UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK - DSG Retail Limited

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UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK - DSG Retail Limited
DSG Retail Limited

UNITS 1 AND 2 (BLOCK A), CURRYS
PC WORLD, CRIBBS CAUSEWAY
RETAIL PARK
Planning and Retail Statement

APRIL 2021                      PUBLIC
UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK - DSG Retail Limited
DSG Retail Limited

UNITS 1 AND 2 (BLOCK A), CURRYS PC
WORLD, CRIBBS CAUSEWAY RETAIL PARK
Planning and Retail Statement

PUBLIC

PROJECT NO. 70080687

DATE: APRIL 2021

WSP
Three White Rose Office Park
Millshaw Park Lane
Leeds
LS11 0DL
Phone: +44 113 395 6200
Fax: +44 113 395 6201
WSP.com

                                PUBLIC
UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK - DSG Retail Limited
CONTENTS

1     INTRODUCTION                                                                       1

1.2   SITE CONTEXT                                                                       1
1.3   PROPOSAL                                                                           2
1.4   BUSINESS MODEL                                                                     2
1.5   PLANNING HISTORY                                                                   3
1.6   PLANNING POLICY                                                                    4
1.7   REASON 1                                                                           5
1.8   REASON 2                                                                           5
1.9   REASON 3                                                                           5

2     REASON 1 - THERE ARE NO SEQUENTIALLY PREFERABLE SITES                              6

2.2   ALTERNATIVE FORMATS                                                                6
2.3   ASSESSMENT OF ALTERNATIVE SITES                                                    8
2.4   FILTON TOWN CENTRE                                                                 9
2.5   BRADLEY STOKE TOWN CENTRE                                                          9
2.6   STOKE GIFFORD DISTRICT CENTRE                                                     10
2.7   PATCHWAY DISTRICT CENTRE                                                          11
2.8   ACCESSIBILITY OF THE APPLICATION SITE                                             11
2.9   CONCLUSION                                                                        11

3     REASON 2 - THE PROPOSAL WILL NOT HAVE A SIGNIFICANT ADVERSE
      IMPACT ON THE VITALITY AND VIABILITY OF NEARBY CENTRES   13

3.2   TURNOVER OF PROPOSED MEZZANINE                                                    14
3.3   TRADE DIVERSION AND IMPACT                                                        14
3.4   SUMMARY ON TRADE DIVERSION AND IMPACT                                             15
3.5   IMPACT ON INVESTMENT                                                              16
3.6   IMPACT ON VIABILITY AND VITALITY                                                  17

      UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK   PUBLIC | WSP
      Project No.: 70080687                                                      April 2021
      DSG Retail Limited
3.7   CONCLUSION                                                                              17

4     OTHER MATERIAL CONSIDERATIONS                                                          18

4.2   HIGHWAYS                                                                                18
4.3   ENERGY / SUSTAINABILITY                                                                 18
4.4   BENEFITS                                                                                18

5     THE PLANNING BALANCE AND CONCLUSIONS                                                   20

      TABLES
      Table 1 - Mezzanine retail space at Cribbs Causeway Retail Park                          4
      Table 2 - Turnover of Comparison Floorspace in Centres within South Gloucestershire
      Retail Study Area                                                                       15
      Table 3 - Anticipated Trade Diversion from Centres within South Gloucestershire from
      Currys Mezzanine                                                                        15

      FIGURES
      Figure 1 - Extract from Retail Study to show catchment area encompassing Zones 5, 10 and
      11.

      UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK         PUBLIC | WSP
      Project No.: 70080687                                                            April 2021
      DSG Retail Limited
1        INTRODUCTION
1.1.1.   This Planning and Retail Statement has been prepared by WSP to support a full planning
         application for additional retail floorspace at mezzanine level at Currys PC World, Cribbs Causeway
         Retail Park, Lysander Rd, Bristol, BS34 5TX.

         © Google Maps

1.2      SITE CONTEXT
1.2.1.   The application site is Units 1 and 2 (Block A) Cribbs Causeway Retail Park, which is part of the unit
         currently occupied by Currys PC World. The store is located within a retail park, which comprises of
         11 units that sits at the corner of Merlin Road and Lysander Road. Other retailers include Smyths
         Toys, Argos, Sports Direct, Wren Kitchens and Next Home. The retail park forms part of the larger
         Cribbs Causeway Retail Park and adjacent Mall.
1.2.2.   Car parking for the Currys PC World unit is located to the front (south) of the unit and accessed from
         Lysander Road and shared with the aforementioned retail units. Servicing is undertaken from the
         rear of the unit and is accessed from Centaurus Road.
1.2.3.   The full extent of Cribbs Causeway Retail Park totals 74,245sqm of A1 retail floorspace across 33
         units. In addition to the retailers previously referred to within the wider area there is also Morrisons,
         Dunelm, TK Maxx, Go Outdoors and B&Q, plus the stores within The Mall.
1.2.4.   There are no nearby listed buildings or conservation areas, which would be affected by the proposal.
         The site is located in Flood Zone 1 and is therefore at the lowest risk of flooding. Furthermore, the
         proposal is for additional floorspace at mezzanine level within an existing building, and therefore
         would not increase the risk of flooding.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                      PUBLIC | WSP
         Project No.: 70080687                                                                          April 2021
         DSG Retail Limited                                                                           Page 1 of 20
1.3      PROPOSAL
1.3.1.   Units 1 - 4 (Block A) is occupied by Currys PC World. The existing unit extends to 6,850sqm (gross)
         in total, comprising 6,391sqm (gross) at ground floor level and 459sqm (gross) at mezzanine level.
         The mezzanine floorspace sits within Units 1 and 2. The proposal is to sub-divide the existing retail
         space into two units (Units 1 and 2, and Units 3 and 4), and install an additional 1,394sqm of gross
         floorspace at mezzanine level, resulting in a total mezzanine of 1,853 sqm (gross).
1.3.2.   This application therefore seeks planning permission for the installation of mezzanine floorspace for
         retail sales (1,394sqm gross).
1.3.3.   In accordance with Section 55(2) of the Town and Country Planning Act (1990), the sub-division of
         the unit does not require planning permission and it will remain in a retail use. As such, the site for
         the purpose of the application relates to Units 1 and 2 only, rather than the whole of Block A.
1.3.4.   The application will result in Currys PC World occupying only Units 1 and 2, with a total gross
         floorspace of 5,042sqm (3,532sqm net); this is smaller than their existing store (Units 1 to 4), which
         is 6,850sqm (gross) / 5,269sqm (net).
1.3.5.   The other half of the unit (Units 3 and 4) will be occupied by a new operator.
1.3.6.   There is an extant planning permission (ref: PT17/5941/F) for 1,495sqm of mezzanine floorspace in
         the other half of Block A (Units 3 and 4), as the intention was previously for Currys PC World to
         occupy that half of the unit. However, Currys PC World now intends on occupying Units 1 and 2
         instead and, as such, permission ref: PT17/5941/F will not be implemented (it expires in March
         2021). The amount of floorspace proposed under this application is similar, it is actually slightly less,
         than what was approved in the adjacent unit.
1.3.7.   Alongside this Planning and Retail Statement, the application is accompanied by existing and
         proposed floorplans, a Design and Access Statement, a Transport Statement and a Flood Risk
         Note.
1.3.8.   The Transport Statement demonstrates that the site is well served by public transport, as well as the
         car and by foot. It also explains that the proposal will likely result in only a 1.3% increase in the
         number of customers visiting the site, and even if all of these additional customers travelled by car,
         any increase in car trips on the local road network is likely to be insignificant in the context of the
         existing traffic flows. Furthermore, the majority of cars visiting the site would likely be visiting other
         units at the retail park anyway. Moreover, even if it is assumed that all of the additional trips are
         made by car, the proposed additional floor area within Units 1-2 and the splitting of the units is
         unlikely to significantly increase maximum parking demand at Cribbs Causeway Retail Park.

