Planning for Retail

TOWN CENTRE USES IN OUT/EDGE OF CENTRE LOCATIONS

Sequential Approach Guidance

Background

The National Planning Policy Framework (NPPF) requires applications for main town centre uses [1] in edge of centre or out of centre locations to be supported by a sequential test, to ensure that there are no sequentially preferable sites available that would better support the vitality and viability of Town Centres.

Experience at the City Council shows that applicants take a variety of approaches to addressing the sequential test, and this can result in delays to decisions, as the City Council often has to request further information to ensure the sequential test is comprehensive and sufficiently robust.

The City Council has therefore prepared this advice, which seeks to ensure that applicants provide sufficient information to allow speedy decision-making on planning applications for Main Town Centre Uses, and to minimise the need to request further information before an application can be determined.

Catchment/search area

The applicant should agree the most appropriate catchment/search area with the City Council, for instance a 5 or 10-minute drive time from the proposal. The area of search will vary depending on the nature and scale of development, a specialist leisure use may have a relatively wide catchment area, whilst a discount food store’s catchment will be more influenced by the pattern of existing alternative food store provision.

The applicants should include a plan showing the catchment/area of search within their Retail Planning Statement and the methodology for calculating drive time. For ‘out of centre’ sites, it may be necessary for applicants to consider alternative sites in both ‘in centre’ and ‘out of centre’ locations (if no ‘in centre’ locations are available, there may be other ‘out of centre’ locations  which are sequentially preferable to the proposed site).

Alternative sites

The applicant should list all the available premises/sites within the area of search. This should include any Land & Planning Policy (Local Plan part 2) site allocations, where the development proposed is in accordance with the uses set out in the Local Plan for the site allocations. Where proposals seek provision for multiple operators, disaggregation should be considered by an assessment of  potential sites or combination of sites that are smaller than the current application, based on the application of reasonable flexibility to the proposed uses and floorspace.

Use of web-based sources such as Zoopla and Rightmove can be a good starting point, but site visits may well be necessary to ensure all options are included. Applicants should also confirm the date of the search/site survey. The submission should provide all supporting evidence to corroborate the  conclusions on the availability/suitability of premises identified within the site search.

Assessment of alternative sites

The Retail Planning Statement should provide justification for each of the identified vacant premises/sites, and provide justification for each as to why it is not suitable or sequentially preferable.

Impact Assessment Requirement

Planning applications for retail and other main town centre uses which are not in an existing centre and not in accordance with an up-to-date development plan should be accompanied by an impact assessment if the development is over 1,000 square metres gross floorspace. This should include assessment of:

The impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and
The impact of the proposal on town centre vitality and viability, including local consumer choice and trade in the town centre and the wider retail catchment (as applicable to the scale and nature of the scheme

[1] Main town centre uses: 

1.According to Annex 2: Glossary of the NPPF, "main town centre uses" include

• Retail development (including warehouse clubs and factory outlet centres)
• Leisure, entertainment and more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, nightclubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls)
• Offices
• Arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities