appendix 4 retail

8/9/2019 Appendix 4 Retail

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TESCO PLANNING APPLICATIONS

REVIEW OF RETAIL ISSUES

1.0 RELEVANT DOCUMENTS

(i) Mole Valley Town, District, Local and Village Centres Study November 2007

Roger Tym & Partners (RTP 07)

(ii) Tesco First Application (MO/2008/1127):

Retail Assessment July 2008 (including supplementary note) G L Hearn(GLH 08)

Review of Retail Assessment February 2009 Roger Tym & Partners(RTP 08)

Planning Officers Report (PR 2008)(iii) Tesco Second Application (MO/2009/1322):

Retail Assessment November 2009 G L Hearn (GLH 09) Review of Retail Assessment January 2010 Roger Tym & Partners

(RTP 09)

Planning Officers Report (PR 2009)2.0 OVERVIEW

2.1 This review contains observations and analysis of the above documents with a

view to critically examining:

the retail impact of the proposed Tesco store (second application) on thelocal independent retailers in Ashtead; and

determining whether the impact should be considered detrimental to thecharacter, vitality and viability of Ashtead.


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2.2 From a reading of this review, it will become evident that a critical

examination of the retail impact of Tescos second application upon existing Ashtead

convenience retailers also requires an examination of each of the above documents,

as the underlying principles and data predominantly originate from RTP 07 and then

flow through each of Tescos applications, and the reviews and comments on them

by Roger Tym & Partners and MVDC Planning Officers. Unsurprisingly, the bulk of

the observations and analysis relate to GLH 09 and RTP 09 (7.0 and 8.0 below).

2.3 In very brief outline, the key points from the observations and analysis

contained in this review are:

RTP 07, which relies heavily for its statistical justification on a telephonehousehold survey of a catchment area which includes a part Epsom,

recommends greater retail convenience floor space in Ashtead. The

survey focuses only on supermarkets and does not seek information on

shopping in local independent retailers, leaving a significant gap in

relevant information from which to readily determine the retail impact

upon the existing Ashtead convenience retailers.

GLH 08 was lodged (as part of Tescos first application), drawing largelyupon the underlying premise and data from RTP 07 to justify its case.

RTP 08 agrees with the principle of a supermarket (hardly surprising giventhe RTP 07 recommendation), but includes its own analysis to show there

would be a significant impact onsmaller shopsand thatthis may put

some or all of them at risk of closure.

PR 2008 recommends refusal of Tescos first application, fundamentallybecause of its very significant impact on local independent retailers and

the consequent detrimental effect on the vitality and viability of Ashtead.

PR 2008 contains significant criticism of the fundamental premise andunderlying statistical basis for RTP 07 and notes the information gap

regarding the local independent retailers in the underlying survey.


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RTP 07 was incorporated into MVDCs Core Strategy in October 2009. GLH 09 was lodged (as part of Tescos second application) again drawing

largely upon the underlying premise and data from RTP 07 to justify its

case.

RTP 09 again agrees with the principle of a supermarket and includesanalysis which this time shows minimal impact on local retailers. RTP 09

thus concludes there are no grounds for refusal on this issue.

Examination of the impact analysis in RTP 09 indicates:(i) it is estimated that 1.18 million (17%) of the combined turnover of

the local retailers (6.95 million) would be captured by the proposed

store;

(ii) it is estimated that only 0.12 million (10%) of the 1.18 million

would be captured from the local independent retailers, representing less

than 5% of their combined turnover;

(iii) the basis of estimating the amount of turnover captured by the

proposed store from the local retailers appears fundamentally flawed;

(iv) the basis of apportionment of turnover captured from the local

retailers to the local independent retailers changes very significantly from

that used in RTP 08 (no explanation or justification is given); and

(v) the result of (i) and (ii) is a very significant underestimate of the

turnover captured from the local independent retailers by the proposed

store.

Calculations (based upon RTP 07 and RTP 09 data) indicate that:(i) the turnover impact on the local retailers is 2.82 million (not 1.18

million);

(ii) the turnover impact on the local independent retailers is perhaps 10

times higher than that estimated in RTP 09; and

(iii) even using mid-point calculations, the turnover impact on the local

independent retailers is 5 times higher than estimated in RTP 09.


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From these calculations it is evident the turnover impact on localindependent retailers is very significant and it seems reasonable to

conclude some or all of them would be at risk of closure.

Calculations (using RTP 09 data) show the proposed store would have:(i) a 67% share of the local food market;

(ii) a turnover of 2 times that of all other local retailers combined; and

(iii) a turnover of 3 times that of the local independent retailers

combined;

It therefore seems reasonable to conclude that the proposed store woulddominate local food retailers.

Overall, it is reasonable to conclude Tescos second application should berefused on the same grounds as their first application.

PR 2009 accepts RTP 09s (incorrect) conclusion on retail aspects eventhough it again notes the information gap regarding local independent

retailers and makes the extraordinary statement that the Planning Officers

are uneasyabout placing reliance uponsome of the statistics of both

consultants, but they are the best available.

3.0 RTP 07

3.1 RTP 07 was commissioned by MVDC and effectively adopted by MVDC into its

Core Strategy in October 2009.

3.2 Underpinning RTP 07 area telephone household survey across the study

area, visitor surveys and retailer surveys ....(Para 1.2). Data extracted and

conclusions drawn from these surveys in RTP 07 are used throughout Tescos first

and second applications and it is essential to analyse and understand RTP 07 in

order to be able to critically examine Tescos applications.

3.3 Thecomprehensive telephone survey of householdswas used to assess

shopping patterns in the study area (Para 3.1).


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3.4 The telephone household survey area was divided into 8 zones (Para 3.2)

based upon post code areas, with Ashtead being in Zone 4. The setting of the

boundaries of Zone 4 has an enormous impact on the interpretations placed on, and

inferences drawn from, the survey data. Zone 4 contains no large supermarkets, yet

there are large supermarkets adjacent to, but outside of, Zone 4s boundaries (Tesco

in Leatherhead, Waitrose and Sainsburys in Epsom) thus survey results indicate

people are travelling outside their local area to shop, when in fact large numbers of

those people are actually shopping in what for them are their local supermarkets.

Geographically, Zone 4 is the smallest zone and is located at the edge of the study

area (Figure 3.1). This results in relatively short shopping journeys by residents in

Zone 4 being treated as journeys outside the local area when much longer journeys

within other zones are treated as within the local area. It could be said, at least for

Zone 4, that the survey results do not reflect shopping reality.

3.5 The telephone survey had 100 completed household responses from each

area, making 800 in total approximately 1% of households in the study area. It is

stated (Para 3.4) thata sample size of 0.4% is usually considered statistically valid

for a telephone survey and so this is a robust sample size. However, one key

question in the household survey (Q4:where does your household undertake most

top-up food and grocery purchases? Appendix 1) has been put to only 67 people.