1.4      BUSINESS MODEL
1.4.1.   Dixons Carphone Plc (DSG Retail Limited) is a leading retailer in the electrical goods sector with
         presence in the market via the Currys, Currys digital, PC World and Carphone Warehouse brands.
1.4.2.   This proposal forms part of a wider national programme of store improvements, which will enable
         Currys PC World to operate more efficiently and in a more cost-effective manner.
1.4.3.   Throughout the UK, Dixons Carphone have been undertaking a programme of refurbishment and
         resizing their stores. They have introduced a format where the products from Currys and PC World
         are traded on separate floors in the same unit. Consequently, they require less space at ground

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                      PUBLIC | WSP
         Project No.: 70080687                                                                          April 2021
         DSG Retail Limited                                                                           Page 2 of 20
floor. This has proved to be a successful format with customers, and Dixons Carphone wish to
         facilitate a similar change to their Currys PC World store at Cribbs Causeway.
1.4.4.   The focus of the proposal, and Dixons Carphone’s wider programme of store improvements, is
         therefore to improve customer satisfaction, through enhanced consumer choice, display space and
         customer service. It also creates a more efficient and financially viable store format for the longer
         term, which will enable the business to remain competitive in light of increasing online competition.
1.4.5.   The retail market has been undergoing significant changes in recent years and, as mentioned
         above, the impact of the increase in internet shopping on retail stores is detrimental. These issues
         have been further compounded by the recent COVID-19 pandemic, forcing retailers to close their
         stores for a prolonged period of time and increasing consumers’ reliance on online shopping.
1.4.6.   To help secure the future of Block A, and to help stimulate economic development in South
         Gloucestershire and the Bristol area, especially during COVID-19, the applicant is investing in the
         site to provide a more diverse and attractive offering that is better suited to today’s retail
         environment.

1.5      PLANNING HISTORY
1.5.1.   Planning permission for Cribbs Causeway Retail Park was granted under outline application ref:
         P84/0051/7 in 1985 for retail, regional and local warehousing and light industrial development on
         approximately 18.2 hectares. Reserved matters application ref: P85/0051/16 was then granted
         permission in 1994 for the erection of two retail warehouses totalling 160,000 sqft (14,864sqm).
1.5.2.   In 1986, an application was approved for the use of 6,750sqft (627sqm) of the land as a garden
         centre (part of Unit 1) (ref: P86/0051/54) and an application for a certificate of lawful development
         was granted at Units 1 and 2 (Block A) in 2005 (ref: PT05/2461/CLP) for the installation of a
         mezzanine floor of 3,014sqm. This however was not implemented.
1.5.3.   An application for a certificate of lawfulness for the proposed use of the retail park as Class A1
         (comparison and convenience goods) was then approved in 2009 (ref: PT09/0729/CLP).
1.5.4.   In February 2018, planning permission was granted (ref: PT17/5942/F) for external alterations to
         Units 1 to 4 (Block A) to facilitate their subdivision to form 2no. retail units (Class A1).
1.5.5.   Subsequently, in March 2018, planning permission was granted (ref: PT17/5941/F) for the
         installation of 1,495sqm of floorspace at mezzanine level in Units 3 and 4 (Block A). However, this
         permission has not been implemented and is due to expire soon.
1.5.6.   We understand that mezzanines have been installed in Oak Furniture Land, Wrens Kitchens and
         Next.
1.5.7.   In light of the above, the principle of retail floorspace at mezzanine level has already been
         established both within Block A and within other units at Cribbs Causeway, as shown in Table One
         below.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                     PUBLIC | WSP
         Project No.: 70080687                                                                         April 2021
         DSG Retail Limited                                                                          Page 3 of 20
Table 1 - Mezzanine retail space at Cribbs Causeway Retail Park

          Unit   Current Occupier               Approved Mezzanine            Installed
                                                                              Mezzanine

          1-4    Currys PC World                Yes (ref: PT05/2461/CLP)

          1-4    Currys PC World                Yes (ref: PT17/5941/F)

          5      Smyths Toys                    Yes (ref: PT11/1147/F)

          7      Oak Furniture Land             Yes (ref: PT14/2630/F)        Yes

          8      Argos                          Yes (ref: PT09/0393/F)

          9      Harveys                        Yes (ref: PT11/3962/F)

          10     Wren Kitchens                  Yes (ref: PT11/3962/F)        Yes

          12a    Next Home                      Yes (ref: PT13/1156/F)        Yes

1.6      PLANNING POLICY
1.6.1.   Section 38(6) of the Planning and Compulsory Purchase Act 2004 refers to the Development Plan
         as a whole and requires that:
          “If regard is to be had to the Development Plan for the purpose of any determination to
          be made under the Planning Acts, the determination must be made in accordance with
          the Plan unless material considerations indicate otherwise.”

