Lidl, Blackwater · Lidl, Blackwater, Camberley | Planning & Retail Statement February 2016 gva.co.uk/planning 3 2.7 Blackwater is defined as a district centre in HDC‟s most recent

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Lidl, Blackwater

Planning & Retail Statement

On behalf of Lidl UK

June 2016

Lidl, Blackwater, Camberley | Planning & Retail Statement

February 2016 gva.co.uk/planning

Contents

1. Introduction ......................................................................................................................................................................................... 1

2. The Site and Surroundings ................................................................................................................................................................. 2

3. Proposed Development .................................................................................................................................................................... 4

4. Planning Policy Framework ............................................................................................................................................................... 6

5. Appraisal of Blackwater Town Centre .......................................................................................................................................... 12

6. The Sequential Test ........................................................................................................................................................................... 14

7. Other Planning Considerations ...................................................................................................................................................... 16

8. Conclusions ....................................................................................................................................................................................... 19

Prepared By: Peter Atkin

Authorised by: Adam Bunn / Caroline Marginson

Status: Final

Date: February 2016

For and on behalf of GVA Grimley Ltd


February 2016 gva.co.uk/planning 1

1. Introduction

1.1 Bilfinger GVA has been appointed by Lidl UK to prepare a Planning and Retail Statement in

support of a planning application for the erection of a replacement Lidl foodstore at 21

London Road, Blackwater, Camberley. The proposal seeks the demolition of the existing Lidl

store, and erection of a replacement larger Lidl store of 1,562 sqm net sales area. In addition,

the proposal seeks alterations to access, parking and servicing, further details of which are

provided in the Design & Access Statement which accompanies the application.

1.2 This Planning and Retail Statement has been prepared to assess the application against the

relevant provisions of the statutory development plan and other material planning guidance,

particularly the National Planning Policy Framework (NPPF). The scope and level of detail

provided here is proportionate to the nature of the proposal under consideration, in

accordance with National Planning Practice Guidance (PPG). Where relevant, we make

reference to the Council‟s recently-published retail and town centres evidence base,

specifically the findings of the Retail, Leisure and Town Centres Study prepared by Nathaniel

Lichfield & Partners (NLP) in 2015.

1.3 The store functions as part of Blackwater district centre and emerging local policy indicates

that the store operates an „in-centre‟ location in sequential terms. This means that there is no

explicit policy requirement to demonstrate compliance with the „sequential‟ and „impact‟

tests set out at paragraphs 24 and 26 of the NPPF. However, for completeness, as part of our

Planning & Retail Statement we have considered whether there are any alternative sites in the

district centre which could accommodate the proposed development.

1.4 Our report is structured as follows:

Section 2 describes the location and physical characteristics of the site and surrounding

area and provides more detail on the proposed development;

Section 3 highlights the proposed development, the Lidl business model and the

application package;

Section 4 reviews the planning policy framework and material considerations;

Section 5 provides an appraisal of Blackwater District Centre;

Section 6 sets out the case in respect of the sequential approach in accordance with

Paragraph 24 of the NPPF;

Section 7 reviews the other relevant planning considerations; and

Section 8 sets out our conclusions.



2. The Site and Surroundings

2.1 In this section we describe the location and physical characteristics of the application site and

the surrounding area, and review the relevant planning application history for the site.

Location

2.2 The application site is located in the centre of Blackwater, within the administrative area of

Hart District Council (HDC). Blackwater is situated approximately 400m to the west of

Camberley, approximately 3.5km east of Yateley and approximately 7.5km north-east of Fleet

in the county of Surrey.

Site Description

2.3 The site is bound by London Road (A30) (north), by residential properties on New Road (South),

residential properties and business units on Vicarage Road (east) and a public car park on

Green Lane (west). The application site extends to approximately 0.75 ha. The existing

development on the site comprises a Lidl foodstore (net sales area 1562 sq.m) with associated

car parking (including a public car park) and servicing areas. The existing store is positioned in

the south-east corner of the site, with the remainder of the site used for car parking (79

spaces), servicing and perimeter landscaping. The foodstore is single storey in height.

2.4 Pedestrian and vehicular access into the site is from London Road (A30) to the north, with

parking to the front of the store. The site lies within Flood Zone 1 and is therefore at low risk of

flooding. Foodstores are categorised as „less vulnerable‟ uses and the proposal is therefore

wholly acceptable within Flood Zone 1. Furthermore, the site is not subject to any

environmental or heritage designations.

2.5 Local bus services are available along London Road directly opposite the entrance to the

application site and provide connections to Reading, Aldershot, Camberley and Yateley.

