Truro and Threemilestone Area Action Plan Review of Retail Representations For Carrick District Council - Cornwall Housing
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Truro and Threemilestone Area Action Plan Review of Retail Representations For Carrick District Council DTZ 48 Warwick Street, London W1B 5NL 30 May 2008
Contents
1. Introduction Page 2
2. Quantitative Need for New Retail Development Page 5
3. Review of Representations Page 13
4. Responses to the Retail Objections Page 18
5. Implications for the Retail Strategy Page 25
6. Recommendations Page 28
Appendices
Appendix 1 – Truro RECAP Model 2008
Page 11. Introduction
th
1 DTZ was instructed on 25 July 2007 by Carrick District Council to advise on how to deal with
the objections received by the Council in response to the Truro and Threemilestone Area
Action Plan (the AAP). Specifically DTZ was asked to review and summarise each
representation, and advise on the implications for the Council’s retail development strategy
set out in the draft AAP. In November 2007, the Council further instructed us to update and
roll forward to 2026 the retail capacity forecasts set out in Donaldsons’ ‘Truro Retail, Leisure
and Offices Study 2006’ (hereinafter referred to as ‘the Retail Study’). As the up-to-date
context for our review of the retail representations, our work on this update of the quantitative
need forecasts is described in Section 2 of this report. The reviews of the representations are
set out in Section 3. Section 4 is our response to each retail representation. We then looked
at the implications of these representations for the retail strategy, as discussed in Section 5.
Section 6 sets out our recommendations to the Council.
2 Representations were made by 25 parties, most of which included comments on some of the
retail policies in the draft AAP. This report reviews these representations; which cover a
range of retail issues including city centre policies, the potential relocation of Tesco and
policies for a new district centre. Some of the representations are in broad terms, whereas
one amounts to a detailed critique of the retail forecasts set out in the Retail Study.
Key Features of the Area Action Plan
3 Preferred Options CC1 to CC4 are general policies concerning the primary shopping area,
primary and secondary shopping frontages and improving the retail offer of Truro. The AAP
states that the preferred location for new retail development will be within the city centre
primary shopping area as defined on the proposals map. It also states that primary shopping
frontages will be protected from further changes of use to A2, A3, A4 and A5 uses unless the
change contributes to the vitality and viability of the city centre. It states that changes of use
in secondary shopping frontages from retail to non retail will be carefully assessed. Finally,
the AAP states that provision will be made for up to 34,900 sq m net additional comparison
goods and 3,500 sq m of convenience goods retail space within the city centre by 2016.
These capacity forecasts are based on the Retail Study.
4 The AAP envisages that the main location for this retail space will be on the Pydar Street site.
Currently the Pydar Street site is used for office accommodation, car parking and some retail
uses. It is of an appropriate size and location for major retail growth and supports the
Council’s ‘dumbbell strategy’ of providing major retail attractions at opposite ends of the city
centre. Preferred Option CC5 sets out development principles for this site, which include,
amongst others:
Page 2– Development which integrates well with the existing centre
– A variety of retail spaces to suit a range of retail requirements
– Mixed use development
– Provision of adequate car parking
– Provision of on and off site highway improvements
– High level of permeability
– Contribution to improvements to the public realm.
5 Truro Riverside is designated as a Key Area of Change; it is recognised as an under-utilised
asset within the city, particularly as Tesco owns and occupies a key site in the waterfront
area. A need to invigorate the waterfront has been identified. Tesco has expressed a desire
to expand and relocate away from the Waterfront site. However this would be likely to have
an impact on the city centre, as its main convenience goods store would be relocated out of
the city centre. Preferred Option AC1 sets out the development principles for the Garras
Wharf redevelopment site, the key principles being as follows:
– Development that contributes to the leisure offer and distinctiveness of the city centre as
well as integrating well with the city centre.
– Development that allows public access to the waterfront.
– Mixed development to include leisure, commercial and residential uses.
– Provision of car parking and highway improvements, particularly between the site and
Lemon Quay.
– Provision of a half tide sill and marina.
6 There are two main areas of housing growth mentioned in the AAP, to the south and west of
the city centre. These growth areas will have some influence on the amount, and particularly
the siting of any future retail developments. There are also two District Centre location
options, one in the Gloweth and Higher Town corridor to the west of the city centre, and one
at High Newham Farm and Tolgarrick to the south of the city centre. The following details the
main development principles for the identified housing expansion areas.
7 Preferred Option H3 concerns the Gloweth and Higher Town corridor and states that the aim
for this area is to develop an urban extension, grouping sites to the North and South of the
A390 to strengthen existing neighbourhoods. The following are some of the main principles
for the development in this area.
– Any development should respond positively to the existing settlement pattern.
– Employment uses are to be concentrated on the plateau to the north of the A390, with
residential developments on the slopes.
– Development of a network of local centres that meet the day to day shopping needs of the
proposed new communities.
Page 3– All new development will be required to link through to existing residential and commercial
areas.
8 The second main potential housing growth area is located at Higher Newham, located to the
south of the city centre. This site is topographically a challenge to develop, as it is fairly
steeply sloping and any development will have a high landscape impact. Preferred Option H4
concerns the key development principles for this site. The main ones are listed below.
– The development should be a mixed use development to include commercial, retail and
residential uses.
– A new primary school should be provided.
– The development should use the contours of the site to provide an area of open space at
the higher levels to retain the green background to the city.
– An opportunity to relocate the existing Tesco foodstore at Garras Wharf into the entrance
to the Higher Newham site. This relocation would allow redevelopment of the waterfront
area and allow an expansion of the convenience goods floorspace within the city.
However taking Tesco out of the city centre (as previously discussed) may be detrimental
to its viability and vitality.
9 A further area of housing growth is located at Tolgarrick, which is an area of land slightly
smaller that the Higher Newham Site, but is adjacent to it, to the south of the city centre. This
site requires an integrated scheme for housing, community and retail facilities.