1.6.2.   The above is in addition to Section 54A of the 1990 Act and is a reiteration of the presumption in
         favour of development that accords with an adopted and up to date development plan, as qualified
         by Paragraph 12 of the National Planning Policy Framework (‘the Framework’).
1.6.3.   The development plan for South Gloucestershire comprises the Policies, Sites and Places Plan
         (2017) and the Core Strategy (2013).
1.6.4.   Policy CS14 confirms that Cribbs Causeway is an out of centre location and as such development
         proposals need to satisfy the sequential assessment.
1.6.5.   The development plan at Policy PSP31 directs proposals for main town centre uses to town and
         district centres. Out of centre proposals for main town centre uses will only be acceptable where:
          No centre or edge of centre sites are available; and
          The proposal(s) would be in a location readily accessible on foot, cycle, and by public transport;
           and
          Alternative formats for the proposed uses have been considered.
1.6.6.   Policy PSP31 also states that out of centre development proposals should not have an
         unacceptable impact on:

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                   PUBLIC | WSP
         Project No.: 70080687                                                                       April 2021
         DSG Retail Limited                                                                        Page 4 of 20
A. Existing, committed and planned public and private investment in a centre, in the catchment
              area of the proposals; and
           B. The vitality and viability of established centres.
1.6.7.   An impact assessment is required for retail proposals larger than the locally set threshold of 350sqm
         in all locations outside Primary Shopping Areas.
1.6.8.   This Planning and Retail Statement therefore demonstrates that the proposal complies with the
         development plan and the Framework, given the following:

1.7      REASON 1
1.7.1.   There are no sequentially preferable sites which would be able to accommodate the proposal.

1.8      REASON 2
1.8.1.   The proposal would not have a significant adverse impact on the vitality and viability of nearby
         centres or any planned investment in these centres.

1.9      REASON 3
1.9.1.   There are no material considerations which warrant the refusal of the application.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                   PUBLIC | WSP
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         DSG Retail Limited                                                                        Page 5 of 20
2        REASON 1 - THERE ARE NO SEQUENTIALLY PREFERABLE
         SITES
2.1.1.   Given the site is out of centre in retail planning policy terms, in accordance with requirements of
         Policy PSP31, WSP has undertaken a sequential assessment of the town and district centres within
         the catchment area, for in-centre and edge-of-centre locations which could accommodate the
         proposal.
2.1.2.   The following section therefore considers alternative formats, the availability of alternative sites and
         the accessibility of the application site.
2.1.3.   Finally, it is important to note that the sequential test is intended to implement the Government’s
         ‘town centres first’ policy. This seeks to locate main town centre uses (including retail development)
         in the most central sites possible. However, it is a town centres first policy, not a town centres only
         policy. There is no embargo on development outside town centres.

2.2      ALTERNATIVE FORMATS
2.2.1.   The proposed additional floorspace in Units 1 and 2 will result in a gross floorspace of 5,042sqm
         gross split over the ground and mezzanine floors. In the Supreme Court Judgment Tesco Stores
         Limited v City of Dundee1, the Court confirmed that consideration of alternative sites must take into
         account the developers’ proposals. The Judgement confirms that the key matter is:
               “…whether an alternative site is suitable for the proposed development, not whether
               the proposed development can be altered or reduced so that it can be made to fit an
               alternative site” (paragraph 29).

2.2.2.   In short, the Dundee decision confirms that the sequential test must be related to the proposals for
         which the developer is applying, not an alternative scheme which might be preferred by the local
         planning authority, and that the commercial requirements of the proposed operator must be
         considered within the decision-making process.
2.2.3.   In regard to extensions (such as the current proposal) the sequential assessment must consider the
         store as a whole, i.e. the existing store and its extension. This arises from an appeal decision at
         Telford Forge Retail Park2 where Sainsbury’s sought an extension to their existing store. The
         Inspector in that case considered the application of the sequential test to be inappropriate for
         extensions:
               “The proposal is for an extension, albeit with considerable alterations to the existing
               store; it cannot reasonably be considered as for a new store. And, since the proposal
               is for an extension to an existing store, there cannot logically be a more suitable site
               within or on the edge of the town centre. In other words, application of the sequential
               test appears inappropriate” (paragraph 20).

         1
             Source: https://www.supremecourt.uk/cases/docs/uksc-2011-0079-judgment.pdf
         2
             Source: https://secure.telford.gov.uk/planning/PCViewAttachment.aspx?AttachID=62945

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                       PUBLIC | WSP
         Project No.: 70080687                                                                           April 2021
         DSG Retail Limited                                                                            Page 6 of 20
2.2.4.   Despite expressing this view, the Inspector went on to acknowledge that paragraph 24 of the
         Framework requires LPAs to apply a sequential test to planning applications for main town centre
         uses that are not in an existing centre, and so appears to apply to extensions. He went on to
         confirm that:
            “…since an extension cannot logically be located elsewhere, it is appropriate to
            undertake the sequential test in relation to the store as proposed to be extended”
            (paragraph 21, our underlining).

