albion road, new mills v2 - high peak, derbyshire

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www.wyg.com creative minds safe hands Kirkland Developments Limited Proposed Mixed Use Development at Albion Road, New Mills Planning and Retail Statement January 2015 Address: Quay West at MediaCityUK, Trafford Wharf Road, Trafford Park, Manchester, M17 1HH Tel: 0161 872 3223 E-Mail: [email protected] Web: www.wyg.com

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Page 1: Albion Road, New Mills v2 - High Peak, Derbyshire

www.wyg.com creative minds safe hands

Kirkland Developments Limited Proposed Mixed Use Development at

Albion Road, New Mills

Planning and Retail Statement January 2015

Address: Quay West at MediaCityUK, Trafford Wharf Road, Trafford Park, Manchester, M17 1HH

Tel: 0161 872 3223

E-Mail: [email protected]

Web: www.wyg.com

Page 2: Albion Road, New Mills v2 - High Peak, Derbyshire

www.wyg.com creative minds safe hands

Document Control

Project: Albion Road, New Mills

Client: Kirkland Developments Limited

Job Number: A087263

Document Checking:

Prepared by:

Checked by:

Verified by:

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Contents Page

1.0 INTRODUCTION ............................................................................................................................. 1

2.0 THE APPLICATION SITE AND PROPOSED DEVELOPMENT ................................................................. 3

3.0 PLANNING POLICY CONTEXT .......................................................................................................... 6

4.0 PRINCIPLE OF DEVELOPMENT ........................................................................................................ 12

5.0 THE SEQUENTIAL APPROACH ......................................................................................................... 16

6.0 COMPLIANCE WITH THE IMPACT TEST ........................................................................................... 23

7.0 OTHER MATERIAL CONSIDERATIONS ............................................................................................. 32

8.0 CONCLUSION................................................................................................................................. 39

Appendix Contents

Appendix 1 – Sequential Sites

Appendix 2 - Study Area

Appendix 3 - Health Checks

Appendix 4 – Trade Diversion Impact Tables

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1.0 INTRODUCTION

1.01 WYG Planning (‘WYG’) has prepared this Planning & Retail Statement on behalf of Kirkland

Developments Limited (‘the applicant’) to assist High Peak Borough Council (‘the Council’) in its

determination of a hybrid planning application for a mixed use development at land off Albion Road,

New Mills. Full planning consent is sought for the demolition of the New Bodies Fitness Centre on

Chapel Street and the development of a foodstore (Class A1), Newtown Station overflow car parking

and associated access, parking, servicing, facilities and landscaping. Outline planning consent is

sought for the development of a light industrial unit (Class B1).

1.02 This Planning and Retail Statement describes the development proposed for the land off Albion Road,

New Mills. It provides an overview of relevant national and local planning policies, assesses the

principle of the proposed use, assesses the proposal in relation to the key retail planning policy tests

(the sequential test and the impact test), and considers other material planning considerations. The

Statement will demonstrate that the scheme for Albion Road complies with national and local planning

policy requirements with regard to design, highways and access, amenity and environmental issues.

1.03 Pre-application correspondence was received from the Council on the 21st July 2014 confirming the

validation requirements of the planning application submission. In accordance with the Council’s

requirements, the planning application submission comprises:

• Planning Application Forms and Certifications;

• Planning Application Fee;

• Site Location Plan/Existing Site Plan;

• Proposed Site Plan;

• Proposed GA Plan;

• Proposed Roof Plan

• Proposed Elevations;

• Proposed Sections;

• Proposed Landscaping Scheme;

• Design and Access Statement (including Sustainability Statement);

• Transport Assessment;

• Flood Risk Assessment;

• Noise Assessment;

• Archaeological Assessment;

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• Phase 1 Ecological Assessment; and

• Geo-environmental Desk Top Study.

1.04 The remainder of this Statement is set out as follows:

• Section 2 sets out the details of the application site and the proposed development;

• Section 3 sets out relevant retail planning policy, comprising the statutory development plan and

national guidance contained in the NPPF;

• Section 4 assesses the principle of development in the context of the site’s existing employment land

allocation;

• Section 5 examines the proposal in terms of the sequential approach to development;

• Section 6 assesses the likely impacts of the development (having regard to the twin tests of the

NPPF);

• Section 7 sets out other planning considerations relevant to the development proposal; and

• Section 8 summarises our findings and provides our overall conclusions.

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2.0 THE APPLICATION SITE AND PROPOSED DEVELOPMENT

The Site

2.01 The site, which extends to 1.1 hectares and is irregular in shape, was formerly used as a storage yard

but has been vacant since 2011. The majority of the site comprises hardstanding and scrubland. The

New Bodies Fitness Centre is located on the north west corner of the site. An overhead footbridge

crosses the site linking Chapel Street to the north and an industrial area to the south.

2.02 The site is bounded by the Newtown railway station car park to the west, beyond which is Albion

Road. Residential properties which front onto Chapel Street are located to the north west of the site

and industrial buildings are located to the north east of the site. An area of dense tree cover is

situated to the east of the site beyond which lies the Peak Forest Canal. The railway line bounds the

south of the site.

2.03 There are two existing vehicular access points to the site. One is located on the western boundary of

site and requires access through Newtown Station car park. The other is located on the northern

boundary of the site and is accessed via the private access road leading from Chapel Street.

2.04 The site is located within the built-up area of New Mills (Saved Policy GD2) as defined by the High

Peak Local Plan (adopted 2005) and is allocated as a Primary Employment Zone (Saved Policy EMP4).

The Proposed Development

2.05 The hybrid planning application seeks full planning permission for the development of a 1,725 sq.m

gross discount foodstore (Class A1), overflow car parking to serve Newtown railway station and

associated works, and outline planning permission for a 454 sq.m gross light industrial unit (Class B1)

2.06 The light industrial unit will be positioned at the eastern end of the site. The single storey foodstore,

which will be operated by Aldi and will provide a sales area of 1,254 sq.m, will be positioned to the

west of the light industrial unit. Customer car parking to serve the foodstore and station overflow

parking will be located on the western part of the site. Ninety-five customer car parking spaces will be

provided, including six accessible spaces and eight parent and child spaces. Seventeen additional

spaces will be provided for station overflow parking. Six further parking spaces for Aldi staff will be

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located to the east of the store building. The servicing area for the foodstore will also be located to

the east of the store.

2.07 Vehicular access to the site will be provided by an improved access off Albion Road. The current

access off Albion Road is constrained. The improved access will improve visibility and aid movements

to the proposed development, New Mills Newtown Station car park and Chapel Street. In order for an

adequate access route to be provided to serve the proposed development and adjacent station, the

demolition of New Bodies Fitness Centre is required. The removal of this building is necessary in order

to provide a suitable and safe access.

2.08 Pedestrian access to the development will be off Albion Road. A pedestrian link will be created from

the adjacent station car park. Clear pedestrian links and crossing points will also be created across the

development’s car park to provide legible and safe access to the foodstore.

2.09 The pedestrian footbridge that crosses over the site will remain insitu. The applicant has liaised with

Network Rail, the owners of the footbridge, in relation to the development proposal who have

confirmed that the bridge should remain as existing with no alterations or improvements.

2.10 Secure fencing will be installed to separate the proposed light industrial unit from the adjacent

foodstore, in order to clearly demarcate the defined uses and to ensure safety for users of the

proposed foodstore. A gated access point will be installed to control entry to the light industrial site.

2.11 A landscaping scheme has been prepared for the site. Enhanced landscaping is proposed at the

entrance of the site at either side of the main access road. The addition of landscaping at this location

will act as a buffer between the site access and the surrounding development, as well as enhancing

views of the site when viewed from Albion Road. Landscaping is also proposed within the store car

park and will act as a buffer between the car park and the service road to the south.

Aldi’s Trading Characteristics

2.12 Aldi Stores Ltd has been secured as the operator for the proposed foodstore on the site and the

proposed retail unit will be purpose built to meet the specific requirements of the operator. Aldi has

developed a distinctive retail model and trading characteristics in order to set the store apart from

mainstream supermarket operators in the UK. Aldi is a limited line deep discounter retailer of

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European origin with an established and ever growing presence in the British retail market since its

first store opened in 1990. Aldi has over 500 stores in the UK.

2.13 The Aldi trading philosophy is materially different to that of the mainstream food retail operators. The

aim of Aldi is to offer the customer high quality exclusive own label groceries at heavily discounted

prices. The key objective is to offer unrivalled value for money for the customer across the full range

of products. This is achieved through maintaining the highest levels of efficiency in every aspect of the

Aldi operation, from the way the products are sourced and supplied, through to the presentation of

the products within the individual stores. This has resulted in a type of food retailing which is unique

in its operational style and approach.

2.14 Since Aldi deliberately restricts the range of goods that are sold within their stores, they do not sell a

wide range of products which are normally found in mainstream supermarkets. Therefore, Aldi

customers will often link their shopping trip with a trip to other shopping destinations.

2.15 While Aldi stores sell a range of predominantly own label non–food goods, these take up a relatively

small amount of the net sales floorspace (at around 15%) and the goods are sold as ‘special

purchases’ on a WIGIG (when it’s gone, it’s gone) basis. This approach is often seasonal, so that there

is a constant variety in terms of the range and choice of non-food products sold in an Aldi store, with

no particular type of comparison goods predominating. In this way, the potential for an Aldi store to

compete with high street comparison retailers is relatively limited.

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3.0 PLANNING POLICY CONTEXT

3.01 This section provides a review of planning policy and guidance at the national and local level relevant

to the development proposal.

The National Planning Policy Framework (March 2012)

3.02 The main theme of the NPPF is that there should be ‘a presumption in favour of sustainable

development.’ The document stresses the Government’s commitment to securing economic growth in

order to create jobs and prosperity, with the Government seeking to ensure that the planning system

does everything it can to support sustainable economic growth.

3.03 Paragraph 24 of the NPPF sets out that local 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 stated that local planning authorities should:

‘...require applications for main town centre uses to be located in town centres, then in edge-of-

centre locations, and only if suitable sites are not available should out-of-centre sites be considered.

When considering edge-of-centre and out-of-centre proposals, preference should be given to

accessible sites that are well-connected to the town centre. Applicants and local planning

authorities should demonstrate flexibility on issues such as format and scale.’

3.04 With regard to impact, paragraph 26 of the NPPF states that:

‘When assessing applications for retail, leisure and office development outside of town centres,

which are not in accordance with an up-to-date Local Plan, local planning authorities should require

an impact assessment if the development is over a proportionate, locally set floorspace threshold (if

there is no locally set threshold, the default threshold is 2,500 square metres). 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 wider area, up to five years from the time the application is

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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 the application is made.’

3.05 Paragraph 27 indicates that, where an application fails to satisfy the sequential test or is likely to have

a significant adverse impact on one or more of the above factors, it should be refused. However,

appeal decisions and judgments have confirmed1 that this ‘direction’ does not extinguish the

requirement set out in statute to examine all material considerations and for the decision maker to

assess the ‘planning balance’ in reaching a decision.