The statistical validity of the responses to this question should perhaps be

considered, particularly as these responses form an important element of RTP 07

and flow through to the retail impact assessments in both Tesco applications.

3.6 For food and groceries the results of the two types of shopping trip questions(main and top-up) were then merged(Para 3.7) and the result is a ratio of 70:30

for main:top-up shopping. Despite the brief explanation, it is not clear how the

70:30 ratio was obtained. As this ratio is used in, and is crucial to, many aspects of

Tescos applications (including the retail impact assessments), a more robust

justification/explanation is warranted.

3.7 The stores with the highest market share of expenditure by residents of Zone

4 (Figure 3.4, Para 3.13) are shown as Tesco Leatherhead 25% and Waitrose Epsom


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19%. To these could be added Sainsburys Epsom 19% (Table 10, Appendix 5). A

total of 63% of the market share of expenditure from residents of Zone 4 goes to

these three supermarkets just outside the boundaries of Zone 4, but close to the

homes of the people in Zone 4 who shop in them.

3.8 It is noticeable that, in capturing market shares and Zone 4 convenience

expenditure, there is no attempt to identify expenditure in non-supermarkets ie

butchers, bakers etc in Ashtead. This leaves an important gap in the data which has

significant implications for impact assessments on local Ashtead shops and which is

later acknowledged by Roger Tym & Parners.

3.9 The retention level is the percentage of expenditure in each zone which is

spent in the stores within that zone(Para 3.17). Zone 4 is shown as having the

lowest retention level (12%) and it is stated thata high proportion of residents .....

travel to other centres to shop in supermarkets(Para 3.19). This is a gross

misrepresentation of the facts. The reality is a high proportion of the residents in

Zone 4 shop at their local supermarkets which just happen to be adjacent to, but

outside, the boundaries of Zone 4. In other words they are shopping in their localcentres, not travelling to other centres. The implication that there is a problem is

therefore largely false. The point is effectively noted in PR 2008 (Page 10)that

about a third of the population and expenditure within (Zone 4) are within Epsom.

They might be expected to look to Epsom town centre.....and other facilities in the

locality. A similar situation exists at the other side of Zone 4 in relation to

Leatherhead. As will be seen in the further analysis below, this issue goes directly to

the question of where people will shop, where turnover will be captured from by theproposed store and thus the extent of the impact of the proposed store on the

turnover of the existing Ashtead convenience retailers.


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3.10 It is noted again (PR 2008, Page 12):

3.11 Further, it is noted (PR 2008, Page 13):

3.12 Perhaps a valid question to ask is what is the relevance of the Zone 4

boundaries (based on post code areas), or indeed any boundaries, to shopping

patterns?

3.13 Section 6 of RTP 07 discusses the visitor and business survey results from

Ashtead. For the former, a total of 126 people were questioned in the survey; 65 at

Craddocks Parade and 61 in The Street. A person with local knowledge of Ashtead

would know that answers to some questions would be expected to be completely

different, depending at which location the question was asked.

3.14 Of those surveyed in Ashtead, 67% travelled by car, 33% on foot and less

than 1% by public transport (Q1, Appendix 2). This is not surprising given the very

limited bus services (Para 6.45) and the location of the railway station, especially in

relation to The Street (Para 6.44).


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3.15 A total of 55% of people indicated (Q4 and Q5, Appendix 2) they were in

Ashtead to shop. Contrary to the comments (Paras 6.5 to 6.7), this would appear to

be a healthy indicator of retail activity in Ashtead.

3.16 Dislikes about Ashtead are mentioned (Para 6.9), but conspicuous from these

(but very relevant to the rationale behind RTP 07) is that only 1.6% of people

disliked thelack of a larger supermarket(Q7, Appendix 2).

3.17 When askedhow could Ashtead best be improved for shopping?(Q8,

Appendix 2), only 3.2% of people chosea better/bigger supermarket,but this fact

is not mentioned. However, the 17% who chosea better choice of shopsis

mentioned (Para 6.10). Reading the two statements together (rather than only the

latter) would quite conceivably leave a reader of RPT 07 with a significantly different

perspective of what the people were actually suggesting.

3.18 It is stated (Para 6.22) that the main problems with Ashtead were considered

by the businesses surveyed to be a poor range of multiple/national retailers. This

statement is not supported by the underlying survey responses (Q14 Ashtead,

Appendix 3). These show that of the 21 businesses that responded, 6 choseseek

to improve the number of national retailerswhereas 17 choseseek to increase the

number of specialityretailers.

3.19 The overall conclusion from theconsultation event findings(Para 6.24)

again does not appear to be supported by the underlying survey responses. As

indicated above, responses from both Ashtead individuals and businesses were

shown to be looking for more choice of speciality shops, and there is no indication ofa strong feeling for a largeanchor storein The Street.

4.0 GLH 08

4.1 GLH 08, which supports Tescos second application, draws heavily upon the

contents of RTP 07 and its underlying survey (Sections 4 to 8) with similar

emphasis/omissions. Comments made at 3.0 above regarding RTP 07 are therefore

also relevant in respect of GLH 08.


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4.2 Comment is made (Para 4.19) thatfootfall in the town centre is moderate.

This conflicts with RTP 07, which indicates (Para 6.49)relatively highor better

pedestrian flows.

4.3 The conclusion is reached (Para 4.40) thatthe centre(Ashtead) lacks focus

and requires stronger retail provision to enhance attraction and improve its

performance. This statement does not appear to be supported by the survey data

where 42% of people indicated they disliked nothing in particularabout Ashtead

(the only significant dislikes being road congestion and parking), 30% liked the

selection/choice of independent shops/specialist shops, 28% liked the

character/atmosphereand only 3.2% chosea better/bigger supermarketas the

best way to improve shopping in Ashtead. In fact, the survey results could easily

lead to a conclusion that it is the particular diversity of independent retailers in

Ashtead that is its attraction.

4.4 The discussion on retail need (Section 5) cites the analysis and conclusions in

RTP 07 as support for Tescos application.

4.5 An additional Note on Retail Impact (NRI) was prepared by G L Hearn to

supplement GLH 08. There are no paragraph numbers in the NRI which, once

again, draws heavily on RTP 07.

4.6 The NRI again cites RTP 07 as support for a supermarket to be located on the

vacant site in The Street (Page 6).

4.7 It is asserted (Page 5) that the proposed store will reduce the turnover of

existing Ashtead retailers by less than 5%. No details are given to support this

assertion.

5.0 RTP 08

5.1 It is stated (Para 2.4(d)) thatthe catchment area identified for the proposed

Tesco store is considered to be in line with the size and function of the Ashtead

centre. This is not surprising as it conforms to the catchment area in RTP 07.