Page 42. Quantitative Need for New Retail Development
1 The Retail Study included detailed forecasts of the quantitative need for new retail floorspace
in Truro, distinguishing between convenience and comparison goods, and prepared with the
aid of our RECAP forecasting Model. A full description of the Model and the data inputs and
assumptions on which it was based is set out in the Retail Study. The forecasts prepared with
the Model ran only to 2016, but the Council now requires forecasts to 2026. As instructed by
the Council therefore, we have rolled forward the forecasts to this later date. We have also
taken the opportunity to update some of the principal data inputs, where more recent
information has become available. In addition, we have built in a greater allowance for growth
in internet shopping, as a result of more up-to-date information on this, in response to
concerns of the Council. In the remainder of this Section, we describe the principal data
inputs and assumptions, and then set out and discuss the resulting updated forecasts.
2 The detailed RECAP Model tables are set out in Appendix 1, and this section should be read
in conjunction with that Appendix.
Principal Data Inputs
Catchment Area and Household Interview Survey
3 In updating the RECAP Model for Truro and rolling it forward to 2026, we used the same
catchment area as in the Retail Study. We also used the same results of the Household
Interview Surveys, as our data on shopping patterns in the catchment area. Thus we did not
undertake a new Household Interview Survey, because the results of the previous surveys are
still sufficiently up-to-date to be reliable (in the absence of any substantial new retail
development in central and west Cornwall).
4 It will be desirable for a new Household Interview Survey of shopping patterns in Truro’s
catchment area to be undertaken before irrevocable decisions which depend on the retail
capacity forecasts are taken. It may therefore be appropriate for developers submitting a
major retail planning application (e.g. for the Pydar Street site) to commission a new survey at
that time, and base their supporting Retail Assessments on that new data. Otherwise, we
would expect the Council to need to commission a new survey in about 2009 to 2010, and
update the forecasts again at that time, because the previous surveys on which our latest
update are based were undertaken in 2004 and 2005. This would give time for the new city
centre developments in Exeter and Plymouth to achieve fully settled patterns of trade, and for
the St Austell town centre development to be completed; and for the new shopping patterns
which result to be measured.
Page 5Catchment Population
5 The updated forecasts are based on the same population forecasts to 2016 as used in the
Retail Study. These have been projected forward to 2026 using trend projection. The
population forecasts are set out in RECAP Model Table 1.
Forecasting Dates
6 2005 has been retained as the base year for forecasting. Forecasts have been prepared to
2011, 2016, 2021 and 2026. If forecasts are required for intermediate years, an adequate
approximation can be obtained by interpolation.
Price Basis
7 The updated forecasts in this report are also on the basis of 2003 prices, for compatibility with
the Retail Study.
Per Capita Expenditure
8 This was based on the average per capita expenditure in 2003 in the catchment area obtained
from MapInfo and used in the Retail Study (£1,436 for convenience goods and £2,253 for
comparison goods, both including expenditure on special forms of trading, such as internet
shopping, mail order, etc). To these base figures we applied subsequent national average
growth over the period 2003 to 2006 indicated in MapInfo Brief 07/02. For convenience
goods, we applied the actual growth 2003 to 2005 (2.91%) and 2005 to 2006 (1.0%); and for
comparison goods the actual growth 2003 to 2005 (10.83%) and 2005 to 2006 (5.5%). For
the years 2006 to 2026, we assumed the MapInfo ‘best fit’ trend rate of 1.0% per annum
(convenience goods); and the ultra long term trend rate of 3.9% per annum (comparison
goods). We consider that these forecast rates of growth in expenditure (which includes
internet shopping) are realistic. In the case of comparison goods, they are well below the
recent short term trends, and below the medium and long term trends. They therefore allow
for the current slowdown in growth of expenditure as a result of the ‘credit squeeze’.
Internet Shopping
9 The per capita expenditure and growth rates described above all include expenditure on
special forms of trading (SFT), which includes mail order, party plan retailing, vending
machines and internet and other on-line shopping. Such expenditure is not available to retail
shops and therefore must be excluded from the RECAP Model. Internet shopping is now the
largest component of SFT, and has been growing very rapidly. In its latest report on ‘e-retail
2007’, Verdict Research Limited estimates that internet shopping accounted for 4.0% of all
retail sales in 2006 (up from 1.4% in 2001); and that it will grow to 8.9% by 2011. Verdict also
Page 6identified significant differences in rates of growth between different categories of retail goods.
The highest proportion of all retail sales taken by internet shopping in 2006 was on music and
video (22.6%) and the lowest was on health and beauty goods (1.8%). In the case of food
and groceries, the proportion was 2.4%, although much of this was sourced from local food
superstores (rather than separate warehouses), and should therefore be included in the
RECAP Model.
10 We have therefore allowed for significant growth in SFT as a result of these trends. Based on
Verdict’s work, we have assumed that SFT expenditure (of which internet shopping is only
one, albeit the major component) on convenience goods will rise from 2.0% in 2005 to 6.0%
by 2026; and on comparison goods from 7.0% in 2005 to 15.0% in 2026. Verdict does not
forecast so far ahead, but its forecasts show internet shopping on comparison goods to
account for 10.25% in 2011, up from 5.0% in 2006. We have extrapolated this trend, whilst
allowing for some flattening of growth as the market for internet shopping approaches
saturation. These deductions for expenditure on SFT are shown in RECAP Model Table 2.
11 We have based the updated retail capacity forecasts on our best estimates of growth in
Special Forms of Trading (which includes internet shopping as its major component). In the
short to medium term, any deviation from these best estimates is likely to be small and thus
the range of realistic retail capacity forecasts as a result of changes in this variable will be
narrow. In the longer term, deviation from our current estimates could be greater. However, if
the forecasts are updated every few years as we recommend, each update will take account
of the latest data at that time, thus maintaining the reliability of the short to medium term
forecasts.
Shopping Patterns in the Catchment Area
12 We have based our forecasts on the same data on shopping patterns in the catchment area
derived from the Household Interview Surveys and set out in the Retail Study. We have also
retained the same market share correction factor of 65% for comparison goods shopping in
Truro City Centre as described in the Retail Study. For comparison goods shopping in the
non-central retail warehouses and Sainsbury superstore, we have increased the market share
correction factor from 125% as used in the Retail Study to 140%. This because more recent
information shows that retail warehouse and food superstore sales densities for comparison
goods have been rising significantly since the Retail Study was completed.