Blackwater rail station, which lies on the Reading to Gatwick Airport line, is also a short

distance (180m) away.

Surrounding Area

2.6 The existing foodstore lies directly to the south of the district centre boundary as currently

defined on the HDC Proposals Map, however for reasons that we set out in full in this report,

we consider the site to form part of the Blackwater district centre and accordingly function as

an „in-centre‟ store.



2.7 Blackwater is defined as a district centre in HDC‟s most recent planning policy documents,

and provides a mix of uses either side of the A30 which bisects the centre. On the northern

side of the A30 are predominantly retail uses, including an Aldi store, but also include some

office space, financial and professional services, community uses, as well as limited car

parking. On the southern side of the A30, the commercial offer comprises a garage, public

house, some warehousing as a spill-over from the industrial estate (to the east) and a small

amount of retail (including the application site) and professional services. Beyond the district

centre lies low density residential estates to the north, west and south.

Planning History

2.8 We have undertaken a desk-based review of planning history for the site; a summary of

relevant planning applications is set out in Table 2.1. The foodstore which currently occupies

the application site was granted under planning permission ref 02/00943/FUL (approved

January 2002), for the „Erection of a foodstore (Use Class A1) with associated car parking.

Subsequent applications for store extensions were granted in 2013, but have not been

implemented.

2.9 There have been a number of further „minor‟ implemented planning permissions related to the

site, the majority of which are advertisement consents.

Table 2.1: Relevant Planning History

Reference Status Description of Development

00/00749/FUL Refused 19th October

2000

Erection of a foodstore – use class A1, with associated car

parking and environmental improvements

01/00799/COU Appeal Allowed 11th

January 2002

Change of use from former car showroom (sui generis) and

petrol filling station forecourt to A1 retail with ancillary car

parking

02/00943/FUL Granted 17th January

2002

Erection of a foodstore ( Use Class A1) with associated car

parking

13/00012/FUL Granted 5th March 2013 Erection of single storey front extension and cladding to

fascias and soffits

13/00803/FUL Granted 20th June 2013 Erection of single storey front extension and cladding to

fascias and soffits.

Source: HDC planning applications database

Pre Application Consultation

2.10 On the 27th April 2016, representatives from Lidl attended a pre application meeting with

Planning Officers and Highways Officers from Hart District Council and local councillors to

discuss the proposals. The proposed development has been amended to reflect comments

made at this meeting.



3. Proposed Development

3.1 The planning application seeks the demolition and redevelopment of the existing Lidl

foodstore and the construction of a replacement foodstore which will continue to be

operated by Lidl. The proposed replacement foodstore is to be reconfigured on a north-west-

south east axis as opposed to the existing north-west – south-east orientation. The

replacement foodstore will have a gross internal area of 2,563 sq. m and a net sales area of

1,562 sq. m, an increase in 554 sq. m of net sales area over the existing store.

3.2 Surface car parking will also be reconfigured to provide 104 spaces (including 6 disabled and

3 parent and child spaces) representing an increase of 25 spaces overall. Pedestrian and

vehicular access, including servicing access, to the new store will remain via London Road to

the north. Further details are provided in the Transport Assessment which accompanies this

application.

3.3 Associated landscaping is to be incorporated along the north, east and southern boundary of

the site.

The Lidl Business Model

3.4 Lidl has a successful and proven retail format which is based on simplicity and maximum

efficiency, offering high quality products from a limited range of exclusive own brand labels at

the lowest prices.

3.5 Verdict classifies Lidl as part of the „deep‟ or „hard‟ discount sector of the convenience

market. Deep discounters have a number of operational characteristics which distinguish

them from the more mainstream retailers (such as Tesco, Sainsbury‟s, Morrisons, Asda, Co-

Operative etc) and influence the way they trade, including:

Relatively basic product lines with only a few recognised brands are sold in store;

Limited type of convenience goods and services offered. For instance, Lidl stores do not

include a fresh meat counter, fresh fish counter, delicatessen/cheese counter, hot food,

pharmacy, dry cleaning services, post office services, photograph shop, mobile phone

shop, or café/restaurant. Lidl also do not sell cigarettes or tobacco; and

Restricted number of lines stocked in store. For instance, a standard Lidl store stocks

between 1,800 core product lines with around 70 and 100 seasonal non-food „special

items‟, whereas a similar sized foodstore operated by a mainstream convenience retailer

will offer between 10,000 and 15,000 lines of mainly branded goods, with larger

convenience stores often offering in excess of 30,000 lines.