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However, in PR 2008 (page 12) this comment is implicitly criticised and contradicted

as follows:

5.2 It is pointed out (Para 4.18) that the RTP 07 household survey did not show

how many households use non-supermarkets for their top-up shopping. A total of

21.7% of people surveyed either indicatedother stores(ie not supermarkets) or

did not know/variesas their choice for top-up shopping and a large number of

these are likely to be shopping in Ashtead.

5.3 It is stated (Para 4.20) that 40% of the top-up shopping turnover of the

proposed store would come from other Ashtead shops, with the other shops losing

between 20% and 36% of their turnover. It is important to note the proposed store

will not contain meat, fish or delicatessen counters(PR 2008, Page 11).

5.4 It is stated that the impact on smaller shopswould be significant and, in our

view, put some or all of them at risk of closure. We recognise there would be some

positive spin-offs from the proposed new store through new linked trips, though we

suspect these will be negligible(Para 4.22).

5.5 RTP 08 conclusions (Para 7.1) are:

Need - assessment broadly follows best practice.

Scale - broadly appropriate. Impact - trade diversion from existing shops will be substantially greater

than suggested and that this is grounds for refusal.

Accessibility - dealt with in transport assessment.


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6.0 PR 2008

6.1 PR 2008 is the report, conclusions and recommendation of the Planning

Officers on Tescos first application. The main retail planning issue is whether the

principle of a supermarket and of the proposed size are acceptable(Page 8).

6.2 The discussion on this aspect is stated (Page 11) to draw largely on RTP 08

which, as indicated above, in turn draws heavily on RTP 07.

6.3 The following discussion is highly relevant (Page 12):

6.4 As are the following comments (Page 13):

6.5 In making the above comments, PR 2008 is implicitly criticising the

fundamental basis of RTP 07 on which GLH 08 is substantially based.

6.6 It is noted in PR 2008 that the proposal would result in 40% of the whole

Districts retail need (2800 sq m as identified in RTP 07) being allocated to Ashtead,

a small District Centre, whilst Dorking, a higher order centre, isclearly in urgent

need of improved food shopping(Page 12).


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6.7 It is noted (Page 12) that Ashtead is an appropriate location for a

supermarket butit does not follow that it is appropriate for a supermarket to be of

the proposed size.

6.8 Concerns expressed in RTP 08 regarding turnover diverted from other

Ashtead convenience retailers are noted (Page 13). It is also noted the proposed

store turnover would be about 2.5 times the combined turnover of other Ashtead

convenience retailers.

6.9 It is noted that ifthe opening of the proposed new store was to have such

an impact on existing shops that they were to close this would provide grounds for

refusal, on the basis this would have a negative impact on the health of the centre

(Page 14).

6.10 It is noted that the positive spin-offs through new linked trips are likely to be

negligible (Page 14).

6.11 It is noted thatthe new store would be likely to dominate convenience goods

shopping in (Ashtead) significantly lessening consumer choice because independent

convenience stores would potentially close. Consequently, it would have the

opposite effect that Tesco claim(Page 14).

6.12 The following comments are highly relevant (Page 14):

6.13 The conclusion on the retail planning issue is as follows Page (15):


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7.0 GLH 09

7.1 GLH 09, which supports Tescos second application, again draws heavily on

RTP 07 and its underlying survey, with similar emphasis/omissions. Comments

made in 3.0 above regarding RTP 07 are, therefore, also relevant in respect of GLH

09.

7.2 GLH 09 is also stated to draw upon a household survey carried out in October

2008 for Tesco in support of a planning application for a new large store in Epsom.

The results of this later survey are stated to support the RTP 07 survey, but only

brief details are given.

7.3 As in GLH 08, the comments on footfall (Para 4.23) conflict with RTP 07.

7.4 The comment on bus services (Para 4.24) makes no mention of the very

limited nature of the services.

7.5 As in RTP 07, the results of the question in the household survey asking what

people dislike about Ashtead (Para 4.30) omit to mention that only 1.6% chose the

lack of a larger supermarketand that 42% indicated there wasnothing in

particularthey disliked (3.17 above).

7.6 As in RTP 07, the stated responses (Para 4.31) to the survey question how

could Ashtead best be improved for shoppingomit the fact that only 3.2% of

people chosea better/bigger supermarket. This omission gives a misleading

perspective of what the people were actually saying (3.18 above).

7.7 As in RTP 07, the conclusion (Para 4.47) thatthe centre(Ashtead) lacks

focus and requires stronger retail provision to enhance attraction and improve its


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performanceis not supported by the survey responses. In fact, it could be

concluded from the responses that it is the particular diversity of independent

retailers in Ashtead that is its attraction (3.19 and 3.20 above).

7.8 As in RTP 07, great weight (Para 5.7) is placed on the fact that the retention

level for expenditure on convenience goods is around 12%. As discussed above (3.4

and onwards), the determination of Zone 4 boundaries has a huge bearing on this

figure and brings into question the fundamentals of retention/leakage between

artificially imposed zones which bear no relation to practical reality.

7.9 Perhaps the sensitivity of the issue can best be illustrated by the following:

Total convenience goods expenditure of 39.6million by residents of Zone 4 is

broken down as follows (using market shares from RTP 07, Q1 and Q4, Appendix 1),

assuming about 50% of the other stores/did not know/varies expenditure relates to

Ashtead (a reasonable assumption and one supported by the turnover levels of the

existing convenience stores in Ashtead) and also assuming a 70:30 ratio of

main:top-up expenditure:

Main Top-up Total

% m % m m

Epsom 42 11.6 29 3.5 15.1

Leatherhead 39 10.8 12 1.4 12.2

Ashtead 1 0.3 41 4.9 5.2

Internet 7 1.9 - - 1.9

Other 11 3.1 18 2.1 5.2

100 27.7 100 11.9 39.6

7.10 Approximately 33% of the residents of Zone 4 live in Epsom and could,

therefore, be expected to do their shopping in Epsom (PR 2008, Page 10). It is also

the case thattop-up shopping is largely undertaken close to peoples homes(RTP

2008, Para 4.20) and it would therefore not be expected that top-up shopping would


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significantly leak from a particular locality with adequate convenience shops. Thus,

the market shares for top-up shopping (29% for Epsom and 12% for Leatherhead)

could be said to provide a very crude indication of the household spread in Zone 4.

On this basis, and assuming expenditure by Zone 4 residents who live in Epsom or

close to Leatherhead should more accurately be described as retained expenditure

(since it is expenditure actually incurred by residents in their local shops), the

retention level could perhaps be more realistically determined (using figures from

the table at 7.09 and assuming) as:

m

Ashtead total expenditure 5.2

Epsom + Leatherhead top-up expenditure (3.5 + 1.4) 4.9

Epsom main expenditure (29/42 x 11.6) 8.0

Leatherhead main expenditure (12/39 x 10.8) 3.3

21.4m

The retention level then becomes (21.4/39.6) 54%. This is very close to the 55%

70% range which is considered healthy (RTP 07, Para 3.17). Indeed, if internet

shopping is also considered to be retained, then the retention level becomes

(23.3/39.6) 59%. These figures are simply intended to highlight the flaw in RTP 07

regarding shopping habits which ultimately flows through to the analysis of impact of

the proposed store on the turnover of the existing Ashtead convenience retailers.

