Local Plan Examination in Public Council Hearing Statement

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Local Plan Examination in Public

Council Hearing Statement

Matter 5: Retail, Leisure and other Main

Town Centre Uses

July 2018

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Contents Issue 5.1: Need for Main Town Centre Use Development ..................................................................... 3

Issue 5.2: Accommodating Main Town Centre Uses .............................................................................. 6

Issue 5.3: Development Management Policies relating to Retail and Town Centres ........................... 15

This appendix relates to Q81

Appendix 1: Local Centre Boundaries

Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses

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Issue 5.1: Need for Main Town Centre Use Development Local plans should be based on assessments of the needs for land or floorspace for all foreseeable

types of economic activity over the plan period, including retail and leisure development33.

The Council’s Retail and Leisure Study 2015 [RT3] and Addendum [RT2] identify “capacity” or

potential demand during the plan period for:

• 6,000 to 7,600 sqm of additional net floorspace for convenience goods;

• 11,900 to 41,700 sqm of additional net floorspace for comparison goods; and

• new health and fitness clubs, a ten pin bowling alley, additional restaurants, and a small

multiplex cinema.

The Study advises that the long term assessment should be treated with caution due to the obvious

difficulties inherent in predicting the performance of the economy and shopping habits over time. In

any event, any identified capacity should not necessarily be viewed as justification of new retail

floorspace outside centres as this could prejudice the implementation of any emerging town centre

redevelopment strategies and the development of more central sites which may be currently

available or which could become available over time.

62. Does the Council’s evidence accurately identify the “capacity” for additional floorspace for

convenience and comparison goods shopping over the plan period? In particular, does the

evidence make realistic assumptions about (a) sales densities and (b) shopping patterns across the

catchment area?

Yes. The methodology adopted in identifying capacity (quantitative need) for additional convenience

and comparison goods shopping over the plan period is an industry standard / accepted one. The

methodology is frequently subjected to scrutiny by third parties and Inspectors and has been found

to be sound. The latest capacity findings are set out in the 2018 Broxbourne Retail and Leisure Study

2nd Addendum [RT3A].

In terms of the assumptions made in relation to sales densities and shopping patterns:

(a) Sales Densities - Having regard to the fact that the level of floorspace capacity will vary

dependent on the type of retailer proposed and, in the case of comparison goods, the type of

goods traded, minimum and maximum floorspace capacity figures are identified. The sales

density figures adopted for convenience goods floorspace capacity are derived from average

sales density figures for grocers identified by GlobalData.com (previously VerdictRetail.com)

which is an industry recognised source for grocers sales densities. The sales density figures

adopted for comparison goods floorspace capacity have regard to average sales density figures

published by Mintel Retail Rankings which again is an industry recognised source for sales

densities for comparison goods retailers. The minimum comparison goods sales density figure

is based on the identified capacity being met through the delivery of ‘high street’ floorspace and

the maximum figure relates to the identified capacity being met by bulky goods retailers or in

smaller town centre (which both generally accommodate operators which achieve lesser sales

densities). They represent both a higher and lower end of what is considered could be achieved

in the Borough of Broxbourne having regard to available sales density data of retailers.


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(b) Shopping Patterns – Market Researchers NEMS were commissioned, as part of the market

research for the July 2015 Retail Study, to undertaken a comprehensive household telephone

survey to identify shopping patterns in the Borough and wider Study Area. The undertaking of a

household telephone survey is a standard and widely industry accepted approach in

establishing shopping patterns for both retail studies and planning applications for retail

development.

63. What are the most appropriate assumptions to make about sales densities for the type of

retail development proposed at Brookfield?

In the absence of named retailers for the planned Brookfield development professional judgements

have been made on sales densities for the convenience and comparison goods retail floorspace.

These judgements have been made having regard to average/benchmark sales density data

published by retailers and WYG’s retail planning experience. This is an orthodox, and NPPG

compliant, approach to estimating the turnover of planned/proposed retail developments.

In terms of the estimated sales density for the planned convenience goods floorspace for Brookfield

(£12,000/sq m at 2026), the figure is based on an average of the sales densities of the leading four

supermarkets (Tesco, Asda, Sainsburys and Morrison). The figure has been derived from sales

density data published by GlobalData.com.