3.06 Paragraph 19 of the NPPF sets out the Government’s commitment to supporting sustainable economic

growth through the planning system. It is explained that planning should operate to encourage and

not act as an impediment to sustainable growth. Therefore, significant weight should be placed on the

need to support economic growth through the planning system. Paragraph 22 goes on to state that:

‘Planning policies should avoid the long term protection of sites allocated for employment use

where there is no reasonable prospect of a site being used for that purpose. Land allocations should

be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated

employment use, applications for alternative uses of land or buildings should be treated on their

merits having regard to market signals and the relative need for different land uses to support

sustainable local communities.’

The Statutory Development Plan

3.07 The statutory development plan relevant to the site comprises the saved policies of the High Peak

Local Plan (adopted March 2005). The emerging High Peak Local Plan is also of relevance to the site.

The emerging Local Plan was submitted to the Secretary of State for examination in August 2014.

Once adopted, the new Local Plan will provide strategic planning guidance and details of specific sites

identified for future development or protection, covering the period from 2011 to 2031.

High Peak Local Plan (March 2005)

3.08 The site is allocated as a Primary Employment Zone (Saved Policy EMP4) in the adopted Local Plan.

This policy seeks to safeguard sites for employment development. The site is also located within the

1– Easthampstead Road, Bracknell (PINS ref. APP/R0335/A/12/2181506) and Zurich v North Lincolnshire Council (Case No.CO/4764/2012)

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built up area boundary of New Mills, as defined by Saved Policy GD2, which the Local Plan states will

provide the main focus for development.

3.09 Saved Policy EMP9 of the Local Plan relates to proposals for the change of use of industrial or business

land. The policy sets out criteria which should be met in order for the LPA to support changes in use

of industrial or business land for both mixed use development or the change of use of the whole site.

3.10 The application site is located 750m to the south west of New Mills’ Town Centre Boundary and is

therefore ‘out-of-centre’. Saved Policy TC4 of the Local Plan is therefore of relevance to the proposal,

which relates to large stores which cannot be located in existing town centres. The policy states that,

planning permission will be granted for large stores (more than 500 sq.m) out of town centres where

there are no suitable sites and no suitable buildings for conversion within the defined town centre or

edge of centre locations. The policy states that, where appropriate, proposals will be accompanied by

a Retail Impact Study to assess the likely effects of the development on the vitality and viability of any

nearby centre. The policy includes several additional criteria which must be met, for example in

relation to need and scale, however it is considered that these requirements are out of date, and have

been superseded by the requirements of the NPPF.

3.11 Saved Policy GD4 relates to the design of proposed developments. It states that planning permission

will be granted provided that a proposal’s character, form and design are sympathetic to the character

of the area, and there will not be undue detrimental effect on the visual qualities of the locality or

wider landscape. Saved Policy GD5 relates to amenity and states that planning permission will be

granted provided that it will not create an unacceptable loss of privacy or general amenity. Saved

Policy GD6 encourages the incorporation of high quality landscaping treatment in relation to new

development proposals which are in keeping with the character of the area.

3.12 Saved Policy TR1 relates to transport and states that planning permission will be granted for new

development provided that it seeks to reduce the need to travel, widens transport choice for people

and goods, and integrates transport and land uses. Saved Policy TR4 requires that where a proposed

development generates significant travel movements, a transport assessment will be required to

assess the likely effects of the development on the local transport network. Saved Policy TR5 requires

high quality access and parking arrangements to be incorporated into the design of proposed

development.

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3.13 Saved Policy BC10 of the Local Plan states that planning permission will not be granted for

development which is likely to result in harm to a Scheduled Ancient Monument or other nationally

important site, or its setting or amenity value. It is stated that elsewhere planning permission will be

granted provided that there will not be a significant adverse effect upon other known archaeological or

heritage features. Where planning permission is granted, conditions will be imposed, and/or planning

obligations sought, to ensure that archaeological or heritage features are recorded and retained intact

in situ; or where this is impractical, archaeological or heritage features are appropriately excavated

and recorded, prior to development.

Emerging High Peak Local Plan

3.14 The emerging High Peak Local Plan was submitted for examination in August 2014 and the

examination hearing sessions are due to commence in January 2015. The new Local Plan, which will

cover the period from 2011 to 2031, will set out strategic planning guidance and will identify specific

sites for future development or protection. Once adopted, the policies of the new Local Plan will

supersede the policies contained within the existing Local Plan. As the new Local Plan has not yet

been through examination, full weight cannot be attributed to the draft Local Plan policies.

Notwithstanding this, given that the plan is well progressed and has been through several rounds of

consultation it provides a clear indication of the Council’s intended position.

3.15 Emerging Policy E1 (New Employment Development) states that new business and industrial

development in sustainable locations that contribute towards the creation and retention of a wide

range of jobs, education and training opportunities will be supported.

3.16 The application site, except for the north west corner of the site where the access road is proposed, is

allocated in the emerging Local Plan as an industrial legacy site (emerging Policy E5). This policy

refers to the application site as ‘Land at New Mills, Newtown’. The policy recognises that the

application site is constrained for employment purposes due to the infrastructure and/or premises at

that location no longer being suited to meeting the needs of modern businesses. Therefore, emerging

Policy E5 seeks to achieve the following in relation to industrial legacy sites (including the application

site):

� Encouraging proposals for the redevelopment or reuse of sites which are no longer conducive to

meeting the needs of modern businesses in their present form.

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� Stimulating investment on constrained sites in order to encourage their beneficial re-use.

� Encouraging mixed-use developments, which retain or create employment opportunities on the

site, particularly those that support local economic growth sectors.

3.17 Emerging Policy DS13 relates specifically to the application site and identifies the site as the Newtown

Industrial Legacy site at Newtown, New Mills. The policy allocates the application site for a mix of uses

including housing and B1b/c uses, and states that land to provide additional parking to serve New

Mills Newtown Station should also be retained within the site. It also states that any proposals for

town centre uses on the site should accord with Policy CF1.

3.18 Emerging Policy S6 sets out the a strategy for the Central Area of High Peak, which includes New Mills.

The policy states that the Council will seek to promote the sustainable growth of the Central Area such

that it reflects the historic character of the settlement, provides an increasing range of employment

opportunities, promotes the growth of a sustainable tourist economy and meets the housing needs of

the local community. The Policy states that proposals for a new A1 foodstore will be supported in

order to address the lack of provision within New Mills, and that out-of-centre proposals will be

supported in accessible locations that are well connected to New Mills town centre by public transport.

The Policy explains that the Council will also seek to deliver additional parking to serve New Mills

Newtown railway station on the site.

3.19 Emerging Policy CF1 relates to retail and town centres. The policy states that proposals for a new A1

foodstore will be supported in order to address the lack of provision within New Mills. The policy goes

on to confirm that no town centre or edge of centre sites have been identified. The policy states that

out-of-centre proposals will therefore be supported in accessible locations that are well connected to

New Mills town centre by public transport and which comply with the impact and sequential tests.

3.20 Other policies of relevance in the emerging Local Plan include:

• Policy S1 – Sustainable Development Principles;

• Policy S1a – Presumption in Favour of Sustainable Development;

• Policy S2 – Settlement Hierarchy;

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• Policy EQ1 – Climate Change;

• Policy EQ5 – Design and Place Making;

• Policy EQ10 – Flood Risk Management; and

• Policy CF6 – Accessibility and Transport.

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4.0 PRINCIPLE OF DEVELOPMENT

4.01 The site is allocated as a Primary Employment Zone (Saved Policy EMP4) in the Local Plan. The policy

states that planning permission for employment development, including Use Classes B1, B2, B8 and

other employment generating uses, will be granted within the Primary Employment Zone. It can

therefore be concluded that the proposed light industrial use fully accords with the site’s allocation.

4.02 Policy EMP4 goes on to state that retail development will not normally be granted within the Primary

Employment Zone. In considering this policy, it is helpful to refer to paragraph 22 of the NPPF, which

states the following:

‘Planning policy should avoid the long term protection of sites allocated for employment use where

there is no reasonable prospect of a site being used for that purpose. Land allocations should be

regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated

employment use, applications for alternative uses of land or buildings should be treated on their

merits having regard to market signals and the relative need for different land uses to support

sustainable local communities.’

4.03 It is considered that the site at Albion Road constitutes a site where there is little prospect of the site

in its entirety coming forward for employment use. This is evident due to the fact that the site has

been vacant since 2011 and during this time has not come forward for employment use. Indeed, the

Council’s own evidence, in the form of the Employment Land Review Site Assessments 2014,

concludes that the site is constrained in its potential for employment use. The application site is

identified as Site Reference HPBC11 (Newtown Station) in the Employment Land Review Site

Assessments 2014, which concludes that the site is constrained and is of poor quality for employment

development with restricted access. The Council’s assessment sets out that the site is unlikely to be

viable for speculative development and that enabling development and/or public sector assistance

would likely be required to bring the site forward for development. As a result of the constraints on

the site, the assessment recommends that the site should be reallocated for mixed use development.

It is therefore clear that the Council are no longer of the view that this site should be protected for

employment use, and that for the site to be successfully brought back into use that the development

of the site for alternative uses is required.

4.04 In response to the Council’s evidence base, the emerging Local Plan (Draft Policy E5) specifies that the

application site, which is identified as ‘Land at New Mills, Newtown’ is constrained for employment

purposes due to the infrastructure and/or premises no longer being suited to meeting the needs of

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modern businesses. Indeed, the Council are seeking to remove the employment allocation in the new

Local Plan with the reallocation of the site for mixed use development. This is a clear recognition by

the Council that the employment allocation is out-of-date and that there is no reasonable prospect of

the whole site being developed for employment use. Emerging Policy E5 states, in relation to the

application site (and other industrial legacy sites), that the Council will support proposals that:

• Provide for the redevelopment or reuse of the site;

• Stimulate investment on constrained sites to encourage their beneficial re-use; and

• Encourage mixed-use development, which retain or create employment opportunities on site.

4.05 The proposed development directly accords with each of these criterion. Substantial investment is

required to bring this constrained site back into viable use and this investment will be provided by the

proposal. The scheme will generate jobs in the local area, improve the appearance of this derelict site

which has been vacant for a number of years, and will bring a much needed supermarket to the local

area.

4.06 Draft Policy DS13 of the emerging Local Plan relates specifically to the application site and seeks to

allocate the site for a mix of uses including housing and B1b/c uses, along with the provision of

additional parking to serve New Mills Newtown Station. The policy also provides an indication that

town centre uses, including retail uses, will be appropriate on the site as part of a mixed use

development, provided Draft Policy CF1 of the emerging Local Plan, which relates to town centre uses,

is accorded with.

4.07 Although full weight cannot be given to the policies of the emerging Local Plan, the Plan is well

advanced and has been submitted for Examination following several stages of consultation. It is

apparent that the Council consider the existing employment allocation on the site to be outdated and

consider that in order for this previously developed site to be successfully brought back into use a

wider mix of uses will need to be delivered on the site. We are in agreement that the site should no

longer be protected for employment use. The site is constrained for employment purposes and this is

reflected in the fact that the site has been vacant for a number of years. The application proposal will

result in the effective reuse of land by bringing this disused brownfield site back into viable use.

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4.08 It has been demonstrated that the allocation of the application site in the adopted High Peak Local

Plan as a Primary Employment Zone is outdated and that there is little prospect of the site being

delivered solely for employment use. For this reason, in accordance with paragraph 22 of the NPPF, it

is considered that this application for an alternative mixed use development on the site, with an

element of employment use, should be considered on its merits having regard to market signals and

the relative need for different land uses to support sustainable local communities.

