UNITS 11A & 11B, ROARING MEG RETAIL PARK, STEVENAGE, SG1 1XN - JANUARY 2021 PLANNING AND RETAIL STATEMENT
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UNITS 11A & 11B, ROARING MEG RETAIL PARK, STEVENAGE, SG1 1XN PLANNING AND RETAIL STATEMENT JANUARY 2021
CONTENTS 1.0 INTRODUCTION…………………………………………………………….3 2.0 THE SITE AND RELEVANT PLANNING HISTORY…………………….5 3.0 THE PROPOSED DEVELOPMENT……………………………………….8 4.0 PLANNING POLICY OVERVIEW………………………………………..10 5.0 RETAIL CONSIDERATIONS……………………………………………..17 6.0 DEVELOPMENT MANAGEMENT CONSIDERATIONS………………36 7.0 SUMMARY AND CONCLUSIONS……………………………………….38 APPENDICES 1 SITE LOCATION PLAN 2 DECISION NOTICE 99/00097/OP 3 STEVENAGE TOWN CENTRE SEQUENTIAL SITES 4 STEVENAGE OLD TOWN SEQUENTIAL SITES 5 MAJOR OPPORTUNITY AREA SITES 6 STEVENAGE TOWN CENTRE VACANT UNITS (NOVEMBER 2019)
1.0 INTRODUCTION
1.1 This Planning and Retail Statement (PRS) has been prepared on behalf of Stevenage Retail
Limited (SRL), in relation to proposals at Unit 11A/11B, Roaring Meg Retail Park, Stevenage,
SG1 1XN (the Site). The proposals comprise external alterations and reconfiguration of the
existing internal mezzanine floorspace within Units 11A/11B and variation of condition 10 of
planning permission 99/00097/OP to allow the units to be used for retail sales under Class E(a)
of the Town and Country Planning (Use Classes) (Amendment) Regulations 2020.
1.2 The proposed development is to facilitate the relocation of DFS from the existing accommodation
at Unit 18 into Unit 11B, and allow the adjoining Unit 11A to be occupied by Sofology, a sister
company within the DFS parent company.
1.3 Following the proposed reconfiguration of the floorspace within the two units, the floorspace will
be as follows:
Table 1: Proposed floorspace breakdown
Unit 11A Unit 11B
Ground Floor 973sqm 983sqm
Mezzanine 743sqm 743sqm
Total (GEA) 1,716sqm 1,726sqm
Combined Total 3,442sqm
(GEA)
1.4 The proposals will meet DFS’s current operational requirements for their DFS brand and also
address DFS’s parent company requirement for the retailer’s two key fascia, namely DFS and
Sofology, to trade from immediately adjoining units.
1.5 The application is submitted further to pre-application discussions with Stevenage Borough
Council (the Council) including a meeting with Officers on 18 December 2020.
1.6 The proposals are progressed as two separate planning applications, one application for the
reconfiguration and insertion of additional mezzanine floor within Units 11A/11B and the use of
the units for retail sales, and separate application for the external alterations to the units, including
new entrances and increased double height glazing on the front elevations and side elevation of
Unit 11A. This is to facilitate a phased construction process.
3
1.7 This PRS sets out the scope of the planning application, identifies the key planning issues, and
provides an assessment of the proposals against these key issues. The PRS will focus on the
acceptability of the development in land use terms, having regards to the relevant policies of the
National Planning Policy Framework (NPPF) and Development Plan Policy.
1.8 The application should be read in conjunction with the other supporting application documents
as set out in the accompanying covering letter. The remainder of the Statement is structured as
follows:
The Application Site and Relevant Planning History – This section provides
an overview of the application Site and summarises the relevant planning history
at the Retail Park;
The Proposed Development – This section provides an overview of the
development proposals. This section also provides an overview of the proposed
occupiers, DFS and Sofology;
Relevant Planning Policy – This section identifies the relevant planning policy
at a national and local level which the development proposals will be assessed
against. At a local level, this includes the Statutory Development Plan for
Stevenage, including The Stevenage Borough Local Plan 2011-2031 (May 2019)
and the adopted Proposals Map (2019).
Retail Considerations - Sequential test and impact considerations are
assessed within this section of the PRS;
Development Management Considerations – the limited development
management considerations, focused on highways and design, are set out within
this section;
Summary and Conclusions – Finally we provide a brief summary of the key
planning issues and provide conclusions of the assessment. We conclude that
the proposed development is fully in line with national and local policy and should
therefore be considered favourably.
42.0 THE APPLICATION SITE AND PLANNING
HISTORY
2.1 The site is located approximately 1km south of Stevenage Town Centre. As such, the retail
park occupies an ‘out-of-centre’ location in terms of planning policy. A Site Location Plan is
enclosed as Appendix 1.
2.2 Roaring Meg Retail Park is an established retail destination serving the wider Stevenage area.
The Retail Park complements the Town Centre’s retail and leisure offer, and is a significant
employer in the local area.
2.3 The Retail Park extends to a total of circa 33,000sqm of retail floorspace. It comprises a
number of units including shops, restaurants, cafes and hot food takeaways, including
Debenhams, Currys PC World, Tapi, Furniture Village and Oak Furnitureland, and a number
of restaurant and coffee operators, including Pizza Hut, Costa Coffee and Harvester pub
among others. The majority of these uses now fall within new Class E of the Town and Country
Planning (Use Classes) (Amendment) Regulations 2020.
2.4 The application Site comprises Units 11A and 11B, extending to 3,070sqm GEA of Class E(d)
floorspace in total, split as follows:
Table 2 – Existing floorspace breaddown
Unit 11A Unit 11B
Existing Floorspace
Ground Floor 973sqm 983sqm
Mezzanine Floor 625sqm 489sqm
Total 1,598sqm 1,472sqm
Combined 3,070sqm
2.5 DFS currently occupy Unit 18, within the southern part of the Retail Park. The unit extends
to 1,712sqm at ground floor and 74sqm at mezzanine floor (a total of 1,786 sqm).
2.6 The use of Units 11A and 11B falls assembly and leisure uses within Use Class E (d), with
Unit 11A currently occupied by TruGym and Unit 11B occupied by Partyman.