3.6 Non-food (comparison) goods normally account for around 15% of floorspace in Lidl stores,

most of which are concentrated on household cleaning and health and beauty products. Lidl

stores receive a twice weekly delivery of what are known as „non-food specials‟, which are

sourced on a pan European scale and are thus able to achieve very competitive pricing.

These items are provided on a „when it‟s gone it‟s gone‟ basis. Due to the limited and

constantly changing offer, the potential for impact upon other retailers is negligible.

3.7 Due to the nature and scale of provision at Lidl stores, customers tend to purchase only part of

their main grocery shop in store and visit other retailers to purchase other specialist or branded

goods. Indeed, it is not unusual to find Lidl stores in close proximity to other foodstore

operators, highlighting the complementary role that deep discounters play to more

mainstream main food and top-up convenience shopping destinations.

3.8 Due to strict operational requirements needed to allow Lidl‟s full range of goods to be sold,

stores are generally between 1,063 – 1,689 sq.m (net). As a result of the limited size and due to

the nature of goods sold, Lidl stores only tend to serve residents within a five minute drive time

catchment area of their stores.

Supporting Documentation

3.9 The Application is supported by a suite of technical assessments and documents, which

confirm that the application will not result in any adverse impacts. These documents include:

Design and Access Statement;

Flood Risk Assessment;

Landscaping Plans;

Lux Plans;

Transport Assessment;

Noise Impact Assessment; and

Existing and proposed plans including Street Scene elevation.

3.10 These documents have all been submitted separately as part of the planning application

however we provide a non-technical summary of the headline findings from these

assessments in Section 7.



4. Planning Policy Framework

4.1 In accordance with Section 38(6) of the Planning and Compulsory Purchase Act (2004),

planning applications should be determined in accordance with the development plan,

unless material considerations indicate otherwise.

4.2 For the purposes of this application, the development plan comprises of the following:

Hart District Local Plan (Replacement) 1996-2006 and First Alterations to the Hart District

Local Plan (Replacement) 1996-2006 Saved Policies (April 2009); and

Policy NRM6: Thames Basin Heaths Special Protection Area of the South East Plan

4.3 The National Planning Policy Framework (NPPF) and the National Planning Policy Guidance

(NPPG) are both material considerations in planning decisions.

National Planning Policy Framework (NPPF)

4.4 The NPPF was formally adopted in March 2012 and replaces the suite of national Planning

Policy Statements, Planning Policy Guidance notes and some Circulars with a single,

streamlined document. It requires Local Planning Authorities (LPAs) to adopt a positive

approach to decision-taking and to apply a presumption in favour of sustainable

development. The NPPF makes clear the Government‟s commitment to securing economic

growth in order to create jobs and prosperity and to ensure that the planning system does

everything it can to support sustainable economic growth.

4.5 In terms of retail policies, the NPPF maintains the general thrust of the old Planning Policy

Statement 4. It advocates a „town centres first‟ approach, and requires planning policies to

positively promote competitive town centre environments and manage the growth of centres

over the plan period. Paragraphs 24-27 confirm that applications for new retail floorspace on

sites that are not in a town centre location and not in accordance with an up-to-date

development plan must:

demonstrate compliance with the „sequential test‟; and

undertake an impact assessment if the development is over a proportionate, locally set

threshold or a default threshold of 2,500 sq.m.

National Planning Policy Guidance (NPPG)

4.6 On 6 March 2014 the Department for Communities and Local Government (DCLG) launched

online planning policy guidance, which cancelled a number of previous planning practice

guidance documents, including the Practice Guidance on Need, Impact and the Sequential



Approach (2009). The web-based resource provides guidance on the application of the NPPF

retail (sequential and impact tests) and how they should be used in decision-making.

However, as we have stated above, under the terms of the NPPF there is no requirement for

the application scheme to demonstrate compliance with these tests, we do not assess the

NPPG in any further detail.

Local Planning Policy

Local Plan

4.7 HDC withdrew its emerging Local Plan: Core Strategy 2011-2029 on 30th September 2013. As a

result, the saved policies of the Hart District Local Plan (Replacement) 1996-2006 and First

Alterations to the Hart District Local Plan (Replacement) 1996-2006 (April 2009) remain in force

and provide the broad policy framework for guiding and determining new development in

the District.

4.8 In accordance with paragraph 215 of the NPPF, due weight should be given to relevant

policies in the Local Plan according to their degree of consistency with the NPPF (i.e. the

closer the policies in the plan to the policies in the Framework, the greater the weight that

may be given).