4.09 The High Peak Retail Study Update (HPRSU) and Addendum identify a need for a new foodstore to be

delivered in New Mills. It is stated that the first priority for new convenience development in High Peak

Central should be the New Mills locality, in order to address the deficiency in main food shopping

provision, rebalance the network of centres and reduce overtrading at the existing mainstream

foodstores in the catchment. This is reiterated in the Council’s emerging Local Plan which seeks to

redress the balance in terms of shopping patterns in High Peak Central through support for proposals

for a new A1 foodstore in the New Mills locality (Draft Policy CF1). The supporting text at paragraph

5.177 states that:

‘Whilst the overall catchment retains a reasonable proportion of main food expenditure, New Mills is

currently lacking in terms of provision with a number of residents travelling to foodstores in Whaley

Bridge or elsewhere for their main food shopping. The Retail Study (Addendum) identified a

quantitative capacity of 945m2 (gross) for convenience retail in the Central Area by 2031. Due to

the need for a store to provide a comprehensive offer, the study concluded that a higher level of

floorspace could be supported. Given the spatial deficiency in the catchment, the study

recommended that New Mills should be the first priority for new development. To help broaden

range of choice in the catchment, the provision of a deep discount store is likely to be appropriate.’

4.10 The application proposal directly responds to the requirement for improved convenience shopping

provision in New Mills and accords with emerging Policy CF1. The proposed development will create

more sustainable shopping patterns, ensuring that a greater proportion of expenditure which

originates in New Mills is spent in New Mills, therefore strengthening the position of the town. Given

that there is a need for a new foodstore in New Mills to respond to the limited convenience provision

at this locality, the release of part of the site for retail use will deliver considerable benefits to New

Mills. It is considered that the application proposal is wholly appropriate at this location, particularly

given the Council’s acknowledgement that this site is constrained for employment purposes and is no

longer suited to meeting the needs of modern businesses.

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Conclusion

4.11 The Council’s evidence base and emerging Local Plan (Policy CF1) are clear that there is a requirement

for the delivery of a new foodstore in New Mills. The development proposal will directly respond to this

need through the delivery of a discount foodstore which will result in more sustainable shopping

patterns and the retention of expenditure in New Mills. It is acknowledged that the site is currently

allocated for employment use in the adopted Local Plan. However, it is evident that the site is

constrained for such use. The site has been vacant for several years and has not come forward for

this purpose, and the Council’s Employment Land Review concludes that the site is constrained for

employment use and should be reallocated for mixed use development. This is reiterated in the

emerging Local Plan (Policy E5 and DS13) which seeks to bring the site back to beneficial use through

its re-allocation.

4.12 National policy is clear that the long term protection of sites allocated for employment use where there

is no reasonable prospect of a site being used for that purpose should be avoided.

4.13 It is therefore concluded that, in accordance with national policy and the Council’s priorities for the site

and the wider New Mills area, the benefits of delivering a much needed foodstore in New Mills, along

with new employment premises and parking to serve the adjacent station, will bring substantially

greater benefits than safeguarding the whole site for employment use.

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5.0 THE SEQUENTIAL APPROACH

5.01 The principle of the proposed development in terms of the allocated use of the site was explored at

Section 4. This section considers the acceptability of the proposed foodstore on the site in the context

of the sequential approach to development.

Applying the Test

5.02 As highlighted in Section 3, paragraph 24 of the NPPF sets out the sequential approach to

development proposals for main town centre uses which are not in an existing centre and not in

accordance with an up-to-date development plan. It indicates that proposals for main town centre

uses should be located in town centres, then in edge-of-centre locations, and only then in out-of-

centre locations, should no other suitable sites be available. When considering edge-of-centre and

out-of-centre proposals, it continues that preference should be given to accessible sites that are well

connected to the town centre. It is stated that applicants and local planning authorities should

demonstrate flexibility on issues such as format and scale.

5.03 Paragraph 10 of Ensuring the Vitality of Town Centres, National Planning Practice Guidance (NPPG)

provides a checklist setting out the considerations that should be taken into account in determining

whether a proposal complies with the sequential test. The onus is on the applicant to consider:

• The suitability of more central sites to accommodate the development proposal.

• Whether there is scope for flexibility in the format and/or scale of the proposal.

5.04 The guidance states that if there are no suitable sequentially preferable locations, the sequential test

is passed.

5.05 The application site is located approximately 750m from the New Mills Town Centre Boundary as

defined in the High Peak Local Plan and therefore constitutes an out-of-centre site. As such, in

accordance with national policy, there is a requirement for the applicant to consider the suitability of

more central sites to accommodate the proposed development.

5.06 Given that the NPPF requires, when considering out-of-centre proposals, that preference should be

given to accessible sites that are well connected to the town centre, it is helpful to consider the

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accessibility of the application site. It is considered that the proposed development will occupy an

accessible position. Bus stops are located immediately adjacent to the site’s entrance on Albion Road,

which are served by bus numbers 60, 61, 62, 64, 199, 358 and 399. A frequent service is provided to

New Mills town centre from the application site thus providing the opportunity for linked trips between

the proposed foodstore and New Mills town centre. In addition, the store will be located directly

adjacent to New Mills Newtown railway station. Therefore, again there will be the opportunity for

linked trips to take place between the railway station, foodstore and the town centre, albeit some of

these linked trips between the store and town centre may take place by car.

5.07 In undertaking the sequential assessment, it is useful to take into account the Tesco Stores Limited v

Dundee City Council Supreme Court Judgment which considered the meaning of ‘suitable’ when

determining whether alternative sites are suitable for the proposed development in accordance with

the sequential test. Paragraph 38 of the Judgment states 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…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

in doing so’.

5.08 The Dundee decision has since been referred to by Inspectors in relation to subsequent appeals. In

relation to an appeal between Next and Sheffield City Council (PINS Ref: APP/J4423/A/13/2189893),

the Inspector’s decision stated at paragraph 35 that:

‘…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.’

5.09 The Inspector found that the shape of a potential sequential site precluded Next from developing a

store in its preferred format and he therefore concluded at paragraph 53 that:

‘Having regard to all the points detailed above it is my view that the extent to which Next would

have to compromise its business model to operate a H&G store from Moorfoot would be both

excessive and unreasonable. Accordingly I am satisfied that this site has been shown to be

unsuitable for the development which Next is seeking to progress, and to expect it to operate from

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such a site would clearly run counter to the principles set out in the Supreme Court ruling referred

to above.’

5.10 The above cases demonstrate that in considering suitability as part of any sequential assessment that

the specific requirements of the proposed operator (if secured) needs to be taken into account, and

that any potential alternative sites are required to be considered in terms of whether they are suitable

for the development as proposed by the applicant.

Area of Search

5.11 As we have set out at Section 4, there is a deficiency in food shopping provision in the New Mills

locality, which is recognised by the Council and their independent retail advisers. In response, the

proposed foodstore to be delivered as part of this mixed use development is required to be located in

New Mills in order to respond to this deficiency. The spatial deficiency is highlighted in the HPRSU

which sets out at paragraph 9.22 and 9.23 that:

‘...The 2009 Study specifically recommended that the Council proactively plan for a new foodstore in

the New Mills locality to address the clear spatial deficiency in main food shopping provision,

balance network of centres and reduce overtrading at the existing foodstores in the catchments

(Tesco Whaley Bridge and Morrison’s Chapel-en-le-Frith continue to trade over benchmark). The

New Mills locality therefore remains the first priority for new convenience development in the

catchment although it is our understanding that the Council has been unable to identify an

appropriate through the emerging Local Plan process. However, in accordance with the NPPF, the

Council should develop and thereafter set an appropriate policy to accommodate a new foodstore in

an accessible location which is well connected to New Mills town centre.’

5.12 The requirement for new foodstore to be delivered in New Mills is reiterated in the HPRSU Addendum

Report which states at paragraph 3.4 that:

‘...there remains a ‘location-specific’ need for a new foodstore in New Mills to address the existing

spatial deficiency in provision’.

5.13 It is evident from the findings of the Council’s own retail study, our own observations and as food

retailers are seeking representation in New Mills, that there is location-specific requirement for a new

foodstore at this location. Given that this spatial deficiency relates specifically to New Mills it would be

illogical for the area of search to be extended beyond the New Mills area. For this reason, in applying

the sequential test, we have assessed whether any suitable sites for the proposed development are

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available in New Mills town centre and in edge-of-centre locations. We have also considered other out-

of-centre sites that are well connected to the town centre.

5.14 Our approach accords with Paragraph 12 of the NPPF Ensuring the Vitality of Town Centres which

states that:

‘Use of the sequential approach should recognise that certain main town centre uses have particular

market and locational requirements which mean that they may only be accommodated in specific

locations.’

5.15 The following sites have been considered in terms of whether they are suitable and available to

accommodate the entire scheme proposed when flexibility is exercised. The sites have been identified

taking into account the High Peak Local Plan, the emerging High Peak Local Plan, WYG’s own

observations and the EGi database. In considering any sequential sites, it is helpful to take into

account the local context of New Mills. New Mills is heavily constrained due to the presence of Green

Belt land, flood plains, green wedges and the local topography, which means that there are a limited

number of potential development sites in the area. The town centre itself is constrained as the

majority of the town centre comprises small scale, historic properties, which do not meet the

requirements of the majority of modern food retail operators.

5.16 A plan of the sequential sites considered as part of our assessment is contained at Appendix 1.

Sites in and edge-of New Mills town centre

5.17 It is evident from review of the High Peak Local Plan Submission document that the Council are not

aware of any sites in or on the edge of New Mills town centre which could accommodate a new

foodstore. The Local Plan Submission document states at paragraph 5.178 that:

‘No site in New Mills town centre or edge-of-centre has been identified to accommodate

development and opportunities are limited. Consequently, proposals for a food store in an out-of-

centre location that is easily accessible to New Mills town centre will be considered...’

5.18 WYG are in agreement with the Council’s findings that there are no town centre or edge-of-centre

sites which could accommodate a foodstore development. As part of our assessment, we have

updated the latest Experian Goad Survey (December 2012) for New Mills town centre and we can

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confirm that there are no available buildings or sites within the town centre which would be capable of

accommodating the type of accommodation that is proposed.

5.19 In terms of edge-of-centre sites, for completeness, we re-assess below two sites which the Council

requested were included in the sequential assessment for the Aldi, Chapel-en-le-Frith planning

application (LPA reference: HPK/2013/0484) which was approved on the 25th November 2013.

Land to West of Market Street, New Mills

5.20 The land to the west of Market Street, which extends to 0.7 hectares, is occupied by a range of active

uses including a medical centre, Council owned car park, telephone exchange, nursery and residential

properties. The site is not currently being marketed and it understood that the site is in multiple

ownership. For this reason, WYG conclude that the site is not currently available for the proposed use.

In addition, the site is subject to several constraints which make it unsuitable for the proposed use.

The site is not of a sufficient size to accommodate the development proposal and given the multiple

ownerships present on the site, it is considered that even if it were possible to assemble an available

portion of the site, this would provide a much smaller area than required to accommodate the

proposed use. The topography of the site would also form a constraint to development as the site is

steeply sloping in parts.