52.7 Part of the Retail Park is located within Flood Zone 2 and Flood Zone 3. Units 11A and 11B
are located within Flood Zone 2. The proposals result in no change to the overall building
footprint and therefore does not give rise to any flood related issues.
Accessibility
2.8 Vehicular, pedestrian and cycle access to the Retail Park forms off London Road and the
A606 Monkswood Way. The A606 provides a primary A road, connecting the Site and wider
Stevenage to the A1(M).
2.9 Stevenage is also easily accessible from further afield by train, bus and bike. There are two
bus stops located along London Road, approximately 100 metres south-west of the units.
Roaring Meg Retail Park Stop A and B provide bus services: 44, 45, 301, 378 and 379.
2.10 A network of cycle lanes serve the site and the wider area, with cycle access via a dedicated
cycle lane is provided from London Road and Monkswood Way.
Relevant Planning History
2.11 Planning permission was originally granted for the Retail Park in April 1987 (under permission
2/0048/87). The description of development was for:
‘Sub regional durable goods retail warehouse complex, ice rink and leisure unit,
residential flat, licensed restaurant, 2 fast food units, community arts centre and
car and coach parking facilities, and improvements to water meadow’.
2.12 Units 11A and 11B were subsequently granted permission on 23 November 2000, under
planning permission ref. 99/00097/OP, attached as Appendix 2. The description of the
approved development is as follows:
'partial redevelopment involving demolition, extension, and new build, improved
internal circulation and adjustment of car parking and landscaping'.
2.13 The permission was subject to 13 conditions. Condition 10 relates specifically to Units 11A
and 11B and states:
'Prior to the demolition of the existing leisure unit, identified as a sports centre
on drawing reference number MJP1, a replacement leisure building of
approximately 1944sqm of gross floorspace shall be constructed and made
available for occupation, and it shall be used only for assembly and leisure
6purposes, in accordance with Class D2 of the Town and Country Planning (Use
Classes) Order 1997.'
2.14 Therefore, whilst the existing and proposed uses both fall within Class E, the effect of
Condition 10 above is to restrict the use of the units to Class E(d). In other words, were it not
for Condition 10, the units could be used for retail sales (and other uses within Class E) without
the need for planning permission.
73.0 THE PROPOSED DEVELOPMENT
3.1 The development proposals comprise the variation of condition 10 of planning permission
99/00097/OP which currently restricts the use of the Units 11A and 11B to assembly and leisure
uses within Class E(d), the reconfiguration and insertion of additional floorspace at mezzanine
floor, and associated external alterations, to allow the unit to be used for Class E(a) retail uses.
3.2 The proposals will facilitate the occupation of the units by DFS and Sofology, furniture and sofa
retailers within the DFS group of companies.
3.3 The proposed reconfiguration of the internal floorspace will result in the following breakdown of
floorspace within the units:
Table 3: Proposed floorspace breakdown
Unit 11A Unit 11B
Sofology DFS
Ground Floor 973sqm 983sqm
Mezzanine 743sqm 743sqm
Total (GEA) 1,716sqm 1,726sqm
Combined Total 3,442sqm
(GEA)
3.4 The proposals result in a minor increase of floorspace of 372sqm, with the total combined
floorspace within Units 11A/11B increasing from 3,070sqm to 3,442sqm GEA.
3.5 The proposed external alterations comprise amendments to the front elevations including
increasing the glazing to mezzanine level, additional glazing on the side elevation of Unit 11A,
removing the dated portico features and canopies, and introducing new signage zones.
3.6 Additionally, the proposals seek to increase the height of the parapet with metal cladding to match
the design of recently refurbished units at the Retail Park. There will be no increase in the height
of the roof.
3.7 Further details of the proposed design and materials to be used are included within the Design
and Access Statement and application drawings prepared by Mountford Pigott.
8The Proposed Occupiers- DFS and Sofology
3.8 Units 11A and 11B are to be occupied by Sofology and DFS respectively. The two prospective
retailers are part of the same parent company, DFS Furniture.
3.9 Furniture shopping tends to be a “comparison” shopping trip. When customers are looking to buy
a big-ticket item, such as furniture, they will generally shop around comparing different products
before making a purchase. For a furniture item like a sofa, this is most likely to be in-store, so
customers can try out the product for comfort, fabric choices, etc. For this reason, whilst online
sales of furniture is growing, the majority of purchases are still made in-store.
3.10 Typically, furniture retailers, particularly those selling a similar range of goods or complimentary
products (such as home furnishings), like to locate close to one another to allow customers to
make linked trips (e.g. to view a range of different products offered by different retailers in a single
visit). The benefits of these type of retailers locating close to one another goes beyond those for
the retailers.
3.11 Given the bulky nature of the products sold, most furniture retailers are located in large format
stores in edge or out-of-centre locations. Locating similar retailers close to each other therefore
reduces the number of trips customers have to take to ‘test-run’ products prior to making a
purchase.
3.12 For DFS and Sofology, which are operated under the same parent company (Sofology as a
subsidiary of the DFS Furniture parent company), this co-location strategy has the additional
benefit of being able to share resources, such a servicing, where possible. Although under the
same parent company, DFS and Sofology generally have different price points and target
markets. As such, although there will be a degree of competition between the two stores, they
will complement each other, offering greater choice and competition within the local market.
3.13 Currently, DFS and Sofology trade either alongside one another or in close proximity in 25
locations and presently there are plans for a further 20-25 dual locations.
94.0 PLANNING POLICY OVERVIEW
4.1 This section sets out a planning policy overview relevant to the consideration of this pre-
application. We consider national policy contained in the National Planning Policy Framework
2019 (NPPF) and the accompanying guidance contained in the Planning Practice Guidance
(PPG).
4.2 At a local level, we consider the statutory development plan to include Stevenage Borough Local
Plan 2011-2031 (May 2019) and the adopted Proposals Map (2019). The Local Plan forms the
part of the Development Plan for Stevenage and replaces the previous District Plan (2004).
National Planning Policy
4.3 The National Planning Policy Framework (NPPF) states that the purpose of the planning system
is to contribute to the achievement of sustainable development - performing economic, social and
environmental roles. The three roles are interdependent and need to be mutually supported.
