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Application for the erection of temporary structure in existing car park area to be used for seasonal retail sales at Tesco store, Lake Road, Douglas, Isle of Man, IM1 5AF
1.1 This statement is submitted in support of a planning application, on behalf of Tesco Stores Ltd, for the erection of a temporary structure in existing car park area to be used for seasonal retail sales.
2.1 It is proposed that the additional floorspace of 54 sq m to be sited within the existing car park area, will trade the following types of seasonal goods:
3.1 The Key planning policy provisions in consideration of the proposal are those contained within the Douglas Local Plan 1998 and the Isle of Man Strategic Plan 2007. We acknowledge the more recent publication of the Retail Sector Strategy (December 2013) and its accompanying Evidence Base (Peter Brett Associates, June 2013), the content of which have been used to inform our assessment of retail need and impact.
Douglas Local Plan 1998
3.2 In anticipation of the emerging East Area Plan, the relevant Area Plan is the Douglas Local Plan 1998. As a Written Statement was never formally published as part of the Area Plan, the key document is Central Map No. 1. This identifies the application site as falling within an Area of Retail/Commercial within the Central Area Boundary, referring specifically to Retail Warehousing at the site.
The Isle of Man Strategic Plan 2007 (the "Strategic Plan")
General Policy 2
3.3 General Policy 2 of the Strategic Plan seeks to permit well designed and appropriately sited development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan along with other relevant policies of the Strategic Plan.
Strategic Policy 9 3.4 Strategic Policy 9 seeks to direct new retail development to town and village centres on land zoned for these purposes in Area Plans. Business Policy 9
3.5 Business Policy 9 provides support for new retail provision in existing retail areas at an appropriate scale and which will not have an adverse effect on adjacent retail areas.
Business Policy 10
3.6 Business Policy 10 states that retail development will only be permitted in established town and village centres.
4.1 In light of the retail designations indicated on the published Douglas Local Plan (1998) Central Area Map, it is considered that the proposal is in accordance with the appropriate Area Plan as per the provisions of General Policy 2.
4.2 In the context of Strategic Policy 9 and Business Policy 10 there is no defined town centre on the Central Map No 1 of the Douglas Local Plan (1998). Whilst the map identifies an Area of Predominantly Shopping Use, it would be inaccurate to simply assume this reflects a defined town centre as other ‘town centre uses’ i.e. office development are clearly defined outside of this area.
4.3 In respect of the above point, we acknowledge the previous appeal decision in 2009 relating to an application for an additional 4,777 sq m of floorspace at the site (planning application ref. 09/00301/B). The Inspector in this case determined that the site was out of centre, however, we would maintain our position that in the absence of conclusive planning policy and in light of the fact the application site is expressly identified as being appropriate for retail development on the Central Map, the application site represents a suitable location for retail development of the scale proposed.
4.4 This view was in fact shared by the Council of Ministers in its review of the Inspector’s 2009 appeal report (Planning Appeals Office Correspondence dated 6th July 2010 ref. L09NEW/09/00001/CI). In considering the Inspector’s conclusion that the application falls within an out of centre location, the Council reported that Douglas town centre and retail centre did not have sufficiently defined boundaries. Prior to publication of the Eastern Area Plan it was considered premature to refuse an application on this basis. Of course, it should also be noted that the principle of retail development at the application is already well established with the presence of the existing Tesco store.
4.5 Furthermore, in respect of provisions contained within Business Policy 9 we contend that at only 54 sq m in total, the current proposal is of an entirely appropriate scale in this established retail location. This point was reinforced by the Council of Ministers in their observation that sufficient weight should be applied to established retail use at the site.
4.6 In light of the above, we propose that the development being sought is of an appropriate scale at an established retail premises, identified within the Council’s own planning policy documents as appropriate for such uses. On this basis, we do not consider that there will be any significant adverse harm caused to the vitality and viability of existing businesses within Douglas, which of course is reflective of the planning officer’s conclusions in consideration of previous application ref. 13/00687/B. Notwithstanding that Business Policy 9 only requires submission of a Retail Impact Assessment for major retail development proposals (over 500 sq m), for completeness the following section assesses the retail impact of the current proposal.