13 The resulting market shares of catchment area expenditure attracted to the City Centre are
set out in RECAP Model Table 7, and for the non-central shopping in Table 15. Table 18
shows the expenditure on each of the 8 categories or comparison goods which is attracted by
the City Centre in the base year of 2005; and Table 9 the expenditure on convenience and
comparison goods attracted at the base year and each forecasting year. The corresponding
tables for the non-central shopping are Tables 16 and 17 respectively.
Page 7Visitor Expenditure
14 We have retained the same assumptions about expenditure in Truro on comparison goods by
people who live outside the catchment area, as in the Retail Study. These are indicated in
RECAP Model Tables 12 (City Centre) and 21 (non-central shopping). As discussed in
Section 4 below, we do not agree with objectors that allowances should be made for
expenditure by visitors on convenience goods.
Existing Shop Floorspace and Sales Densities
15 We are not aware of any significant changes in existing retail floorspace in Truro since
completion of the Retail Study. We have therefore based the RECAP Model on the same
data as was used before. However, where appropriate, we have updated retailers’ space
allocation ratios (for food stores) and sales densities, based on the latest available information
published by Mintel and Verdict Research.
Development Scenarios Assessed
16 We have assessed the same two development scenarios as in the Retail Study, as follows:
Scenario 1 – the ‘baseline’ scenario, which assumes that there will be no change in the
market shares of available expenditure attracted from the catchment area through the period
to 2026; except for small increases in the market shares of comparison goods expenditure
attracted by the retail warehouses, as a result of the permitted new retail warehouse at
Threemilestone (assuming that this is developed and occupied by 2011) and new Aldi store.
Scenario 2 – increases in comparison goods market shares attracted by Truro City Centre
from those indicated by the adjusted results of the household interview surveys, as a result of
the proposed Pydar Street retail development in the city centre. This reflects the likely ability
of that proposed development to attract additional expenditure, thus partially creating its own
support. In this scenario, we also allow for this new city centre development to recapture a
small amount of market share from the retail warehouses in the city.
17 Scenario 2 is more realistic, in that it takes account of the likely effects of a major
development which accords with the Council’s strategy for the city centre. However, Scenario
1 provides a useful ‘baseline’ with which the development-focused forecasts in Scenario 2 can
be compared.
The RECAP Model Forecasts
18 We set out in below our retail capacity forecasts for Truro, and discuss the relationship
between the existing centres and potential new retail developments. The forecasts are
Page 8summarised in Table 2.1. We also comment on the implications for future development
strategy.
Table 2.1
Summary of Retail Capacity Forecasts
Goods/Scenario/Location 2011 2016 2021 2026 RECAP
(sq m net) (sq m net) (sq m net) (sq m net) Model Table
Appendix 3
Convenience Goods:
Scenarios 1 & 2:
Truro city centre 2,250 3,250 4,250 5,300 12 & 24
Truro non-central 1,050 1,500 1,900 2,400 21 & 27
Comparison Goods:
Scenario 1:
Truro city centre 8,400 21,100 36,100 54,350 12
Truro non-central 3,650 10,750 18,600 27,950 21
Scenario 2:
Truro city centre 13,750 27,650 44,000 63,900 24
Truro non-central 2,050 8,800 16,300 25,150 27
Source: RECAP Model Tables in Appendix 1 as indicated, rounded to the nearest 50 sq m net.
Notes: The forecasts in Table 2.1 are cumulative, i.e. the forecasts for each date include the forecasts for the
previous dates and are not additional to those earlier forecasts.
The forecasts are for new floorspace additional to current commitments (new retail warehouse at Threemilestone and
Tesco mezzanine floor).
Convenience Goods
Truro City Centre
19 As in the Retail Study, in Table 2.1 for convenience goods, the capacity forecasts for Scenario
2 are the same as for Scenario 1 and for the same reasons. In practice, there would be little
difference between Scenario 1 and a scenario which made realistic allowances for market
share increases in Truro, and we have therefore not modelled a different Scenario 2 for
convenience goods.
20 The updated capacity forecasts for the city centre for the years 2011 and 2016 are slightly
lower than in the Retail Study. This is because the slightly higher more recent growth in per
capita expenditure on convenience goods and the small reductions in sales densities of some
of the main food retailers have been slightly more than offset by the committed new
mezzanine floor in the existing Tesco superstore. Table 2.1 shows that there should be
capacity for up to 2,250 sq m net additional convenience goods floorspace in the city centre
by 2011, rising to about 3,250 sq m net by 2016, 4,250 sq m net by 2021 and 5,300 sq m net
Page 9by 2026, if forecast trends occur. These forecasts are for new floorspace additional to the
committed Tesco mezzanine floor.
21 As stated in the Retail Study, these are theoretical maxima, because they assume that all
stores will trade at the estimated company average levels. They are also based on the
assumption that new convenience goods floorspace will trade at £12,000 per sq m net. This
is a ‘generic’ level for food superstores. If some or all of the floorspace is provided in different
formats, for example discount supermarkets, or neighbourhood centre food stores, which
have lower sales densities, the forecast capacity would be greater than indicated in Table 2.1.
Non-central Food Stores
22 Table 2.1 shows that there should be forecast capacity for up to 1,050 sq m net additional
convenience goods floorspace in non-central locations by 2011, rising to about 1,500 sq m net
by 2016, 1,900 sq m net by 2021 and 2,400 sq m net by 2026, if forecast trends occur. Again,
these are theoretical maxima for the same reasons. They also assume that new floorspace
will trade at £12,000 per sq m net; so if the new floorspace was developed in a lower sales
density format, the forecast capacity would be greater.