7.11 Whilst the above calculations are somewhat crude, they are no more

unrealistic than the concept of determining retail needs by reference to shopping

habits within an artificial grouping of post codes which takes no account of practical

realities, particularly the shops located just outside the chosen area, which are

naturally the local shops for those residents within the chosen area closest to them.

The point here is that people shop where it is convenient (eg Epsom residents shop

in Epsom) and thus the RTP 07 analysis (relied upon by GLH 09) is flawed in that itdid not recognise this point when using the survey data to assess the impact of the


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proposed store on the existing Ashtead convenience retailers. The analysis below

adjusts the available data so as to eliminate the expenditure that will be retained in

Epsom and Leatherhead and thus provide a more realistic estimate of the

expenditure available for capture by the proposed store and from where it is

available for capture.

7.12 It is stated (Para 5.18) that the catchment area (based on the post codes

KT18, KT21 1and KT21 2) was confirmed as appropriate in RTP 08 in relation to

Tescos first application for the larger store. However, it is stated in PR 2008 (Page

13)officers consider that the catchment area and population used for the statistical

justification of the need for the store is too large. It exaggerates the case for a

supermarket of the proposed size. If the catchment area/population for the

proposed bigger store were considered too large, how can they be appropriate for

the proposed smaller store?

7.13 As in GLH 08, a ratio of 70:30 main:top-up expenditure isconsidered

appropriate(Para 5.26). This ratio appears to be taken from RTP 07, where

minimal justification is given for its adoption, although its genesis presumably is theanecdotal evidence obtained from the household survey where no specific question

was asked on this point.

7.14 Great emphasis is placed (Paras 5.29 to 5.31) on the available expenditure

capacity within Zone 4 after taking account of the existing shops in Ashtead and the

proposed new store the figure quoted for 2011 is 25.18 million. This is used to

show there is ample capacity within Zone 4 to accommodate the proposed store. As

indicated below (basically a re-analysis of the figures in the table at 7.9 between

expenditure that will be retained where presently incurred and thus not be available


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for capture and expenditure that will be available for capture), the position is not

that simple:

Main Top-up Totalm m m

(a)Turnover of proposed store 5.99 2.57 8.56Expenditure by Zone 4residents that will continueunchanged and will not beavailable for capture:

- Epsom 8.0 3.5 11.5- Leatherhead 3.3 1.4 4.7- Ashtead (note below) - - -Other expenditureInternet expenditure 1.9 - 1.9

13.2 4.9 18.1Total expenditure by Zone4 residents 27.7 11.9 39.6

(b)Available expenditurecapacity 14.5 7.0 21.5

Available expenditure

capacity that must be

captured by proposed store

(a)/(b)% 41% 37%

Note: It is assumed all expenditure in Ashtead and all Other expenditure is available

for capture by the proposed store.

7.15 To meet its projected turnover level, the proposed store must capture around

40% of the available main shop expenditure capacity. This could be problematical

for several reasons, including:

The existing supermarkets that Ashtead residents use in Leatherhead andEpsom are notfar away(PR 2008, Page 12).


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Main food shopping is almost always undertaken in higher order centres(PR 2008, Page 12).

7.16 The proposed store will also need to capture around 40% of the available

top-up expenditure capacity of 7.0 million, made up of 4.9 million of expenditure

in Ashtead and 2.1 million of other expenditure (7.9 above). It is most likely a

large amount of this latter sum is actually being spent in Ashtead. This is pointed

out in RTP 08 (Para 4.18). Given that top-up shopping generally takes place locally

it is reasonable to conclude that the bulk of expenditure will be captured by the

proposed store from existing top-up expenditure in Ashtead. Even assuming the

whole of the other unspecified expenditure is outside Ashtead (unlikely) and that the

proposed store will capture 37% of that expenditure, it means that 1.8m (4.9m x

37%) of expenditure will be captured by the new store from existing Ashtead shops.

This would represent about 33% of their estimated turnover considerably more

than the 8% projected in GLH 09 (Para 7.13 and Table 10, Appendix C).

7.17 It is stated (Para 7.15) that as it is not intended the store will have meat,

fish or delicatessen countersthe proposed store is not anticipated to significantlydiverttrade or impact upon specialist convenience stores within the town centre.

In fact such stores are expected to benefitfrom the proposed store as it will

attract more shoppersand provide significant potential for linkage between the

store and thespecialist convenience retailers. It should be noted that:

The statement regardingmeat, fish or delicatessen countersis one ofintent only, and intentions can change at any time and, in any case, it is

acknowledged (NRI, Page 6) that such goods will be available pre-packed

from chiller cabinets;

Tesco has said that it would not accept a condition precluding meat, fishor delicatessen counters (PR 2008, Page 14).

Any benefit from linkage (or linked trips) is considered in RTP 08 (Para4.22) to be negligibleand this view is endorsed in PR 2008 (Page 14).


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7.18 It is again stated (Para 7.16) that Ashteadlacks focus and requires stronger

retail provision to enhance attraction and improve performance. Onceagain, no

justification is given for this statement, nor is it supported by any survey data. In

fact, it would reasonably be concluded that the survey shows the exact opposite.

7.19 It is stated (Para 7.19) that themodestdiversion of trade within Ashtead

will be more than compensated for by an increase in visitor numbers to the centre

and the spin-off linked shopping trip benefits. No evidence is given to support this

statement, which is effectively contradicted in RTP 08 and PR 2008 (7.17 above).

7.20 It is stated (Para 7.20) that the proposed store will increase consumer choice.

The following perhaps paints a different picture (using figures taken from Tables 6

and 7, Appendix C) it should be noted that the Tesco Express store is actually

twice the size shown below (8.6 below), and that consequently Tescos market share

is understated here:

Net sales Impliedm 2 Turnover m

Existing convenience stores in Ashtead

excluding Tesco Express 615 3.69

Tesco Express 125 125 1.43 1.43

Total Existing 740 5.12

Proposed store 750 750 8.56 8.56

Total existing + proposed 1490 13.68

Proposed store as percentage of:

Existing excluding Tesco 122% 232% Existing 101% 167% Existing + proposed 50% 63%


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7.21 It can be readily seen from the above that the proposed store alone will have

a turnover of nearly 2 times the combined turnovers of all other non-Tesco

convenience stores in Ashtead (before any capture of turnover by the proposed

store).