5.1 The application proposal extends to 54 sq.m. The benchmark non-food sales density of Tesco according to Experian is £8,238 per sq.m. (2012 Prices). As such, based on the company average sales density for non-food products, the total annual turnover for the proposed marquee is £444,852 per annum.
5.2 The reality is that this estimate of turnover is likely to be an overestimate. This is because the benchmark sales density used is for sales generated from a traditional Tesco store. We contend that the sales associated with a marquee will be lower as the shopping environment will be less attractive and will, to an extent, put off an element of the customer base. Moreover, the Tesco benchmark sales density is an average derived from all of the company’s stores across the UK. As such, given that the per capita expenditure in the Isle of Man is below the national average, it is reasonable to assume that the sales density of the proposal would be lower than the benchmark.
5.3 It addition, it is of note that the Peter Brett Associates/Roger Tym Isle of Man Retail Sector Strategy Evidence Base Report (“the PBA Report”) uses a benchmark sales density for comparison goods of £250 per sq.ft (£2691 per sq.m.). If this figure is applied to the application proposal, the turnover of the proposal would be £145,314 per annum. Whilst we
accept that this figure is likely to represent an underestimate of the actual turnover, it reflects that the benchmark turnover estimate is very likely to be an overestimate. As a consequence, the assessment which follows should be treated as a worst case scenario.
5.4 Table 1.8 of the PBA Report sets out the anticipated growth in expenditure from 2013 to 2017 and beyond to 2022. For non-bulky comparison goods, this indicates that there will be a growth in expenditure between 2013 and 2017 of £26.22M. As such, the anticipated turnover of the proposed development equates to just 1.7% of the growth in non-bulky goods comparison expenditure between 2013 and 2017. This means that even following the introduction of the marquee, there would be 98.3% of the growth in expenditure, equivalent to £25.8M, available to support further new floorspace or to support the growth of existing retail provision.
5.5 Table 4.8 of the PBA Report sets out the additional floorspace required to meet the identified surplus in available expenditure. Crucially, Table 4.8 takes account of existing retailers increasing their efficiency and resultant turnover year on year. PBA assess two scenarios, the first assuming that current trade draw is maintained and the second examining the potential to clawback some of the trade currently being lost to the internet and other destinations. Assuming current trade draw patterns, the PBA report concludes that by 2017 there will be a need for a further 1,858 sq.m of comparison goods floorspace. If the increased clawback scenario is applied, the PBA report concludes that there will be a need for a further 3,732 sq.m of additional comparison goods floorspace by 2017. As such, at just 54 sq.m., the proposal equates to between 3% and 1.5% of the comparison goods floorspace required by 2017. As such, it can be seen that there is more than adequate expenditure to support the application proposals and support the growth of existing retailers.
5.6 In light of the above assessment of the ‘need’ for further floorspace, which shows that the small turnover of the proposals represents a tiny fraction of the annual growth in available expenditure, we contend that the resultant impact on existing stores will be zero.
5.7 Rather than diverting expenditure from existing stores and centres, the proposal will just divert a very small percentage of the growth in expenditure which the existing stores and centres do not have the capacity to absorb. If the application proposals do not come forward then the turnover that it would have absorbed will not go to an existing store, it will be lost.
5.8 The above view that there will not be any impact to existing stores is supported by the nature of the proposal, which we consider below.
5.9 The existing Tesco store is the most popular destination for main food grocery shopping, attracting 44% of the available main food expenditure. As set out earlier in this assessment, the application proposal simply seeks to enable a very small increase in the area devoted to the sale of non-food goods, the majority of which are already available within the store. As such, the vast majority of the turnover generated by the proposals will be from people already visiting the Tesco store.
5.10 The nature of the goods being sold, and the environment in which they are being displayed, means that it is highly unlikely that people will make a dedicated trip just to shop at the application proposal. Moreover, the main reason for the proposal is for the display of ‘seasonal’ products. By their nature, these tend to be lower value products that people purchase as part of their main food shopping trip. They are ‘impulse’ purchases rather than considered purchases where shoppers are looking for a range and choice of one particular product.