4.4 Paragraphs 8-11 confirm that at the heart of the NPPF is a presumption in favour of sustainable
development. The planning system should therefore promote sustainable development solutions.
Economic Growth
4.5 Paragraphs 80-82 state that planning policies and decisions should help create the conditions in
which businesses can invest, expand and adapt. Significant weight should be placed on the need
to support economic growth and productivity, taking into account both local business needs and
wider opportunities for development. Planning decisions should also recognise the specific
locational requirement of different sectors.
Town Centres
4.6 Paragraphs 85-90 of the NPPF seek to ensure the vitality of town centres and requires that
planning policy should provide a framework to assess proposals for main town centre uses, such
as retail, which cannot be accommodated in or adjacent to town centres. Paragraph 86 requires
proposals to demonstrate compliance with the sequential test, and paragraph 89 to demonstrate
that the proposals will not have a significantly adverse impact on any designated local centres.
4.7 LPA’s should apply a sequential test to planning applications for main town centre uses that are
not in an existing centre and are not in accordance with an up-to-date Local Plan. That is to say
that main town centre uses should be located in town centres, then in edge of centre locations
and only if suitable sites are not available (or expected to become available within a reasonable
10period) should out of centre sites be considered. Applicants and local planning authorities should
demonstrate flexibility on issues such as format and scale, and the sequential test should be
considered in light of the latest NPPF policy, which confirms that when considering availability, it
is necessary to consider sites which may become available within a reasonable period.
4.8 Details of how this policy should be applied are contained in the NPPF Planning Practice
Guidance 2019 as well as relevant Secretary of State decisions, which are explored in more detail
later in this Statement.
4.9 The application of the sequential test should be proportionate and appropriate for the given
proposal. The following considerations should be taken into account in determining whether a
proposal complies with the sequential test (Paragraph 011 of Planning Practice Guidance):
With due regard to the requirement to demonstrate flexibility, has the suitability of more
central sites to accommodate the proposal been considered? Where the proposal would
be located in an edge of centre or out of centre location, preference should be given to
accessible sites that are well connected to the town centre. It is important to set out any
associated reasoning clearly.
Is there scope for flexibility in the format and/or scale of the proposal? It is not necessary
to demonstrate that a potential town centre or edge of centre site can accommodate
precisely the scale and form of development being proposed, but rather to consider what
contribution more central sites are able to make individually to accommodate the
proposal.
If there are no suitable sequentially preferable locations, the sequential test is passed.
4.10 Paragraph 012 of the PPG guidance further states that the implementation of the sequential test
should reflect the specific characteristics of the development proposals:
Use of the sequential test should recognise that certain main town centre uses have
particular market and locational requirements which mean that they may only be
accommodate in specific locations
4.11 With regards to retail impact, the PPG confirms:
The impact test only [our emphasis] applies to proposals exceeding 2,500 square metres
gross of floorspace unless a different locally appropriate threshold is set by the local
11planning authority. In setting a locally appropriate threshold it will be important to
consider:
the scale of proposals relative to town centres
the existing viability and vitality of town centres
cumulative effects of recent developments
whether local town centres are vulnerable
likely effects of development on any town centre strategy
impact on any other planned investment
As a guiding principle impact should be assessed on a like-for-like [our emphasis] basis
in respect of that particular sector (e.g. it may not be appropriate to compare the impact
of an out of centre DIY store with small scale town-centre stores as they would normally
not compete directly). Retail uses tend to compete with their most comparable
competitive facilities. Conditions may be attached to appropriately control the impact of
a particular use.
Transport
4.12 Transport issues should be considered from the earliest stages of development proposals. In
assessing specific applications for development, it should be ensured that:
Appropriate opportunities to promote sustainable transport modes can be taken
up, given the type of development and its location;
Safe and suitable access to the site can be achieved for all users; and
Any significant impacts from the development on the transport network or on
highway safety can be cost effectively mitigated and acceptable to a degree.
4.13 Paragraph 109 of the NPPF confirms that development should only be prevented or refused on
highway grounds if there would be an unacceptable impact on highway safety, or the residual
cumulative impacts on the road network would be severe.
4.14 All developments that will generate significant amounts of movement should be required to
provide a Travel Plan and the application should be supported by a transport statement or
transport assessment to enable the likely impacts of the proposal to be assessed.
Sustainability
4.15 Paragraph 148 of the NPPF confirms that the planning system should support the transition to a
low carbon future in a changing climate, including encouraging the re-use of existing resources,
such as the conversion of existing buildings.
12Local Planning Policy
4.16 Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and
Compulsory Purchase Act 2004 states that planning applications must be determined in
accordance with the Development Plan unless material considerations indicate otherwise.
4.17 The statutory development plan for Stevenage Borough Council consists of the following:
Stevenage Borough Local Plan 2011-2031 (2019); and
Stevenage Borough Local Plan 2011-2031 Policies Map (2019).
Site Designations
4.18 Figure 1 provides an extract from the Council’s adopted Policies Map (2019).
Figure 1: Extract from Stevenage Borough Local Plan Policies Map (2019)
4.19 As identified from the above policies map the Retail Park is located within a Flood Risk Area.
Aside from this, the Site has no specific allocations. The relevant policies are set out below,
against which the emerging development proposals should be assessed.
Relevant Local Plan Policies
4.20 Policy SP1 relates to Sustainable Development, and the Council’s positive approach to
consider development proposals in favour of sustainable development. This states that the
Council will work proactively with applicants to find solutions that will allow proposals to be
approved where possible. Additionally, the Council will secure development that improves
social, environmental and economic conditions in the area.
134.21 Policy SP4 relates to Stevenage’s Town Centre and retail facilities. The policy states that the
Council will make provision for the type and range of retail facilities that are required to support
Stevenage’s role, following the sequential test and the Borough's retail hierarchy. The Council
seek to maintain the below retail hierarchy:
i. Stevenage Town Centre;
ii. High street, Major Centre;
iii. Poplars, District Centre;
iv. Seven Local Centres; and
v. Seven Neighbourhood Centres.