5.21 In summary, the land to the west of Market Street is not available for development. There are a range

of active uses present on the site, the site is not being marketed and it is not considered that a site of

a sufficient size could be assembled to accommodate the proposed use. In addition, the site

constraints, in terms of its topography, size and multiple ownerships render the site unsuitable and

unviable for the proposed use.

5.22 The Sequential Assessment Update produced by HOW Planning in support of a planning application for

an Aldi store in Chapel-en-le-Frith also determined this site to be unsuitable, unviable and unavailable

for a discount foodstore. This assessment was accepted by the Council in their approval of the Chapel-

en-le-Frith Aldi foodstore.

Land to south of Albion Road, New Mill

5.23 The site, which extends to approximately 5.0 hectares, mainly comprises Green Belt land. National and

local policy states that the construction of new buildings in the Green Belt is not appropriate except in

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very special circumstances. The proposed use does not constitute an exception to this policy

requirement and therefore it can be concluded that the land to the south of Albion Road, New Mills

does not constitute a suitable site for the proposed development. In addition, the site is further

constrained and deemed to be unsuitable for the proposed development due to its location in Flood

Zone 3, the varying topography of the site and as the River Goyt runs through the site. The site is not

currently being marketed and there is no evidence that the site is available for the proposed use,

therefore the site is also considered to be unavailable.

5.24 In summary, it is concluded that the land to the south of Albion Road, New Mills is unavailable and

unsuitable for the proposed use. There is a policy presumption against the development of this site for

the proposed use due to its position in the Green Belt, the site is heavily constrained and the site is

not currently available.

Alternative Out-of-Centre Sites

New Mills Football Club

5.25 The New Mills Football Club site, which extends to approximately 1.7 hectares, is located

approximately 750m to the east of New Mills town centre boundary and therefore constitutes an out-

of-centre site. As the football club site is located an equivalent distance from the town centre

boundary as the application site, it is not considered to afford any appreciable sequential advantage

and therefore does not constitute a sequentially preferable site.

Conclusions

5.26 It is clearly set out in the HPRSU and in the emerging Local Plan that there is a location-specific

requirement for a new foodstore in New Mills to address the spatial deficiency in shopping provision,

to balance the network of centres in High Peak, to reduce the existing expenditure leakage out of the

area and to improve sustainable shopping patterns. The application proposal seeks to respond to this

need and given the location-specific nature of this need, the sequential assessment focuses on New

Mills as this need could not be met elsewhere.

5.27 It is acknowledged by the Council in the emerging Local Plan that there are no in-centre or edge-of-

centre sites which could accommodate a foodstore development. This is reiterated in the HPRSU and

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has been verified by our own research. In addition, our assessment has concluded that there are no

alternative out-of-centre sites which are sequentially preferable to the application site.

5.28 Our analysis has demonstrated that there are no suitable sequentially preferable locations which could

accommodate the development proposal and the proposal therefore wholly accords with the

requirements of the sequential test.

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6.0 COMPLIANCE WITH THE IMPACT TEST

Introduction

6.01 This section considers the impact of the foodstore element of the application proposal. As highlighted

in Section 3 of this Statement, paragraph 26 of the Framework sets out a twin impact test for

proposals for main town centre uses (including retail). It states that this assessment should consider:

• The impact of the proposal on existing, committed and planned public and private investment in a

centre or centres in the catchment area of a proposal, and

• The impact of a proposal on town centre vitality and viability, including local consumer choice and

trade in the town centre and wider area.

6.02 Paragraph 27 clearly sets out that planning permission should only be refused where a proposal is

likely to have a ‘significant adverse’ impact.

6.03 In seeking to consider the significance of the impacts arising from the proposed development, it

should be recognised that impacts will arise from all retail developments but these impacts will not

necessarily be adverse, as the development may have a positive impact by enhancing choice and

competition. The key challenge is to differentiate between those developments that will have an

impact and those that will fundamentally undermine the future vitality and viability of established

centres i.e. a ‘significant adverse’ impact.

Impact Considerations

6.04 The application proposal is considered below against the two retail impact tests as set out at

paragraph 26 of the Framework.

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

6.05 We are not aware of any existing, committed and planned public and private investment in New Mills,

or in any other centre which could be adversely impacted upon by the proposal.

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6.06 In modelling the trade diversion impacts arising from the application proposal (a matter which we turn

to below), we have taken into consideration a single convenience goods retail commitment within the

defined Study Area (Appendix 2) , this being the extant planning permission (reference

HPK/2103/0484) which provides for an Aldi store in Chapel-en-le-Frith. The Aldi store will be located

to the north of Chapel-en-le-Frith town centre and, as such, investment at this location is not offered

any policy protection by the NPPF.

6.07 Given the above, the application proposal clearly accords with the requirements of the first part of the

NPPF impact test.

Impact of the Proposal on Town Centre Vitality and Viability, Including Local Consumer

Choice and Trade in the Town Centre and Wider Area

6.08 In order to inform judgements as to the likely impact in relation to trade in established centres it is

necessary to consider the likely diversion of expenditure that may occur once the proposed

development is implemented and fully trading. The National Planning Practice Guidance (NPPG)

provides a check list of the stages which should be followed in applying the impact test as follows:

• establish the state of existing centres and the nature of current shopping patterns (base year);

• determine the appropriate time frame for assessing impact, focusing on impact in the first five

years, as this is when most of the impact will occur;

• examine the ‘no development’ scenario (which should not necessarily be based on the assumption

that all centres are likely to benefit from expenditure growth in convenience and comparison

goods and reflect both changes in the market or role of centres, as well as changes in the

environment such as new infrastructure);

• assess the proposal’s turnover and trade draw (drawing on information from comparable

schemes, the operator’s benchmark turnover of convenience and comparison goods, and carefully

considering likely catchments and trade draw);

• consider a range of plausible scenarios in assessing the impact of the proposal on existing centres

and facilities (which may require breaking the study area down into a series of zones to gain a

finer-grain analysis of anticipated impact);

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• set out the likely impact of that proposal clearly, along with any associated assumptions or

reasoning, including in respect of quantitative and qualitative issues; and

• any conclusions should be proportionate: for example, it may be sufficient to give a broad

indication of the proportion of the proposal’s trade draw likely to be derived from different centres

and facilities in the catchment area and the likely consequences to the viability and vitality of

existing town centres.

6.09 WYG’s approach to each of these steps is set out below.

Establish the state of existing centres and the nature of current shopping patterns

6.10 In order to assess the impact of the proposal on town centre vitality and viability, an evaluation of the

current health of New Mills town centre has been undertaken. This involved WYG visiting the centre in

November 2014 to gather evidence in order to analyse the centre against the following indicators,

which are set out in the NPPG, to be used to determine the health of town centres:

• Diversity of uses;

• Proportion of vacant street level property;

• Commercial yields on non-domestic property;

• Customer views and behaviour;

• Retailer representation and intention to change representation;

• Commercial rents;

• Pedestrian flows;

• Accessibility;

• Perception of safety and occurrence of crime; and

• State of town centre environmental quality.

6.11 The full health check of New Mills is contained at Appendix 3. In summary, the town centre comprises

a traditional high street format which is focused on Market Street, Union Road and High Street. The

majority of retail units are occupied by independent operators, with a limited number of national

multiple retailers present in the centre. The town centre is located in a Conservation Area and is

characterised by traditional, small scale, terraced units. 80 units are present in the centre in total,

which provide 7,490 sq.m gross floorspace.

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6.12 New Mills provides a reasonable proportion and range of retail and service floorspace; the proportion

of convenience, retail service, leisure service and financial and business service floorspace in the

centre is greater than the respective national average figures. Notwithstanding this, the centre is

lacking in terms of supermarket provision. The vacancy rate in the centre is low; the proportion of

vacant units (8.8%) is below the national average figure (11.5%). At the time of WYG’s visit to the

centre, New Mills was reasonably busy and it is considered that New Mills provides a valuable role in

catering for the day-to-day needs of local residents. The centre is accessible on foot from the

surrounding residential areas. In addition, the centre is well served by public transport. The

environment quality of the centre is good, the centre is clean and well maintained, and the centre’s

special architectural and historic interest is recognised by the centre’s inclusion within the New Mills

Conservation Area. Overall, it is considered that New Mills performs well against the key indicators of

health, as set out in the NPPG, and it is concluded that New Mills is a vital and viable centre.

6.13 It is also helpful to refer to the floorspace survey of New Mills undertaken by GVA as part of the

HPRSU in considering the health of New Mills. GVA conclude in relation to New Mills, with reference to

the latest Goad survey (December 2012) at the time of preparing the HPRSU, that ‘...notwithstanding

the limited convenience and comparison retail offer, the town centre is a viable destination with low

vacancy levels.’ (paragraph 4.32). This is an indication that GVA also considered New Mills to be a

healthy centre.

6.14 Notwithstanding the fact that both WYG and GVA have concluded that New Mills is a vital and viable

town centre, it is considered that there is the opportunity for the health of New Mills to be improved

further through the development of a supermarket in the locality. It is considered that a supermarket

would act to retain expenditure in the area which is currently being leaked to surrounding centres, and

would provide the opportunity for linked trips between the supermarket and town centre, (albeit a

proportion of these trips may take place by car).

6.15 In terms of current shopping patterns, as we set out in Section 4, the HPRSU concludes that as a

result of the limited main food shopping provision in New Mills, customers are currently travelling from

New Mills to other areas in the High Peak to meet their main food shopping needs. This is resulting in

significant trade leakage from New Mills to main food shopping destinations elsewhere, mainly to the

Morrison’s in Chapel-en-le-Frith and Tesco in Whaley Bridge. The HPRSU and the emerging Local Plan

advise that a new foodstore is required in New Mills to respond to the existing deficiency in

convenience shopping provision in the locality.

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6.16 The proposed development will act to rectify this imbalance in shopping patterns, through the

retention of expenditure within New Mills which is currently leaked elsewhere. The proposed

development will deliver substantial economic and sustainability benefits through the promotion of

more sustainable shopping patterns and strengthening the offer of New Mills. By retaining expenditure

within the New Mills area the opportunity for linked trips between the foodstore and New Mills town

centre will be increased.

Determine the appropriate time frame for assessing impact

6.17 The baseline has been established as 2013 in accordance with the HPRSU. The design year has been

established as 2018. This accords with the guidance provided by the NPPG which states that the

design year for impact testing is conventionally taken as the second full calendar year of trading after

opening. We would expect the discount foodstore to be open for trading by 2016, based on planning

permission being granted in 2015, and therefore 2018 represents an appropriate year to test impact.

We acknowledge that the NPPF states that impact should be assessed up to five years from the time

the application is made i.e. 2019. However, it is considered that taking into account both the NPPF

and NPPG, and the characteristics of the development proposal, that 2018 provides an appropriate

year to test impact.

Examine the ‘no development’ scenario

6.18 In undertaking the impact assessment, we have utilised the population and expenditure figures set out

in the HPRSU which is up-to-date and therefore forms a reliable basis for the assessment. As a result

of the increases in population and expenditure in High Peak Central which take place between 2013

and 2018, if no development were to take place it can be assumed that the expenditure captured by

existing facilities will increase. If new floorspace were to be delivered, or improvements were to take

place to existing floorspace outside of the catchment during this period, this could result in the

additional expenditure leaking from the catchment.