23 Overall, we remain of the opinion expressed in the Retail Study that there should be sufficient
expenditure capacity in practice for one new food superstore in Truro; or a combination of
smaller food stores such as further discount supermarkets, a new town centre foodstore,
and/or extensions to existing stores, from about 2011 onwards. In deciding how these
forecast needs should be accommodated, the sequential approach should be applied as
indicated in PPS6. This gives priority to town centre and edge of centre locations over out-of-
centre locations. Thus some or all of the forecast capacity for additional non-central
floorspace (which has been treated separately from the city centre merely for forecasting
convenience) should be accommodated by means of city centre or edge-of-centre
development, if a suitable site or sites exist or could be assembled. Alternatively, it could be
directed to a new district centre, to support an ‘anchor’ foodstore for such a centre. We
comment further on this later in the report.
24 In the event that substantially more new convenience goods floorspace was developed than
indicated by the retail capacity forecasts, there would probably be significant adverse impacts
on existing foodstores in the city. The actual effects would depend upon the degree of over-
provision and the new store formats in which it was developed. However, if too much new
food superstore floorspace was developed outside the city centre, it would be likely to result in
closure of the weakest of the city centre supermarkets, for example Somerfield and/or the Co-
op Pioneer store. Thus whilst it might take more food shopping closer to where people live, it
would be likely to reduce the availability of food shopping facilities in the city centre, where it is
currently accessible to all residents, including those without the use of cars. It would also be
likely to inhibit the prospects for securing a new high quality food supermarket in the city
centre, for example as part of the proposed Pydar Street development.
Page 1025 Modern food superstores now contain a substantial amount of non-food sales space in
addition to food. Overprovision of non-central food superstore floorspace would therefore
increase out-of-centre comparison goods shopping, thus decentralising comparison goods
expenditure which would be needed to support new city centre development, for example in
the Pydar Street scheme. It would tend to make this scheme (or any other city centre
comparison goods development) harder to achieve.
Comparison Goods
Truro City Centre
26 Table 2.1 shows that with no increase in market shares (Scenario 1), in addition to the
committed Tesco mezzanine floor, there will be capacity for additional comparison goods
floorspace in Truro City Centre of about 8,400 sq m net by 2011, increasing to about 21,100
sq m net by 2016, 36,100 sq m net by 2021 and 54,350 sq m net by 2026, if forecast trends
occur. In Scenario 2, we assume that the proposed Pydar Street scheme will increase
marginally the city centre’s market share of catchment area expenditure attracted, from an
overall 29.0% in 2005 to 31.7% in 2016. On this basis, the forecast capacity at 2011 would be
about 13,750 sq m net in 2011 (assuming that the Pydar Street scheme was completed by
then), rising to about 27,650 sq m net by 2016, 44,000 sq m net by 2021 and 63,900 sq m net
by 2026, if forecast trends occur.
27 These forecasts are a little lower than the capacity forecasts in the Retail Study. The main
reasons are growth of internet shopping, for which a greater allowance has been made than in
the Retail Study, as a result of recent indications of higher growth; and the committed Tesco
mezzanine floor devoted mainly to comparison goods sales absorbing some of the growth in
expenditure. However, preparations for the Pydar Street scheme have progressed more
slowly than expected at the time of the Retail Study, and a planning application has still not
yet been submitted. This means that the scheme, if it goes ahead, will open a few years later
than expected at the time of the Retail Study. It is now unlikely to open by 2011; which means
that despite the lower capacity forecasts, there should still be sufficient expenditure to support
it within a year or two of the likely time of opening.
28 Even if the Pydar Street scheme does not go ahead, the capacity forecasts show that there
will be a quantitative need for substantial additional comparison goods retail floorspace in the
City Centre within the period covered by the AAP. Sites for at least some of the forecast
capacity will be needed, if Truro is not to lose market share to major competing centres, such
as Plymouth and Exeter.
Page 11Non-central Locations
29 Table 2.1 shows that in Scenario 1, with no changes in market shares (other than those due
to the permitted retail warehouse at Threemilestone), there will be capacity for additional
comparison goods floorspace forecast as in non-central locations of about 3,650 sq m net in
2011, rising to about 10,750 sq m net by 2016, 18,600 sq m net by 2021, and 27,950 sq m net
by 2026, if forecast trends occur. In Scenario 2, allowing for the impact of major city centre
development, there will be reduced capacity, for about 2,050 sq m net by 2011, rising to about
8,800 sq m net by 2016, 16,300 sq m net by 2021, and 25,150 sq m net by 2026, if forecast
trends occur.
30 The capacity for additional non-central floorspace has been forecast separately from that for
the city centre merely for forecasting convenience. In practice, such new floorspace should
be located in accordance with the sequential approach, and not necessarily in the form of low
sales density retail warehouses, or in food/non-food superstores. Thus the growth in
expenditure forecast as non-central will be available to support new city centre or edge-of-
centre development. In this case, because such new development would be in the form of
higher sales density town centre shops and stores, the forecast capacity would be reduced
commensurately with the increased sales densities.
31 The updated capacity forecasts continue to demonstrate that development of a new district
centre in Truro, as recommended in the Retail Study, is realistic in terms of growth in
expenditure. They show that it could be anchored by a new food superstore, and could also
include significant comparison goods floorspace without adverse impact on the city centre.
However, it will be important that such a new retail development in the city is strictly limited as
to size and type of retail floorspace, so that it does not become a major competitor with the
city centre, but complements it by providing for the day-to-day needs of the existing and new
residents of west Truro.
Use and Review of the Forecasts
32 As in the Retail Study, we must emphasise that all expenditure based forecasts of future shop
floorspace capacity are based on imperfect data and contain a number of assumptions. Our
forecasts set out in this report are based on the most up-to-date and reliable information
currently available to us. However, they are intended as an indication of the likely order of
magnitude of future shop floorspace capacity (if forecast trends are realised) rather than as
growth targets or rigid limits to future growth. The forecasts should be periodically revised as
necessary in the light of actual population and expenditure growth, and as development
proceeds and its effects become measurable.