7.22 The worddominantis defined (New English Dictionary and Thesaurus

Geddes & Grosset 1999 Edition) ascommanding; prevailing over others. It is clear

that the proposed Tesco store will be in the dominant position for convenience

shopping in Ashtead. and it is difficult to see how the development of a new store of

the size proposed could be considered to be on alevel playing fieldwith existing

town centre retailers (Para 7.21).

7.23 It is stated (Para 8.6) thatthe majority of the proposed stores trade is

anticipated to be diverted from those stores outside the catchment area which

currently attract a significant proportion of the catchment areas convenience

expenditure. As indicated (7.9 and 7.14 above), this is clearly the case in relation

to main shopping expenditure, but clearly not the case for top-up shopping

expenditure where at least 70% (4.9m/7.0m) of the expenditure available tocapture occurs within Ashtead itself. It would thus seem clear that the majority of

top-up expenditure will be captured by the proposed store from existing Ashtead

convenience stores. This makes fundamental sense as top-up shopping is largely

carried out close to home (RTP 2008, Para 4.20) evidenced by the high 41%

survey respondents who top-up shop in Ashtead and it is the top-up shopping of

those living close to Ashtead which will be captured from the stores close to them (ie

the stores in Ashtead) by the proposed new store in Ashtead.

7.24 It is stated (Para 7.13) that 8% of the turnover of existing Ashtead

convenience shops will be captured by the proposed store, but no evidence is

produced to support this assertion. The impact on the other retailers is shown in


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Table 10, Appendix C. However, using the figures calculated above (7.13), the

position would perhaps be better shown as follows:

Implied CapturedTop-Up Expenditure by New Store

AvailableFor Capture m % m

Epsom - -

Leatherhead - -

Ashtead 4.9 37% 1.80

Internet - -

Other 2.1 37% 0.77

7.0 2.57

7.25 This calculation assumes an even distribution of the capture from Ashtead

and other expenditure. If, as is likely (but extent unknown), the other expenditure

actually largely represents top-up shopping in Ashtead (RTP 07, Para 4.18) there will

clearly be a greater impact on existing Ashtead convenience shops. Alternatively, if

a greater proportion of the captured expenditure comes from the available Ashtead

top-up expenditure, this will also produce a greater impact on existing Ashtead

convenience shops. There is a degree of sensitivity in this if of the other

unspecified expenditure is actually incurred in Ashtead then existing Ashtead

retailers would have 45% of their turnover captured by the proposed store.

8.0 RTP 09

8.1 RTP 09 fundamentally looks at the following retail matters (Para 2.26)

considered in GLH 09:

Whether there is a need (not now required under PPS4). Whether the development is of an appropriate scale. Whether there are any unacceptable impacts on existing centres.

8.2 It is stated (Para 3.3) that the indicative turnover of the proposed store

should be 13,099/ sqm (not 11,410/sqm as in GLH 09).


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8.3 It is stated that differing floor spaces have been quoted (750 sqm in GLH 09

and 815 sqm on plans). Given it is recommended (Para 5.48) thatthe net sales

area should be restricted to 750 sqm, the following analysis has used the figure of

750 sqm and has drawn upon Table 5.5 of RTP 08 as themost robust source(Para

5.38).

8.4 Based upon a floor space of 750 sqm, the turnover of the store is (13,099 x

750) 9.82 million (Para 3.3). Using a 70:30 ratio this indicates main shopping of

6.87 million and top-up shopping of 2.95 million.

8.5 It is stated (Para 3.7) that the sales area of Tesco Express is 250 sqm (not

150 sqm as used in GLH 09).

8.6 Taking the above into account, the implied turnover of the existing

convenience stores in Ashtead in 2011 is now shown (Table RTP 3.2) as follows:

Sales Area sqm 2011 Turnover m

Alldays 153 0.91

Local Stores The Street 397 2.38

Local Stores Craddocks 65 0.39

615 3.68

Tesco Express 250 3.27

865 6.95

8.7 It is stated (Para 4.4) that the proposed store of 750 sqm will be 15% of the

total Ashtead floor space of 5,115 sqm including the new store and that this issignificant but not dominant.

8.8 It is stated (Para 4.9) thatwe are satisfied (the store) can be accessed by a

variety of modes of transport. This statement is surprising given the comment in

RTP 07 (Para 6.45) thatbus services to and from Ashtead are very limitedand that

the railway stationis a further 15 minutes walk to (the store) and thus access from

the station ..... may be difficult for elderly or disabled visitors. How can these two

positions be reconciled, as nothing has changed? The question might also be asked


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how will the store be accessed by bus on Sundays or after 6.00 pm when there are

no bus services, and on Saturdays when the already limited services are further

curtailed? In fact, the railway station is approximately 1 kilometres from the

proposed store and is further from the proposed store than the adjacent stations in

each direction are from larger stores (Epsom Waitrose and Leatherhead

Sainsburys). As for bus times during weekdays:

The 408 is a 2 hour service. Arriving from the Epsom direction, the nextreturn journey is 1 hours later, and thus not viable just for a shopping trip;

arriving from the Leatherhead direction, the next return journeys are 24

minutes and 2 hours 24 minutes later; again not viable for shopping trips.

Furthermore, within 5 to 7 minutes of Ashtead on this bus route in both

directions are significantly larger supermarkets (Sainsburys in Leatherhead

and Waitrose in Epsom).

The 479 bus also serves Sainsburys in Leatherhead and Waitrose in Epsom,and so it is unlikely to be used for shopping at the smaller store in Ashtead.

The 516 has only 3 services per day in each direction. The same comments asfor the 408 service apply in respect of times until return journey, and also in

respect of passing larger supermarkets in Leatherhead and Epsom.

The 623 cannot be used for a return journey the same day (or even week),except for travelling from the top of Greville Park Road to the store, which is

a 3 minute walk, and the time until the return journey is 3 hours.

The reality, therefore, is that there are no bus services which are likely to be used

for shopping at the proposed store and it is unrealistic to expect any use of trains to

access the proposed store.

8.9 It is concluded (Para 4.13) thatthe proposed development is of an

appropriate scale subject to an investigation of wider impacts.


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8.10 It is stated (Para 5.29) that residents of Zone 4are often travelling

substantial distances to undertake main food shopping. No indication is given of

the meaning ofsubstantialin this context. It is difficult to reconcile this statement

with the comment in PR 2008 (Section 1(h) Page 12) thatthe existing supermarkets

that Ashtead residents use in Leatherhead and Epsom are not far away. It is also

worth noting that some residents of Epsom would have to travel further to the

Sainsbury store in Kiln Lane, Epsom than some Ashtead residents would have to

travel to the Sainsburys or Tesco stores in Leatherhead.

