S/2008/0164 : Netherton Activity Centre, Glovers Lane ... · SALFORD QUAYS MANCHESTER M50 3XP Lancashire County Council May 2008 White Young Green Planning Regatta House Clippers

PLANNING COMMITTEE : 7 MAY 2008

Late Representations/Information

Part 1 APPENDIX 4 Petitioned Item Item 4A S/2008/0164 : Netherton Activity Centre, Glovers Lane, Netherton Additional objection from 16 Harrops Croft on grounds of parking provision for residents; noise; no need for the facility. In view of the requirements of Sport England for the Orrell Lane development, it will be necessary for the mini-pitches to be provided in advance of the finalisation of the NAC scheme. Conditions need to be worded to permit this. Conditions 2, 3, 4, 5, 6, 7, 8 insert : “except the provision of the mini football pitches”. Add Condition

17. Conditions 2, 3, 4, 5, 6, 7 and 8 shall not apply in respect of the provision of the mini-football pitches.

Reason 17. To allow early provision of these pitches to provide

compensatory provision for loss of Greenspace in Orrell Lane in accordance with UDP Policy G1.

APPENDIX 5 Item 5A N/2008/0089 – 5-23 King Street, Southport Add Note: Development shall not be commenced until an Outline Travel Plan has been submitted to and approved in writing by the local planning authority. The provisions of the Travel Plan shall be implemented and operated in accordance with the timetable contained therein and shall not be varied other than through agreement with the local planning authority. Please see attached further information:

APPENDIX 5 Approvals Item 5C N/2008/0251 – 7 Somerset Drive, Ainsdale, Southport Please see attached documents from Mr & Mrs Caven – 5 Somerset Drive, Ainsdale

Item 5F S/2008/0270 : Pennington Road Footbridge, Pennington Road, Litherland Technical Services – Highways : Please add the following comments:- The bridge forms part of the adopted highway. The proposal will take additional land and it is this part which will need to be dedicated for formal adoption in due course, pursuant to Section 37/38 of the Highway Act 1980. The proposed site plan illustrates that the development is DDA compliant. During construction of the new footbridge a Temporary Closure Order will need to be implemented. In view of the above there are no objections to this application as it will provide essential links to Linacre Road and Hawthorne Road.

APPENDIX 12 Kirkby Town Centre – Neighbouring Authority Consultation on Planning Application for Major Development Copy Appraisal of Retail Application attached.

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Appraisal of Retail Application Proposed Mixed Use Development on Land South of Cherryfield Drive,

Kirkby

Report Prepared For Sefton Council, St Helens Council, West Lancashire District Council and

Lancashire County Council

Telephone: (0161) 872 3223 Facsimile: (0161) 872 3193

Project No: A042092 Date:

2nd May 2008

Prepared By:

Adrian Fox – Principal Planner

Approved By:

Keith Nutter - Director

Planning Committee - 7 - Late Reps 1 *

1 INTRODUCTION

Scope and Purpose

1.01 This report has been prepared at the joint request of Sefton Council, West Lancashire

District Council, Lancashire County Council and St Helens Council to review the

application submitted by DPP on behalf of Tesco Stores Limited in respect of the

proposed mixed use development at Kirkby.

1.02 This report provides an assessment of the Retail Assessment (November 2007) together

with an assessment of the Addendum to the Retail Assessment (April 2007) both

prepared by DPP in support of the application. Set out below is a detailed review of the

methodology and key assumptions adopted in DDP’s Retail Assessments as well as an

overview of the conformity of the proposal with national, regional and local planning

policy.

The Proposed Development and its Location 1.03 The application site extends to 54.58 hectares.

1.04 DPP highlights that the ‘key development’ is the new stadium for Everton Football Club,

which will be sited in the western third of the application site south of Cherryfield Drive.

The remainder of the proposal comprises retail and leisure uses that are identified by

DPP to be necessary to ‘enable’ the stadium.

1.05 The current application includes, inter alia, the following elements:

• New stadium (50,000-seater) for Everton Football Club;

• New foodstore and related atrium and mall (22,070 sq m gross), of which 14,970

sq m is the foodstore (10,219 sq m net), 1,655 sq m is non-food retail

floorspace, 1,655 sq m is non-food service use floorspace in the mall and 3,790

sq m ancillary facilities;

• New comparison retailing north east of the stadium: 13 units, comprising 19,697

sq m (gross) of floorspace – 8,382 sq m (net) at ground floor and 9,251 sq m

(net) at mezzanine/first floor level;

• Further comparison retailing further north east of stadium, comprising 11 units


and some 16,901 sq m (gross) of floorspace. Net floorspace at ground floor

(7,243 sq m) and 7,243 sq m (net) at mezzanine/first floor; and

• New comparison retailing east of the stadium, comprising five units and 9,594 sq

m (gross) of floorspace. Net floorspace at ground floor 4,112 sq m and some

4,112 sq m (net) at mezzanine/first floor level.

1.06 In addition, within the existing town centre, the proposal comprises the following:

• New food and drink units (3,629 sq m gross);

• 29 new retail units (17,072 sq m gross/14,632 sq m net);

• Leisure unit (3,573 sq m gross); and

• Retail, leisure and hotel units comprising 8,626 sq m (gross) with the main

retail/leisure unit comprising 3,780 sq m (net).

1.07 DPP identifies that much of the proposed development will involve the demolition of a

number of existing buildings. In this respect, the applicant identifies that approximately

13,580 sq m (gross) of existing retail, leisure and other town centres uses in the existing

town centre would be demolished to make way for the new units.