5.11 The PBA Report confirms that for comparison goods, the second most popular shopping destination was the Internet (accounting for 15% of expenditure). The PBA Report goes on to confirm that the latest Household Survey findings suggest that restricted choice is one of the
factors influencing the shift away from Douglas and towards the Internet. As such, it is clear that without new development, the level of expenditure being accounted for by the internet will increase.
5.12 Finally, even if it was assumed that the existing stores and centres could absorb the growth in available expenditure and the application proposal impacted upon them, we contend that the impact would be so small it would not threaten the vitality and viability of the any store. The PBA report states that Douglas Centre has a total floorspace of 262,511 sq.ft. Applying the benchmark sales density of £250sq.ft derived from Table 4.8 generates a current turnover of £65.6M. As such, if we assumed that the entire turnover of the application proposal was diverted from Douglas Centre (which is a worst case and unrealistic scenario), the impact at 2013 would be just 0.68%. Moreover, if the impact is assessed at 2017 and constant marketshare is assumed, the turnover of Douglas Centre would increase to £75.93M, making the impact at 2017 just 0.59%. In light of this, we contend that even assuming that existing stores can absorb the growth in expenditure, the level of impact would be so small that it would in no way affect the vitality and viability of Douglas.
5.13 The above assessment demonstrates that there is a clear quantitative need for additional retail floorspace. The application proposals account for less than 2% of the anticipated growth in expenditure between 2013 and 2017. As such, from an impact perspective, the proposals can easily be absorbed through the growth n expenditure rather than through an impact on existing stores and centres. However, the above also shows that even if it was possible for existing stores and centres to absorb the growth in expenditure, the resultant impact from the application proposals would be less than 1%. As such, it is clear that the proposals will no material impact on the vitality and viability of Douglas or any other centre. It will absorb a very small proportion of the growth in expenditure which would otherwise not be taken up by existing shops and centres and would most likely be spent on the internet.
5.14 We conclude, therefore, that the application proposals meet an identified need and will not result in a material impact on the vitality and viability of any centre.
6.1 This application does not propose any external alterations to the existing Tesco store building.
6.2 The application proposes a temporary structure in the existing car park area to be used for seasonal retail sales. The proposed use is considered to be entirely appropriate in the context of the existing use at the site.
6.3 The proposal seeks the erection of a 54 sq m temporary structure with an external canopy above the entrance.
6.4 The proposed temporary structure will be sited adjacent to the front (western) elevation of the existing store, occupying an area currently used for car parking.
6.5 It is considered that given the comparatively small loss of car park spaces at the store, the proposal will not result in an unacceptable impact on overall parking provision at the site.
6.6 The scale and massing of the proposed development is considered to be entirely appropriate within the context of the existing retail store and the wider surrounding area.
6.7 At 3.97m in height the ridge line of the proposed extension sits below the highest part of the existing retail store’s roof.
6.8 This application seeks permission for a temporary structure within the car park area. There are no changes proposed to existing landscaping and, as such, the proposal will have no impact upon landscaping at the retail store.
6.9 The proposed structure has been designed to sit comfortably within the context of the existing store and the proposed materials have been chosen to complement the host building.
6.10 There are no changes proposed to existing public safety measures which will remain in place at the application site. As such, the proposal will have no detrimental impact on community safety.
6.11 The application proposal will not impact upon the environmental sustainability of the development and the materials can be re-used.
7.1 There are no changes proposed to existing access routes and/or service access routes.
7.2 The proposal will result in the loss of only four car parking spaces. However, it is considered that existing provision within the site is sufficient to accommodate this loss and there will be no detrimental impact on parking or highway safety at the site.
7.3 The proposal includes the provision of a ramped access platform to ensure access for all.
7.4 As such, the proposed development will have no detrimental impact upon the accessibility of the unit.
8.1 The application seeks to allow a temporary structure in the car park area for seasonal retail sales.
8.2 No physical alterations are proposed to the existing retail store and the proposal has been designed to sit comfortably within the context of the site and wider surrounding area.
8.3 The application should not raise any concerns in terms of visual amenity.
8.4 The proposal is considered to be entirely appropriate in scale in this established retail location.
8.5 It has been demonstrated that the development will not result in any significant adverse impact on the vitality and viability of Douglas.
8.6 In light of the above, the proposal is considered to be wholly appropriate to its location and will provide existing customers with increased choice.
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