4.22 Chapter 7 of the Local Plan relates to Stevenage’s Town Centre. Policy TC1 identifies the
extent of the town centre as defined on the Policies map. For the purposes of paragraph 23
of the NPPF, the town centre is defined as follows:
The Town Centre Shopping Area (TCSA);
The Southgate Park, Central Core and Station Gateway MOAs in their
entirety; and
That part of the Northgate MOA south of Fairlands Way and that part of the
Marshgate and Gardens MOA west of St George’s Way.
4.23 Chapter 7 goes on to identify six Major Opportunity Areas within the Stevenage Central Area.
These include Southgate Park, Centre West, Station Gateway, Central Core, Northgate and
Marshgate. Individual policies are included within the Local Plan for each of these Major
Opportunity Areas identifying specific redevelopment requirements for each of the areas.
4.24 Policy TC9 relates to the High Street Shopping Area (HSSA), as defined on the policies map,
which encompasses the Old Town High Street. Policy TC10 goes on to identify the High Street
Primary and Secondary Frontages, setting out the need for development to benefit the overall
vitality and viability of the High Street.
4.25 The Local Plan sets out a number of generic retail policies relating to retail development
proposals. Policy TC11 is of particular relevance and refers to provision of new retail
floorspace. The policy states that new Class A1 retail floorspace provision will be expected to
follow the sequential test and the Borough's retail hierarchy.
4.26 Policy TC13 relates to Retail Impact Assessments. The policy states that proposals for main
town centre uses should be located in the Town Centre, then in edge-of-centre locations and
only if suitable sites are not available will out-of-centre sites be considered. When considering
edge-of-centre and out-of-centre sites, preference will be given to accessible sites that are
well connected (preferably by multi-modal means) to the Town Centre.
4.27 An impact assessment will be required for any proposals in excess of 300sqm for main town
centre uses outside the Town Centre. This should include an assessment of:
14i. The impact of the proposal on existing, committed and planned public
and private investment in centres in the catchment area; and
ii. The impact of the proposal on town centre vitality and viability, including
local consumer choice and trade in the Town Centre and wider area, up
to five years from the time that the application is made. For major
schemes, where the full impact will not be realised in five years, the
impact should also be assessed up to ten years from the time that the
application is made.
4.28 Proposals will be permitted unless they fail the sequential test, or are likely to have a
significant adverse impact on one or both of the above factors.
4.29 Reflecting the Site’s out of centre location and that the proposed development is for a retail
store, this statement will consider the effect of the development against Policy TC11 and
TC13.
Summary of Planning Policy
4.30 In the context of the scale and type of development proposed, it is our opinion that the
proposals should be considered against the following:
Are the proposals for a scale of retail development appropriate? The proposed
development is located within an established retail destination, and relates to the re-
use of existing commercial units, with the minor increase in mezzanine floorspace.
The proposals reflect the specific requirements of the identified operators. The
proposals are therefore of an appropriate scale to its location as an established retail
destination.
Is the proposed development appropriate to the character and appearance of
the site and the surrounding built environment? The proposed development
comprises the refurbishment and upgrade of Units 11A/11B, providing increased
double height glazing along the front elevation as well as the side elevation of Unit
11A. The proposed external alterations will modernise the existing units, and will
reflect the refurbishment of other retail units at the Retail Park. Therefore we
conclude that the proposals are fully compliant in this regard.
Is the proposed development easily accessible, or capable of being made easily
accessible, by a choice of means of transport, including by public transport,
walking and cycling? The application site forms part of an existing retail destination
that is accessible by bus, walking and cycling as well as by private vehicles. The site
benefits from strong cycle path linkages with Stevenage Town Centre, as set out
within the enclosed Transport Statement. Therefore, we conclude that the proposals
are fully compliant in this regard
15 Will the proposals comprise sustainable economic development? The
development will deliver an improvement on the existing building, secure the long
term occupation of the site, maintain and enhance employment opportunities and
generally meet sustainable economic development objectives. Therefore, we
conclude that the proposals are compliant in this regard
Will the proposals have a significant detrimental impact on the vitality and
viability of Stevenage Town Centre? The proposal relates to bulky goods furniture
and sofa retailers which are typically located in large format retail warehouse units in
out of centre locations. There is therefore considered to be limited overlap between
the proposals and the retail offer of Stevenage Town Centre. A consideration of
impacts of the proposed development is set out within Section 5 of this PRS.
Are there any sequentially preferable sites? A sequential assessment has been
undertaken and is set out within Section 5 of this PRS. The assessment has been
undertaken on the basis of the specific occupier-led floorspace and business model
requirements, including the specific need for co-location.
165.0 RETAIL CONSIDERATIONS
5.1 This section of the report sets out the considerations relating to the implementation of the
sequential and retail impact tests in accordance with national and local planning policy.
The Sequential Test
5.2 This section of the PRS assesses the proposed development against the provisions of
Paragraphs 86-87 of the NPPF, namely whether there are sequentially preferable sites that have
the potential of accommodating the floorspace associated with the application.
5.3 Paragraph 86 of the NPPF states that Local Planning Authorities should apply a sequential test
to planning applications for main town centre uses that are not in an existing centre and are not
in accordance with an up-to-date Local Plan. It is important to note that the Units 11A/11B are
currently occupied for town centre uses, and the proposal do not therefore introduce additional
town centre uses.
5.4 The proposed development comprises a town centre use in an out–of-centre location. This
section of the assessment therefore provides an assessment of the sequential test in accordance
with the requirements of paragraph 86 of the NPPF.
5.5 We make the following general observations which set the context for this sequential assessment:
It is intended for Units 11A and 11B to be occupied by Sofology and DFS respectively.
The proposed use of the units as furniture and sofa retailers requires appropriate large
format floorplate, with additional mezzanine floorspace at mezzanine level for the
display of goods. Mezzanine floors are typically used for the display of goods within
room settings and are not as intensively traded as ground floor areas.
Currently, the units are in Class E (d) use. This use is also a Town Centre use that
would be subject to the retail NPPF tests (e.g. sequential test).
The proposed reconfigured units will result in two units extending to a total floorspace
of 1,716sqm within Unit 11A and 1,726sqm within Unit 11B, including the reconfigured
and additional mezzanine floorspace.