8.11 It is stated (Para 5.30) that the impact assessment on local shops contained

in GLH 09 isa little simplisticas it makes no distinction between main food and

top-up shopping. It is only the latter which is of relevance to the impact on local

shops in Ashtead.

8.12 It is noted (Para 5.33) that the survey results showed 11.6% of households

identified a store which was not one of the identified major retailersand 10.1%

whodid not know or advised that their choice of store for top-up shopping varies.

It is suspected that a large proportion of this 21.7% of households is shopping atsome of the specialist stores in Ashtead and Craddocks Parade, such as the butcher,

greengrocer and fishmonger. The fact that the survey did not cover this aspect

leaves a very significant gap in the data.

8.13 However, the recalculated implied 2007 turnover amounts (Table RTP 3.2)

showing a total for Ashtead convenience retailers of 6.95 million and the estimated

percentage of top-up turnover in those retailers (Table RTP 5.5) indicate that

approximately 56% of the total expenditure by Zone 4 residents on top-up shopping

of 11.9 million (7.9 above) is incurred in Ashtead (ie 6.7m), leaving only 3%

(0.3m) unaccounted for. The position in terms of top-up expenditure by the

proposed store now becomes:


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Implied Top-Up Captured by

Expenditure Available New Store

For Capture m % m

Epsom - - -

Leatherhead - - -

Ashtead 6.7 42 2.82

Internet -

Other 0.3 42 0.13

7.0 2.95

8.14 The proposed store will, therefore, capture at least 2.82m of the turnover of

the Ashtead convenience stores ie about 40% of their total turnover of 6.95 million.

8.15 Looking at main shopping, the turnover of the proposed store will be captured

from the following (using figures from 7.9 and 7.14 above):

Implied Main Captured by

Expenditure Available New StoreFor Capture m % m

Epsom 3.6 47% 1.71

Leatherhead 7.5 47% 3.56

Ashtead 0.3 47% 0.14

Internet - 47% -

Other 3.1 47% 1.46

14.5 6.87

8.16 The proposed store must capture around 47% of the available main shop

expenditure capacity to meet its projected turnover level. As indicated above (7.15),

this may be problematic.

8.17 RTP 09 estimates (Para 5.35) that 40% of the proposed stores top-up

shopping turnover will be captured from existing Ashtead convenience retailers ie

1.18 million (Table RTP 5.2). No explanation or analysis is provided in RTP 09 to


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support this estimate and it appears the basis of estimation (by reference to top-up

turnover of the proposed store) is flawed and that the more correct approach (taken

above) is to determine from where the top-up expenditure will be captured and how

much is available to capture. For the reasons explained above, the figure of 1.18

million appears to be a very significant underestimate of the impact of the proposed

store on existing Ashtead convenience retailers. The calculations (7.9, 7.14 and

8.14 above) indicate a figure of 2.82 million, approximately 2 times the estimate

in RTP 09. See the further discussion on this below (8.21 to 8.24).

8.18 RTP 09 then seeks to apportion the captured turnover across the various

categories of Ashtead convenience stores. The basis of the apportionment is an

estimate by Tym (note 4, Table RTP 5.3). No analysis is provided to support the

basis for apportionment, except for the comment (Para 5.36)... we recognise that

it is not intended that the proposed store would (sell) fresh meat, fish or

delicatessen from specialist counters. For that reason we assume that the impact

would fallmost heavily on the existing Alldays and Tesco Express stores. This

assumption would seem to be invalid as it is acknowledged (NRI, Page 6) such

goods will be available pre-packed from chiller cabinets. No support is provided for

this assumption or to the degree to which RTP 09 weights the captured turnover

impact across the stores. . Also, no consideration has been given to the impact on

local bakers and greengrocers.

8.19 The basis of apportionment of the top-up expenditure captured by the

proposed store from other local convenience retailers used in RTP 09 (Table RTP

5.5) is significantly different from that used in RTP 08 (Table RTP 4.1). Noexplanation is given for this change in basis. Since the relevant underlying

circumstances have remained fundamentally unchanged, it is difficult to see why

such a change has been made. The following illustrates the different apportionment

bases used:


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Apportionment of Captured Top-up Expenditure %

RTP 08 RTP 09

Alldays, The Street 10.8 15.2

Local Convenience Stores, The Street 39.6 7.6

Local Convenience Stores, Craddocks 7.8 2.6

57.9 25.4

Tesco Express, Craddocks 42.1 74.6

100.0 100.0

8.20 As in RTP 09,RTP 08 uses an estimate of 40% of the proposed stores top-up

turnover to provide the amount (1.9m) captured from existing Ashtead

convenience retailers (Para 4.20). It follows from this that however big or small the

size of the store, it will always capture 40% of its top-up turnover from existing

convenience retailers in Ashtead irrespective of the quantum of top-up shopping in

Ashtead hence the amount of 1.18 million estimated (Para 5.35) in RTP 09. No

explanation or justification is provided in either RTP 08 or RTP 09 for this proposition

and it would appear difficult to provide such justification.

8.21 The amount of top-up expenditure captured from existing Ashtead

convenience retailers will be fundamentally determined by the amount of top-up

expenditure incurred in those stores ie top-up expenditure currently incurred in

Ashtead by people who will switch their top-up shopping to the proposed store.

8.22 Top-up expenditure will be captured by the proposed store from the top-up

expenditure available to be captured. Where the expenditure is actually captured

from will be determined by where the available expenditure is located. The amount

of top-up turnover of the proposed store is irrelevant in determining where the

expenditure will be captured from it is relevant only in determining how much

expenditure will be captured. Thus, the first task is to establish where the existing

top-up expenditure is incurred. The second task is to establish how much is incurred

in each location. The third task is to identify how much (if any) top-up expenditureincurred in each location is available for capture.


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8.27 This table illustrates the RTP 08 basis of apportionment applied to the RTP 09

estimate of captured expenditure.

2011 Top-up Turnover Top-up Capture TurnoverTurnover % m % m Capture %

Alldays, The Street 0.91 95 0.87 10.5 0.12 13

Local ConvenienceStores, The Street 2.38 100 2.38 39.6 0.47 20

Local ConvenienceStores, Craddocks 0.39 100 0.39 7.8 0.09 23

3.68 3.64 57.9 0.68

Tesco Express,Craddocks 3.27 90 2.93 42.1 0.50 15

6.95 6.57 100 1.18

8.28 This table illustrates the RTP 09 basis of apportionment applied to the

estimate of captured expenditure per 8.13 above.





3.68 3.64 25.4 0.71


6.95 6.57 100 2.82


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8.29 This table illustrates the RTP 08 basis of apportionment applied to the

estimate of captured expenditure per 8.13 above.





3.68 3.64 57.9 1.64


6.95 6.57 100 2.82

8.30 It can be seen from the above tables that:

Using the RTP 09 estimate (1.18m) of captured expenditure, the capture oflocal convenience store turnover (excluding Alldays) ranges from 4% (8.26

above) to 23% (8.27 above).