4.9 The Borough has a well-established network of town centres and the Local Plan identifies

Blackwater as one of the „Rural Centres‟. The withdrawn Core Strategy identified Fleet as the

only „town centre‟ in the District, with Blackwater defined as a „district centre‟. Although HDC‟s

Core Strategy has now been withdrawn, for the purposes of our report we continue to refer to

Blackwater as a „district centre‟ for ease of reference.

4.10 The HDC Proposals Map illustrates land use designations across the Borough. An Extract of the

Proposals Map covering the application site is provided at Figure 4.1 below which identifies

that the application site is currently dissected by the existing district centre boundary, with the

existing foodstore located adjacent to, but outside the defined district centre boundary. It

therefore occupies an „edge-of-centre‟ location, when assessed against the HDC Proposals

Map.



Figure 4.1 Proposals Map Extract

Source: HDC Proposals Map, 2009

4.11 There are two „saved‟ Local Plan policies which are of particular relevance to the

development. Saved Policy URB10 (Out of Centre Retailing) states that proposals for large

scale retail development (over 2,500 sq.m) outside the defined town centres, district shopping

centres and local centres will not be permitted unless there is an identified need for additional

shopping provision which cannot be met in the commercial centre, in which case the

sequential approach to site selection will be adopted. This means that town centre sites are

the first preference for the location of large-scale retail units, followed by edge of centre sites,

followed by district or local centres (serving residential areas). Only as a last resort will an out-

of-centre site be considered. The policy continues that all sites must additionally satisfy the

following criteria:

i) The proposal is capable of serving the area without adversely affecting the character,

vitality and viability of nearby centres, either as a result of the individual proposal or of

the cumulative impact of several such proposals or developments; and

ii) The proposal would not cause a local shortage of land for business, industrial,

distribution or other uses; and

iii) The site is easily accessible by public transport, walking and cycling.

4.12 Policy B1 (Blackwater Town Centre: Retention of Retail Uses) states that in order to safeguard

the vitality and neighbourhood shopping function of the district centre, development

proposals involving the loss of retail uses from the existing shopping area (fronting the northern



side of the A30, between The White Swan Public House and the supermarket on the corner of

Rosemary Lane inclusive) will not be permitted. The application site is not covered by this

policy.

Material Considerations

4.13 As set out above, HDC withdrew its previous Local Plan: Core Strategy in 2013 and has since

been working towards the preparation of a new Local Plan. It is anticipated that the Council

will undertake Regulation 18 consultation on their „preferred approach‟ to future

development in the district in Summer 2016.

4.14 As part of its evidence base to inform the emerging Local Plan, HDC commissioned a Retail,

Leisure and Town Centres Study prepared by Nathaniel Lichfield & Partners (NLP). The Study

consists of two parts – „Part 1 – Development Needs‟ (February 2015) and „Part 2 – Town

Centres‟ (May 2015). The Retail Study Part 1 states at paragraph 4.43 that:

“The level of expenditure attracted to Blackwater is surprising given the relatively

limited provision of convenience good stores in the centre, however the

household survey results showed a high proportion of trips to the existing Aldi

store, which suggests that this store in particular is trading at a level significantly

above national average.”

4.15 The information presented in Table 6B of the Retail Study Part 1 indicates that the Blackwater

Aldi‟s total turnover (£8.48m) is approximately three times greater than Lidi‟s (£2.96m).

4.16 The Retail Study Part 1 provides the following recommendations (set out in Table 4.1 below) for

suggested new convenience floorspace demand in HDC to be delivered in the emerging

plan period i.e. up to 2032, based on ONS Population and Strategic Housing Market

Assessment (SHMA) projections.



Table 4.1: Blackwater Convenience Goods Retail Floorspace Projections

Projection Additional Convenience Retail Floorspace (sq.m gross)

2014-2018 2018-2022 2022-2027 2027-2032 Total

2014-2032

ONS

Population

3,385 185 259 249 4,078

SHMA

Population

3,420 202 290 288 4,200

Source: NLP, Retail Leisure and Town Centres Study Part 2 – Town Centres (2015)

4.17 The baseline capacity forecasts indicate that Blackwater could therefore support the

proposed additional net sales area of 554 sq.m put forward in this application.