Given the representations and discussions that took place at the previous Core Strategy examination

with regard to the sales density for the then larger amount of planned comparison goods floorspace

at Brookfield an assessment of three trading assessment scenarios is provided – each adopting

different sales densities [RT1A]. The precise comparison goods turnover of the planned Brookfield

will vary depending on the end retailers. It is considered that having regard to inter alia: the level of

planned retail floorspace, existing retail provision in Brookfield; the location of existing retail

provision (notably in Harlow and Enfield); and published average sales density, Scenario B, which

adopts a sales density of £5,750/sq m (at 2026), represents the most likely comparison goods

turnover figure. For reference purposes average sales density figures for a number of the main high

street comparison goods retailers are set out in the table below:

Retailer Sales Density (£/sq m)

Retailer Sales Density (£/sq m)

John Lewis Marks & Spences House of Fraser Next Primark

10,726 5,548 2,792 4,878 7,283

Arcadia Group H&M TK Maxx WH Smith Wilkinson

4,545 5,567 4,632 5,169 3,304

Average of above 10 Retailers = £5,444/sq m

Source: Mintel Retail Rankings 2017 Arcadia Group includes Top Shop/Top Man, Dorothy Perkins, Evans, Burton, miss Selfridge, Wallis, Oasis and Warehouse Sales Density figures are @ 2026. Allowance made for increased turnover efficiency as set out in Table 4b of Experian Retail Planner 15 2012 Prices


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64. Does the Council’s evidence accurately identify the potential demand for additional leisure

developments in the Borough over the plan period?

Yes. In order to ascertain whether that are any shortfalls in respect of existing commercial leisure

uses the 2015 Retail and Leisure Study [RT3] identifies commercial leisure needs for the Borough by

assessing its existing provision against accepted sector ‘benchmarks’. The adopted methodology is

set out in Section 8.2 of RT3. Again, the methodology has adopted is an industry standard /

accepted one and is frequently subjected to scrutiny by third parties and Inspectors and has been

found to be sound.

As noted in RT3, the assessment of quantitative need in the leisure market necessarily departs from

the quantitative retail need methodology for a number of reasons, including the fragmentation of

leisure markets and the limited availability of accurate data. The household telephone survey

undertaken to support the 2015 Retail and Leisure Study however allows an assessment of the

market share secured by commercial leisure facilities with the Borough and the wider Study Area for

a variety of leisure sectors. This qualitative assessment of the attractiveness of the Borough’s leisure

facilities is supplemented through the use of national data in respect of the typical level of provision

of specific types of facilities across the UK. By referencing to estimated increases in the Retail Study

area population, the ‘benchmarking’ exercise informs our judgement in respect of the likely future

need for additional commercial leisure facilities in the Borough.

65. Does the potential “capacity” or potential demand for additional main town centre uses

identified in the Council evidence represent a “need” for such forms of development during the

plan period?

Yes. RT3, RT2 and RT3A identify both quantitative (capacity) and qualitative needs for retail and

commercial leisure uses for the Borough. They represent the retail and commercial leisure needs for

the Borough. The NPPF (paragraph 23) places emphasis on the requirement for all identified needs

to be met (met in full) and that such needs are not compromised by limited site availability.

Accordingly, in planning for Brookfield, the Council has had regard to both quantitative (capacity)

and qualitative needs identified in RT3, RT2 and RT3A.

If the Council does not plan to meet the identified retail and commercial leisure needs identified in

RT3, RT2, RT3A, residents in Broxbourne will continue to be disadvantaged and have to travel

distances to other centres outside the Borough.

66. Given that the Retail and Leisure Study and Addendum set out ranges for the potential

capacity for additional retailing, and the caution that it recommends in the use of the long term

assessments, is the proposal in the Plan for around 40,000 sqm of new retail development

justified?

Yes. Notwithstanding the acknowledged difficulties inherent in predicting the performance of the

economy and shopping habits over a long period, the planned retail floorspace at Brookfield has

been allocated having regard to the requirements of paragraph 23 of the NPPF. Paragraph 23

requires LPA’s, in drawing up Local Plans, to set out policies for the growth of centres over the plan

period. Bullet point 6 of paragraph 23 specifically identifies that it is important that needs for retail,

leisure, office and other main town centre uses are met in full. In accordance with bullet point 7 of


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paragraph 23, in the absence of appropriate town or edge of centre sites the Council has proposed

policies to seek to meet the identified plan period needs (in full) in a new town centre at Brookfield

which will be a highly accessible location.

67. Given that the Retail and Leisure Study does not quantify the amount of floorspace that may

be needed for the leisure uses that it suggests that the Borough could support, is the proposal in

the Plan for 10,000 sqm of new leisure development justified?

Yes. As noted in our response to Q65, the NPPF (paragraph 23) places emphasis on the requirement

for all identified needs (both quantitative and qualitative) to be met. Accordingly, in planning for

Brookfield, the Council has had regard to both quantitative (capacity) and qualitative commercial

leisure needs identified in the 2015 Retail and Leisure Study [RT3].

The methodology for assessing commercial leisure needs in the Borough is summarised in

our response to Q64.