1.08 On this basis, DPP identifies that the proposed net retail floorspace will comprise 40,854

sq m of floorspace south of Cherryfield Drive including Tesco store (10,219 sq m net)

with uplift in retail floorspace (following demolition of existing floorspace) being 9,015 sq

m (net). Of this new additional floorspace, some 5,142 sq m (net) is identified to be for

the sale of convenience goods with 54,946 sq m (net) for the sale of comparison goods.

This equates to some 60,088 sq m (net) of new retail floorspace.

1.09 Whilst it is acknowledged that the level of floorspace now proposed is a reduction on that

submitted with the application in November 2007, the level of floorspace has been

reduced by only 3,088 sq m (net). The level of comparison goods floorspace now

proposed has reduced (from 58,408 sq m to 54,946 sq m) whereas the level of

convenience goods floorspace proposed has increased (from 4,767 sq m to 5,142 sq m).

Although the proposed store is identified to remain the same scale, the revised proposal

allows for an additional convenience goods unit (375 sq m net convenience floorspace)

north of Cherryfield Drive.

1.10 The current application seeks to create a significant increase in retail floorspace in Kirkby

and the level of retail floorspace identified as being advanced in the Kirkby Retail


Evidence Base Report, undertaken by DTZ. Indeed, this report identified that the

additional retail floorspace will be only 47,000 sq m (gross) inclusive of the new Tesco

store comprising 15,000 sq m (gross) of floorspace. This compares to the current

application proposing some 72,221 sq m (gross) of additional retail floorspace.

Potential Turnover of the Proposal Proposed Foodstore

1.11 It is intended that the proposed foodstore will be occupied by Tesco and will comprise a

net sales area of 10,219 sq m (inclusive of checkouts). Of this net floorspace, 4,767 sq

m (net) will be used for the sale of convenience goods, with some 5,452 sq m (net) being

used for the sale of comparison goods. Accordingly, it is evident that the majority of the

sales area proposed (53%) will be for the sale of comparison goods.

1.12 On this basis, DPP identifies a potential turnover of the proposed Tesco store of

£116.46m by 2012 (at 2003 prices). This turnover is identified to comprise a

convenience goods turnover of £62.23m and a comparison goods turnover of £54.23m.

WYG considers this turnover is a reasonable assumption to adopt.

1.13 In addition, the amended scheme also makes allowance for a small convenience outlet to

the north of Cherryfield Drive (375 sq m). Based on this unit being occupied by one of

the leading four retailers DPP identifies that the convenience goods turnover could be in

the region of £4m. Notwithstanding this, DPP highlights that as the location of this unit is

within the defined Kirkby Town Centre there is no requirement (in accordance with

PPS6) to demonstrate need for this additional floorspace.

Proposed Additional Comparison Goods Floorspace

1.14 With regard to the additional comparison goods floorspace proposed (including the new

floorspace created as part of the redevelopment of the existing Kirkby Town Centre)

DPP identifies a potential turnover of £252.21m (including comparison goods in Tesco)

by 2012. This turnover is based on applying an average sales density of £4,000 per sq

m (at 2003) prices to the net increase in floorspace. Although the end-operators of the

new floorspace created are not known, given that the application seeks to create

modern retail floorspace, located just off the M57 Motorway, it is likely that the new retail

floorspace will be attractive to a broad range of retailers, many of which have higher

sales densities than the £4,000 per sq m identified by DPP. Given this, the potential

turnover identified by DPP should be treated with a ‘note of caution’ as it could be


considered an underestimate.

Relevant National Planning Policy

1.15 Planning Policy Statement 6 (PPS6) ‘Planning for Town Centres’ was published in March

2005 and sets out the Government’s key objectives for town centres.

1.16 PPS6 (paragraph 3.1) indicates that advice contained in the policy statement is applicable

for all proposals relating to main town centre uses. In accordance with national planning

advice, it is necessary for all applications for a main town centre use (e.g. retail, leisure,

etc) that would be in an edge-of-centre or out-of-centre location to demonstrate:

• The need for the development (‘Need’).

• That the development is of an appropriate scale (‘Appropriateness of Scale’).

• That there are no more central sites for development (‘Sequential Approach’).

• That there are no unacceptable impacts on existing centres (‘Impact’).

• That locations are accessible (‘Accessibility’).

1.17 Accordingly, the remainder of this assessment considers the conformity of the current

proposal against these relevant tests.


2 NEED AND APPROPRIATENESS OF SCALE

Quantitative Need (‘Retail Capacity’)

Study Period

2.01 In seeking to demonstrate a quantitative need for additional retail floorspace proposed,

DPP has adopted a base year of 2007 and a ‘design year’ of 2012. This approach

accords with guidance in PPS6, which states that need for additional floorspace should

normally be assessed no more than five years ahead.

Primary Catchment Area

2.02 In seeking to identify the Primary Catchment Area (PCA) of the proposed development,

DPP have undertaken a household survey within a wider Study Area (broken down into

11 zones), which covered an extensive area including Liverpool to the west, Haydock to

the East and Southport and Burscough to the north.