4.18 Significantly, the Retail Study Part 2 recommends at paragraph 3.44 that:

“The town centre boundary should be extended to include the Lidl store to the

south of London Road. It is not essential to define a separate PSA [Primary

Shopping Area] for Blackwater, however the area identified under Policy B1

could be redefined as a PSA. If so, this should be extended to include the Lidl

store. Alternatively, this could be defined as primary shopping frontage, with the

remainder of the frontages within the centre boundary defined as secondary

shopping frontages.” (our emphasis)

4.19 The Council‟s most recent evidence base study therefore makes a clear policy

recommendation that the Lidl store should form part of the defined centre boundary for

Blackwater. We have also undertaken informal discussions with HDC policy officers which

indicate a commitment from HDC to carry forward the Retail Study‟s recommendations within

the emerging Local Plan to extend the Blackwater district centre boundary to include the

existing Lidl store which is now proposed for redevelopment.

Summary of planning policy framework

The National Planning Policy Framework (NPPF) sets out the Government‟s planning

policies for England. It replaces the suite of national Planning Policy Statements, Planning

Policy Guidance and some Circulars with a single, streamlined document.

At the heart of the NPPF is a „presumption in favour of sustainable development‟, which

should be seen as a golden thread running through both plan-making and decision-

taking.

The NPPF advocates a „town centres first‟ approach, and requires planning policies to

positively promote competitive town centre environments and manage the growth of

centres over the plan period.



The application site lies adjacent to, but outside the defined Blackwater district centre

boundary. Accordingly, for retail purposes, the application site is situated within an „edge-

of-centre‟ location. However, it is clear that the store functions as part of the commercial

offer of the district centre and this is reflected in the policy recommendations contained

within the Council‟s most recent evidence base study.

In accordance with the saved Local Plan policies the Council will seek to achieve

sustainable development by preserving and enhancing the existing network of town

centres and require a sequential approach to site selection to be adopted before out-of-

centre and/or edge-of-centre sites may be considered for new retail provision.

HDC are currently preparing a new Local Plan and have commissioned a Retail Study to

inform the evidence base. The Retail Study highlights that sufficient capacity exists within

Blackwater to accommodate the proposed development and also recommends that the

district centre boundary be extended to include the Lidl store in its entirety. Informal

discussions with HDC Policy Officers have identified a commitment to carry forward the

findings of the Retail Study within the emerging Local Plan.

In light of the above, it is necessary to undertake a sequential test to confirm that no other

sequentially preferable sites are available within the district centre to accommodate the

proposed development, although the emerging policy position also represents a

significant material consideration in favour of the proposed development.



5. Appraisal of Blackwater Town Centre

5.1 Blackwater is situated to the north-east of Hart District and, as we have previously identified, is

designated as a „Rural Centre‟ in the saved policies of the HDC Local Plan. HDC‟s

abandoned Core Strategy defines Blackwater as a „district centre‟. Blackwater is a linear

centre primarily comprising existing units on the northern side of the A30 (London Road) and

extending from the border with the railway lines at the eastern end of the centre to the Aldi

Store to the west, as well as incorporating elements to the south of the A30 (London Road)

and Green Lane. The centre lacks clear definition and is within close proximity to

neighbouring Camberley, in the adjoining borough of Surrey Heath.

5.2 The centre is focused on London Road and includes:

Convenience shopping – including Aldi and Lidl supermarkets as well as newsagents and

general store;

Comparison shopping – limited provision, largely focussed on day-to-day shopping needs;

Services – limited to hairdressers and beauty parlours;

Entertainment – including a pub and music venue.

Diversity of Uses & Retailer Representation

5.3 Blackwater has a total of 29 retail/service units. The diversity of uses present in the centre in

terms of the number of units is set out in Table 5.1 compared against the national average.

Table 5.1: Blackwater Use Class Mix by Unit

Type of Unit Units 2015 % of Total Number of Units

Blackwater % UK Average

Comparison Retail 9 31.0 36.0

Convenience Retail 4 13.8 8.1

A1 Services 5 17.2 14.1

A2 Services 2 6.9 12.1

A3/A5 6 20.7 14.7

A4 pubs/bars 2 6.9 2.9

Vacant 1 3.4 12.1

Total 29 100.0 100.0

Source: NLP, Retail, Leisure and Town Centres Study – Part 2 (2015)

5.4 As identified in the Retail Study, Blackwater‟s mix of units shows that representation of

comparison retailers is below the national average, and the proportion of convenience

retailers is above. However, this is to be expected from a district centre as these typically

serve fairly limited catchment areas. The lack of comparison goods retailers in the centre is



not, therefore, an indication that the centre suffers from poor vitality and viability. The

Council‟s Retail Study highlights that the Aldi supermarket is trading very well, significantly

above the national average.