Using the estimate (2.82m) of captured expenditure per 8.14 above, thecapture of local convenience store turnover (excluding Alldays) ranges from

9% (8.28 above) to 56% (8.29 above).

8.31 It is apparent the basis of apportionment of the captured expenditure is

critical to estimating the impact on the the local convenience stores.

8.32 No explanation or justification is provided in either RTP 08 or RTP 09 to

support the two bases of allocation adopted, which differ significantly. Both bases

clearly seek to weight the adverse impact on the local stores more towards Alldays

and Tesco Express. The difference is that RTP 09 seems to adopt the far more

extreme view that trade in the local stores would suffer only 10% of the total impact

whereas in RTP 08 the view was taken that they would suffer 47% of the total


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impact. The difference is largely accounted for by the increase in RTP 09 of the

adverse impact on Tesco Express from 42% to 75% ie almost a doubling of the

impact.

8.33 It is difficult to see the justification for such a significant change in the

relative impacts. The following underlying facts are essentially unchanged between

RTP 08 and RTP 09:

The turnover of Tesco Express comprises 90% top-up shopping. Tesco Express is physically separated from the proposed store by a 10-15

minute walk.

The location of Tesco Express makes it very convenient for people living inLower Ashtead and it benefits significantly from its proximity to Ashtead

station and to the top-up (and take-away) shopping made by commuters on

their journeys to/from the station.

Tesco Express benefits significantly from shopping by families on school runs.8.34 The difficulty in anticipating the turnover impact on the local convenience

stores is acknowledged but, having said that, it would seem highly unlikely that 75%

of the expenditure captured by the proposed store would come from Tesco Express

as assumed in RTP 09 (Table RTP 5.5). For the reasons detailed above, it seems

reasonable to conclude that the figures in the Table at 8.29 above represent the

more likely impact on local convenience shops.

8.35 However, so as to provide a mid-point between the RTP 08/RTP 09 based

figures (Tables at 8.26 and 8.27 above) and those figures calculated above (Tables

at 8.28 and 8.29 above), the following table adopts a mid-point position between the

two different bases of apportionment and the two different estimates of captured

expenditure:


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Alldays, The Street 0.91 95 0.87 13 0.26 29

Local ConvenienceStores, The Street 2.38 100 2.38 24 0.48 20

Local ConvenienceStores, Craddocks 0.39 100 0.39 5 0.10 26

3.68 3.64 42 0.84

Tesco Express,

Craddocks 3.27 90 2.93 58 1.16 35

6.95 6.57 100 2.00

8.36 For the reasons discussed above, it is not considered the figures shown in the

table at 8.35 above represent the more likely impact. These figures merely illustrate

that the mid-point between the two sets of calculations would still produce a very

significant impact on the local convenience stores.

8.37 It can be seen from the table at 8.35 above that the capture of local

convenience store turnover (excluding Alldays) ranges from 20% to 26%.

8.38 RTP 09 concludes (Para 5.4) thateven if the proposed development did

result in the closure of one or both (of Alldays and Tesco Express) the wider impact

on vitality would be relatively limited. Even based upon the mid-point position

shown in the table at 8.35 above, this conclusion is obviously incorrect. In fact, it

would be reasonable to conclude that a reduction in turnover of between 20% and

26% is very significant and may well put some or all of the local convenience stores

at risk of closure. Added to this is the very real possibility of the closure of Alldays,

as it could reasonably be assumed that a reduction in turnover of around 30% would

make it extremely difficult, if not impossible, for Alldays to continue trading viably.

Of course, whether a reduction in turnover of around 35% would cause Tesco

Express to close is more difficult to judge, particularly as a closure of Alldays would

likely mean Tesco capturing 100% of Alldays turnover and therefore increasing thecombined local convenience market share of the two Tesco stores to around 85%,


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after taking account of the turnover impact on the other stores and before taking

into account the possible closure of other shops. It is certainly not inconceivable

that Tesco could, within a relatively short period of time, capture close to 100%

market share.

8.39 Although not mentioned in RTP 09, there would seem to be no reason to

change the conclusion in RTP 08 thatthere would be some positive spin-offs from

the proposed new store through new linked trips, though we suspect these will be

negligible(Para 4.22). In other words, there would be minimal, if any, benefit to

the local convenience retailers from the proposed store, but a very significant

adverse impact.

8.40 RTP 09 finally concludes (Para 5.44)the impact on specialist shops is likely

to be lower (than on Tesco Express or Alldays). For that reason we do not believe

that the overall impact on the vitality and viability of the centre is unlikely to be

significant enough to justify refusal of the application. Even based upon the

position shown in the mid-point table at 8.35, this conclusion is obviously incorrect.

A reduction in turnover of existing local independent convenience shops of between20% and 26% is certainly very significant and would most likely put some or all of

them at risk of closure. There is also the real possibility that Alldays will close. The

position would thus seem to be no different to that in Tescos first Application, in

relation to which PR 2008 stated:

the applicants state in their own retail study(GLH 08, but also stated in GLH09)that the key consideration in assessing qualitative need is to provide

consumer choice. If permitted, the new store would be likely to dominate

convenience shopping in(Ashtead) significantly lessening consumer choice

because independent convenience stores would potentially close.

Consequently it would have the opposite effect that Tesco claims(Page 14).

If, however, the opening of the proposed new store was to have such animpact on existing shops that they were to close this would provide grounds


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for refusal on the basis that this would have a negative impact on the health

of the centre(Page 14).

9.0 PR 2009

9.1 PR 2009 is the report, containing conclusions and recommendations, of the

Planning Officers on Tescos second application. Relevant to retail issues, the main

planning issues considered (Page 14) include whetherthe principle of a

supermarket and of the proposed size are acceptableand whetherthe

amendments to the scheme(iefrom Tescos first application) have overcome the

reasons for refusal for the previous scheme.

9.2 It is made clear (Page 14) that the view expressed in RTP 09 isset out and

has been taken into account in the officers conclusions.

9.3 The Mole Valley Core Strategy (Page 15) is a crucial factor in the

determination of Tescos second application. The Core Strategy is based largely on

RTP 07.

9.4 The Core Strategys vision for Ashtead Village Centreincludes (Page 15)

making provision for an increase in convenience shopping floor space that is

appropriate to the scale, nature and function of the centre and complements its

existing provision (underlining added).

9.5 In discussingthe principle and size of supermarket(Page 18), it is made

clear that PR 2009draws largely uponRTP 09. Comments made at 8.0 above in

relation to RTP 09 are thus clearly relevant to PR 2009.