2.03 It is important to note that the results of the survey are not included in the supporting

evidence. Neither are the assumptions from which DPP have developed their primary

and secondary catchments. Therefore, it is difficult to examine the true validity of the

approach taken. DPP identifies that the PCA for the proposal would be focused mainly

on zones 1, 2 and 4 of the defined Study Area. DPP also considers that some trade is

anticipated to be derived from the area north of Zone 6 and beyond towards Southport/

Ormskirk/ Skelmersdale. The same PCA is identified for both the Tesco store and the

comparison goods floorspace proposed. The PCA is identified to contain the centres of

Kirkby, Prescot and Huyton and have a population of 224,737 people in 2007, falling to

222,972 people by 2012. The majority of this population (67%) is identified to fall within

Zone 4 (‘Huyton’).

Available Expenditure

2.04 DPP has utilised MapInfo TargetPro Report Data on local consumer expenditure

generated in the PCA. Whilst this is accepted as a robust source of data, WYG

questions why more up-to-date population and expenditure data has not been utilised

rather than basing the assessment on out-of-date MapInfo data from October 2006.

2.05 In addition, with regard to expenditure projections through to 2012, it is notable that prior

to the completion of the applicant’s Retail Assessment, an updated MapInfo Brief

(07/02), which supersedes information contained in earlier Briefs (including the one


utilised by DPP – 06/02) has been published. Again, WYG questions why more up-to-

date expenditure data has not been utilised by DPP.

2.06 Despite our concerns with the appropriateness of the population and expenditure data

utilised by DPP, the PCA is identified by DPP to generate some £317m of convenience

goods expenditure in 2007, increasing to £329m by 2012. With regard to comparison

goods, the resident population generates some £566m of expenditure in 2007, rising to

£720m by 2012.

Turnover of Existing and Committed Floorspace

2.07 In seeking to identify capacity for additional convenience and comparison goods

floorspace within Kirkby, DPP has assessed the turnover of existing and committed retail

floorspace within the PCA. This assessment is based upon a combination of company

average turnover derived from published sources, professional assumptions and the

findings of the household survey.

2.08 DPP identifies that existing convenience goods retail floorspace within the PCA has a

turnover of approximately £240m in 2007, increasing to £243m by 2012 (allowing for

improved productivity of +0.2% per annum). Of this identified turnover, DPP identifies

that £192m (or 80%) of this turnover in 2007 will be derived from the PCA. Although the

results of the household survey are not provided so it is impossible to verify this, we

assume that this is based on DPP assumptions combined with the findings of the

household survey. As previously highlighted the findings of the household survey are

not included in the applicant’s Retail Assessment and therefore it is not possible to

assess the robustness of the assumptions adopted by DPP.

2.09 A similar approach with regard to assessing the potential turnover of existing comparison

goods floorspace has been undertaken. DPP identifies that existing floorspace has a

comparison goods turnover of £206m in 2007, of which £188m (or 91%) is identified to

be derived from the PCA. By allowing for improved productivity of 1.5% per annum, this

turnover derived from the PCA is anticipated to increase to £203m by 2012. Again, it is

unclear how the turnover derived from the PCA has been identified.

2.10 As acknowledged by DPP, it is also important to take into account outstanding

commitments within the PCA. These are identified by DPP to include the Tesco

extension and mezzanine at the existing Tesco Extra store at Cables Retail Park

together with the new floorspace created elsewhere at Cables Retail Park. DPP


identifies outstanding commitments to have a convenience goods turnover of almost

£7m by 2012 (of which less than £5m will be derived from the PCA). With regard to

comparison goods, DPP identifies a potential turnover of £27m by 2012, of which all this

turnover is identified to be derived from the PCA. This reflects the inconsistency of the

assumptions adopted by DPP.

2.11 Based on the approach adopted, DPP identifies convenience goods capacity of some

£131m and a comparison goods capacity of more than £490m by 2012. Whilst DPP has

demonstrated a ‘theoretical capacity’ (based on no outflow) to support the level of

floorspace proposed, WYG are not able to assess the robustness of this approach given

the lack of household survey information and clarification as to what assumptions have

been used and where they apply.

2.12 Although DPP acknowledges that their approach does not show anticipated outflow of

retail spend from the PCA, they consider that the proposed development is intended to

retain resident’s expenditure. Furthermore, DPP considers that even after allowing for

the implementation of the current application there will still be some outflow of

convenience and comparison goods expenditure.

2.13 However, the approach adopted by DPP is based on a theoretical exercise that by

building more floorspace, existing shopping patterns will be automatically reversed and

the market share of existing facilities in Kirkby will be dramatically increased. WYG

considers that the necessary increase in market share to support the additional

floorspace is wholly unrealistic and need cannot simply be identified on the premise that

all out-flowing expenditure at the moment is available to new development in Kirkby.

This completely ignores the presence of the regional centre of Liverpool and the network

of centres that exist just beyond the catchment boundary.

2.14 Based on the current market share of existing convenience goods floorspace identified by

DPP (which is not based on empirical data and does not identify whether existing

provision is over or undertrading) the market share of the PCA will need to increase from

almost 61% to more than 75% by 2012 (an increase of 25%) to support the additional

turnover created by outstanding commitments and the proposed development (assuming

that 75% of the proposed Tesco store’s turnover is derived from the PCA). Such a level

of retention is highly questionable given the strength and proximity of competing

provision outside the PCA.


2.15 Although DPP has taken into account outstanding commitments within the PCA, no allowance has been made with regard to outstanding commitments outside the PCA, which will have an impact on shopping patterns within the PCA and the wider area.