5.5 Blackwater has a good range of non-retail service uses, with all categories present apart from

estate agents / valuers and travel agents. There are a number of cafes, fast food takeaways

and hairdressers / beauty parlours trading in the centre.

Vacancies

5.6 Table 5.1 shows that as of 2014 (the time of the survey which supported the NLP study) there

was just one vacant unit in Blackwater, equating to a vacancy rate of 3.4%. This is significantly

below the national average of 12.1%, highlighting a robust level of demand for units within the

centre, and confirming that the centre exhibits generally positive signs of vitality and viability.

Environmental Quality

5.7 The environmental quality of Blackwater is generally functional and somewhat dated in parts,

with no defining features and a poor public realm. The busy main road dissects the centre,

which compromises the environmental quality of the centre.

Accessibility

5.8 Blackwater railway station is situated at the eastern edge of the district centre on London

Road and provides regular services to Reading and Gatwick Airport. Blackwater is also served

by several bus services connecting the centre with areas including Reading, Aldershot,

Camberley and Yateley.

5.9 Our assessment of Blackwater has identified that:

The centre can be considered to be performing generally well in respect of vitality and

viability, and the diversity of uses in the centre is such that residents‟ day to day shopping

needs can readily be met.

The centre has a mix of uses which is orientated towards convenience retailers and

services. Representation from foodstores in the centre is particularly strong with existing

foodstores helping to drive footfall throughout the centre. The comparison offer of the

centre is more limited, but this is not unusual in smaller centres such as Blackwater.

The overall vacancy rate is well below the national average.

The environmental quality of the centre is generally functional; however the proposed

development will make a positive contribution to this relative to the current position.

Further details of this are provided in the Design & Access Statement which accompanies

the application.



6. The Sequential Test

6.1 In line with national and development plan policies. it is necessary to demonstrate that there

are no sequentially-preferable sites which can accommodate the proposed development

within Blackwater district centre.

6.2 As set out in this report, the application site is located adjacent to, but outside the boundary

of Blackwater District Centre, as defined by the Council‟s Local Plan Proposals Map. It is

therefore „edge of centre‟ when assessed against the Proposals Map. However, the store

clearly functions as part of the district centre and the Council‟s most recent retail evidence

base (NLP, 2015) agrees with this position.

6.3 Paragraph 24 of the NPPF confirms that local planning 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‟ (our emphasis). Annex 2 to the

NPPF defines „main town centre uses‟ as including „retail development‟. Annex 2 to the NPPF

also defines „town centre‟ as:

“Area defined on the local authority’s proposals map, including the primary

shopping area and areas predominantly occupied by main town centre uses

within or adjacent to the primary shopping area. References to town centres

apply to city centres, town centre, district centres and local centres but exclude

small parades of shops of purely neighbourhood significance”

6.4 Annex 2 of the NPPF defines „edge of centre‟ as:

“For retail purposes, a location that is well connected and up to 300 metres of the

primary shopping area”

6.5 It is clear from the Proposals Map extract (Figure 4.1) that the application site is adjacent to

the defined „district centre‟ boundary and within 50m of the primary shopping frontage on the

north side of the A30 (London Road). The application site is therefore considered to comprise

an „edge of centre‟ location as defined by the NPPF. However, as our analysis has

demonstrated, to all intents and purposes the site functions as part of the district centre.

6.6 Blackwater district centre is limited in size and based on our visits to the centre and

examination of local policy documentation there are no sequentially preferable sites

available within the centre to accommodate the proposed development as the physical

space required does not exist. There is no requirement under the NPPF to consider sites which

are too small and therefore not „suitable‟ for the proposed development.



The Rationale for Development

6.7 The rationale for the proposed development will provide customers of the Blackwater store

with an improved shopping experience, with enhanced circulation space, better stock

availability, and additional car parking facilities. Therefore, any alternative site would need to

be able to deliver the same operational benefits to Lidl as that proposed by the application

scheme. A site which failed to deliver these operational benefits would not be suitable for Lidl

as there would be no merit in the company relocating from its existing premises.

6.8 As we have set out in Section 3, Lidl stores draw the majority of their trade from a five-minute

drive-time. The proposed scheme is location-specific, designed to improve the shopping

experience for customers in what is currently a successful trading . There is an established

network of Lidl foodstores in the surrounding area, including in Camberley and Crowthorne,

and therefore it is not appropriate to consider opportunities in locations other than Blackwater

district centre.