Page 123. Review of Representations
1 Overall the council received 25 representations on the AAP. Comments were made by a
variety of respondents including supermarket operators, residents, public sector bodies
including Councillors, local authorities and regional development agencies; and the remainder
of the representations came from developers, architects, landowners and the CPRE. We
have grouped the responses into relevant retail topics, although some responses comment on
more than one topic.
Representations on Pydar Street
2 Truro City Council (Ref 184) submitted a response covering a number of topics including
housing, the economy, sustainable communities and the environment. The Council has
specific concerns about the large increases in retail floorspace proposed. The response
directly refers to Preferred Option CC5, the Pydar Street redevelopment site. It states that the
level of retail proposed on this site is excessive; and the Council is also concerned that this
development and Lemon Quay will become polarised. A further concern is the loss of the
NCP car park through the redevelopment, and the lack of details on reprovision of this car
parking.
3 Montague Evans on behalf of Simon Developments (Ref 1293) submitted a response which
covered a number of topics. They make a specific reference to the Pydar Street
Redevelopment and include some general comments on wording:
– The AAP should clearly set out the site’s characteristics and the Council’s policy
objectives, and should reinforce Truro’s sub-regional retailing role.
– The Council’s requirement for the scale of the development to be determined by the ability
to reflect the character and form of the city centre, is too prescriptive, and should be
rephrased to include the statement ‘has regard to’
4 They generally support Preferred Option CC5 but do make two specific points for amendment.
The first is that the document should include the need for a department store within the
preferred option. The second is that the NCP site is unlikely to become available, and
therefore the AAP requirement to remove and re-provide the current NCP car park is
unreasonable. A further comment is that the AAP is inconsistent with PPS6 with regard to the
sequential approach and Pydar Street. Pydar Street is currently identified as an edge of
centre site. This would make any retail proposals for the site difficult to develop, as it would
have to be demonstrated that there are over-riding reasons in terms of suitability, availability
or viability that this is the only site suitable within Truro for retail development. They suggest
that the proposed policy should be amended to include a specific reference to the need to
provide a department store-led scheme
Page 135 Further, they state that the physical capacity for retail development on the Pydar Street site
should be stated in the AAP so that it will be a material consideration in the determination of
any planning application that is not on an allocated site. This will ensure that the
redevelopment of Pydar Street is not compromised by retail development elsewhere in the
city.
6 The CPRE (Ref 1023) states that the ‘Dumbell Strategy’ for the city centre and the Pydar
Street site should be abandoned. The reasons given are more practically based as opposed
to policy driven, and include that the removal of Truro Bowl would reduce amenity for city
dwellers; that the site is too steep for pedestrian shoppers; and that the walk from Lemon
Quay is too far. Finally, they suggest that there needs to be better landscaping on Pydar
Street; and that there needs to be more emphasis on the ope-ways that lead from Pydar
Street to River Street.
7 Cornwall County Council (Ref 63) has made a number of short comments on retailing in the
city centre and on the Pydar Street redevelopment. They accept the Pydar Street
Redevelopment Area in principal, however they state that there should be additional market
justification for the retail space proposed, to ensure preference of implementation in advance
of other existing retail areas. This is similar to the representations submitted by Montague
Evans on behalf of Simon Developments.
Comments on the Waterfront site
8 The ‘waterfront site’ refers to a group of three sites on the waterfront in Truro, these include
the Garras Wharf site, the site currently occupied by Tesco and the retail warehouses
occupied by Staples et al. These sites are adjacent to each other and collectively form the
‘waterfront site’. Many of the representations use ‘Garras Wharf’ loosely to mean the
waterfront site. Hereafter this report will use the term the ‘waterfront’ site to encompass all
references to Garras Wharf and the surrounding area.
9 There were a number of representations on whether Tesco should be moved from its
waterfront site to free up the waterside location for new development. RPS on behalf of
Walker Developments (Ref 1249) was particularly concerned that the Tesco store should not
be moved to a sequentially less preferable site to the one it is on now, as this would dilute the
city centre’s convenience goods offer and could prejudice development of the proposed
District Centre at Maiden Green Farm.
10 DPP on behalf of Tesco Stores Ltd (Ref 1248) generally promote the Waterfront site for
redevelopment. They state that better pedestrian links should be provided to link the city
centre with Garras Wharf. They also state that additional comparison goods floorspace
should be considered on sites other than Pydar Street, including Garras Wharf. They
Page 14question the status of the position of the Garras Wharf site in relation to the town centre
boundary and the primary shopping area. DPP state that the inconsistency creates an
uncertain planning policy context for any future development.
11 RPS on behalf of Asda Stores Ltd (Ref 1245) has made a comment on Preferred Option AC1,
and state that they want the reference to the relocation of Tesco to be deleted. This is
because relocating the store to an out-of-centre site would be contrary to PPS6. They state
that the plan should encourage improvements to the Garras Wharf area but should not
advocate relocation of the foodstore, and argue that a replacement or reconfigured foodstore
in the waterfront area may be more appropriate.
12 RPS on behalf of Newham Farm (Ref 1308) support the need to relocate Tesco, as this would
unlock other aspirations contained within the AAP, particularly the rejuvenation of the riverside
area. However it clearly states that the Higher Newham development should not in any way
be construed as being dependent upon this relocation.
13 A4 Architects (Ref 89) state that the aspirations to extend the city centre primary shopping
area to accommodate a new department store are not practical. They also state that moving
Tesco would be a problem, as Tesco is a significant retail attraction to the city centre and
many people use its car park to make linked trips into Truro.
14 A local resident (Ref 1226) objects to Tesco being relocated, unless another supermarket can
be located on the same site. The letter also states that any redevelopment of Garras Wharf
would result in the loss of a city centre car park which is well used. This view is supported by
another resident (Ref 1034) who states that Tesco is the only easily accessible supermarket
within the city, and therefore it shouldn’t be moved to an out-of-centre location. A further
resident (no reference given) suggests relocating Tesco to the Treliske Industrial Area.
District Centre Options
15 As well as commenting on the Waterfront site, RPS on behalf of Walker Developments (Ref
1249) made representations on the potential District Centre at Maiden Green Farm.