The proposed use requires suitable servicing arrangements and an appropriate level
of surface level customer car parking.
17 The application site forms part of an existing retail park, located within an established
retail and leisure destination in Stevenage, serving the wider needs of the local
catchment area; and
The proposals will facilitate the occupation of the units by identified occupiers DFS
and Sofology. DFS who are already trading Unit 18 at Roaring Meg Retail Park, and
it is not therefore a speculative application.
5.6 Furniture retailers, which retail larger household items including sofas, beds and dining room
furniture, typically occupy large out-of-centre warehouse units due to the nature of goods they
sell, the requirement to display goods in a room setting, and requirements for premises that cannot
typically be located within town centres.
5.7 It should be noted that although the proposed units are to be occupied separately by DFS and
Sofology, they are operated under the same parent company, DFS Furniture. The proposals are
progressed on the basis of the two units trading alongside each other, and the commercial benefits
that this will deliver to the parent company. Splitting the two units into separate units in different
locations will not satisfy the operator’s requirement for this co-location. The proposals are
therefore assessed on the basis of the total floorspace within the two units.
5.8 The Planning Practice Guide makes clear that the Government does not seek the arbitrary
subdivision of proposals splitting operations into separate sites beyond the flexibility of a business
model. Therefore, individual retailers should not be required to separate the sale of categories of
products onto separate sites.
5.9 The approach to disaggregation and suitability of sequential sites has been clarified in a number
of Judgements and Secretary of State decisions.
5.10 The Dundee judgement (Tesco Stores Limited v Dundee City Council (Scotland), 21 March 2012),
establishes the key principles of site ‘suitability’ in respect of the sequential test. It is important to
note that whilst the Dundee case was a Scottish case, the Supreme Court’s decision applies in
England as well as Scotland.
5.11 In considering alternative sites as part of the sequential test, Paragraph 20 of the Dundee
judgement states that key considerations in assessing the suitability of a sequential site are:
“...whether an alternative site is suitable for the proposed development, not whether the
proposed development can be altered or reduced so that it can be made to fit an
alternative site”.
5.12 Paragraph 38 of the Dundee judgement goes on to state:
18“Here too the context indicates that the issue of suitability is directed to the developer’s
proposals, not some alternative scheme which might be suggested by the planning
authority. I do not think that this is in the least surprising, as developments of this kind are
generated by the developer’s assessment of the market that he seeks to serve. If they do
not meet the sequential approach criteria, bearing in mind the need for flexibility and
realism to which Lord Reed refers in para 28, above, they will be rejected. But these
criteria are designed for use in the real world in which developers wish to operate,
not some artificial world in which they have no interest doing so”. (our emphasis)
5.13 The findings of the inspector in the consideration of the Rushden Lakes Inquiry (Ref.
APP/G2815/V/12/2190175) and proposals for a Next store in Sheffield (Ref.
APP/J/4423/A/13/2189893), are also pertinent to the considerations in this instance, in
considering disaggregation, the Inspector at the Rushden Lakes Inquiry stated at paragraph 2.68:
“There is no longer any such requirement stated in the NPPF. Had the Government
intended to retain disaggregation as a requirement it would and should have
explicitly stated this in the NPPF. It is too large a point to rest on implication. If it has
been intended to carry on with the requirement then all that would have been required is
the addition of the word “disaggregation” at end of NPPF [24]”. (our emphasis)
5.14 In considering the proposals for a Next store in Sheffield, the Inspector stated at paragraph 35:
“What needs to be established is whether an alternative site is suitable for the
development proposed, not whether the proposed development can be altered or
reduced so that it can be made to fit an alternative site”. (our emphasis)
5.15 These findings are reinforced by the findings of Scunthorpe judgement (Zurich Assurance Limited
V North Lincolnshire Council) focusing the considerations of the sequential test on the real world,
with corresponding commercial realities to be given due consideration:
“It is important to mark that developers, and planning authorities work in the real world”
(our emphasis)
5.16 The implementation of the sequential test was further considered by the Secretary of State for a
retail proposal in Tollgate (APP/A1530/W/16/3147039). Paragraph 12.3.20 states:
“The sequential test therefore means that whilst a sequentially preferable site need not
be capable of accommodating exactly the same as what is proposed, it must be capable
of accommodating development which is closely similar to what is proposed.”
195.17 It is therefore clear that there is no requirement to disaggregate proposals into its smaller
constituent parts when implementing the sequential test, and when considering sequential sites,
these need to be able to be suitable for the development proposed as a whole, and not an
alternative hypothetical smaller version of the proposal.
5.18 The proposed development is based on a clear understanding of the form and size that is required
for DFS and Sofology's established business model.
5.19 Any compromises to the retailer’s business model would result in the occupier not being able to
fully implement its established retail model, and would result in the retailer not proceeding with the
site.
5.20 In considering the sequential test in relation to the development proposals, we would set out the
following relevant considerations.
Format: The scale of the development has been driven by the size of the existing unit
and the requirements of both retailers for a large floorplate with appropriate mezzanine
floorspace for the display and sale of the occupiers’ full product range. Should the
proposed floorspace at the Site be any smaller, it would be unable to accommodate both
DFS and Sofology business models, and would therefore have an unacceptable
commercial impact on the viability of the stores to operate;
Parking/Servicing: The proposed use requires appropriate and easily accessible
customer car parking ; and
Location: It is key to the business model of the retailer that the proposed stores should
be located where it is accessible to its customer base. Given the nature of the products
sold by DFS and Sofology, the store must be served by a range of transport modes,
including the private car. It is also important for it to be located close to stores selling
similar ranges of goods.
5.21 Units 11A and 11B, to be occupied by Sofology and DFS respectively, will extend to a total of
3,442sqm GEA floorspace (1,716sqm and 1,726sqm).
5.22 To demonstrate flexibility for the purposes of undertaking the sequential test, we have searched
for units of between 3,098sqm and 3,786sqm floorspace. This demonstrates a flexible
interpretation of the sequential test, with sites 10% smaller and larger than the application site
considered as part of the assessment.