9.6 It is stated (Page 15) that Tescos first applicationwas refused on the

grounds that the proposed food store would be too large for Ashtead village centre

and would dominate local food shopping and be likely to result in the closure of a

number of food shops that would detrimentally affect consumer choice and

character, vitality and viability of the shopping centre. It is, therefore, clear that if

this description could be shown to apply to the proposed store in Tescos second

application, the application should be refused.


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9.7 Whilst it is indicated (Page 20) that there is no longer any requirement to

consider the need for the proposed store (due to changes in planning legislation),

the need analysis in GLH 09does help to inform their impact assessment that is

required.

9.8 The analysis used in, and conclusions drawn from, the GLH 09 assessment of

need (which then flow through to the assessment of impact on local convenience

retailers) is based largely on the premise and data underlying RTP 07. In PR 2008,

it was stated in relation to that underlying data in RTP 07officers consider that the

catchment area and population used for the statistical justification of the need for

the store is too large. It exaggerates the case for a supermarket of the proposed

size(Page 13).

9.9 The same statistical data used in RPT 07 flows through to the impact

assessment on local shops in GLH 09. The very clear criticism in PR 2008 of the

data in GLH 08 would seem just as valid for GLH 09, particularly as the same data

now seeks to justify a smaller store. This fact has been recognised in PR 2009,

where the statement is made (Page 20) thatit should be noted that the catchmentarea referred to as Zone 4 is wider than just Ashtead. About a third of the

catchment population and expenditure used by both consultants includes people

living in parts of Epsom. They would not be expected to look to Ashtead for their

main food shopping but to Epsom that is closer for many and offering several

supermarkets. Consequently, officers are uneasy about too much reliance being

placed upon some of the statistics of both consultants, but they are the best

available(underlining added). However, the analysis above shows the data can beused if analysed properly, but in so doing it clearly demonstrates that the impact of

the proposed store would be significantly detrimental to the other retailers.

9.10 As discussed and illustrated above, the major consequence from the way in

which the RTP 07 data has been used is that the amount and location of top-up

expenditure available to be captured by the proposed store are misrepresented.

This then leads to the impact on the turnover of existing Ashtead convenience stores

being very significantly understated. It therefore seems the officers in PR 2009 were


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correct to beuneasyabouttoo much reliancebeing placed on the RTP 07 data

as used by the consultants.

9.11 As it was in PR 2008, it is again pointed out in PR 2009 (Page 21) that the

household survey (which underpinned RTP 07 and which forms the basis for the

assessment of the impact on local convenience shops) does not disclosehow many

of the households use other shops, such as the butcher, greengrocer and

fishmonger in Ashtead, for additional top-up shopping(Page 21). Of course, what

this should refer to is butchers (2), greengrocers (2), fishmonger, bakers (2), as

these are the actual independent convenience shops in The Street and Craddocks

Parade. It is also pointed out that theCouncils consultantssuspect, though cannot

be sure, that a large number of these households are shopping at some of the

specialist stores in Ashteadand thatthe proportion of top-up shopping for more

local Ashtead residents is likely to be even higher than shown in the survey(Page

21). Indeed, since these shops are currently trading successfully, it is inevitable this

is the case.

9.12 In order to estimate this higher amount, MVDCs consultants (RTP 09, Para5.35) assumed 40% of the proposed stores top-up turnover would be captured from

the local stores. For the reasons explained at 8.21 to 8.24 above, this basis appears

fundamentally flawed, with the consequence that the impact on local stores is

significantly understated in RTP 09.

9.13 In RTP 09, MVDCs consultants also significantly changed (from the basis used

in RTP 08) the basis of apportionment of this turnover impact to the various local

stores without any reasons given. This change further significantly reduces the

estimated impact on the specialist stores shown in RPT 09, as clearly illustrated in

the tables at 8.26 and 8.27 above.

9.14 The position shown in the table at 8.29 above would seem to show the more

likely impact upon the turnover of the local convenience shops. It is clear the impact

(a loss of between 33% and 56% of turnover) is very significant indeed. Even using


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mid-point calculations (table at 8.35 above) the impact remains very significant (a

loss of between 20% and 29% of turnover).

9.15 In either case it would seem reasonable to conclude that the proposed food

store wouldbe likely to result in the closure of a number of food shops that would

detrimentally affect consumer choice and the character, vitality and viability of the

shopping centre.

9.16 In regard to the impact on Ashteads vitality and viability, it is acknowledged

thatsome centres may be particularly vulnerableand that incentres which rely on

a particular diversity and special character, it may be appropriate to take a cautious

approach to potential adverse impacts(Page 21). It is also acknowledged that this

could be interpreted as meaning that adverse impacts may not just relate to the

commercial vitality and viability of a centre but whether its character is undermined

in some way by a development(Page 23). This is an important point as it is clear

from the comments made by MVDCs Economic Development Unit Manager (Page

22) that the proposed supermarket wouldattract alternative businesses to vacant

sites .....with a possible increase in comparison goods shops.

9.17 Since there are currently virtually no vacant shops in Ashtead, what is really

being suggested by the MVDCs Economic Development Unit Manager is that

comparison goods shops will take the place of any existing specialist convenience

food shops which will close down as a result of the proposed store. Such an

outcome would clearly be a change in the existingparticular diversity and special

characterof Ashtead which was recognised by approximately 30% of people in the

RTP 07 survey.

9.18 Given the analysis above has clearly demonstrated the likelihood of some or

all of the local convenience shops closing, it would seem reasonable to conclude that

a cautious approach to adverse impactsshould be taken.

9.19 The proposed store is projected to have a turnover of 9.82 million (RTP 09,

Para 3.3). After taking account of the turnover impact on local food stores shown in


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the mid-point table at 8.35 above (6.95m-2.0m=4.95m) relative market shares

will become:

2011 Turnoverm %

Alldays, The Street 0.65 4.4

Local Convenience Stores,

The Street 1.90 12.8

Local Convenience Stores, Craddocks 0.29 2.0

2.84 19.2

Tesco Express, Craddocks 2.11 14.3

4.95 33.5

Proposed Store 9.82 66.514.77 100.0

9.20 As the proposed store alone would have a 67% share of the local

convenience market, a turnover of 2 times all the other retailers combined and a

turnover of 3 times the other retailers (excluding Tesco Express) combined, it

would seem reasonable to conclude that the proposed storewould dominate local

food shops. Given the significant impact on the turnover of the other retailers, it is

likely to move to a much higher market share.

9.21 From the analysis above, it would seem reasonable to conclude that the

proposed development should be rejected on the same grounds as that of the

previously proposed development, namely:

the proposed food store would be too large for Ashtead village centre and

would dominate local food shopping and be likely to result in the closure of a

number of food shops that would detrimentally affect consumer choice and

the character, vitality and viability of the shopping centre.

Michael John Butler.

Fellow of The Institute of Chartered Accountants in England and Wales.

appendix 4 retail

Documents