Regarding Preferred Option H3C at Llangarth which the AAP indicates as an area for an
integrated scheme of housing, community and commercial facilities, the representation gives
some siting suggestions for where the employment uses and the residential uses should be
located. It states that the land controlled by Walker Developments and proposed for mixed
use development is more suitable for residential development. A key concern in this
representation is to see land at Maiden Green Farm allocated for a major mixed use
development rather than the current allocation as an Area of Change. They also believe that
there is enough retail capacity to justify a new supermarket in the city centre and a new food
superstore in a new District Centre at Maiden Green Farm.
Page 1516 Similarly to the above, RPS submitted a further representation on behalf of Asda Stores Ltd
(Ref 1245) which fully supports the need for a new District Centre at Maiden Green Farm. Lidl
(Ref 1147) also submitted an objection which concerns Preferred Option AC3 (the Treliske
Industrial Estate). They request that they would like a specific reference made to the need for
a discount supermarket to anchor the proposed District Centre.
17 NLP submitted a representation on behalf of Royston Leigh (Ref 1113) which concerns the
proposals for the Llangarth urban extension. They state that their development proposals
follow the broad principles of the AAP, though they state that the potential District Centre
should be located closer to the proposed housing area.
Comments on the Retail Study
18 DPP on behalf of Tesco Stores Ltd (Ref 1248) question the Retail Study 2006 prepared by
Donaldsons on behalf of Carrick District Council, and particularly disagree with the retail
capacity forecasts in the study. They make reference to the fact that in the Retail Study, the
waterfront site is treated as a town centre site. However in the Proposals Map the site of the
Tesco store falls outside the city centre boundary. For convenience goods they dispute the
fact that there has been no allowance made for visitor expenditure as is the case for
comparison goods. For comparison goods they have two concerns. First that there is no
mention of need for comparison goods floorspace in non-central locations. Second they claim
the expenditure growth rates used are too conservative and therefore the need for additional
floorspace is underestimated in the report. They then proceed to rework the capacity figures
making the amendments as above.
19 RPS on behalf of Newham Farm Ltd (Ref 1308) also challenge the forecasts set out in the
Retail Study. As do DPP, they object to the absence of forecasts for additional retail
floorspace in non-central locations. They also state that visitor expenditure should be applied
to non-central convenience goods locations. The expenditure growth rates used in the retail
study are also questioned. They state that Scenario 2 in the Retail Study is likely to
underestimate the level of comparison goods expenditure available to support additional non-
central comparison goods floorspace. We respond to these retail objections separately in
Section 4 below.
Other Retail Concerns
20 CPR Regeneration (Ref 1243) is mainly concerned about the role of the other towns within
Carrick District with particular reference to what is written in the RSS. The main objection
concerning retail is that the level of additional retail development in Truro could seriously harm
the retail growth identified in the Cambourne Pool Redruth Area Action Plan. Kerrier District
Council (Ref 1239) has a similar concern to that of CPR Regeneration. They too are
concerned about the impact of any development in Truro on Cambourne Pool Redruth,
Page 16particularly how an increase in retail floorspace in Truro could harm regeneration in other
Cornish towns.
Other Submissions
21 Peacock and Smith submitted an objection on behalf of Morrisons Supermarkets, though it
does not make any specific comments on retail issues and mainly concentrates on developer
contributions and renewable energy. A resident (Ref 1211) has made comments on open
space and retail development. Specifically on retail there is a comment that the Marks &
Spencer store should be relocated, as it is too far out from the city centre. A second resident
(Ref 1121) makes general comments about the Plan, but overall does not think there is any
more need for new retail space within Truro. A third resident (Ref 776) makes general
comments on the AAP but makes no comments on retail. A fourth resident (Ref 1150) agrees
with the need for a new department store. The South West Regional Development Agency
(no reference given) generally supports the AAP; but makes no specific comment on retail
policies. GOSW make a number of comments on retailing, but mainly suggest rewording of
various sections to enhance clarity.
22 The Council’s response to these representations will depend on how it wishes to proceed with
the strategic options which we have outlined in Section 5 of this report. The Council should
therefore decide on its strategy before starting to draft responses to these representations.
Page 174. Responses to the Retail Objections
1 This section identifies in more detail the retail objections to the AAP and gives guidance on
the Council’s likely response. It specifically concentrates on the two main retail objections
made by Tesco and Newham Farm; and also the concerns expressed by CPR Regeneration
and Kerrier District Council.
Objection 1248 DPP on behalf of Tesco Stores Ltd
Objection 1308 RPS on behalf of Newham Farm Ltd
Objection
2 For convenience goods, the objectors dispute the fact that there has been no allowance made
for visitor expenditure as is the case for comparison goods.
Response
3 No allowance has been made because visitors to the city are much less likely to visit food
shops than they are to visit comparison goods shops. All of our many household interview
surveys across the country have shown that people shop more locally for convenience goods
than for comparison goods; therefore we considered that an increase in visitor expenditure for
convenience goods would be unrealistic. We believe that most self-catering holiday visitors to
Cornwall are likely to be staying closer to the coast, and few in Truro. Their purchase of food
and other convenience goods is therefore much more likely to be in food stores in the coastal
towns, than in Truro. Further, representation of convenience goods shops and stores is low
within Truro City Centre, compared with the representation of comparison goods shops. This
means that visitors from outside the catchment area are much more likely to be coming to
Truro for the comparison goods shops than the convenience goods shops.
4 A further reason for making no allowance for visitor expenditure on convenience goods is that
residents of the catchment area also go on holiday, and to destinations outside the catchment
area. Whilst there, they will be likely to spend some money on convenience goods. It is a
reasonable assumption that inflowing convenience goods expenditure in Truro by visitors
would be balanced by outflowing expenditure by catchment area residents when on holiday
elsewhere. Thus overall, there would be no net increase in convenience goods expenditure
due to visitors.
