UNITS 11A & 11B,


1.0    INTRODUCTION…………………………………………………………….3
3.0    THE PROPOSED DEVELOPMENT……………………………………….8
4.0    PLANNING POLICY OVERVIEW………………………………………..10
5.0    RETAIL CONSIDERATIONS……………………………………………..17
7.0    SUMMARY AND CONCLUSIONS……………………………………….38

2       DECISION NOTICE 99/00097/OP

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

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

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

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

                         Ground Floor             973sqm               983sqm

                           Mezzanine              743sqm               743sqm

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

                        Combined Total                      3,442sqm

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

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

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

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

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


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

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

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

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

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

                                               Existing Floorspace

               Ground Floor                              973sqm                 983sqm

              Mezzanine Floor                            625sqm                 489sqm

                    Total                                1,598sqm              1,472sqm

                 Combined                                           3,070sqm

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

2.6   The use of Units 11A and 11B falls assembly and leisure uses within Use Class E (d), with
      Unit 11A currently occupied by TruGym and Unit 11B occupied by Partyman.

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


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

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

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

       Relevant Planning History

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

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

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

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

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

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

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

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


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

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

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

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

                         Ground Floor           973sqm              983sqm

                          Mezzanine             743sqm              743sqm

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

                       Combined Total                    3,442sqm

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

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

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

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

The Proposed Occupiers- DFS and Sofology

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

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

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

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

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

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

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

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

       National Planning Policy

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

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

       Economic Growth

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

       Town Centres

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

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

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

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

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

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

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

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

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

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

4.11   With regards to retail impact, the PPG confirms:

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

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

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


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

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

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

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


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

Local Planning Policy

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

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

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

       Site Designations

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

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

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

          Relevant Local Plan Policies

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

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

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

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

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

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

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

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

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

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

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

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

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

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

       Summary of Planning Policy

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

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

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

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

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

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

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


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

            The Sequential Test

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

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

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

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

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

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

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

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

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

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

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

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

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

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

“Here too the context indicates that the issue of suitability is directed to the developer’s
               proposals, not some alternative scheme which might be suggested by the planning
               authority. I do not think that this is in the least surprising, as developments of this kind are
               generated by the developer’s assessment of the market that he seeks to serve. If they do
               not meet the sequential approach criteria, bearing in mind the need for flexibility and
               realism to which Lord Reed refers in para 28, above, they will be rejected. But these
               criteria are designed for use in the real world in which developers wish to operate,
               not some artificial world in which they have no interest doing so”. (our emphasis)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

       Stevenage Town Centre – Existing Opportunities

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

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

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

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

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

                Table 4: Summary of Sequential Survey

         Site              Address                                   Floorspace

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

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

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

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

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

          6              SG1 Development Site                     Up to 151sqm

          7              Matalan Retail Park, Danesgate           Up to 454sqm

          8              Major Opportunity Areas                  N/A

          9              Local / Neighbourhood Centres            N/A

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

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

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

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

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

       2. Former Office Outlet - Unit 11, Fairlands Way

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

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

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

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

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

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

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

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

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

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

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

       4. Park Place, Stevenage, SG1 1DP

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

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

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

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

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

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

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

6. SG1 Development Site, Town Centre Stevenage

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

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

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

       7. Matalan Site, Danestrete

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

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

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

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

5.55   The site is therefore dismissed as unavailable and unsuitable.

8. Major Opportunity Areas (MOAs)

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

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

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

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

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

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

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

       9. Stevenage 2007 Town Centre Regeneration Development

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

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

       10. Local and Neighbourhood Centres

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

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

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

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

       Summary of Sequential Test

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

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

       Town Centre Impact Considerations

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

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

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

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

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

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

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

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

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

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

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

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

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