With regard to the convenience goods sector, outstanding commitments include a new

Tesco Store at Great Homer Street/Scotland Road, Liverpool (11,148 sq m gross); a

new Asda store at Breck Road, Liverpool (5,435 sq m gross); a new Tesco store at

Litherland (6,745 sq m gross) and a new Asda store at Bootle (6,596 sq m gross). In

addition, further proposals are planned in Skelmersdale Town Centre (a new foodstore

of 9,290 sq m gross) and St Helens (replacement Tesco store of 13,000 sq m gross).

2.16 Given these significant commitments/proposals for additional convenience goods

floorspace, whose catchment areas will overlap the PCA identified by DPP, we find it

difficult to understand how DPP have not assessed the likely trade draw of these

commitments and how this could impact upon future levels of expenditure retention

within Kirkby in the future. The approach adopted basically treats the defined catchment

as an isolated area that is not influenced by retail facilities beyond the boundary.

2.17 With regard to comparison goods capacity, DPP identifies capacity of £490m in 2012

within the PCA to support the additional comparison goods floorspace proposed. This

compares to DPP identifying the proposed development to have a comparison goods

turnover of £197.98m in 2012, of which £138.58m is identified to be derived from the

PCA.

2.18 However, it is important to note that DPP’s assessment does not include the comparison

goods turnover of the proposed Tesco store, which is identified to be in excess of £54m

in 2012. By assuming that 75% of this turnover will be derived from the PCA (in line with

the assumption adopted for the convenience goods element of the store) the proposed

development is identified to have an increased comparison goods turnover of £185m in

2012 from the defined PCA. This compares to the analysis undertaken by DPP being

based on a reduced turnover of £139m from the defined PCA.

2.19 By taking into account outstanding commitments, it will be necessary for Kirkby’s market

share to increase from its current level of 33% to around 57% by 2012. As

acknowledged by DPP this represents a large increase over the existing situation – an

increase of 75%.

2.20 Whilst this assessment identifies that there remains expenditure ‘leakage’ to competing


centres elsewhere (c. £300m in 2012) this is understandable given the strength of

competing provision, such as Liverpool. Indeed, DPP considers that such an increase is

realistic despite significant developments taking place elsewhere, such as in Liverpool

City Centre (creation of 160,000 sq m of retail floorspace at Liverpool One), the

development of a new district centre at Great Homer Street and two new foodstores in

Sefton (the Asda at Bootle and the Tesco at Litherland). Furthermore, significant

proposals are also planed in nearby Skelmersdale (24,150 sq m gross) and St Helens

(25,650 sq m gross). The ongoing improvements in competing centres elsewhere will

also have an impact on the market share achieved by facilities in the PCA. Indeed,

many of the schemes will be competing for the same expenditure, being equally

accessible to residents within and just beyond the PCA than the proposed development

in Kirkby. Furthermore, the level of capacity identified is available for the PCA as a

whole (which also includes Prescot and Huyton) and not just Kirkby.

2.21 The quantitative need assessment undertaken by DPP follows an extremely simplistic

approach which effectively ignores planned commitments beyond the PCA boundary. It

also ignores the strength of established current shopping patterns and assumes that

these patterns can be reversed regardless of why people currently undertake these trips.

The simplistic approach ignores the draw of the regional centre of Liverpool and the

influence of other major centres beyond the PCA which current capture expenditure from

the catchment.

2.22 Although it is every centre’s ambition to claw back expenditure and improve trading

performance, this has to be assessed realistically and has to acknowledge competing

and planned provision beyond the catchment. At the moment, we are unable to assess

the robustness and validity of the proposed changes in market share that DPP are

suggesting will occur because no information has been provided on existing shopping

patterns and the household survey results are also not available. This is a major

omission when seeking to justify a quantitative need for a scheme whose size is of sub-

regional, if not, regional significance.

Qualitative Need 2.23 PPS6 places greater weight on demonstrating a quantitative need for the proposed

development. However, it acknowledges that account should be made with regard to

qualitative considerations that might provide additional justification for the development.


2.24 In considering a qualitative need for the proposed development, DPP provide a review of

existing and proposed retail provision in Kirkby and the surrounding area. This

assessment identifies that there is currently a gap in provision in the PCA.

2.25 WYG accepts that there is a need to improve convenience and comparison goods

floorspace in Kirkby and the wider PCA. However, as previously discussed,

improvements in the local retail offer have to respect the role and function of the existing

network of centres. Clearly, the qualitative benefits promoted by DPP could easily be

met by development of a much smaller scale which would be more in keeping with the

role and function of Kirkby Town Centre and would not have such wide ranging

implications for other centres within and beyond the PCA.

Appropriateness of Scale 2.26 PPS6 advises that retail development should be of a scale directly related to the role and

function of the centre and its catchment, relating to the wider hierarchy and ensuring that

it fits into that centre and that it complements its role and function.

2.27 As previously highlighted the submitted application proposes approximately 60,000 sq m

(net) of additional retail floorspace (both convenience and comparison) – or

approximately 72,200 sq m (gross). This compares to the existing Kirkby Town Centre

which has a total net sales area of less than 19,000 sq m (as identified by DPP). This

represents a 330% increase in retail floorspace within Kirkby. Clearly, the proposal

represents a significant change in the current role and function of Kirkby.

2.28 Currently, Kirkby Town Centre is identified by DPP to comprise some 19,000 sq m of retail

floorspace (both convenience and comparison), which is comparable to Huyton (19,100

sq m net) and marginally less than Prescot Town Centre (20,300 sq m net) by including

the Cables Retail Park. The current application results in Kirkby providing approximately

60,000 sq m (net) of additional retail floorspace. Clearly, this would result in a significant

imbalance in retail provision within the three town centres in the Borough. Indeed, in

considering impact upon Kirkby Town Centre, DPP suggest that the proposal will have a

positive impact on the turnover of the town centre by more than 400%. This level of

impact on the retail turnover of Kirkby underlines the significant scale of the proposal

and the impact that would be created not only within the PCA, but beyond.