5.23 Given that the proposals relate to existing retail units, and the operator’s immediate requirement
20to relocate into Units 11A/11B, for a site to be considered genuinely available, it needs to be
currently vacant, or be available in the immediate short term. Sites which require redevelopment
to facilitate occupation cannot be considered genuinely available in the context of the application
proposals.
Stevenage Town Centre – Existing Opportunities
5.24 Stevenage Town Centre is located approximately 1km to the north of the application Site and is
the dominant retail centre within the Borough. Located directly north of the Town Centre is
Stevenage Old Town, also known as the High Street Shopping Area (HSSA).
5.25 Stevenage Town Centre and Stevenage Old Town therefore represent the appropriate focus for
the sequential test given their role and function within the local retail hierarchy, and is consistent
with the recently approved proposals at Monkswood Retail Park.
5.26 Given the current Government guidance on the closure of non-essential retail in addition to travel
restrictions, for the purposes of this sequential test, a desktop survey has been undertaken. This
takes into consideration the findings and the fieldwork undertaken in support of planning
application 20/00111/S106 at Monkswood Retail Park.
5.27 The desktop survey identified a total of 21 vacant units within Stevenage Town Centre and 5
vacant units within Stevenage Old Town. The vast majority of these were very small with only 4
vacant units larger than 1,000sqm. The table below identifies the largest vacant sites within the
Town Centre and Old Town, as well as other sequential sites assessed below. An overview of the
relevant sequential sites is set out below.
5.28 Whilst a number of vacant sites of below 300sqm were identified within Stevenage Town Centre,
these have not been included below, given the quantum of floorspace to which the application
relates. A plan identifying sites 1-7 is enclosed at Appendix 3 & Appendix 4.
Table 4: Summary of Sequential Survey
Site Address Floorspace
1 Former BHS Store, 7 The Forum, 2,340sqm
2 Former Office Outlet, Unit 11, 1,625sqm (ground floor).
Fairlands Way Amenity block mezzanine
of 37sqm,
3 Former Waitrose Store, 74 High 1,370sqm (two units with
Street – Now split into 2 units floorspace of 758sqm
and 612sqm)
214 Park Place, Stevenage, SG1 1DP 1,950sqm (two units of
975sqm)
5 85 - 103 Queensway, Stevenage, Floor space ranging from
SG1 1EA 113sqm – 789 sqm
6 SG1 Development Site Up to 151sqm
7 Matalan Retail Park, Danesgate Up to 454sqm
8 Major Opportunity Areas N/A
9 Local / Neighbourhood Centres N/A
1. Former BHS Store – Unit 7, The Forum Shopping Centre
5.29 The unit extends to 2,340sqm across the ground floor (the unit extends across the ground floor
only), and was previously occupied by BHS. The store closed on 20th August 2016 and has
remained vacant since that time. The store is currently subject of a planning application for its
redevelopment for predominantly residential uses (application ref. 19/00647), with a ground floor
retail unit.
5.30 The retail element within the proposed application, at circa 520sqm is significantly below the
identified minimum floorspace threshold of 3,098sqm and would not therefore be able to
accommodate the development proposals.
225.31 The site does not provide immediately adjoining customer car parking, and does not therefore
reflect the fundamental business model requirements of the prospective tenants of Units 11A and
11B.
5.32 It is therefore concluded that the unit is not a suitable or genuinely available site for the proposed
development, and the vacant unit is dismissed as a sequentially preferable site.
2. Former Office Outlet - Unit 11, Fairlands Way
5.33 Unit 11, Fairlands Way extends to 1,625sqm at ground floor, and a small amenity mezzanine block
of circa 37sqm, and was previously occupied by Office Outlet. The store closed in 2019.
5.34 The minimum flexible floorspace threshold of the proposed development is of 3,098sqm, which is
significantly greater than the existing floorspace within the former Office Outlet.
5.35 Whilst the unit could be split into two separate units of circa 812sqm at ground floor, this would be
circa 15% smaller than the ground floor of Units 11A/11B. Mezzanine cover of over 90% would
be needed within each unit to reach the identified minimum floorspace threshold of 3,098sqm
within each unit. Whilst a small staff amenity mezzanine floor exists within the unit, it is not clear
whether the unit (internal height clearance, building frame etc) is able to facilitate the necessary
mezzanine floorspace identified. It is important to note that even with 100% full mezzanine cover
(i.e. providing circa a total of 3,250sqm within the unit), this does not provide the quantum of
floorspace that is subject of the proposals (3,442sqm).
235.36 Notwithstanding the above, the site provides limited and constrained car parking spaces located
around the perimeter as well as the rear of the site, with relatively limited car parking provided at
the front of the unit. The unit does not therefore provide convenient customer parking. This is one
of a number of factors which has contributed to the unit remaining vacant since the closure of the
Office Outlet unit in January 2019.
5.37 The site is located in a stand-alone and isolated position in retail terms, with no other comparison
goods retailers in immediate proximity of the site. The location does not provide a sufficient critical
mass of retail floorspace to attract sufficient numbers of potential shoppers to this isolated location
to be commercially viable to the operators. The proposals subject of the application relate to an
established retail park location, where existing occupiers benefit from having a range of retailers,
attracting an appropriate customer base.
5.38 The former Office Outlet store is therefore dismissed as a sequentially preferable site on the basis
of suitability from a site selection perspective and viability relating to the commercial implications
of the prospective tenants trading from a compromised bulky goods retail location.
3. Former Waitrose, 74 & 74A High Street, Stevenage Old Town
5.39 74 & 74A High Street previously extended to a total of 1,370sqm, split between circa 612sqm and
758sqm, was formerly occupied by Waitrose. The store closed on 27th October 2019 and has
24remained vacant since. The two units are in two separate ownerships and the marketing
particulars confirm that the units are being let separately, with both units previously under offer,
and no longer being marketed.
5.40 The development proposals relate to a proposed combined floorspace of 3,442sqm. The former
Waitrose Unit, at a combined floorspace of 1,370sqm is significantly small than the floorspace
threshold of the proposed development, and can be dismissed on the basis of suitability.
5.41 The former Waitrose store is therefore not considered available as the two units are under offer
or suitable for the proposed development and is dismissed as a sequentially preferable site on
this basis.