2.2.5.   Furthermore, in the Scotch Corner Secretary of State decision from December 2016 (Ref.
         APP/V2723/V/15/3132873 and APP/V2723/V/16/3143678), the Inspector found that the sequential
         test does not require the applicant to disaggregate schemes and stated at paragraph 11.7 of the
         decision that the “sequential test seeks to see if the application, i.e. what is proposed, can be
         accommodated on a town site.”
2.2.6.   The Secretary of State’s decision in October 2018 in relation to The Mall at Cribbs Causeway (Ref:
         APP/P0119/V/17/310627) also confirms again that disaggregation is not required.
2.2.7.   Thus, it is clear that a sequentially preferable site must be capable of accommodating the proposal
         as a whole and not altered to fit an alternative site. This implies the business model of the operator
         is key to determining the suitability of a site.
2.2.8.   This approach to the sequential test was accepted and agreed previously by South Gloucestershire
         Council in respect of the consideration of the construction of the first floor in Units 3 and 4 Block A
         Cribbs Causeway (LPA application ref: PT17/5941/F).
2.2.9.   Currys PC World currently occupy an existing unit in an established retail park. The current unit is in
         a profitable location with a high level of footfall, however it does not fit their business model and is
         not an efficient use of the space. The proposal will enable them to remain in this location, thereby
         ensuring consumer choice for electrical products is maintained and existing employment
         opportunities are retained.
2.2.10. The officer report for application ref: PT17/5941/F, which granted the installation of a similar amount
        of mezzanine floorspace in the other half of the unit, but which will not be implemented stated:
            “….the premises are an existing retail unit located in an established retail park. There
            will be no new building of additional external retail footprint as such, but utilisation and
            maximisation of an existing building already in retail use. Given the existing nature of
            the site and surrounding area for in particular retail and leisure, the site is accessible.
            The scale and nature of the addition are also relevant, and it would be considered a
            relatively small addition of floorspace in relation to the surrounding retail park. It is
            considered that the proposals therefore pass the sequential test in this instance.”

2.2.11. Sequentially preferable sites must be capable of accommodating the applicant’s proposal as a
        whole. Further, sites where the floorspace can be accommodated entirely at ground floor level do
        not meet the new Dixons Carphone business model nor differ from their existing store at Cribbs
        Causeway and as such they would not be considered suitable. Sequentially preferable sites must
        therefore be able to accommodate the entire quantum of floorspace split over ground and
        mezzanine floors.
2.2.12. In light of the above a sequential assessment has been carried out in the nearby town and district
        centres, based on the following parameters:

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                       PUBLIC | WSP
         Project No.: 70080687                                                                           April 2021
         DSG Retail Limited                                                                            Page 7 of 20
 To maintain existing levels of trade Dixons Carphone, require an existing unit with mezzanine
           floorspace, available for occupation by Currys PC World in 2022.
          Circa 3,189sqm (+/- 10% to demonstrate flexibility) at ground floor in order to accommodate bulky
           goods; with c,1,853sqm at mezzanine level.
          Easily accessible and level car parking; and
          A location near to similar retailers, in order to benefit from linked trips.

2.3      ASSESSMENT OF ALTERNATIVE SITES
2.3.1.   This sequential assessment gives consideration to potential sites which are located in and on the
         edge of the town and district centres located within Zones 5, 10 and 11 as defined by the 2010
         Retail Study and shown in Figure One below.
2.3.2.   The extent of the catchment area is considered appropriate given the scale of the proposals and
         nature of the goods to be sold from the mezzanine. A significant proportion of electrical goods are
         now sold online, and consumers are therefore becoming less willing to travel significant distances to
         purchase products instore.
2.3.3.   The catchment area has also been determined by the location of other Curry PC World stores as
         there are three existing stores located nearby at Cabot Circus, Winterstoke Road and Longwell
         Green.
2.3.4.   The town centres within the catchment area include Filton and Bradley Stoke, but to provide a
         robust assessment we have also assessed the more recently allocated district centres of Patchway
         and Stoke Gifford.
2.3.5.   In searching for sites, we utilised various sources of data including the following;
            South Gloucestershire Policies, Sites and Places Plan (2017);
            Estates Gazette Interactive (EGi) Commercial Property;
            Zoopla Commercial; and
            South Gloucestershire Planning Register regarding existing commitments.
2.3.6.   We are aware that the Arcadia brand, which includes stores such as Topshop, Topman, Burton,
         Wallis, Outfit, Dorothy Perkins and Evans, has been acquired by ASOS and Boohoo recently. As
         such, this may result in some of the existing stores becoming vacant and therefore we have also
         included a review of these stores wherever they are present within the four centres.
2.3.7.   Please note that our searches did identify that there were a number of vacant industrial units located
         near to the designated centres. However, these were located in out of centre locations and
         significantly too large for the proposal. They therefore are not sequentially preferable to the
         application site in any respect and have therefore not been assessed below.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                   PUBLIC | WSP
         Project No.: 70080687                                                                       April 2021
         DSG Retail Limited                                                                        Page 8 of 20
Figure 1 - Extract from Retail Study to show catchment area encompassing
             Zones 5, 10 and 11.

2.4      FILTON TOWN CENTRE
2.4.1.   EGi Commercial Property and Zoopla Commercial did not identify any vacant units within Filton town
         centre or within 300m of the Primary Shopping Area.
2.4.2.   As such, there are no available or suitable sites in or on the edge of Filton town centre.