6.9 In considering the compliance of the application scheme with the sequential test it is also

necessary to have regard to the „fall back‟ position. In the unlikely event that the Council

were to refuse the application on sequential grounds, Lidl would not seek to develop a smaller

store elsewhere in Blackwater district centre, given the presence of the existing store at the

application site. The existing store would simply continue to trade.

Identification of Sites

6.10 We are not aware of any potentially available or suitable sites which have been identified as

having the potential for redevelopment, and that would be sequentially preferable to the

application site. As we have set out above, the application site is in the most sequentially

preferable location to accommodate the proposed development.



7. Other Planning Considerations

7.1 The application is supported by a suite of technical assessments and documents, which

confirm that the application will not result in any adverse impacts. These documents have all

been submitted separately as part of the planning application however we provide a non-

technical summary of the headline findings from these assessments in this section.

Design and Access

7.2 Lidl UK as an operator acknowledges that store format and design are important in terms of

the wider built environment and the setting of the site in the broader context. The design

therefore is sympathetic in scale and massing to existing development in the surrounding

areas.

7.3 The design incorporates corporate branding in terms of format, layout, materials, finish,

external environment and signage similar to other new stores.

7.4 The proposed store is positioned along the north eastern boundary of the site 90 degrees to

the existing store location. The remaining parts of the site are laid out for customer car parking

and a trolley enclosure. The trolleys will have the standard £1 system that is used across the

country to ensure the safe return of trolleys to the enclosure.

7.5 Vehicular access into the site is via an improved junction off Green Lane made possible due

to the inclusion of No 1 Green Lane within the overall site. Additional landscaping is proposed

along London Road and the existing landscaping along the north east boundary will be

maintained. Additional soft landscaping will be provided between the car parking and rear

boundaries to No‟s 5 to 13 Green Lane

7.6 The car parking spaces provided are located to the south west of the proposed store. The

layout has been arranged to make it safe and easy for customers to manoeuvre around the

car park when looking for somewhere to park. A total of 104 car parking spaces are provided

including 6 disabled spaces and 3 parent and child spaces located close to the main

customer entrance to the store for ease and convenience.

7.7 The service area is located along the south eastern side of the building and carefully

positioned to facilitate the manoeuvring of the delivery vehicle into the ramped area in front

of the delivery doors. Tracking drawings have been prepared which confirm that delivery

vehicles can service the store during trading hours with no impact on the car parking

provision.



Flood Risk Assessment

7.8 The site is located within Flood Zone 1 and is at low risk of surface water flooding. The Flood

Risk Assessment has demonstrated that the proposed scheme will not create an

unacceptable risk elsewhere, and confirms the suitability of the site for the proposed

development.

7.9 As the proposed development will lead to an increase in impermeable area, Sustainable

Drainage Methods are proposed to ensure that surface water is managed effectively. Surface

water discharge from the proposed development will be limited to that from the existing site

and attenuation storage will be provided to store run off from 100 yr storm events.

Transport Assessment

7.10 The site is located close to public transport (bus and rail). In order to further improve

accessibility and permeability, pedestrian and cycle links are proposed to connect the store

with the surrounding area, including the A30 London Road.

7.11 The access proposals have been tested using AutoTRACK plots. This demonstrates that

adequate geometry and mobility can be provided. The design of the internal layout will

comply with standards set out by Hampshire County Council.

7.12 The site is also considered to be conveniently located for local residents to walk to and from

the site. It is likely that a site travel plan will be secured by condition. It is considered that

subject to planning conditions and for legal agreement, the transport assessment has

demonstrated that there are no technical, operational or road safety reasons to preclude

planning consent being granted.

Sustainability

7.13 Lidl Food Stores have an environmental policy that represents a conscious effort to reduce

carbon emissions through responsible and considerate operating procedures which include,

but are not limited to:

For energy conservation reasons, Lidl‟s chosen store heating systems are highly efficient

condensing boilers which recover waste heat from the combustion process. All heating is

regulated by sensors; Lidl aim for checkout areas to be heated to 21°C, sales area to 19°C,

and welfare to 21°C and the storage area to 13°C.The average gas consumption is

approximately 100,000 kWh per annum.

The lighting in the storage and welfare areas is controlled by movement sensors, which

means that lights are not left on unnecessarily. The sales area uses full lighting during



trading hours and cuts back to one third lighting before and after trading hours to allow for

the stocking of the store. Electricity consumption is approximately 150,000 kWh per annum.

Water consumption is carefully monitored and on average is limited to 13 cubic metres per

month, and therefore approximately 156 cubic metres per year.

A Building Management System and LUX sensors control the external lighting. This means

that lights are only on during hours of darkness and ensures that lights do not remain on

later than 1 hour after the store closes.