Assess the proposal’s turnover and trade draw

6.19 As set out at Table 6.1 below, we estimate that the turnover of the proposed discount foodstore will

be £11.8m at 2014. This is based on the 1,066sq.m net convenience goods floorspace trading at a

sales density of £8,952 per sq.m and 251 sq.m net comparison goods floorspace trading at a sales

density of £8,952 per sq.m at 2013. It should be noted that this total turnover figure effectively

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equates to 105% (85% convenience/20% comparison) of the total sales area (1,254 sq.m) in order to

allow a degree of flexibility to the operator in terms of the convenience and comparison goods split.

Therefore, in reality, the total turnover at 2014 will be less than the total turnover which has been

tested. The sales densities are in accordance with Aldi’s company average sales densities derived from

Mintel Retail Rankings 2014 at 2012 prices.

Table 6.1 – Proposed Aldi Foodstore Turnover Gross

Floorspace

(sq.m)

Net

floorspace

(sq.m)

Sales

Density (£

per sq.m)

Total

Turnover

2014 (£m)

Total

Turnover

2018 (£m)

Total

Turnover

with Inflow

Allowance

2018 (£m)

Total 1,725 1,254 - 11.8 11.9 10.7

Convenience Goods - 1,066 8,952 9.5 9.4 8.5

Comparison Goods - 251 8,952 2.2 2.5 2.2

Source: Appendix 4, Table 4

6.20 The turnover of the proposed development at 2018 (the ‘test’ year) has been calculated by increasing

the productivity of convenience and comparison goods floorspace in accordance with Experian Retail

Planner Briefing Note 12.1 Figure 4a and 4b. This increases the turnover of the proposed foodstore to

£11.9m at 2018. As it is assumed that 10% of the store’s turnover will be derived from outside the

Study Area, it is considered that the total turnover of the store derived from within the Study Area at

2018 will be £10.7m.

6.21 In assessing the trade draw to the proposed development, a number of factors, including the physical

location of the proposed development, the local geography and transport networks, the scale of the

proposal, the location of competing centres/competing facilities and the current shopping patterns

within the catchment based on the household survey supporting the HPRSU have been reviewed.

Taking these factors into consideration, we assume that the majority of the store’s trade draw will be

from Zone 2. Additional customers will be drawn from throughout the Study Area.

Assess the impact of the proposal on existing centres and facilities

6.22 Table 5 of Appendix 4 sets out our estimates of trade diversion from the proposed development in

terms of the convenience goods floorspace proposed. This assessment has been derived from the

results of the household survey which informed the HPRSU, the range and location of competing

facilities, the scale and quality of the development and its ability to alter current shopping patterns.

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The trade diversion assessment has taken account of the committed Aldi development at Chapel-en-

le-Frith to provide a cumulative assessment of the impact.

6.23 Based on the detailed assessment of trade diversion set out at Table 5 of Appendix 4, we estimate

that the greatest impact of the proposed foodstore will be on the committed Aldi store to the north of

Foresters Way at Chapel-en-le-Frith and the out-of-centre Tesco store at Whaley Bridge.

6.24 It is estimated that £1.70m will be diverted from the Aldi store. We consider this to be a reasonable

judgement given the overriding principle ‘like affects like’ and the fact that it will be more convenient

for consumers residing in New Mills and areas to the north of New Mills to visit an Aldi store in New

Mills rather than travelling to Chapel-en-le-Frith. The committed Aldi store, north of Foresters Way is

situated in an out-of-centre location and therefore is not protected in terms of the impact test.

Notwithstanding this, the Chapel-en-le-Frith Aldi store would continue to operate successfully at the

reduced post-impact turnover. This is evident due to the fact that Aldi consider it to be commercially

viable to open new stores in both Chapel-en-le-Frith and New Mills.

6.25 It is estimated that £1.70m would be diverted from the Tesco store to the north of Whaley Bridge.

This is considered to be a reasonable judgement given that the Tesco store at Whaley Bridge forms

the closest mainstream main food shopping destination to New Mills and, as concluded by the HPRSU,

customers are currently travelling from New Mills to this store to undertake their main food shopping.

The proposed discount foodstore provides the opportunity for these trips to be undertaken in a more

convenient location in New Mills, thereby reducing the need to travel. The impact on the Tesco store

would not constitute a significant adverse impact on the store. Notwithstanding this, the store is

located in an out-of-centre location and therefore is not protected in terms of the impact test.

6.26 It is considered that £1.53m of the proposed foodstore’s turnover would be derived from the

Morrisons store on the edge of Chapel-en-le-Frith town centre. Again, this is considered to be a

reasonable assessment, as currently people are travelling from New Mills to the Morrisons to satisfy

their main food shopping needs. It is considered that the provision of the Aldi foodstore in New Mills

will act to claw back some of the expenditure which currently leaks from New Mills to the Morrisons

store. The post-impact turnover of the Morrisons store would be £30.03m, which is substantially

greater than the benchmark turnover (£18.30m) of a store of this size, as identified in the HPRSU. It is

therefore evident that, as the Morrisons store would continue to trade above company average, the

impact on this store would not be significantly adverse.

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6.27 Given the deficiencies in main food shopping provision in New Mills, only a very small proportion of the

proposed store’s trade will be diverted from the Co-operative Food store on Church Road, the

Sainsbury’s Local on Torr Top Street or other local shops in New Mills town centre. These stores

largely cater for day-to-day top-up shopping needs, as demonstrated by the HPRSU, and as such the

proposed Aldi store will act to complement the existing top-up shopping offer in New Mills. It has been

estimated that £0.28m will be diverted from the Co-operative Food store, £0.02m will be diverted from

the Sainsbury’s Local and £0.13m will be diverted from local shops in New Mills. In considering the

impact of the proposed development on these smaller stores, we believe that basing the impact

assessment on the survey derived turnovers of these stores from the HPRSU may be misleading. It is

likely that the household survey undertaken as part of the HPRSU may have underestimated the

turnover of these stores, as it is commonplace with any such survey for respondents to focus on the

location where they regularly undertaken their main food shopping, rather than referring to food

shopping destinations which they may visit for smaller purchases or on a less frequent basis. Indeed,

from our own observations the Sainsbury’s Local Store in New Mills appears to be trading well and was

busy at the time of our visit. For this reason, it is considered that the percentage trading impacts

detailed at Table 5 of Appendix 4 are likely to be overestimated and that in actuality the percentage

impact on each of these stores would be far less.

6.28 It is therefore considered that the small proportion of trade to be diverted from the Sainsbury’s Local

and other local shops would not have a significant adverse impact on the performance of these stores

and would certainly not result in their closure. In turn, there would not be a significant adverse impact

on New Mills town centre. Indeed, through the claw back of expenditure to New Mills which currently

leaks to main food shopping destinations elsewhere, there would be the potential for additional linked

trips or spin off benefits. The provision of a much needed foodstore in New Mills will increase the

attraction of New Mills, thus strengthening the town centre. As the Co-operative Food store to the

south of New Mills is located in an out-of-centre location it is not protected in terms of the impact test.

Notwithstanding this, it is not considered that the small proportion of the proposed Aldi store’s trade

to be diverted from the Co-operative Food store would result in a significant adverse impact on the

store.

6.29 Given that the proposed store will be focused on the provision of a convenience goods offer, with a

maximum of 251 sq.m of the store’s net sales floorspace to be dedicated to the sale of comparison

goods, it is not considered necessary for a detailed analysis of the comparison goods trade diversion

to the store to be undertaken. As set out at Section 2, the majority of the store’s comparison goods

offer relates to ‘special purchases’ on a WIGIG (when it’s gone, it’s gone) basis. This approach is often

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seasonal, so that there is a constant variety in terms of the range and choice of non-food products

sold in an Aldi store, with no particular type of comparison goods predominating. In this way, the

potential for an Aldi store to compete with high street comparison retailers is relatively limited. It is

evident that due to the limited sales area to be devoted to comparison goods, that the impact on

existing protected retailer destinations will be extremely limited and will certainly not result in a

significant adverse impact. The total comparison goods turnover of the store will be £2.2m. Therefore,

given that, in accordance with the HPRSU, comparison goods expenditure in High Peak Central is

estimated to grow by £50.0m between 2013 and 2018, the expenditure growth alone is sufficient to

support the proposed store.

Conclusions

6.30 Our assessment has demonstrated that the proposed foodstore development would not have a

significant adverse impact in terms of both existing, committed and planned public and private

investment in a centre or centres in the catchment area of a proposal, and town centre vitality and

viability, including local consumer choice and trade in the town centre and wider area.

6.31 It is therefore concluded that the impact test as set out at paragraph 26 of the NPPF is satisfied.

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7.0 OTHER MATERIAL CONSIDERATIONS

Design

7.01 A Design and Access Statement (DAS), prepared by The Harris Partnership, is submitted as part of the

planning application. The DAS appraises the design of the development scheme in the context of the

site and its surroundings.

7.02 The majority of the site has been vacant for several years and was most recently used for the storage

of vehicles. The application proposal will deliver improvements by bringing the vacant site back into

viable use.

7.03 The layout of the scheme has been developed taking into account at range of factors including: site

levels, existing landscaping, the location of adjacent properties, accessibility and operator

requirements. The foodstore and industrial unit are located to the east of the site to ensure that the

amenity of the residential properties to the north west of the site is preserved and in order to avoid

any conflicts with the existing overhead footbridge. The provision of car parking to the west, including

additional parking to serve New Mills Newtown Station, forms a logical extension to the existing

station parking. The only external plant and servicing areas are provided at the eastern end of the

site, thus ensuring no conflicts with the residential properties to the west.

7.04 The single storey foodstore provides a contemporary and functional design, at the same time as

respecting the local context. The foodstore has been orientated to provide a glazed front elevation

facing west in order to provide an active frontage to those approaching the store from Albion Road

and Chapel Street. The materials have been carefully selected to provide a contemporary feel to the

development, as well as complementing the surrounding area. Materials include split faced stonework

cladding, with elements of stone coloured render, brick and glazing. A canopy is incorporated to

signify the store entrance.

7.05 The scheme provides clear pedestrian routes through the site and ensures legible links are provided to

Albion Road, Chapel Street and the railway station. The improved access arrangement has been

designed to improve the currently confusing junction at the entrance to the site. Landscaping has

been incorporated at either side of the site entrance to improve views of the site when viewed from

Albion Road.

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7.06 The development is compatible with adjacent existing land uses and complements the surrounding

area in terms of its scale, massing, style, siting and use of materials. It is considered that the

proposed scheme represents a significant improvement by bringing this currently vacant site back into

use and represents an opportunity for this underused site to be enhanced. The development accords

with the NPPF and Saved Policies GD4, GD5 and GD6 of the High Peak Local Plan.

Sustainability

7.07 The proposal will bring this currently vacant site back into viable use. The proposal therefore accords

with paragraph 17 of the NPPF which seeks to encourage the effective use of land by reusing land

that has been previously developed. The development site is located within the built up area of New

Mills, as defined by the High Peak Local Plan proposals map, and is accessible by foot, bike and public

transport. The development proposal should therefore encourage sustainable travel patterns.

7.08 The Design and Access Statement submitted with the planning application provides details in relation

to the sustainable measures that will be incorporated into the proposed development. In summary,

the proposal has been designed to: minimise energy use; incorporate sustainable building materials;

use suitable construction methods; and minimise waste generation. The site will be carefully managed

during construction and operation to ensure that sustainability measures are effectively managed.