2.29 In considering the future role and function of Kirkby Town Centre it is important to reflect

upon the strategy set out in the Adopted UDP. The UDP clearly highlights the need to

improve provision within all three town centres in the Borough. Furthermore, it is notable

that the UDP highlights a need to improve the role and function of the centres in a way

that is appropriate in scale. In this respect, the UDP (Paragraph 7.14) highlights that:

‘New development should complement the role and be appropriate to the scale of each centre. This

will mean that the catchment area for a proposed development should generally be not significantly larger than the centre within which it would be located.’

2.30 In terms of identifying need for further shopping development in the Borough, the UDP

identifies a major development of up to 9,000 sq m (gross) floorspace for food retailing in

Kirkby Town Centre and further comparison goods retailing within Kirkby, Prescot and

Huyton of a minimum of 7,000 sq m over the period to 2011 spread over the three

centres (including 2,000 sq m in Kirkby Town Centre). Although the UDP highlighted a

need for at least 2,000 sq m of additional comparison goods floorspace in Kirkby, it is

highly unlikely that the UDP was refereeing to an upper limit of more than 60,000 sq m

(net) of additional retail floorspace as proposed by this application.

2.31 Furthermore, although the UDP acknowledges that the range of shopping and leisure

facilities within Knowsley is relatively limited when compared to that available in larger

city and town centres (such as Liverpool, St Helens and Southport), paragraph 7.8

states that: ‘…the relative shortage of shopping and leisure facilities within Knowsley is to

expected given the limited size of Knowsley’s centres and their role in the wider Merseyside economy. However, the Plan aims to ensure that each centre performs to its optimum in a way that

is appropriate to its scale, role and function.’ (Our emphasis).

2.32 Although we acknowledge that Knowsley Council are currently in the process of preparing

their LDF it is evident that the proposed development is in conflict with the strategy that

has previously been pursued for the three town centres within the Borough. Also the

existing development plan quite rightly acknowledges the role and function of the

centres and the influence of Liverpool as a shopping and leisure destination. However,

this approach has not been adopted by DPP in assessing the need for the scheme or its

true impact.

2.33 In addition, development of this scale must also reflect upon the guidance set out in the

emerging Regional Spatial Strategy. The recent changes published in March 2008 still

include a list of centres within the region where comparison retail facilities should be


enhanced and encouraged. It is important to note that Kirkby is not included as one of

these centres. In fact Policy W5 of the emerging RSS seeks to ensure that any future

developments or investments should be consistent with the scale and the function of the

centre and should not undermine the future vitality and viability of any other centre.

2.34 Although Kirkby is not identified as a centre of regional significance where future goods

comparison goods growth should be encouraged, Policy W5 does allow for investment in

other centres where this may underpin wider regeneration initiatives. However, this

investment is to ensure that these lower order centres adequately meet the needs of

their local communities. WYG does not believe that this policy justifies a major shift in a

centre’s role in the regional network, as proposed by the current application, but seeks to

ensure that lower order centres can improve their offer over the plan period to support

their long term vitality such as the proposals in Skelmersdale.

2.35 Although DPP suggest that RSS does not prevent the proposed development from

occurring within Kirkby, it is important to reflect upon the guidance within PPS6

(paragraph 2.10) which highlights that:

‘…any significant change in the role and function of centres, upward or downward, should come

through the development plan process, rather than through planning applications. Changes to the status of existing centres or the identification of new centres which are more than local importance should be addressed initially at the regional level through regional spatial strategies. Changes to the role and status of lower level centres, and the implications of changes in the status of higher level centres, should be brought forward through development plan documents.’

2.36 Clearly, in this respect the significant improvement in the role and function of Kirkby

should be considered (and assessed properly) as part the development plan process

rather than through a planning application which is currently being progressed.

2.37 In conclusion, it is evident that the scale of the proposed development is wholly

inappropriate. There has been no true assessment of the role and function of the three

centres within the Borough and what level of floorspace could be realistically

accommodated without dramatically changing this established network. In addition,

there has been no detailed assessment of the true impact of such large scale

development on centres outside the catchment which are identified by RSS to be

centres where such development should be concentrated. On this basis, it is evident that

the scale of the development is in direct conflict with the existing and emerging


development plan including RSS.


3 THE SEQUENTIAL APPROACH

Introduction

3.01 As the vast majority of the proposed floorspace falls outside Kirkby Town Centre, in

accordance with PPS6 it is necessary to apply the sequential approach to site selection.

In this respect, Paragraph 3.15 of PPS6 states that:

‘In applying the sequential approach, and considering alternative sites, developers and operators

should be able to demonstrate that in seeking to find a site in or on the edge of existing centres they have been flexible about their proposed business model in terms of the following planning considerations:

• The scale of their development;

• The format of their development;

• Car parking provision; and

• The scope for disaggregation.’

3.02 PPS6 identifies that the purpose of this exercise is to explore the possibility of enabling

development to fit onto more central sites by reducing the footprint of the proposal.