5 In the Retail Study, to account for visitors’ expenditure we allowed for an uplift of 5% of
catchment area residents’ expenditure on comparison goods (which has not been disputed by
the objectors). If there is any net increase in expenditure on convenience goods due to
visitors, which we consider unlikely, it would be at a much lower level than this; and in our
opinion would be de minimis – which is why we have made no allowance. We note that no
Page 18evidence has been provided by the objectors to support their contention that an allowance of
5% would be realistic for convenience goods. Also, no evidence has been put forward by the
objectors to support their statement that ‘such an adjustment should also appropriately be
made in relation to non-central convenience goods expenditure as common sense dictates
that Sainsbury’s will benefit from visitor/tourist expenditure in a similar way to Tesco’. We
consider that the prospects of significant visitors’ expenditure in Sainsburys would be even
less than in the City Centre stores, because being out-of-centre, it does not benefit from being
adjacent to a large number of attractive comparison goods shops which are likely to attract
some visitors’ expenditure. As with city centre foodstores, the same point about inflowing
expenditure by visitors being balanced by outflowing expenditure by catchment area
residents, applies.
Objection
6 The objectors are opposed to there being no acknowledgement within the text of the AAP, of
need for comparison goods floorspace in non-central locations as shown in the retail capacity
tables as at 2016.
Response
7 Retail capacity modelling within the Retail Study has been split between Truro City Centre and
out-of-centre locations for modelling convenience only. Paragraphs 2.50 and 2.56 of the
Retail Study make this clear; and the latter states that ‘new floorspace, although forecast as
non-centrally located, should actually be developed in accordance with the sequential
approach. Thus some of this forecast capacity could help to support potential major city
centre development, rather than being developed in the form of out-of-centre retail
warehouses or superstores.’ They also make clear that sequentially preferable sites (of which
there are some in and on the edge of the city centre) should be developed first before out of
centre sites are considered, in accordance with PPS6. Further, the Retail Study includes the
Tesco site within the city centre, there is forecast capacity for new retail development in Truro
City Centre, and this is clearly stated. We reiterate this advice regarding the location of new
development in respect of the updated retail capacity forecasts set out in this report
(paragraphs 23 and 30 in Section 2 above).
8 It should be noted that in the Retail Study, we included the Tesco superstore on the waterfront
within our forecasts for Truro City Centre, because at that time it was within the city centre
shown on the adopted Local Plan. Our overall conclusions about the scale and location of
new retail floorspace set out in Retail Study took account of the capacity forecast for the city
centre and non-central locations, in the light of the sequential approach.
Page 19Objection
9 The objectors claim the expenditure growth rates used for comparison goods are too
conservative and therefore the need for additional floorspace is underestimated in the report.
They suggest that the medium to long term growth rates should be applied as opposed to the
ultra-long term growth rates.
Response
10 The growth rate of 3.8% pa was used in the Retail Study as it realistically took account of the
recent downturn in the rate of growth of retail expenditure, and the medium term economic
outlook. It is significantly below the historically very high rates of growth of the last few years,
which are exceptional in relation to the trend. It would have been unrealistic to assume that
the preceding high level growth would continue annually throughout the 11 year forecasting
period used in the Retail Study. The ultra long term trend spans the period 1964 – 2004 thus
covering several economic cycles. It is also important to note that in the Retail Study we
applied the 1964 to 2004 ultra-long term trend growth rate (3.8% pa) to the estimated actual
2004 expenditure, which was significantly above the trend line at that point. Thus we implicitly
allowed for above ultra-long term trend growth thereafter.
11 In the updated retail capacity forecasts set out in Section 2 of this report, we have again
applied the ultra-long term trend growth rate (which has now risen to 3.9% pa) to the
estimated actual 2006 expenditure (which remains significantly above the trend); so have
again allowed for above ultra-long term trend growth. In view of the current economic
slowdown, we see no reason for using a higher growth rate as suggested by the objectors.
Indeed, for the next few years, our growth rate may even be somewhat high, as a result of the
current credit squeeze inhibiting growth of consumer expenditure.
12 We do not accept the objectors’ contention that our capacity forecasts set out in the Retail
Study are too low. In the updated forecasts set out in this report, we have used slightly higher
rates of growth in per capita expenditure, but have made a greater (and increasing) allowance
for special forms of trading, as a result of more recent information on growth in internet
shopping. Our updated retail capacity forecasts are therefore marginally lower than those set
out in the Retail Study. We consider that they are realistic. We do not therefore agree with
the revised capacity forecasts set out by the objectors.
Objection
13 DPP for Tesco claims that in Scenario 2 in the Retail Study, we have overestimated the extent
to which out-of-centre development will contribute towards the City Centre’s increased market
share (i.e. we have transferred too much market share from the out-of-centre shopping to the
City Centre as a result of the proposed Pydar Street development). They consider that the
out-of-centre shopping is predominantly ‘bulky goods’ retailing, which will be largely
Page 20unaffected by the expected department store and fashion-based retailing likely to be in the
proposed Pydar Street scheme. The capacity for additional out-of-centre comparison goods
retail floorspace is therefore greater than indicated in the Retail Study.
Response
14 In the Retail Study, we made only very small reductions in the market shares of catchment
area expenditure attracted by out-of-centre shopping for the reasons indicated by the objector.
They show the market share in 2011 falling from 8.9% in Scenario 1 to 8.6% in Scenario 2.
This is a very small reduction. It is realistic because the proposed new city centre
development will be likely to sell some ‘bulky goods’, such as domestic electrical appliances,
audio-visual equipment, household textiles, as well as homewares and health and beauty
goods, in direct competition with the out-of-centre retail warehouses and the Sainsbury
superstore. In the updated retail capacity forecasts, we have retained the assumption in
Scenario 2 that there will be small reductions in the market shares of such non-central
shopping. We consider that these reductions are realistic, and that the objector is incorrect in
asserting that they are too high. Our approach of allowing for some transfer of market share
and expenditure from the out-of-centre shopping to the city centre is in accordance with
PPS6, which states that ‘development should be focused in existing centres’ (paragraphs 2.1
and 3.1).