7.09 The application proposal accords with the NPPF as the development involves the efficient and effective

re-use of a previously developed site, is served by sustainable modes of transport and incorporates

sustainability measures.

Transport and Accessibility

7.10 The planning application is accompanied by a Transport Assessment (TA), prepared by Turner Lowe

Associates. The TA explains that the site is located in an accessible and sustainable location. The site

is located in proximity to existing residential areas and is in easy walking distance of a wide

catchment. Bus stops are located directly adjacent to the application site on Albion Road. Several bus

services use these routes including the 61, 62, 64, 199 and 358, with frequent services from the

application site to New Mills town centre. Secure cycle parking facilities are to be provided as part of

the development to encourage the use of this mode of transport. The TA concludes that the location

of the development is well suited to encourage trips by shoppers and staff to be made by alternative

forms of transport to the private car.

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7.11 The TA explains that the current access at the confluence of Albion Road, Chapel Street and the New

Mills Newtown railway station is complicated, confusing and unsafe. As part of the development

proposal, this junction will be improved and simplified to provide safer access arrangements to and

from Albion Road, Chapel Street, the railway station and the proposed development. In order to

provide a suitable and safe access at this location the demolition of the New Bodies Fitness Centre is

required.

7.12 It is also recommended that the bus stops adjacent to the application site on Albion Road be relocated

slightly in order to improve highway safety at this location; this could be incorporated into the highway

works to be provided as part of the development.

7.13 The TA considers the number of car borne trips likely to be generated by the proposed store in

conjunction with present and likely future traffic flows in the vicinity of the site. It is concluded that

the light industrial unit proposed as part of the development will generate significantly less vehicle

movements when compared to the previous industrial use on the site. In terms of the proposed

foodstore use, it is concluded that the effects of the development in the vicinity of the site in terms of

traffic movements would be minimal and beyond the site access, the effects of development traffic

would be unnoticeable. It is concluded that the proposed new access arrangements would result in no

queuing problems in the busiest peak period.

7.14 The proposed development will not have any adverse impact on the local highway network, and high

quality access and parking arrangements have been incorporated in the design of the proposed

development. It can therefore be concluded that the proposed development accords with the NPPF

and Saved Policy TR1, TR4 and TR5 of the Local Plan.

Ground Conditions

7.15 The planning application is accompanied by a Preliminary Risk Assessment (PRA), prepared by DTS

Raeburn. The PRA assesses the condition of the site in order to establish any risks relating to ground

conditions.

7.16 The assessment concludes that the risk to the long-term health of future site users is generally

considered to be low. The works undertaken to date suggest that there is little or no likelihood of a

significant problem being revealed on the site in relation to the ground conditions. Notwithstanding

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this, it is recommended that intrusive investigations are undertaken to confirm the extent of any

ground contamination.

7.17 WYG can therefore conclude that the development will not be unduly adversely affected in relation to

contaminated land, the site can be redeveloped without adversely affecting the safety, stability or

environmental quality of neighbouring or associated land and the development will not lead to

materially harmful levels of pollution, in accordance with the requirements of the NPPF and Policy

GD12 of the adopted High Peak Local Plan.

Flood Risk

7.18 A Flood Risk Assessment (FRA), prepared by WYG Engineering, has been submitted in support of the

planning application. The site is within Flood Zone 1 which has less than a 1 in 1000 annual probability

of flooding in any one year. However, the site’s area is slightly greater than 1 hectare and therefore a

FRA is required to fully assess the development’s implications.

7.19 The FRA concludes that the site is at low risk of flooding from fluvial, pluvial, overland flow,

groundwater and reservoir failure. It finds that there is a low to medium risk of flooding from

groundwater and surface water flooding.

7.20 It is proposed that surface water from the site will be drained by a new gravity surface water sewer

which will discharge into the existing United Utilities combined sewer to the north of the site. Surface

water flows will be attenuated to ensure that peak flows are restricted to 5 l/s by means of a flow

restrictor device. In terms of foul drainage, it is proposed that the development will be drained by a

gravity drainage system discharging into the public combined sewer system which traverses the site.

7.21 In accordance with the requirements of the NPPF, the proposed development has been directed to a

site which is at low risk of flooding and the proposals will not result in an increased risk of flooding

elsewhere. WYG therefore conclude that the scheme should be deemed acceptable in relation to flood

risk.

Noise

7.22 A Noise Assessment, prepared by WYG, has been undertaken to establish existing noise levels at the

site and predict any potential noise impact of the proposal. The potential noise sources which have

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been considered include the building services plant, good deliveries and customer car parking. The

cumulative impact of the foodstore and industrial unit has been considered on the basis of worst case

scenario assumptions.

7.23 The Noise Assessment concludes the noise levels at existing receptors are predicted to fall below the

Lowest Observed Adverse Effect Level (LOAEL) and therefore the development proposal will not have

an unacceptable impact as a result of new noise sources.

7.24 WYG can conclude that the proposed development will not have a significant adverse impact in terms

of general amenity, health or quality of life and therefore it can be concluded that the proposed

development accords with Saved Policy GD5 of the Local Plan and the NPPF.

Ecology

7.25 An Extended Phase 1 Habitat Report is submitted with the application submission, which has been

prepared by WYG. The Report assesses the site’s potential to support legally protected species or

species of nature conservation importance.

7.26 The site has been assessed for great crested newts, reptiles, badgers, otters, water voles and white-

clawed crayfish. The survey concludes that each of these species is not present on the site, or is

unlikely to be present on the site, and therefore that no further surveys are required.

7.27 In order to ensure the protection of nesting birds, the survey recommends that any works, such as

vegetation clearance, that have the potential to disturb nesting birds should be avoided during the

bird breed season, and that if such works are necessary during the bird breeding season that the site

is checked for nesting birds in advance of works commencing.

7.28 As the invasive species giant hogweed has been identified on the site, a method statement will be

prepared prior to the commencement of development which will outline the procedures which will take

place in order to prevent the spread of the invasive species.

7.29 The internal inspection of the roof void of the New Bodies Fitness Centre found evidence of brown

long-eared bats having roosted in the roof void. It is therefore recommended that further nocturnal

surveys are undertaken to establish the roost status to inform a European Protected Species Licence

from Natural England, and that mitigation and enhancement measures are introduced to provide

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roosting opportunities elsewhere. The remainder of the site was found to be of very low quality for

foraging/commuting habitat for local bats.

7.30 In accordance with the NPPF, the development has taken into account ecological features on the site.

Mitigation and enhancement measures are proposed in order to respect and preserve the habitats and

species on the site.

Archaeology

7.31 An archaeological scoping assessment, prepared by WYG, is submitted in support of the planning

application submission. The assessment has been prepared in response to emerging Local Plan policy

DS13 which requires proposals for the application site to be supported by an archaeological

assessment. The assessment considers all buried and upstanding archaeological remains, built

heritage sites, historic landscapes and any other features that contribute to the archaeological and

historic interest of the site and surrounding area.

7.32 The assessment concludes that there is very low potential for any previously unrecorded remains to

survive within the development site boundary. In response, no further mitigation measures in relation

to unrecorded archaeological remains are considered necessary. It is recognised that the proposed

development will require the demolition of the New Bodies Fitness Centre, a former Methodist Chapel,

on Chapel Street. The removal of this building is required in order to develop an improved and safe

access to serve both Newtown Station car park and the proposed development. Due to the existing

constrained access to the site, it would not be possible for the proposed development to operate

without the widening and improvements to this access point. It is considered that the improvements

to the access arrangements at this location, and the other benefits of the scheme, including job

creation, bringing this long term vacant site back into use, providing much need foodstore provision in

New Mills and providing additional station car parking, outweigh the loss of this non-designated

building. Notwithstanding this, the applicant would be happy to accept a condition requiring the

building to be subject to a historic building survey prior to its removal.

7.33 It can therefore be concluded that the proposed development accords with Saved Policy BC10 of the

Local Plan as the proposed development will not result in a significant adverse impact upon

archaeological features, and the loss of the New Bodies Fitness Centre (a former Methodist Chapel),

could be mitigated through its recording.

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Other Material Considerations

7.34 The proposed development will make a contribution to the local economy through the creation of new

job opportunities. It is estimated that up to 40 FTE jobs will be created within the store. In addition to

these positions, further jobs will be created during the construction process and through the supply

chain. It is likely the majority of the jobs created will be available to those in the local area. The NPPF

sets out that planning should operate to encourage and not act as an impediment to sustainable

growth and therefore that significant weight should be placed on the need to support economic

growth through the planning system. It is evident that the proposed development will make a

significant contribution to local economic growth.

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8.0 CONCLUSION

8.01 This Planning and Retail Statement has been prepared by WYG Planning on behalf of Kirkland

Developments Limited in support of a hybrid planning application for a mixed use development at land

off Albion Road, New Mills. Full planning consent is sought for the demolition of the New Bodies

Fitness Centre on Chapel Street and the development of a foodstore (Class A1), Newtown Station

overflow car parking and associated access, parking, servicing, facilities and landscaping. Outline

planning consent is sought for the development of a light industrial unit (Class B1).

8.02 The Statement has provided an overview of national and local planning policy relevant to the planning

application. It has set out the case for the proposed mixed use development on this vacant site in the

New Mill’s built up area. The development proposal directly responds to the requirement for a new

foodstore to be delivered in New Mills, as set out in the Council’s own evidence base and the emerging

Local Plan. Although the site is allocated for employment use in the adopted Local Plan, it is evident

that there is no reasonable prospect of the whole site being used for this purpose. The site has been

vacant for several years and has not come forward for employment use, and the Council’s

Employment Land Review concludes that the site is constrained for such use and should be reallocated

for mixed use development. This is reiterated in the emerging Local Plan (Policy E5 and DS13) which

seeks to bring the site back to beneficial use through its re-allocation. The proposal for a mixed use

development on the site, including a much needed foodstore, a light industrial unit and parking to

serve the adjacent station will bring substantially greater benefits than safeguarding the whole site for

employment use.

8.03 The Statement has demonstrated that there are no suitable sequentially preferable locations which

could accommodate the foodstore element of the scheme, and that the foodstore will not have a

significant adverse impact on the vitality and viability of New Mills town centre. It is therefore

concluded that the proposed development satisfies both the sequential and impact tests as set out in

the NPPF.

8.04 It has also been demonstrated that the proposed development complies with national and local

planning policy requirements with regard to design, highways and access, amenity and environmental

issues.

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8.05 It can be concluded that the application proposal accords with the NPPF, the emerging High Peak

Local Plan and up-to-date saved policies of the adopted High Peak Local Plan and therefore it is

considered that planning permission should be granted.

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Appendices

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Appendix 1 – Sequential Sites

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1

2

3

Application Site

Albion Road, New MillsSequential Sites

Ordnance Survey © Crown Copyright 2014. All rights reserved.

Licence number 100022432. Plotted Scale - 1:7500

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Appendix 2 – Study Area

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Appendix 3 – Health Checks

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Albion Road, New Mills

Health Check Assessment

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Health Check Assessments

Introduction

The National Planning Policy Framework (NPPF) requires that when assessing applications for retail development outside of towncentres, which are not in accordance with an up-to-date Local Plan, local planning authorities should require an impactassessment if the development is over a proportionate, locally set threshold (if there is no locally set threshold, the defaultthreshold is 2,500 sq.m).