2.5      BRADLEY STOKE TOWN CENTRE
2.5.1.   Policy PSP31 identifies capacity for 4,000sqm of new comparison retail development within the
         Bradley Stoke Primary Shopping Area, as defined on the Policies Map. The vision is that Bradley
         Stoke town centre will grow and diversify to meet the changing needs of the town. At present the
         centre is anchored by the Tesco Extra, there is also an Argos, Pets at Home, Pound Stretcher and
         Poundworld amongst others.
2.5.2.   The Retail Capacity Study (2014) at Paragraph 2.1.3 states that the capacity could be
         accommodated as mezzanines in the existing units as well as through the remodelling of the car
         park. To that end a location to the north of the existing large format stores referred to earlier has
         been allocated as part of the Primary Shopping Area to accommodate this growth.
2.5.3.   However, a hybrid planning application was refused on this allocated site in March 2019 (ref:
         PT18/1491/O) but then allowed at appeal in January 2020 (ref: APP/P0119/W/19/3232136) for the
         erection of two food and drink units each incorporating a drive-through; and to extend the existing
         retail terrace to provide two non-food retail units (up to 3,100sqm including mezzanine) and
         rearrangement of existing car park. Conditions attached to the appeal decision have recently been

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                     PUBLIC | WSP
         Project No.: 70080687                                                                         April 2021
         DSG Retail Limited                                                                          Page 9 of 20
discharged and therefore it is assumed that this development is being delivered. However, the
         additional retail floorspace only currently benefits from outline permission and therefore it is highly
         unlikely that it would be granted reserved matters approval and developed by the end of 2022, in
         time to facilitate the proposal. As such, this site is unavailable for the proposed development.
         Furthermore, the retail space proposed only amounts to 3,100sqm in total, which is too small to
         accommodate the proposal. This site is therefore also unsuitable for the proposed development.
2.5.4.   EGi Commercial Property and Zoopla Commercial did not identify any vacant units within or on the
         edge of Bradley Stoke Town Centre.
2.5.5.   There were previously Burton and Dorothy Perkins concession stores within the Tesco Extra store at
         the Willowbrook Centre in Bradley Stoke. However, we understand that these stores have closed
         permanently as a result of the Arcadia acquisitions. However, the format of the stores, located
         internally within the Tesco Extra store, is not consistent with the Currys PC World business model
         which requires both ground and mezzanine floorspace. The units that these stores are located in are
         therefore unsuitable.
2.5.6.   As such, there are no available or suitable sites in or on the edge of Bradley Stoke Town Centre.

2.6      STOKE GIFFORD DISTRICT CENTRE
2.6.1.   Policy PSP31 identifies capacity for 5,000sqm of new comparison retail development within the
         newly defined Stoke Gifford District Centre and associated Primary Shopping Area, as defined on
         the Policies Map. It is anticipated that the floorspace will be provided across the District Centre but
         focussed on Primary Shopping Area (PSA) and edge of PSA sites.
2.6.2.   The application proposals for a single unit of 5,042sqm, would take up the entire allocation in a
         single unit and not therefore meet the aspiration for the new district centre. Further the levels of
         footfall within the district centre boundary would not generate the linked trips required to sustain the
         application proposals.
2.6.3.   With regard to the two allocated sites in Stoke Gifford; they are already subject to recent proposals.
2.6.4.   At the allocation located adjacent to the existing Sainsbury’s store (Fox Den Road), there is a
         pending application (ref: P20/05916/F) for the erection of mixed-use development comprising of a
         Hotel and Restaurant, Supermarket, Coffee Shop with Drive Thru Facility and multi-use building
         (comprising flexible combinations of Use (Class A1) shops, (Class A2) financial and professional,
         (Class A3) food and drink, (Class A5) hot food takeaways, (Class B1) business, (Class D1) non-
         residential institutions, and (Class D2) Assembly and Leisure), with parking, landscaping and
         associated works. The target date for this application was 9 July 2020 so it is assumed that the
         applicant is working with the Council to resolve outstanding matters before the application is
         determined.
2.6.5.   At the other allocation, located south of the A4174 but north of Abbey Wood, planning permission
         was granted in December 2020 (ref: P20/08495/F) for the erection of a hotel (Class C1) and food
         and beverage retail unit (Class A1) with parking, access, landscaping and associated works.
2.6.6.   These sites are therefore considered unavailable for the development proposed as defined by the
         parameters set out above. Furthermore, even though a multi-use building (which includes retail) is
         proposed as part of application ref: P20/05916/F, it only extends to 1,504sqm and is therefore too
         small and, as such, unsuitable for the proposed development.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                      PUBLIC | WSP
         Project No.: 70080687                                                                          April 2021
         DSG Retail Limited                                                                          Page 10 of 20
2.6.7.   EGi Commercial Property and Zoopla Commercial did not identify any vacant units within or on the
         edge of Stoke Gifford District Centre.
2.6.8.   As such, there are no available or suitable sites in or on the edge of the centre Stoke Gifford
         District Centre

2.7      PATCHWAY DISTRICT CENTRE
2.7.1.   EGi Commercial Property and Zoopla Commercial identified one vacant unit within Patchway District
         Centre and within 300m of the Primary Shopping Area at Unit 2, Charlton Boulevard, Filton, Bristol.
         However, the unit only extends to 196sqm, which is significantly too small for the proposal. As such,
         the unit is unsuitable for the proposed development and there are no other available units.
2.7.2.   There is an extant planning permission within Patchway District Centre for 52 residential
         apartments, 2no. retail units (Class A1) and 1no. children’s day nursery (Class D2) (LPA ref:
         PT16/4740/RM), which has been implemented and is being built out. The approved retail units have
         a floorspace of 196sqm and 370sqm, thereby making the units too small in isolation or in
         combination and therefore unsuitable.
2.7.3.   As such, there are no available or suitable sites in or on the edge of Patchway District Centre.

2.8      ACCESSIBILITY OF THE APPLICATION SITE
2.8.1.   The Transport Statement which accompanies the application sets out in full how the application site
         at Cribbs Causeway can be accessed. It is accessible on foot and by bicycle and there is a footway
         located either side of Lysander Road running along the western boundary of the Cribbs Causeway
         Retail Park site. With a shared footway/cycleway located to the east of the site. There is a bus stop
         located on Lysander Road, within 150m of the site, which is served by a number of routes that
         provide connections to destinations within Bristol and the surrounding area.
2.8.2.   Accessibility of the site will be further enhanced by the proposals set out in Policies CS7 and PSP13
         for a high quality strategic public transport link. This will connect the proposed new railway services
         on the Henbury Line and the Cribbs Causeway retail area. The Cribbs Patchway MetroBus
         Extension will deliver this link through interchange with the proposed railway services at the planned
         new station at North Filton.
2.8.3.   The application site is therefore in a location readily accessible by all modes of transport in
         accordance with Policy PSP14. The level of accessibility will increase over time once the strategic
         public transport links are developed.