Objection 1245 RPS on behalf of Asda Stores Ltd
Objection
15 The capacity forecasts in the Retail Study should be stated as for Truro as a whole, rather
than being divided into forecasts for the city centre and non-central locations. They should
also be expressed in terms of available expenditure rather than floorspace.
Response
16 There is no advantage in stating the capacity forecasts for Truro as a whole, because this can
easily be obtained by adding together the separate forecasts in the Retail Study (whilst
making adjustments to take into account that capacity for new floorspace depends on the
format in which it is provided, e.g. high sales density city centre shops and stores, or low sales
density out-of-centre retail warehouses). Similarly, the capacity in terms of potential
expenditure to support new floorspace is already shown in the Retail Study in the RECAP
Model tables (and in the updated RECAP Model tables in Appendix 1 of this report), so there
is no need to repeat it in the Plan. Furthermore, the capacities in terms of expenditure and
floorspace in the updated forecasts set out in this report have changed somewhat from the
forecasts set out in the Retail Study, and will be likely to change again when the forecasts are
next updated.
Page 2117 In any event, the forecasts in the Retail Study (and the updated forecasts in this report) are
exploratory rather than prescriptive (as stated in paragraph 2.7 of the Retail Study). Our
recommendations about the need for new retail floorspace are based on those forecasts but
do not copy them precisely. The Plan should not therefore imply that the forecasts are more
than a guide to the order of magnitude of retail floorspace needs – but would tend to do so if
the forecasts were stated in the form of precise amounts of available expenditure.
Objection
18 The Retail Study and the Plan are overly pessimistic in concluding that development of a new
high quality supermarket in the city centre would mean that a new District Centre would have
to be restricted to a small discounter sized store. Allowing for an Asda superstore at Maiden
Green Farm of 3,195 sq m net, of which 60% (1,895 sq m net) would be used for convenience
goods sales, there will be capacity for another new high quality foodstore in the city centre.
Response
19 RPS has under-estimated the likely convenience goods floorspace in a new Asda superstore
at Maiden Green Farm. An Asda superstore of 3,159 sq m net sales area would be likely to
have at least 75% of the floorspace used for the sale of convenience goods, rather than the
60% assumed by RPS. 60% is much closer to the company’s average of 55%, which is
skewed by Asda’s many much larger superstores. A net sales area for convenience goods of
only 1,895 sq m would be too small to compete effectively with the significantly larger
Sainsburys, which we estimate has 3,067 sq m net for convenience goods, and with Tesco,
(estimated 2,690 sq m net for convenience goods, plus a commitment for a mezzanine floor).
We would expect an Asda superstore of 3,159 sq m net sales area to have at least 2,369 sq
m net for convenience goods sales, which at the company’s 2006/7 average convenience
goods sales density (£14,142 per sq m net) would generate convenience goods sales of at
least £33.5m. Thus the capacity for a new high quality city centre supermarket would be
commensurately reduced from that suggested by RPS. Our capacity forecasts are also stated
to be maxima (Retail Study paragraph 2.49), hence our conclusions regarding the practical
capacity for new foodstores, set out in the Retail Study. We therefore still consider that these
conclusions are realistic. They are endorsed by the updated forecasts set out in this report,
which are slightly lower.
Objection 1243 CPR Regeneration
Objection 1239 Kerrier District Council
Objections
20 Both these objections are concerned about the impact of new development in Truro City
Centre on Falmouth/Penryn and Camborne-Pool-Redruth. The main objection concerning
Page 22retail is that the level of additional retail floorspace in Truro could seriously harm the retail
growth identified in the Camborne Pool Redruth Area Action Plan and potentially put at risk
the implementation of new retail development on identified shopping opportunity sites there.
There is also an objection to the proposed Pydar Street development in Truro, on the grounds
that such new floorspace should be positively encouraged to relocate to Falmouth/Penryn and
Camborne Pool Redruth in order to support their economic revival. Concern is also
expressed that the level of retail growth proposed in Truro would increase centralisation of
retailing there, with possible adverse impact on Helston.
Response
21 The Scenario 2 retail capacity forecasts set out in the Retail Study, and the updated forecasts
set out in this report, are on the basis that there will be only small increases in the market
shares of catchment area comparison goods expenditure attracted to Truro. Thus in the
updated forecasts, Truro’s overall market share is assumed to increase from 29.0% in 2005 to
31.5% in 2011 (optimistically assuming that the Pydar Street scheme is completed by then).
A small part of this market share increase is offset by slightly reduced market share for non-
central retail warehouses and foodstores in Truro. In catchment zone 1 (Falmouth and
Penryn), Truro’s total comparison goods market share (city centre and non-central shopping
combined) is expected to rise from 22% to 24% as a result of the Pydar Street scheme; in
Zone 6 (Camborne) it is expected to rise from 23% to 25%, and in Zone 7 (Pool/Redruth) from
31% to 33%. Zones 4 and 5 are the zones including and surrounding Helston. In Zone 4 the
increase is from 24% to 25% and in Zone 5 it is from 26% to 27%. These are all small
increases in Truro’s market share. When growth in expenditure is taken into account, there
should still be sufficient expenditure available in future years to support additional retail
floorspace in Falmouth and in Camborne-Pool-Redruth; and growth in sales in existing shops
in Helston.
22 In commercial terms, Truro is the only town centre in Cornwall capable of attracting a town
centre development anchored by a new department store on the scale envisaged by the
Pydar Street scheme. This is because the other town centres all lack the ‘critical mass’ of
existing retailing to attract a new department store. Importantly, shop rental values in all the
other town centres in the County are too low for such a development to be financially viable.
In addition, in most of the other town centres (and certainly in Falmouth) there are no sites in
or on the immediate edge of the town centre and closely connected to the existing prime
retailing which are large enough to accommodate such a development. The practical choice
is therefore between accommodating a substantial new retail development anchored by a new
department store in/on the edge of Truro City Centre, or not achieving such a scheme in
Cornwall at all. We therefore continue to believe that Truro is the right location for such new
retail development, and that it would have only a marginal impact on the prospects for new
retail development in the other towns. The great majority of its expenditure support will come
Page 23You can also read