The impact test is required to include an assessment of the proposal on town centre vitality and viability, including localconsumer choice and trade in the town centre and wider area. The NPPF states that if an application is likely to have asignificant adverse impact on town centre vitality and viability that the application should be refused.

In making a judgement about whether or not the future of any centre will be significantly adversely affected, it is important tounderstand the current performance and health of centres which will be impacted upon and how their role and function mayunderstand the current performance and health of centres which will be impacted upon and how their role and function maychange as a result of the impacts arising.

National Planning Policy Guidance sets out the indicators which should be used to determine the health of town centres asfollows:

• Diversity of uses

• Proportion of vacant street level property

• Commercial yields on non-domestic property

• Customer views and behaviour

• Retailer representation and intention to change representation

• Commercial rents

• Pedestrian flows

• Accessibility

• Perception of safety and occurrence of crime

• State of town centre environmental quality

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Health Check Assessments

In order to determine the significance of any impacts arising with regard to the proposed development at Albion Road, NewMills, a review of the health of New Mills town centre has been carried out which focuses on the health check indicators set outabove.

In order to assess the health of New Mills town centre, WYG visited the centre in November 2014 to gather evidence to analysethe centre against the commonly used health check indicators.

The most recent retail study undertaken in High Peak Borough is the High Peak Borough Council and Staffordshire MoorlandsDistrict Council Quantitative Retail Study Update (HPRSU), which was prepared by GVA in October 2013, and the subsequentAddendum Report (February 2014). The HPRSU includes a survey of the floorspace present in New Millls town centre, theresults of which are referred to in this assessment where relevant. Notwithstanding the recently prepared HPRSU, we haveundertaken our own assessment in order to provide the most up-to-date position in terms of the retail climate in New Mills.undertaken our own assessment in order to provide the most up-to-date position in terms of the retail climate in New Mills.

Other data sources which have been drawn upon in producing the health checks include Experian GOAD, Estates Gazette anddata obtained from local property agents.

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New MillsCENTRE OVERVIEW

New Mills is defined as a town centre by the adopted High Peak Local Plan (March 2005). The Local Plan describes New Mills as having a strong identity characterised by traditional shopping areas. The emerging High Peak Local Plan, which has been submitted for independent examination, seeks to retain New Mill’s town centre status and describes the town as providing a traditional high street with its character protected by a Conservation Area. The emerging Local Plan recognises that there is a need for a new foodstore in New Mills to address the current lack of provision. New Mills town centre is located approximately 750m to the north east of the application site.

New Mills town centre is linear in form, with a range of mainly small scale retail units located in a traditional high street format along Market Street, Union Road and High Street. The main convenience goods offer in the centre is provided by the Sainsbury’s Local foodstore on Torr Top Street. The majority of retail units are occupied by independent retailers, however, there are a limited number of national multiple retailers present in the town.

The main town centre car parks are located at the southern end of Torr Top Street and to west of Market Street. On street parking, which is subject to time restrictions, is also present throughout the town centre.

There are 80 units present in the town centre, in accordance with the Experian Goad town centre boundary, which provide 7,490 sq.m gross floorspace.

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New MillsDIVERSITY OF USES

Previous Number of Units

No.New Mills town centre

Convenience 7 8.9%

Comparison 21 26.6%

Retail Service 13 16.5%

Leisure Service 17 21.5%

Financial and Business Service 14 17.7%

Vacant 7 8.9%

Total 79 100.0%

Previous Floorspace

Sq.mNew Mills town centre

Convenience 1,207 16.4%

Comparison 1,755 23.8%

Retail Service 789 10.7%

Leisure Service 1,793 24.3%

Financial and Business Service 1,170 15.8%

Vacant 668 9.0%

Total 7,382 100.0%

Previous amount of floorspace in New Mills town centre (December 2012)Previous number of units in New Mills town centre (December 2012)

Source: Experian Goad Data – December 2012 Source: Experian Goad Data – December 2012

Existing Number of Units

No.New Mills town

centre UK

Convenience 8 10.0% 8.3%

Comparison 22 27.5% 32.7%

Retail Service 12 15.0% 14.0%

Leisure Service 18 22.5% 22.3%

Financial and Business Service 13 16.3% 10.9%

Vacant 7 8.8% 11.5%

Total 80 100.0% 100.0%

Existing Floorspace

Sq.mNew Millstown centre UK

Convenience 1,260 16.8% 14.9%

Comparison 1,730 23.1% 36.3%

Retail Service 760 10.1% 7.4%

Leisure Service 1,860 24.8% 23.1%

Financial and Business Service 1,200 16.0% 8.3%

Vacant 680 9.1% 9.3%

Total 7,490 100.0% 100.0%

Existing number of units in New Mills town centre (November 2014) Existing floorspace in New Mills town centre (November 2014)

Source: Experian Goad Data – December 2012 Source: Experian Goad Data – December 2012

Source: Site survey and Experian Goad Data – November 2014 and UK average from

the Experian Goad Category Report (May 2014)

Note. based on Experian Goad town centre boundary

Source: Site survey and Experian Goad Data – November 2014 and UK average from

the Experian Goad Category Report (May 2014)

Note. based on Experian Goad town centre boundary

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New Mills

Land Use Plan for New MillsTown Centre

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New Mills

DIVERSITY OF USES

There is a reasonable range of convenience goods units present in New Mills town centre, with the proportion of units (10.0%)and floorspace (16.8%) present in the centre being above the respective national average figures of 8.3% and 14.9%. The main convenience goods offer is provided by the Sainsbury’s Local store (710 sq.m gross), with an additional offer provided by two bakers, two greengrocers, a butchers, an off licence and a shoe repair shop. Although the centre does provide a reasonable convenience goods offer, including a range of fresh food items, it is apparent that the centre is lacking a supermarket. The proportion of convenience goods floorspace in the town centre has remained relatively stable since 2012.

New Mills provides a good range of service uses for a centre of its scale. The proportion of retail service units (10.1%), leisure service units (24.8%) and financial and business service units (16.0%) are above the respective national average figures of 7.4%, 23.1% and 8.3%. The centre provides a range of key service uses, including nine health and beauty units, an opticians, five cafes, eight take aways and three banks. National multiple service operators present in New Mills include Barclays, Betfredfive cafes, eight take aways and three banks. National multiple service operators present in New Mills include Barclays, BetfredLloyds TSB, Natwest and the Post Office. Since 2012, the proportion of retail, leisure and financial/business service floorspace in New Mills town centre has remained relatively stable.

There are 22 comparison goods units in New Mills town centre which provide 1,730 sq.m floorspace. The proportion of comparison goods units (27.5%) and floorspace (23.1%) is less than the respective national average figures of 32.7% and 36.3%. Notwithstanding this, it is considered that New Mills provides a good range of comparison goods units including an artdealers, book shop, chemist, clothes shop, two electrical shops, a florist, a shoe shop, two furniture shops, a card shop, a hardware store, a phone shop and a toy shop. National multiple retailers present in New Mills include Age UK, Boots, Hallmark and Oxfam. Since 2012, the proportion of comparison goods floorspace in New Mills has remained relatively stable.

In addition to the retail and service units present in New Mills, the town centre provides a number of other community facilities including a medical practice and a community centre.

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New Mills

Vacancies in New Mills Town Centre

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New Mills

PROPORTION OF VACANT UNITS

During WYG’s site visit to New Mills town centre in November 2014, seven vacant units were recorded comprising 680 sq.mfloorspace. Both the proportion of vacant units (8.8%) and the proportion of vacant floorspace (9.1%) are below the respective national average figures of 11.5% and 9.3%. Since December 2012, the number of vacant units in New Mills has remained static. The low vacancy rate in the town centre is a key indicator that New Mills is a healthy centre.

PEDESTRIAN FLOWS

There are direct routes from New Mills to Stockport, Manchester and Sheffield, as well as local areas including Marple, Whaley Bridge and Chapel-en-le-Frith. The main bus stop in New Mills town centre is located off the roundabout at the southern end of Market Street. Services are provided from New Mills town centre to the surrounding residential areas and to surrounding towns including Chapel-en-le-Frith, Disley, Glossop, Macclesfield, Marple and Whaley Bridge.

Several residential areas are located in close proximaity to the town centre and there is ease of access for pedestrians to the During WYG’s visit to New Mills town centre on the morning of

Monday 3rd November, pedestrian flows were considered to be good for a centre the size of New Mills at this time during the week. Pedestrians were witnessed throughout the town centre on Market Street, High Street, Union Road and Torr Top Street. The town centre car parks off Torr Top Street and Market Street were busy with pedestrians witnessed walking from both car parks to the town centre.

ACCESSIBILITY

New Mills town centre has reasonable public transport links. The town centre is served by two railway stations which are located outside the town centre. New Mills Central railway station is located to the west of the town centre off Station Road, and New Mills Newtown railway station is located to the south west of the town centre off Albion Road.

town centre and there is ease of access for pedestrians to the centre. Traffic calming measures are in place in the town centre, including a pedestrian crossing, a 20mph speed limit and speed bumps in order to aid pedestrian movement in the centre.

Town centre car parks are present at the southern end of TorrTop Street and to the west of Market Street which provide approximately 100 parking spaces in total. On-street parking is also available throughout the centre. Free parking is provided both on-street and in the town centre car parks for one hour.

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New Mills

PERCEPTION OF SAFETY AND OCCURRENCE OF CRIME

In accordance with the crime and policing website, www.police.uk, the rate of crime in New Mills town centre has remained stable since 2010. 63 crimes were reported within a mile radius of New Mills town centre in September 2014. This is similar to the 61 crimes which were reported in December 2010.

STATE OF TOWN CENTRE ENVIRONMENT

The environmental quality of New Mills town centre is considered to be good. New Mills town centre and the

CONCLUSION

WYG has assessed the health of New Mills town centre against the health check indicators as detailed in the National Planning Policy Guidance. It is concluded that New Mills provides a good range of retail and service units, which are mostly operated by independent retailers. However, it is evident that the town centre is lacking supermarket provision. The vacancy rate in New Mills town centre is lower than the national average and the number of vacancies in the town centre has remained stable in recent years. The majority of buildings in the town centre are of traditional build, which contributes to the town centre environment. However, at the same time, the considered to be good. New Mills town centre and the

surrounding area is covered by New Mills Conservation Area which is recognition of the special architectural and historic interest of the area. At the time of WYG’s visit to New Mills town centre, the centre appeared clean and well maintained.

There are a number of historic buildings present in the town centre which contribute to the favourable environment. The majority of units in the town centre are two-storey, small scale, terraced, stone built properties. Although the historic, small scale properties in the centre contribute to an attractive setting, they are considered to limit the opportunities for expansion in the centre.

the town centre environment. However, at the same time, the scale of the units present is a constraint to further development in the town centre. The town centre is reasonably busy and is considered to perform an important role in catering for the needs of the surrounding residential community. In addition to having a local walk-in catchment, the centre is accessible by public transport.

Overall, it can be concluded that New Mills is a vital and viable

centre.