2.9      CONCLUSION
2.9.1.   In conclusion, there are no existing sites within or on the edge of the centres within the catchment
         area which are suitable for the development proposed. The only vacant units identified nearby were
         industrial units in out of centre locations, which are not sequentially preferable to the application site,
         and which were too large for the proposal anyway.
2.9.2.   The reconfiguration of the existing Currys PC World unit and the addition of the mezzanine floor
         therefore represents the most suitable opportunity in an accessible location. Furthermore, the
         proposed floorspace will be installed instead of the (larger amount of) floorspace that was previously
         granted under permission ref: PT17/5941/F.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                       PUBLIC | WSP
         Project No.: 70080687                                                                           April 2021
         DSG Retail Limited                                                                           Page 11 of 20
2.9.3.   As such, the application site is acceptable for the proposed retail development and the sequential
         test is satisfied in accordance with Policy PSP14.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                  PUBLIC | WSP
         Project No.: 70080687                                                                      April 2021
         DSG Retail Limited                                                                      Page 12 of 20
3        REASON 2 - THE PROPOSAL WILL NOT HAVE A SIGNIFICANT
         ADVERSE IMPACT ON THE VITALITY AND VIABILITY OF
         NEARBY CENTRES
3.1.1.   The proposal is a similar size mezzanine to the planning permission (LPA ref PT17/5941/F) granted
         in 2017. In fact, the current proposal is smaller than that previously consented. Consequently, the
         impact on the vitality and viability of nearby centres is likely to be similar if not less.
3.1.2.   In addition, Currys PC World currently operate with a larger floorspace than proposed, there will be
         no additional trade diversion to the proposed store.
3.1.3.   This proposal will retain the existing jobs and Currys PC World will maintain a well-established
         presence in South Gloucestershire, which is particularly important during the current COVID-19
         pandemic.
3.1.4.   For robustness we have updated the retail impact assessment, which accompanied the previous
         planning application (LPA ref PT17/5941/F) and for ease of reference we have used the same data.
3.1.5.   Whilst the proposals fall below the national planning guidance threshold, which requires a retail
         impact assessment for proposals above 2,500 sqm gross, the adopted Local Plan for South
         Gloucestershire (2017) sets the local threshold for new retail proposals at 350sqm gross.
3.1.6.   In accordance with Policy PSP31 out of centre proposals should not have an “unacceptable impact”
         on existing, committed and planned public and private investment in centres and on the vitality and
         viability of established centres. The Framework and the Practice Guidance refers to the level of
         impact which would be unacceptable as “significant adverse impact”.
3.1.7.   The policy and guidance have been purposefully drafted in these terms because it is accepted that
         most new developments will have an impact on the surrounding area. The pertinent question
         therefore is not whether there will be an impact, but whether the impact is ‘significant’ and ‘adverse’
         and therefore unacceptable.
3.1.8.   The officers report for application ref: PT17/5941/F, which granted the installation of a similar
         amount of mezzanine floorspace in the other half of the unit, but which will not be implemented
         concluded:
            “…..given the existing site compared with the relative scale of the proposal within an
            existing retail unit and the nature of the unit and the retail park, it is not considered
            that the proposals would have a significant or material impact upon trade diversion
            nor a material overall impact upon the vitality or viability of other existing nearby
            centres. Further to this the mezzanine would represent additional exclusive
            floorspace associated to the existing retail unit, not introducing a new separate retail
            unit. The principle of the proposals are therefore considered acceptable.”

3.1.9.   The application proposals are on behalf of an existing retailer at Cribbs Causeway the following
         assessment is therefore a proportionate updated assessment of the impact of the proposals for the
         mezzanine floor. The assessment was previously considered acceptable by South Gloucestershire
         Local Planning Authority in considering the previous application (LPA ref: PT17/5941/F).

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                      PUBLIC | WSP
         Project No.: 70080687                                                                          April 2021
         DSG Retail Limited                                                                          Page 13 of 20
3.2      TURNOVER OF PROPOSED MEZZANINE
3.2.1.   The proposed mezzanine will facilitate the consolidation of the existing Currys PC World floorspace
         into a unit with a slightly reduced gross floorspace, but a significantly reduced ground floor footprint.
         As a result, Dixons Carphone will realise significant cost savings and thereby make the store more
         efficient and profitable in the face of increasing online competition.
3.2.2.   The Dixons Carphone sales density figure available from Mintel Retail Rankings is £7,206 per sqm
         including VAT in 2006 prices. Therefore, the turnover for the existing store (5,269 sqm net) is
         calculated at around £38 m.
3.2.3.   The turnover of the consolidated unit is anticipated to be around £25.5m, based on the net
         floorspace of 3,532 sqm. This is slightly less than the previous approved scheme (LPA ref
         PT17/5941/F), which was anticipated to be £29.2m.
3.2.4.   The turnover of the 1,191 sqm net of retail floorspace at mezzanine level in isolation, is estimated to
         be £8.6m. Again, this is lower than the previous approved scheme (LPA ref PT17/5941/F), which
         was anticipated to be in the order of £10.7m.
3.2.5.   The anticipated turnover of the consolidated unit is less than the existing turnover, however, is viable
         due to the associated rental savings.