Applicant’s Approach 3.03 In considering the sequential approach to site selection, DPP highlights the specific

regeneration needs of Kirkby and that the proposed stadium is the key element in the

overall development. In this respect, DPP suggest that the new stadium can only

progressed if it is enabled through the proposed retailing. Consequently, DPP considers

that this has an impact upon applying the sequential approach, primarily in terms of

format and disaggregation. In addition, DPP considers that the identified qualitative and

quantitative need in Kirkby cannot be met unless a mixed use development comprising a

major foodstore and a substantial amount of comparison retail floorspace is delivered.

3.04 Despite this, in applying the sequential approach, DPP has considered the potential for

the supermarket to be separated from the other retail floorspace proposed. In this

respect, DPP considers that the supermarket element will need to be sizeable to

compete with surrounding modern superstores and carry a similar range of goods.

Given the scale of competing provision, we question why it is necessary to develop such

a large supermarket (22,464 sq m gross, or 10,219 sq m net), which will clearly be larger


than any other supermarket in the North West region. Indeed, DPP compares the

current proposal with competing provision, which highlights that the largest nearby store

is the Asda at Huyton, although the net floorspace is more than 1,500 sq m (net) smaller

than the current proposal. Moreover, given that the population within the Huyton Zone

(as identified by DPP) is more than twice that identified for the Kirkby Zone, WYG

questions why the store in Kirkby needs to be significantly larger than the existing Asda

in Huyton.

3.05 Likewise, WYG questions DPP’s approach in applying the sequential approach on the

basis that the identified need is sufficient to support the level of floorspace proposed. As

we have previously discussed, WYG has serious concerns with regard to the local retail

capacity to support the level of floorspace proposed. Indeed, the level of additional

comparison goods floorspace is significantly higher than that identified in the adopted

UDP.

3.06 In considering alternative sites, DPP highlight that it is reasonable to restrict the area of

search for sequentially superior sites in Kirkby given the wider regeneration benefits

associated with the development and the need for improved retail provision in Kirkby.

Indeed, DPP considers that the regeneration benefits for Kirkby could not be achieved

by locating all or part of the proposed development in an alternative location. Whilst

WYG accept there is a need to improve the retail offer of Kirkby, as previously

highlighted, it is considered that there is insufficient ‘need’ to support the scale of the

proposal.

3.07 Despite this, DPP has also looked at town and district centres within zones 1, 2, 3, 4, 5, 6,

8, 9 and 10 of the defined Study Area. In applying the sequential approach, DPP

highlights that as the application site incorporates most of the existing Kirkby Town

Centre and that the rest of the application site is edge-of-centre, they have limited their

search to sites that are either in or at the edge of defined centres.

3.08 On this basis DPP suggest that are no sequential alternative opportunities for the

proposed development within the PCA. Although WYG would agree with the conclusion

that there is not another sequentially superior site within the defined PCA to

accommodate the proposed development, we would reiterate our previous concerns that

we do not believe that a need has been demonstrated for the scale of development

proposed and that the scale is wholly inappropriate in this location.



4 IMPACT AND TRADE DIVERISON Introduction

4.01 In terms of potential impact of the proposed development, it is significant to note that

PPS6 (paragraph 3.21) states that: ‘The identification of need does not necessarily indicate that

there will be no negative impact.’

4.02 In terms of the potential convenience goods impact of the floorspace proposed, DPP has

based their assessment on the proposed development having a turnover of

approximately £62m in 2012. However, DPP has assumed that less than 40% of the

proposal’s convenience goods turnover will be derived from facilities within the PCA.

Consequently, the majority of trade draw is identified to be derived from facilities outside

the PCA, most notably the Asda at Aintree (£11m). As previously highlighted, given the

strength of existing, committed/proposed convenience goods outside the PCA, it is

questionable whether this level of ‘clawback’ identified (62% of the proposal’s turnover)

is realistic.

4.03 Furthermore, DPP’s assessment of the potential convenience goods impact does not

include the potential convenience goods turnover of the additional unit now being

proposed. This is identified to have a convenience goods turnover of approximately

£4m. DPP suggest that this unit will have a positive benefit on the town centre given

that it is likely to draw its trade mainly from stores elsewhere in the town centre.

4.04 With regard to assessing impact of the comparison goods floorspace proposed, DPP has

assumed that only 15% would be derived from existing centres/facilities within the PCA.

Accordingly, more than £214m of the proposal’s turnover is identified to be derived from

facilities outside the PCA. Again, WYG questions whether such levels of clawback are

achievable given the permitted and ongoing improvements taking place at competing

facilities outside the PCA.

4.05 Whilst it is acknowledged that DPP has assessed the potential convenience and

comparison goods impact separately, the combined impact (convenience and

comparison goods) of the proposed development has also been considered. In addition,

the cumulative impact of the proposal at Kirkby together with outstanding commitments

within the PCA (Tesco extension in Prescot and redevelopment at Cable Retail Park)

has also been considered. Given the scale of the Paradise Street development in


Liverpool City Centre, the cumulative impact of this development has also been taken

into account. The potential trade draw of the redevelopment of Liverpool City Centre

undertaken by DPP has been based on professional judgements taking into account

existing comparison goods shopping patterns within the wider Merseyside area.

4.06 WYG questions why the potential impact of other commitments just beyond the PCA has

not been taken into consideration by DPP. The catchment of these developments will

clearly overlap with the PCA identified by DPP (e.g. new foodstore at Great Homer

Street/Scotland Road, new foodstore in Bootle, etc). Indeed, in applying the sequential

approach, DPP identifies that the natural catchment of Kirkby essentially extends out

from Zone 1 of the defined Study Area, in to parts of Zones 2, 4, 6 and 8.