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Appendix 4 – Trade Diversion Impact Tables

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WYG PLANNING

TRADE DIVERSION IMPACTS OF PROPOSED ALDI NEW MILLS FOODSTORE

TABLE 1: POPULATION AND EXPENDITURE

Zone

2013 2018 2012 2012 2013 2018

with SfT

2 - High Peak Central 40,311 41,668 2,261 2,214 2,191 2,261

Notes

a. Zone 2 derived from the High Peak and Stafordshire Moorlands Retail Study Area and based on the following post code sectors: SK6 5, SK12 2, SK22 1, SK22 2, SK22 3, SK22 4, SK23 0, SK23 6, SK23 7, SK23 9

b. Population data derived from Table 1 of Appendix 2A of the High Peak and Staffordshire Moorlands Quantitative Retail Study Update (GVA, 2014) which relies on Experian data

c. Per capita expenditure data derived from Table 2 of Appendix 2A of the High Peak and Staffordshire Moorlands Quantitative Retail Study Update which relies on Experian data

d. Expendiure growth and allowances for Special Forms of Trading in accordance with GVA's assumptions as set out at footnotes to Table 2 of of the High Peak and Staffordshire Moorlands Quantitative Retail Study Update

e. 2012 prices

Population Per Capita Expenditure

Convenience (£)

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TRADE DIVERSION IMPACTS OF PROPOSED ALDI NEW MILLS FOODSTORE

TABLE 2A: TOTAL CONVENIENCE GOODS EXPENDITURE

2013 2018 Change

2013-18

1 88.32 94.21 5.89

TABLE 2B: CONVENIENCE GOODS EXPENDITURE SPLIT BETWEEN MAIN FOOD SHOPPING AND TOP-UP FOOD SHOPPING SPEND

Main Top-Up Total Main Top-Up Total

1 66.24 22.08 88.32 70.66 23.55 94.21

Notes

a. Zone 2 derived from the High Peak and Stafordshire Moorlands Retail Study Area and based on the following post code sectors:

SK6 5, SK12 2, SK22 1, SK22 2, SK22 3, SK22 4, SK23 0, SK23 6, SK23 7, SK23 9

b. Population data derived from Table 1 of Appendix 2A of the High Peak and Staffordshire Moorlands Quantitative Retail Study Update (GVA, 2014) which relies on Experian data

c. Per capita expenditure data derived from Table 2 of Appendix 2A of the High Peak and Staffordshire Moorlands Quantitative Retail Study Update which relies on Experian data

d. Expenditure derived from multiplying per capita expenditure with population within each zone using data provided at Table 1

e. Expenditure split between main and top-up expenditure is 75:25 as derived from the High Peak and Staffordshire Moorlands Quantitative Retail Study Update

f. 2012 prices

Zone

Zone

Total Convenience Expenditure (£m)

Convenience Goods

Expenditure 2018 (£m)Expenditure 2013 (£m)

Convenience Goods

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TRADE DIVERSION IMPACTS OF PROPOSED ALDI NEW MILLS FOODSTORE

TABLE 3: CONVENIENCE GOODS SHOPPING PATTERNS AND EXPENDITURE

Study Area (%) 2013 (£m) 2018 (£m) (%) 2013 (£m) 2018 (£m) 2013 (£m) 2018 (£m)

Chapel en le Frith

Local Shops, Chapel-en-le-Frith 0.0 0.00 0.00 1.5 0.33 0.35 0.33 0.35

Co-operative Food, Eccles Road 0.0 0.00 0.00 6.4 1.41 1.51 1.41 1.51

Morrisons, Market Street 33.9 22.46 23.95 22.3 4.92 5.25 27.38 29.21

Whaley Bridge

Local Shops, Whaley Bridge 0.6 0.40 0.42 8.8 1.94 2.07 2.34 2.50

Co-operative Food, Buxton Road 0.0 0.00 0.00 1.4 0.31 0.33 0.31 0.33

Tesco, Bridgemont 27.9 18.48 19.71 11.2 2.47 2.64 20.95 22.35

New Mills

Local Shops, New Mills 0.0 0.00 0.00 5.9 1.30 1.39 1.30 1.39

Co-operative, Church Town 2.0 1.32 1.41 9.2 2.03 2.17 3.36 3.58

Sainsbury's Local, Torr Tops Street 0.0 0.00 0.00 0.8 0.18 0.19 0.18 0.19

Outside Study Area

Glossop

Aldi, Arundel Street 2.0 1.32 1.41 0.0 0.00 0.00 1.32 1.41

M&S Simply Food 0.0 0.00 0.00 0.8 0.18 0.19 0.18 0.19

Tesco, Wren Nest 9.4 6.23 6.64 4.4 0.97 1.04 7.20 7.68

Buxton

Aldi, Station Road 3.2 2.12 2.26 1.4 0.31 0.33 2.43 2.59

Iceland, Spring Gardens 0.8 0.53 0.57 0.0 0.00 0.00 0.53 0.57

Waitrose, Spring Gardens 1.4 0.93 0.99 0.8 0.18 0.19 1.10 1.18

M&S, Spring Gardens 0.0 0.00 0.00 1.4 0.31 0.33 0.31 0.33

Other Local Centres 0.0 0.00 0.00 8.7 1.92 2.05 1.92 2.05

Other Outside Catchment Area 18.8 12.45 13.28 15.0 3.31 3.53 15.77 16.82

TOTAL 100.0 66.24 70.66 100.0 22.08 23.55 88.32 94.21

Notes

a. Zone 2 derived from the High Peak and Stafordshire Moorlands Retail Study Area and based on the following post code sectors: SK6 5, SK12 2, SK22 1, SK22 2, SK22 3, SK22 4, SK23 0, SK23 6, SK23 7, SK23 9

b. Total expenditure derived from multiplying per capita expenditure with population within each zone using data provided at Table 1

c. Market shares derived from High Peak and Staffordshire Moorlands Quantitative Retail Study Update

d. 2012 prices

Total Food ShoppingMain Food ShoppingDestination Top-Up Food Shopping

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TRADE DIVERSION IMPACTS OF PROPOSED ALDI NEW MILLS FOODSTORE

TABLE 4: PROPOSED ALDI FOODSTORE TURNOVER

Gross Net Sales Density Total Turnover Total Turnover Total Turnover with Inflow

Floorspace (sq.m) Floorspace (sq.m) (£ per sq.m) 2014 (£m) 2018 (£m) Allowance 2018 (£m)

Total 1,725 1,254 - 11.8 11.9 10.7

Convenience Goods - 1,066 8,952 9.5 9.4 8.5

Comparison Goods - 251 8,952 2.2 2.5 2.2

Notes

a. Assumed convenience and comparison goods sales density equates to 105% of net sales area (convenience goods tested at 85% and comparison goods tested at 20%) to allow some degree of flexibility

b. Sales density is Aldi company average as identified by Mintel Retail Rankings 2014

c. Improvements in convenience goods sales densities derived from Experian Retail Planner Briefing Note 12.1 Addendum Figure 4a

d. Improvements in comparison goods sales densities derived from Experian Retail Planner Briefing Note 12.1 Addendum Figure 4b

c. Assumed that 10% of turnover will derived from outside High Peak and Stafordshire Moorlands Retail Study Area

d. 2012 prices

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WYG PLANNING

TRADE DIVERSION IMPACTS OF PROPOSED ALDI NEW MILLS FOODSTORE

TABLE 5: CONVENIENCE GOODS TRADE DIVERSION ASSESSMENT

Study Area 2013 (£m) 2018 (£m) 2013 (£m) 2018 (£m) 2013 (£m) 2018 (£m) (%) (£m) (%) (£m) (%) (£m)

Chapel en le Frith

Local Shops, Chapel-en-le-Frith 0.33 0.35 0.36 0.38 0.69 0.74 0.5% 0.03 0.0% 0.00 3.5% 0.71

Co-operative Food, Eccles Road 1.41 1.51 0.00 0.00 1.41 1.51 1.0% 0.05 0.5% 0.04 6.3% 1.41

Morrisons, Market Street 27.38 29.21 3.95 4.18 31.33 33.38 35.0% 1.82 18.0% 1.53 10.0% 30.03

Aldi Commitment - - - - - - - - 20.0% 1.70 32.7% 3.50

Whaley Bridge

Local Shops, Whaley Bridge 2.34 2.50 2.34 2.48 4.68 4.97 0.5% 0.03 0.25% 0.02 0.9% 4.93

Co-operative Food, Buxton Road 0.31 0.33 0.24 0.26 0.55 0.59 0.5% 0.03 0.25% 0.02 8.1% 0.54

Tesco, Bridgemont 20.95 22.35 0.30 0.31 21.25 22.67 25.0% 1.30 20.0% 1.70 13.2% 19.67

New Mills

Local Shops, New Mills 1.30 1.39 0.00 0.00 1.30 1.39 0.5% 0.03 1.5% 0.13 11.0% 1.24

Co-operative, Church Road 3.36 3.58 0.00 0.00 3.36 3.58 1.0% 0.05 3.25% 0.28 9.2% 3.25

Sainsbury's Local, Torr Tops Street 0.18 0.19 0.00 0.00 0.18 0.19 0.0% 0.00 0.25% 0.02 11.3% 0.17

Outside Study Area

Glossop

Aldi, Arundel Street 1.32 1.41 20.11 21.28 21.44 22.70 10.0% 0.52 10.0% 0.85 6.0% 21.33

M&S Simply Food 0.18 0.19 4.26 4.51 4.44 4.70 0.0% 0.00 0.0% 0.00 0.0% 4.70

Tesco, Wren Nest 7.20 7.68 27.37 28.96 34.57 36.64 5.0% 0.26 5.0% 0.42 1.9% 35.95

Buxton

Aldi, Station Road 2.43 2.59 16.29 17.24 18.72 19.83 15.0% 0.78 5.0% 0.42 6.1% 18.62

Iceland, Spring Gardens 0.53 0.57 1.01 1.06 1.54 1.63 0.0% 0.00 0.0% 0.00 0.0% 1.63

Waitrose, Spring Gardens 1.10 1.18 10.51 11.11 11.61 12.29 0.0% 0.00 0.0% 0.00 0.0% 12.29

M&S, Spring Gardens 0.31 0.33 1.21 1.28 1.51 1.61 0.0% 0.00 0.0% 0.00 0.0% 1.61

Other Local Centres 1.92 2.05 4.12 4.36 6.04 6.41 1.0% 0.05 1.0% 0.08 2.1% 6.27

Other Outside Catchment Area 15.77 16.82 132.34 140.02 148.10 156.84 5.0% 0.26 15.0% 1.27 1.0% 155.30

TOTAL 88.32 94.21 224.40 237.43 312.72 331.64 100.0% 5.20 100.0% 8.49 - 323.14

Notes

a. Zone 2 derived from the High Peak and Stafordshire Moorlands Retail Study Area and based on the following post code sectors: SK6 5, SK12 2, SK22 1, SK22 2, SK22 3, SK22 4, SK23 0, SK23 6, SK23 7, SK23 9

b. Turnover of Aldi Chapel-en-le-Frith commitment and patterns of trade diversion derived from HOW Planning and Retail Statement submitted in support of application

c. Turnover of proposed New Mills Aldi foodstore derived from Table 4

d. 2012 prices

Trade Diversion to Aldi

New Mills

Trading

Impact

Post-Impact

TurnoverDestination Total Food ShoppingZone 2 Expenditure

Turnover from Wider Study

Area

Trade Diversion to Aldi

Chapel Commitment