4. Park Place, Stevenage, SG1 1DP
5.42 The retail space at Park Place (planning permission ref. 16/00511/FPM) is divided into two retail
blocks of 975sqm each, totalling a combined floorspace of 1,950sqm across the ground floor, with
no opportunity to provide mezzanine floorspace.
5.43 The retail units within Park Place fall significantly below the identified minimum floorspace
threshold, and the site is therefore dismissed on the basis of suitability.
5. 85 - 103 Queensway, Stevenage, SG1 1EA
5.44 The proposed commercial and retail units 85-103 Queensway associated with planning
permission 18/00268/FPM are proposed to be sub-divided into 10 retail units (ranging from Use
Class A1-A4) and a gym (Use Class D2) of circa 3,600sqm floorspace.
5.45 These units range in floorspace from 113sqm – 790sqm, and are therefore materially smaller than
the identified minimum floorspace threshold of the proposed development of 3,098sqm and can
be dismissed as not sequentially preferable site on the basis of suitability and viability.
5.46 Whilst it may be possible to amalgamate the units to satisfy the minimum floorspace threshold of
3,098sqm, this would in effect require the amalgamation of all 10 units, as it is not possible to
install mezzanine floors within these units. This would clearly be contrary to the aspirations for
the Queensway site, seeking to provide a range of mixed retail, commercial and leisure uses
within a range of differently sized units.
5.47 The site cannot therefore be considered as genuinely suitable in the context of the proposals for
bulky goods retail floorspace.
256. SG1 Development Site, Town Centre Stevenage
5.48 Planning committee resolved to approve an application (ref. 19/00743/FPM) for the
comprehensive mixed use SG1 development in October 2020. The detailed elements of the
hybrid planning application include the Phase 1 planning application for Plots A and K.
5.49 Within these two plots 760 residential units and 151sqm of retail/ restaurant (Class A1/A2/A3)
floorspace is proposed. The quantum of retail / leisure floorspace within the development is too
small to accommodate the proposed development.
5.50 The provision of a large format furniture store would not be consistent with the aspirations for the
redevelopment of the site to deliver a high quality mixed use residential led scheme, and the site
is not therefore considered suitable or available on this basis.
7. Matalan Site, Danestrete
5.51 The site is located on the corner of Danestrete and Danesgate, to the south of identified primary
shopping area. On 19 October 2017 an application for outline permission (ref. 14/00559/OPM)
was granted for the demolition of existing buildings and redevelopment of the site for up to 526
residential apartments and commercial units Class A1 (retail) A2 (professional and financial) A3
(restaurant) and A4 (drinking establishments) and A5 (hot food take away) uses.
5.52 A Reserved Matters application (20/00643/RMM) was submitted to the Council in November 2020
and is currently under consideration. The proposals include for 526 residential units and ancillary
commercial and community floorspace. The plans show two separate commercial / retail units of
454sqm and 311sqm, and two additional smaller commercial / community units of 210sqm and
137sqm on the ground floor. The proposed retail units within the residential led development are
therefore too small to accommodate the development proposals.
5.53 The site is allocated in the Local Plan within Southgate Park Major Opportunity Area Policy TC2.
The policy states that planning permission will be granted for “high density Use Class C3
residential units, new multi-storey or basement car parking, new Use Class D1 civic hub, a linear
park running east-west parallel to Six Hills Way and a new primary school on the Eastgate car
park.”
5.54 The proposal for a large format furniture and sofa retail units would therefore be contrary to the
site's allocation included within Policy TC2 for mixed use development.
5.55 The site is therefore dismissed as unavailable and unsuitable.
268. Major Opportunity Areas (MOAs)
5.56 Six MOAs are identified within the Stevenage Central Area, and policies TC3, TC4, TC5, TC6
and TC7 make reference to the provision of new Use Class A1 (now Class E (a) retail uses. Each
MOA is assessed in further detail below. A map identifying the opportunity areas is enclosed as
Appendix 5.
5.57 Policy TC3 (Centre West MOA) seeks to include the provision of a new 'de minimus (by volume)
Use Class A1 shop units', which specifically relates to serving the day-to-day convenience retail
needs of the residents of Centre West. On this basis the Centre West MOA cannot be considered
a suitable sequentially preferable site.
5.58 Policy TC4 (Station Gateway MOA) includes the provision of new Use Class A1 and A3 restaurant
and café uses. The policy sets out the aspirations to significantly regenerate and redevelop the
area to act as a quality landmark gateway environment for all rail visitors. Although the policy
includes the provision of new Use Class A1 uses, the focus of the MOA is to facilitate the
extension and regeneration of the train station, with complementary commercial and leisure use.
The proposed large format bulky goods retail uses cannot be considered an appropriate element
of the redevelopment of the site, and therefore dismissed on this basis.
5.59 Policy TC5 (Central Core MOA) includes for new Use Class A1, A3, and A4 shop, bar, restaurant
and café uses. Specifically, the policy sets out the provision of a southern extension to the
Westgate Centre, containing in the order of 4,700m2 additional comparison floorspace, facing
onto an enlarged Town Square. The proposals for large format bulky goods floorspace would not
be consistent with the aspirations of the policy to improve the retail offer within the Town Centre.
The application proposals relate to total bulky retail floorspace of 3,442sqm, representing nearly
75% of the additional comparison floorspace within this MOA. The Central Core MOA is not
therefore considered an appropriate sequentially preferable site, and can be dismissed
accordingly.
5.60 Policy TC6 (Northgate MOA) includes the provision of new Use Class A1, A3 and A4 uses. The
supporting text of Policy TC6 refers to the Tesco Extra Store being dated in terms of external
appearance and does not meet the operator’s current format expectations. The MOA therefore
includes for the provision of a replacement foodstore. The initial ‘in principle’ discussions with
Tesco, as set out within the supporting text of the Policy TC6, suggest that this site is unlikely to
come forward until the end of the plan period, transitioning into the post 2031 period. The site is
therefore dismissed as a sequentially preferable site on the basis of availability, and the intention
to provide a foodstore rather than bulky goods comparison goods on the site.