Noise Impact Assessment

7.14 The supporting Noise Impact Assessment has assessed activities associated with the

development including plant and deliveries associated with the food store on nearby sensitive

receptors.

7.15 The impact of the plant associated with the store has been assessed to British Standard

4142:2014. The plant rating sound level will result in a British Standard 4142:2014 assessment

“difference” of 0 dB at the most sensitive receivers and as such is estimated to be of a low

impact and once all pertinent factors (i.e. context) are taken into account this impact does

not change.

7.16 The impact of the unloading activities has been assessed to British Standard 4142:2014. The

delivery rating noise level will result in a British Standard 4142:2014 assessment “difference” of -6

dB at the most sensitive receivers and as such is estimated to be of a low impact and once all

pertinent factors (i.e. context) are taken into account this impact does not change.

7.17 The impact of the arrival and departure has been assessed based on the change in noise

level scale from the IOA/IEMA Working Party Consultation Draft (2002) which categorises the

significant of a change in noise level. Based on this scale and the noise modelling the change

in noise levels is expected to be a no adverse impact which would be imperceptible.



8. Conclusions

8.1 The focus of this Planning and Retail Statement has been to consider the key policy issues

raised by the proposal for the demolition and redevelopment of the existing Lidl foodstore and

the construction of a replacement foodstore at London Road, Blackwater. The current store is

dated, inefficient and failure to invest in the portfolio will result in Lidl falling behind its

competitors. The proposed scheme is part of a nationwide programme

8.2 The planning application seeks the demolition and redevelopment of the existing Lidl

foodstore and the construction of a replacement foodstore which will continue to be

operated by Lidl. The proposed development foodstore will have a gross internal area of 2563

sq. m and a net sales area of 1,562 sq. m, an increase in 554 sq. m over the existing store.

8.3 The proposed replacement foodstore is to be reconfigured on a north west- south east axis as

opposed to the existing north-west – south-east orientation. Surface car parking will also be

reconfigured to provide 104 spaces (including 6 disabled and 3 parent and child spaces)

representing an increase of 25 spaces overall. Pedestrian and vehicular access, including

servicing access, to the new store will remain via London Road to the north. Associated

landscaping is to be incorporated along the north, east and southern boundary of the site.

8.4 This Planning and Retail Statement has been prepared to assess the application against the

relevant provisions of the statutory Development Plan and other material planning guidance,

particularly the National Planning Policy Framework (NPPF). The scope and level of detail

provided here is proportionate to the nature of the proposal under consideration, in

accordance with online National Planning Practice Guidance (PPG).

Compliance with Policy and Material Considerations

8.5 The NPPF advocates a „town centres first‟ approach, and requires planning policies to

positively promote competitive town centre environments and manage the growth of centres

over the plan period. As the application site lies adjacent to the defined district centre of

Blackwater it is necessary to demonstrate that there are no sequentially preferable sites within

the district centre which could accommodate the proposed development. We are not aware

of suitable sites within the district centre that could accommodate the proposed

development, and it is not appropriate to consider sites in alternative centres.

8.6 Moreover, as established above the Council intend to extend the boundary of the district

centre to include the entire application site within the emerging Local Plan, reflecting the fact

that the Lidl store clearly functions as part of the district centre. The store plays an important

role in contributing to the vitality and viability of the wider district centre, and the proposed



development represents a positive investment in the centre by a leading national retailer

which will further support the vitality and viability of the centre in the long term.

8.7 Accordingly, in light of the above, it is considered that the proposed development complies

with the provisions of the NPPF.

Principle of Development

8.8 The site is currently occupied by an existing foodstore, therefore the principle of development

has been established. The site is located „edge of centre‟ when assessed against the

proposals map, however, it is clear that the site functions as part of the district centre and the

Council‟s most recent retail evidence base (NLP, 2015) agrees with this position. There are no

sequentially preferable sites available within the centre to accommodate the proposed

development as the physical space required does not exist.

Conclusion

8.9 This Planning and Retail Statement has demonstrated that the proposed scheme is entirely

acceptable when assessed against national planning policy and the Development Plan. The

proposals will deliver significant private sector investment into the Blackwater area, and will

contribute to and strengthen the vitality and viability of Blackwater district centre. The

proposals should therefore be viewed favourably and granted planning permission.

Documents

Lidl, Blackwater · Lidl, Blackwater, Camberley | Planning & Retail Statement February 2016 gva.co.uk/planning 3 2.7 Blackwater is defined as a district centre in HDC‟s most recent