4.07 Given that this exercise has not been undertaken by DPP, the level of impact identified by

DPP should be treated with a considerable ‘note of caution’ as it will be an

underestimate.

4.08 Notwithstanding our concerns with the broad approach adopted by DPP in assessing

impact, we set out below our assessment of the levels of impact identified.

4.09 In assessing the potential cumulative impact DPP identifies that almost £19m of retail

expenditure will be derived from Huyton Town Centre (based on the proposed

development and outstanding commitments identified by DPP). Such a level of trade

draw could have an adverse impact upon the vitality of the town centre. Whilst DPP

suggests that most of this impact would be on the existing Asda store in Huyton, this

store is identified to be overtrading. Therefore, DPP suggests that the existing Asda

store will be able to withstand the level of impact identified. As previously highlighted,

this level of impact is considered an underestimate as it has not taken into account the

additional turnover created by the proposed stand alone convenience store or a number

of outstanding consents located just beyond the PCA. Notwithstanding this, there are

strong linkages between the Asda store and Huyton Town Centre and the trade draw

identified will significantly reduce these linkages at the expense of the viability of the

town centre.

4.10 Accordingly, the potential impact of the proposal on other centres within the Borough is

contrary to the Knowsley Replacement Unitary Development Plan, where one of the

Strategic Objectives is:


‘To improve the provision of shopping and other uses normally associated with town centre consistent with local needs, whilst protecting and enhancing the viability and vitality of town, district

and local centres.’ (Our emphasis).

4.11 With regard to the impact on centres outside the PCA, again WYG question a number of

assumptions made by DPP. Indeed, in considering the potential cumulative impact on

St Helens Town Centre, DPP identifies a combined impact at 2012 of approximately 8%

(or -£26.4m). However, DPP suggest that due to spending growth that will occur

between 2007 and 2012 the turnover of St Helens Town Centre is identified to have

increased from the 2007 level thereby off-setting any impact. Furthermore, DPP

highlights that should planning permission be granted for the current proposal on Chalon

Way in St Helens this will add to its retail offer.

4.12 Even though we consider the level of impact on St Helens Town Centre has been

underestimated by DPP, the reduction of growth that would have been available to new

facilities within St Helens is significant. There are currently two applications for major

retail development in St Helens which will draw upon the growth generated within St

Helens between 2007 and 2012. Therefore, any significant diversion of this growth to

the proposed development at Kirkby will be significant.

4.13 Furthermore, major retail schemes been developed or are proposed at competing centres

such as Wigan Town Centre (which have not been taken into account by DPP in

assessing impact) which, together with the Kirkby proposal will further erode the market

share of St Helens Town Centre. Indeed, the St Helens Retail Study undertaken for the

Council in 2005 identified that the market share of St Helens has declined since 2000.

4.14 DPP identifies a level of trade diversion from Southport Town Centre totalling £33.6m

(8%). Again, DPP identifies that this impact will be offset by potential expenditure

growth. We consider that a potential impact on Southport Town Centre would be

significant given the potential diversion that will also be created by the Liverpool One

development which has yet to open. DPP identifies a cumulative impact on the

comparison goods turnover of more than 11%. Whilst this level of impact is considered

significant, it is not clear whether this is based on the turnover of the town centre or a

combination of the town centre and the nearby retail parks. Given this, the potential

impact on Southport Town Centre could be even greater.

4.15 With regard to Bootle Town Centre, DPP identifies a potential cumulative impact of more


than 7% (-£7.9m) and an impact of 11% on comparison goods trade. Again, WYG

believe that figure is also underestimated. The true impact would be much greater if all

existing commitments were considered including Great Homer and the proposed Asda

and Tesco foodstores which have not been considered as part of DPP’s analysis.

4.16 In terms of Ormskirk and Skelmersdale, DPP identify that £6m and £3.6m will be diverted

from both centres respectively. This would result in an impact of 5.6% on Ormskirk and

6.1% on Skelmersdale. As the majority of this trade draw would be from the comparison

goods sector it is important to note that the impact on this sector in both centres would

be 8.6%. Clearly, this is a significant issue for Skelmersdale where there are plans

currently in place to reinforce the future comparison goods role of the centre to help

‘claw back’ lost expenditure. Although it could be argued that this is exactly what the

development at Kirkby is trying to achieve, it must be noted that the scale of the

development proposed at Skelmersdale clearly reflects the role and function of the

centre and will not result in significant trade draw from neighbouring centres in the

established network.

4.17 It is notable that in considering the impact of the proposed development and other

commitments on established centres both within and outside the PCA, DPP highlights

that the growth forecast in expenditure will offset any trade draw. For example, DPP

highlights that although almost £8m of retail expenditure is identified to be derived from

Bootle Town Centre, the identified turnover by 2012 will still be higher than the current

level resulting in no negative impact. Indeed, DPP highlights that the comparison goods

turnover of many centres would be greater at 2012 after cumulative impact compared to

current trading levels. However, it is important to highlight that this assumption is based

upon other existing centres maintaining their current market share despite significant

improvements in retail provision nearby.