275.61 Policy TC7 (Marshgate MOA) states planning provision will be granted for new high density
residential units, new Use Class D1 and D2 leisure uses, new Use Class A1, A3 and A4 shop,
bar, restaurant and cafe uses, in addition to a new multi-storey / basement car park.
5.62 There are currently no timescales associated with the redevelopment of this MOA. Given that the
proposals relate to an immediate commercial requirement, the site cannot be considered
genuinely available within a reasonable timeframe in this instance.
9. Stevenage 2007 Town Centre Regeneration Development
5.63 On 22 November 2007 an application for outline permission (ref. 07/00810/OP) was submitted to
the Council for a comprehensive redevelopment for a mix of uses to include the full range of retail
uses (Class A1, A2, A3, A4 and A5), housing (Class C3), hotel (Class C1), leisure (Class D2),
offices (Class B1), voluntary services (Class D1), magistrates court, replacement bus station,
together with ancillary and associated developments, pedestrian and cycle circulation and open
space, car parking, vehicular access, servicing facilities, highway works, plant and machinery,
landscaping and enabling works, the demolition of existing buildings and structures, the closure
and alteration of highways and cycleways and the internal and external alteration and change of
use of buildings to be retained, engineering works and construction of new buildings and
structures.
5.64 Planning Committee resolved to grant permission in January 2012, subject to the applicant
entering into and completing the S106 Agreement. However, as far as we understand, the
development partnership is not progressing with the development. The approved scheme cannot
therefore be considered genuinely available for the purposes of this sequential assessment.
10. Local and Neighbourhood Centres
5.65 Policy HC1 of the Local Plan relates to district, local and neighbourhood centres and confirms the
borough's 7 Neighbourhood Centres, 7 Local Centres and 1 District Centre as shown on the
Council’s policies map.
5.66 Policy SP4 relates to town centres and the Borough's retail hierarchy and allocates 500sqm of
convenience floorspace within two Local Centres in the north and west of Stevenage respectively,
and 500sqm of convenience floorspace within the Neighbourhood Centre in the south-east of
Stevenage.
5.67 The proposals comprise bulky goods furniture and sofa retailers extending to a total of 3,442sqm
GEA existing floorspace, and would not therefore satisfy the aspirations for local convenience
provision to serve the localised catchments of the local and neighbourhood centres.
285.68 Given the scale and nature of the proposals for large format bulky goods floorspace, it is not
considered appropriate to consider local and neighbourhood centres, which focus on top-up
shopping provision serving the immediate areas within which the centres are located.
Summary of Sequential Test
5.69 In this section we have considered whether there are any available sites in Stevenage Town
Centre which are suitable for the development proposals. The assessment has concluded that
there are no suitable, available or viable sequentially preferable sites which can accommodate
the development proposals.
5.70 In the absence of any suitable town centre sites, the application site is considered to be an
appropriate location for the use proposed by this application. As such, we conclude that the
sequential test has been passed.
Town Centre Impact Considerations
5.71 In this section we consider the acceptability of the proposed development against other relevant
national and local planning policy, including town centre / retail impact sustainable development,
and transport.
5.72 Policy TC13 of the Local Plan requires an assessment of impacts to be undertaken where a
proposal for a town centre use over 300sqm is proposed outside of the designated Town Centre.
It is important to note from the outset that the proposed development relates to existing units in a
town centre use (i.e. former Class D2 now Class E (d)) within an established retail destination.
The principle of retail use has therefore been accepted within this location.
5.73 At a principle level, the proposed development will have limited town centre impact implications
given the bulky nature of the goods sold and the proposed tenants. The proposals will facilitate
the relocation of DFS from their existing accommodation at Unit 18, and also allow for its sister
company, Sofology, to trade alongside in the adjoining unit. The proposals will therefore maintain
an existing tenant on the retail park, and introduce a new fascia, focusing on the sales of bulky
comparison goods.
5.74 Given the particular circumstances of the proposal, the following observations are made:
o The implementation of the impact test will be undertaken on the accepted
principle of like affects like, where the proposal would have the largest impact on
similar type of retail provision, in accordance with paragraph 15 of the PPG
(Reference ID: 2b-015/20190722).
29o In this instance, given that the proposals comprise a relocation of DFS and the
introduction of only Sofology as a new fascia, this would result in the majority of
the impact from the development experienced by other large format furniture and
sofa stores, including retailers currently trading at the retail park, including ScS,
Furniture Village and Furniture Outlet, as well as the Dunelm store located to the
south of the Retail Park.
o Sales densities for the prospective tenant will be derived from Mintel Retail
Rankings, an accepted industry source, where available.
o The assessment will set out the anticipated impacts of the proposals on any
relevant centres. In this instance, the proposals will focus on Stevenage Town
Centre as the relevant designated retail centre.
5.75 In order to understand the potential impact of the proposed development, it is necessary to
identify the likely turnover that the proposal will generate. Limited trading information is provided
for furniture and sofa retailers within the Mintel Retail Rankings 2020 Report. No sales densities
are provided for DFS, whilst a sales density figure of £2,480/sqm is identified for Sofology in
2017/2018. This is broadly consistent with other comparable retailers, such as ScS (£2,475/sqm),
Sofa Workshop (£3,781/sqm) and Harveys/Steinhoff (£1,894/sqm) for the same time period.
5.76 To provide a robust assessment, we have therefore assumed the 2017/18 sales density of
£2,480/sqm for Sofology, and an average sales density based of the above furniture retailers (i.e.
Sofa Workshop, ScS and Harveys/Steinhoff) of £2,717/sqm at 2017/28 for the DFS unit.
5.77 We have adopted a density growth rate of 3.6% in both 2019 and 2.6% 2020, as set out within
Table 3b of the Experian Retail Briefing Note 17 (February 2020) with the corresponding average
sales subsequently increasing to £2,636/sqm for Unit 11A (Sofology) and £2,888/sqm for Unit
11B (DFS) at 2021.
5.78 It is a generally accepted position that the sales densities of mezzanine floors trade significantly
below the company average, as the mezzanine floor areas are typically used for the display of
items in larger room settings, and do not therefore trade as intensively as ground floor floorspace.
We have therefore assumed that the sales density of mezzanine floorspace will be approximately
50% of the average sales density adopted for the ground floor sales area.
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