3.3      TRADE DIVERSION AND IMPACT
3.3.1.   It is a well-established principal that impact should be assessed on a like for like basis. In regard to
         the current proposals on behalf of Dixons Carphone, the Currys PC World fascia competes with
         other electrical good retailers; their main competitors are online retailers and to a lesser extent larger
         supermarkets and departments stores that sell electrical goods.
3.3.2.   This pattern of spending on appliances is backed by Spreadsheet 6g of Volume 2 of the SGC Town
         Centres and Retail Study (2010). It demonstrates that the majority of expenditure on domestic
         appliances within the catchment area of the Retail Study was within Zone 5 (39.73%) and more
         specifically at Cribbs Causeway Retail Park (31.80%). Expenditure was also directed towards
         Longwell Green Retail Park (14.73%) and Bristol City Centre (7.32%), where there are existing
         Currys PC World stores. With much smaller proportions of expenditure spent at Yate (3.12%) and
         Emerson Green (3.21%).
3.3.3.   The turnover of comparison goods floorspace in defined centres within South Gloucestershire was
         calculated at £165m in 2006 prices (Table 4.11 of the SGC Town Centres and Retail Study 2010).
         A turnover efficiency rate of 2.2% from 2016 has been applied in line with the assumptions of the
         Retail Study.
3.3.4.   Table Two below shows the existing turnover of centres within the Study Area of the South
         Gloucestershire Council Town Centres and Retail Study 2010. Table Three sets out the turnover of
         the mezzanine and the anticipated trade diversion associated with the creation of the new
         floorspace.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                      PUBLIC | WSP
         Project No.: 70080687                                                                          April 2021
         DSG Retail Limited                                                                          Page 14 of 20
Table 2 - Turnover of Comparison Floorspace in Centres within South Gloucestershire Retail
         Study Area
           2021                                 2022                                 2023                                2024       2025
           £m                                   £m                                   £m                                  £m         £m

                                                                                                                                    205
           188                                  192                                  196                                 201

         Notes:

         Turnover of centres based on Table 4.11 of South Gloucestershire Council 2010 (2006 prices)

         Floorspace efficiency of 2.2% applied to turnover from 2016 in line with the assumptions of the Retail Study.

         Table 3 - Anticipated Trade Diversion from Centres within South Gloucestershire from Currys
         Mezzanine

           Turnover of                                                 Trade Diversion                                     Impact     Residual
           mezzanine                                                                                                       %          Turnover
           2022                                   % of mezzanine                          Amount of                                   2022
           £m                                     turnover diverted                       Diverted Trade                              £m
                                                  from centres                            £m

           8.6                                    50%                                     4.3                              2          183.4

         2006 prices

3.3.5.   As shown in Table Three, it is anticipated that the impact of the mezzanine floor proposals, across
         all centres within South Gloucestershire will be just 2%. This small amount of diversion is therefore
         not considered significant adverse, particularly as it would not be concentrated on a single centre.
         Further when the turnover of the centres are considered as a whole, including convenience
         floorspace turnover, the impact would be even less.
3.3.6.   We have estimated that 50% of the turnover of the mezzanine floor would be diverted from centres
         within South Gloucestershire. This is a very robust figure for electrical goods, but a realistic
         assumption if the Unit was occupied by a different retailer.
3.3.7.   Given the council’s retail study is dated, an assessment has also been undertaken using Global data
         2017 projected to 2021 & repriced to 2006 prices. This assessment concludes that the turnover of
         the proposed mezzanine floor is anticipated to be £13.1m. The impact of the mezzanine floor
         proposals of the comparison turnover across all centre would be just 3%.

3.4      SUMMARY ON TRADE DIVERSION AND IMPACT
3.4.1.   Given the robustness of the assumptions applied, the proposed mezzanine will not cause
         unacceptable levels of impact on any of the centres within South Gloucestershire. The 2% impact
         on the comparison turnover of the centres represents the worst-case scenario, particularly as there
         is already trade diversion to the existing (larger) Currys PC World at Cribbs Causeway Retail Park.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                                                             PUBLIC | WSP
         Project No.: 70080687                                                                                                                 April 2021
         DSG Retail Limited                                                                                                                 Page 15 of 20
3.5      IMPACT ON INVESTMENT
3.5.1.   This section considers the impact of the proposal on existing, committed and planned public and
         private investment in the town and district centres that fall within Zones 5, 10 and 11.
3.5.2.   With regards to existing commitments in the nearby centres, the relevant planning permissions are
         set out below.
         Patchway District Centre
3.5.3.   In Patchway District Centre a planning permission has been implemented and is being built out for
         52 residential apartments, 2no. retail units (Class A1) and 1no. children’s day nursery (Class D2)
         (LPA ref: PT16/4740/RM).
3.5.4.   The proposal however will not prevent the two proposed retail units from coming forward as they
         propose small retail stores that would serve the immediate locality. These are likely to be occupied
         by different types of retailers than Currys PC World, such as convenience goods retailers and
         service providers, and therefore will not be impacted by the proposal.
         Bradley Stoke Town Centre
3.5.5.   In Bradley Stoke Town Centre an appeal was allowed in January 2020 (ref:
         APP/P0119/W/19/3232136) for the erection of two food and drink units each incorporating a drive-
         through; and to extend the existing retail terrace to provide two non-food retail units (up to 3,100sqm
         including mezzanine) and rearrangement of existing car park.
3.5.6.   Again, due to the scale of the non-food retail units they are likely to be occupied by different types of
         retailers than Currys PC World.
         Stoke Gifford District Centre
3.5.7.   There is a pending application (ref: P20/05916/F) for the erection of mixed-use development
         comprising of a Hotel and Restaurant, Supermarket, Coffee Shop with Drive Thru Facility and multi-
         use building (comprising flexible combinations of Use (Class A1) shops, (Class A2) financial and
         professional, (Class A3) food and drink, (Class A5) hot food takeaways, (Class B1) business, (Class
         D1) non-residential institutions, and (Class D2) Assembly and Leisure)), with parking, landscaping
         and associated works.
3.5.8.   For the same reasons set out above, the proposal would not prevent the multi-use building from
         coming forward as they propose small units that would serve the immediate locality. This building is
         likely to be occupied by different type of retailers than Currys PC World, such as convenience goods
         retailers and service providers, and therefore will not be impacted by the proposal.
         Conclusion
3.5.9.   The proposal will facilitate the retention of an existing retailer, by creating a more viable format that
         enables them to remain competitive. As Currys PC World will be operating over less floor space,
         the application proposals will not introduce additional retail sales. As such, it will not prevent
         development from coming forward on the sites allocated for retail in Patchway, Bradley Stoke and
         Stoke Gifford, which was explained in more detail in the sequential test section.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                       PUBLIC | WSP
         Project No.: 70080687                                                                           April 2021
         DSG Retail Limited                                                                           Page 16 of 20
3.6      IMPACT ON VIABILITY AND VITALITY
3.6.1.   The Framework requires retail proposals that exceed the local threshold to consider the impact of
         the proposal on town centre vitality and viability, including local consumer choice and trade in the
         town and district centres and wider area, up to five years from the time the application is made.
3.6.2.   Given that Currys PC World currently operate with a larger floorspace than proposed, there will be
         no additional trade diversion as a result of the proposal.
3.6.3.   As set out in Table Three, the impact of the floorspace proposed would be negligible at 2 (or 3%)
         across all comparison floorspace within defined centres within South Gloucestershire. Therefore,
         the vitality and viability of the existing centres within the District would remain unharmed.

