to the qualification that flexibility and realism must be shown by
developers.
6.7 Reference was made in the decision to another case (Lidl (UKGmbH) v Scottish
Ministers [2006]), in which Lord Glennie had observed, in relation to the sequential
approach, that the question to be addressed is whether an alternative site is suitable for
the proposed development, not whether it can be altered or reduced to fit an alternative
site. In the case under consideration (the Asda store proposal in Dundee), the
assessment had not been confined to sites that could accommodate the development in
the precise form in which it had been designed; but had examined sites that could
accommodate a smaller development. Hence, it was considered that flexibility had been
demonstrated by Asda/MacDonald Estates through the application process.
6.8 Indeed, more recent guidance has been issued through other appeal cases that provide
clarification of the meaning of ‘suitable’. A recent Secretary of State decision (LXB RP
(Rushden) Limited, 11 June 2014. Ref. APP/G2815/V/12/2190175) emphasises that the
‘suitability’ of alternative sites must be considered in terms of the development proposed
by the applicant and whether it can be accommodated on an alternative site.
6.9 This decision clarifies that the Dundee decision “expressly rejected the notion that
‘suitable’ means that one should alter or reduce the proposal so as to fit onto an
alternative site” (Inspector’s Report, paragraph 8.44). The decision also confirms that “if
a site is not suitable for the commercial requirements of the developer in question then it
is not a suitable site for the purposes of the sequential approach” and that “the question
is whether the alternative site is suitable for the proposed development, not whether the
proposed development could be altered or reduced so that it can be made to fit the
alternative site.” (Inspector’s emphasis) (Inspector’s Report, paragraph 8.45).
6.10 The proposal seeks to provide a retail development to enhance the retail offer of the
existing area. The proposal will provide retail floorspace in a format that is not available
within the town centre and will improve the retail offer, competition, and choice. An
alternative location would not achieve the same aims and would be ‘unsuitable’ for this
reason; this is a material issue applying the principles established in the Dundee and
Rushden cases (see above).
6.11 Notwithstanding the above, we have adopted a flexible approach and considered more
central sites/units. Our search has focussed on Coleshill and Water Orton and the
parameters for the assessment are set out below.
Sequential Assessment - Parameters
6.12 In relation to site characteristics, the principal assessment parameters are:
• Availability – whether sites are available now or are likely to become available for
development within a reasonable period of time (determined on the merits of a
particular case, having regard to, amongst other matters, the applicant’s suitability
criteria and timescales).• Suitability – with due regard to the requirements to demonstrate flexibility,
whether sites are suitable to accommodate the proposal.
• Viability – whether there is a reasonable prospect that development will occur on
the site at a particular point in time. Again, the importance of demonstrating the
viability of alternatives depends in part on the nature of the proposal and the
timescale over which the applicant requires it to be delivered.
6.13 Whilst ‘viability’ is not expressly referenced by the NPPF in relation to planning
applications, it is cited as a relevant consideration in the allocation of sites. It is our view
that viability remains relevant to the consideration of whether sites are ‘suitable’ (for
completeness we have therefore included viability within our consideration of
sequentially preferable sites).
6.14 The above parameters provide a robust and policy-compliant basis for assessment.
Relevant Sites
6.15 Turley has reviewed both in centre and edge of centre opportunity sites that could be
feasibly considered to be sequentially preferable to the application site, in the light of the
parameters set out above. This exercise has been undertaken in relation to Coleshill
Town Centre and Water Orton Local Centre.
Coleshill Town Centre
6.16 From our observations in June 2015, there is currently only one vacant retail unit within
the defined Coleshill Town Centre. This unit, with a groundfloor retail area of 27.59 sq
m, is clearly too small to accommodate the floorspace proposed by ALDI.
6.17 No other sites were observed within the defined town centre that were either available or
large enough to accommodate the development proposals. Two sites were identified
outside of the defined centre, but within close proximity to the existing Morrisons store:
• The former Coleshill Leisure Centre, Park Road
• The former Warwickshire Police Station, Birmingham Road
6.18 It is understood that the former Coleshill Police Station is now under offer and is
therefore not available. Notwithstanding this, the site is not large enough to
accommodate the proposed development.
6.19 The former Coleshill Leisure Centre is understood to be available for development. The
site, however, extends to 0.31ha and is therefore not considered large enough to
accommodate the proposed development.
Water Orton Local Centre
6.20 The settlement hierarchy set out in the adopted Core Strategy identifies Water Orton as
a Local Service Centre (Green Belt) (Category 3B). The main retail and service uses
are centred on the Station Buildings on Birmingham Road. From our observations inJune 2015, there are currently no vacant units in the main commercial area. Similarly,
we did not observe any sites either in, or on the edge of, the centre, which were either
available or large enough to accommodate the proposed development. The centre is
hemmed in by a railway line to the north and existing uses (predominantly residential) to
the west, east and south. Opportunities to extend the development boundary are also
constrained by the Green Belt, which surrounds Water Orton.
6.21 It is therefore concluded that there are no opportunities to accommodate the proposed
development in Water Orton.
Sequential Assessment Conclusions
6.22 Having visited and reviewed the defined centres, we were unable to identify any sites
within or at the edge of these centres that could meet the needs of the proposed store.
6.23 As such, by this assessment, we consider that compliance with the sequential test can
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