4.18 Such an assumption is considered to be unrealistic. It is highly unlikely that Southport

Town Centre’s market share will remain at the same level in 2012 to that identified in

2007. For example, in considering the potential impact on the comparison goods

turnover of Southport Town Centre, DPP has assumed that the market share will remain

at around 8% in the Study Area despite increased competition elsewhere, including the

Kirkby proposal and the Liverpool One development in Liverpool City Centre. Clearly,

the improved provision in competing centres is likely to reduce the market share of

Southport Town Centre given that there are no significant proposals in the pipeline to

improve the retail offer of the town centre in the future. Consequently, the assumption


made by DPP that the turnover of existing centres will be greater at the design year after

allowing for cumulative impact is highly questionable.

4.19 In conclusion, it is evident that the potential impact of the proposed development at Kirkby

could be far-reaching. More importantly, it is not possible to assess the true impact of

the proposed development because of the lack of survey information provided.

Therefore, although the assessment by DPP suggests that trade draw will be spread

over a large number of centres (thereby diluting the impact) detailed analysis of the

household survey is more likely to reveal that the impact could fall more heavily on those

centres nearby.

4.20 As the scheme seeks to ‘claw back’ over £214m from other centres beyond the defined

primary catchment it is evident that this will have a significant impact. This is particularly

true given the fact that the Liverpool One has yet to open and its future trading

performance will further dilute the amount of expenditure that is spent in key centres

within the primary and secondary catchments of Kirkby. Therefore, the combined impact

of Liverpool One and the proposals at Kirkby would undermine the future vitality and

viability of centres within Sefton, St Helens and to some extent West Lancashire.

4.21 Although DPP are suggesting that turnover levels will be higher in neighbouring centres in

the future (and therefore no impact) this ignores the fact that the impact will have taken

away valuable expenditure growth that will be required to support new investment within

these centres if they are to maintain and enhance their vitality and viability as promoted

by PPS6.


5 SUMMARY AND CONCLUSIONS

5.01 In conclusion, WYG have significant concerns with regard to the analysis that has been

undertaken to support the planning application for the proposed development in Kirkby.

The approach taken to such a major development is far too simplistic and excludes

important background information. The exclusion of the household survey data is a

major omission and does not enable us to robustly assess, and validate the assumptions

made by DPP. With valid data on current shopping patterns within and beyond the

primary catchment it is impossible to understand whether the increases in market share

are sustainable and what will be the true impact of any significant increase in market

share on established centres elsewhere. To this aim we have significant concerns about

the validity of the conclusions reach with regard to ‘need’, the appropriateness of scale

and the likely future impact on established centres.

The Need for the Proposed Development

5.02 As highlighted as part of this assessment, WYG considers that a clear quantitative and

qualitative need for the level of new retail floorspace proposed has not been

demonstrated. The need assessment that has been submitted not only relies on

unrealistic levels of expenditure ‘claw back,’ but it also ignores important commitments

that exist just outside the PCA. Effectively, DPP have ignored current shopping patterns

and the influence of other centres beyond the PCA in reaching their conclusions. Also

no consideration has been made of any future plans for retail development within other

centres beyond the PCA including St Helens and Skelmersdale which also seek to

improve market share and ‘claw back’ expenditure.

5.03 In terms of qualitative need, it is WYG’s view that the qualitative deficiencies that have

been identified by DPP in their assessment could easily be addressed by a much

smaller scheme linked to what was previously planned as part of the UDP strategy for

Kirkby Town centre. Therefore, there is no justification as to why the scale of

development proposed is required to meet certain retail qualitative benefits or needs.

Appropriateness of Scale 5.04 It is evident that the scale of the proposed development is wholly inappropriate. There

has been no true assessment of the role and function of the three centres within the

Borough and what level of floorspace could be realistically accommodated without


dramatically changing this established network. In addition, there has been no detailed

assessment of the true impact of such a large scale development on centres outside the

catchment which, are identified by RSS, to be centres where such development should

be concentrated. On this basis, it is evident that the scale of the development is in direct

conflict with the existing and emerging development plan including RSS.

5.05 For the reasons outlined above, WYG believe that the retail evidence submitted to date in

support of the planning application is inadequate and does not enable the true impact of

this major development to be properly assessed. In summary, the proposed

development can not be properly assessed against the key tests in PPS6 and therefore,

we fail to see how a robust conclusion could be reached on its compliance with local,

regional and national policy.


Potential Impact and Trade Diversion

5.05 Given our concerns with the assumptions adopted by DPP in seeking to demonstrate a

need for the proposed development (most notably in terms of clawback) it is considered

that impact on established centres has been underestimated.

5.06 In addition, DPP has assumed that the market share of existing centres within the Study

Area will remain constant despite increased competition elsewhere (including the

proposed development at Kirkby and Liverpool One). In addition, the potential

cumulative impact of the proposed development, together with outstanding commitments

just beyond the PCA, has not been taken into account by DPP. Clearly, by taking these

commitments into account the potential impact would significantly increase.

5.07 Therefore, we question the robustness of the impact assessment that has been prepared

to date. This is further reinforced by the lack of survey evidence to support the approach

adopted and the fact that numerous commitments have been excluded from the

cumulative assessment. It is our view that the levels of impact estimated by DPP are

significantly underestimated and do not highlight the true impact of the proposed

development on key centres within Sefton, St Helens and West Lancashire.

Summary

5.08 Based on the evidence that has been submitted to date, WYG do not believe that the

proposed development in Kirkby satisfies all of the key tests set out in PPS6. We do not

believe that the need for the proposed development has adequately been demonstrated

and as a result, the scale is clearly inappropriate. More importantly, the potential impact

of this scale of development has not been properly assessed and therefore, the true

effect of this significant development on the vitality and viability of other established

centres within the study area is underestimated.

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