3.7      CONCLUSION
3.7.1.   As such, there will be no significant adverse impact on the viability and vitality of the nearby town
         and district centres. In accordance with Policy PSP31 and The Framework the impact of the
         application proposal is therefore considered acceptable.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                     PUBLIC | WSP
         Project No.: 70080687                                                                         April 2021
         DSG Retail Limited                                                                         Page 17 of 20
4        OTHER MATERIAL CONSIDERATIONS
4.1.1.   Having established that there would be no significant adverse impact, the Guidance states that the
         positive and negative effects of the proposal should be considered alongside all other material
         considerations.
4.1.2.   Foremost amongst ‘other material considerations’ should be the presumption in favour of
         sustainable development and the core planning principles of the Framework which favour economic
         development wherever possible.
4.1.3.   We consider other material considerations to include highways, sustainability and benefits of the
         proposal.

4.2      HIGHWAYS
4.2.1.   The Transport Statement prepared by Vectos, which supports this application, demonstrates that the
         proposal would have no impact on the access, car parking or servicing arrangements for the unit.
4.2.2.   The site is in a sustainable location, easily accessible by foot and with bus stops located nearby.
         The statement concludes that the proposal is likely to only increase trips to Cribbs Causeway Retail
         Park by 1.3% and that a significant proportion of these trips are likely to be made by people already
         on the local road network visiting, for example, other nearby retail parks.
4.2.3.   In light of the above, the impact of any additional traffic arising from the proposal on the local road
         network is likely to be minimal. Furthermore, the proposed additional floor area within Units 1‐2 and
         the splitting of the units is unlikely to significantly increase maximum parking demand at Cribbs
         Causeway Retail Park.
4.2.4.   The proposal will not create or contribute to severe congestion or have an unacceptable effect on
         highway and road safety, and as such accords with Policy PSP11.

4.3      ENERGY / SUSTAINABILITY
4.3.1.   Given that the proposal comprises only internal works to an existing unit, the development will have
         no additional environmental impact. The proposal makes more efficient use of an existing unit, in a
         location that is an established retail park, rather than the loss of undeveloped land.
4.3.2.   There will also be no material increase in the number of car journeys.
4.3.3.   From a sustainability perspective, the proposal is similar to planning permission ref: PT17/5941/F, to
         which the Council raised no objections.

4.4      BENEFITS
4.4.1.   The proposal would enable the unit to continue in operation, make more efficient use of an existing
         building and would meet commercial requirements. It will enable the retention of the existing jobs at
         Currys PC World, which is currently 84 employees. It will also facilitate the occupation of a new
         operator in the adjacent unit; providing a more diverse and attractive offering at the retail park.
4.4.2.   The presumption in favour of sustainable development requires LPAs to support schemes such as
         this unless the sequential and impact tests are failed.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                     PUBLIC | WSP
         Project No.: 70080687                                                                         April 2021
         DSG Retail Limited                                                                         Page 18 of 20
4.4.3.   As this report demonstrates, these tests are satisfied in this case. There are no adverse impacts of
         granting planning permission which would significantly and demonstrably outweigh the benefits of
         the proposal.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                   PUBLIC | WSP
         Project No.: 70080687                                                                       April 2021
         DSG Retail Limited                                                                       Page 19 of 20
5        THE PLANNING BALANCE AND CONCLUSIONS
5.1.1.   The approval of this application will enable Currys PC World to meet their commercial requirements
         and thereby continue in operation, make more efficient use of an existing building and retain 84
         existing jobs.
5.1.2.   The preceding sequential assessment has demonstrated that there are no available sites in any
         nearby town or district centres which are suitable for the development proposed. Therefore, this is
         the most appropriate location and the sequential test is passed.
5.1.3.   Currys PC World is already operating in the unit, over a larger footprint. Our impact assessment has
         demonstrated that there will negligible level of impact across the town and district centres within
         South Gloucestershire and therefore no impact on existing, committed and planned public and
         private investment in the nearby town and district centres.
5.1.4.   The principle of additional mezzanine floorspace for slightly more floorspace was accepted
         previously in 2017, as well as at other units at Cribbs Causeway Retail Park.
5.1.5.   As the retail tests are satisfied, and there are no other material considerations which warrant the
         refusal of the application, it follows that the presumption in favour of sustainable development
         applies and the application should be approved.

         UNITS 1 AND 2 (BLOCK A), CURRYS PC WORLD, CRIBBS CAUSEWAY RETAIL PARK                    PUBLIC | WSP
         Project No.: 70080687                                                                        April 2021
         DSG Retail Limited                                                                        Page 20 of 20
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