The potential mix of leisure uses was derived from 2015 Borough of Broxbourne Retail and

Leisure Study and early master planning discussions with Bayfordbury Estates, the original

promoter of the Brookfield commercial development. It was consequently envisaged that

there would be a mix of leisure uses as follows:

- 4,000 sq m food and drink

- 2,500 sq m health and fitness

- 3,500 sq m cinema

The 10,000 square metre figure within the Policy was drawn from this mix. The potential

impact of the leisure uses was assessed within the Brookfield Retail and Leisure Impact

Study 2017. This concluded that the impacts of the proposed mix of leisure uses on town

centres inside and outside the borough would be acceptable. It is therefore considered that

this policy provision is justified.

Issue 5.2: Accommodating Main Town Centre Uses Local plans should positively seek opportunities to meet the development needs of their area.

Objectively assessed needs should be met in full with sufficient flexibility to adapt to rapid change

unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits

when assessed against the policies in the NPPF taken as a whole or specific policies in the NPPF

indicate development should be restricted.

Local plans should aim to ensure the vitality of town centres and set out policies for their

management and growth over the plan period. Local plans should allocate a range of suitable sites to

meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and

residential development needed in town centres such that those needs are met in full and not

compromised by limited site availability. Local planning authorities should undertake an assessment

of the need to expand town centres to ensure a sufficient supply of suitable sites. Appropriate edge of

centre sites for main town centre uses that are well connected to the town centre should be allocated

where suitable and viable town centre sites are not available. If sufficient edge of centre sites cannot


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be identified, identified needs should be met in other accessible locations that are well connected to

the town centre.

This issue is concerned with establishing whether the strategy for accommodating main town centre

use development is consistent with the available evidence, justified in other respects, and consistent

with national policy.

Policy DS1 states that provision will be made for around 40,000 sqm of new retail development and

around 10,000 sqm of new leisure development.

The Council’s Retail and Leisure Study 2015 [RT3] includes a study area that includes Broxbourne

Borough and surrounding areas in Enfield, Welwyn Hatfield, East Hertfordshire, Epping Forest and

Harlow and identifies 7 “higher order” town centres in that area including “regional centres” in

Welwyn Garden City and Stevenage and “sub regional centres” in Enfield and Harlow.

The Council’s Brookfield Retail Impact Study 2017 [RT1] indicates that, even if the proposed retail and

leisure development at Brookfield takes place, all town centres would experience significant growth

in expenditure 2016-2024 eg Hoddesdon 6%, Waltham Cross 16%, Enfield 30% and Harlow 40%.

Based on high sales density assumptions, the impacts on turnover at other town centres are

predicted to be:

• Cheshunt -2.5%

• Hoddesdon -3.3%

• Welwyn -4.6%

• Waltham Cross -5.2%

• Harlow -5.7%

• Enfield -6.1%

• Others <-3%

The Study does not identify any significant adverse impacts on existing, committed or planned

investments in town centres in the catchment area, and concludes that their viability and vitality is

unlikely to be affected by the retail or leisure developments proposed in the Plan.

The Council’s response to the main issues raised in representations [EXAM5] refers to an update to

the Retail Impact Study being prepared.

The Council responded to Preliminary Question 23 related to this issue [EXAM3A], and to Further

Preliminary Questions 3 and 4 [EXAM4A].

68. Could all, or a greater proportion than proposed in the Plan, of identified needs for main town

use development be accommodated in or through the expansion of existing town centres in the

Borough or elsewhere?

No. In terms of the potential expansion of existing town centres in the Borough, the 2015 Retail and

Leisure Study [RT1] sought to assess, in accordance with the sequential approach to site selection,

where the identified forecast additional retail and leisure capacity/need and growth could be

located. The assessment identified that (1) with the exception of the site at Northern High Street

(Waltham Cross), there were no new opportunities for retail or commercial leisure developments


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within or on the edge of the town centres; and (2) there was very little physical capacity to

accommodate all of the assessed convenience and comparison goods floorspace need/capacity over

the plan period within the existing town centres. As explained in our response to Q69 the Council’s

endeavours to redevelop the site at the northern High Street (Waltham Cross) for a retail led

development have not attracted investors and therefore the Council is now promoting it for a mixed

use residential led development with limited commercial/A1/community ground floor uses. The

evidence available, and the assessment undertaken, identifies that the retail and commercial leisure

needs for the Borough cannot be accommodated in or through the expansion of existing town

centres in the Borough.

It is relevant to note that the Council has not been approached by any party with an interest in

land/buildings within or on the edge of the existing town centres in the Borough. Furthermore, no

parties have identified any alternative sequentially preferable sites elsewhere in the Borough to

accommodate the identified main town centre use development needs.

In terms of meeting the Borough’s retail and commercial leisure needs in existing town centres

outside the Borough, whilst no assessment of sites has been undertaken by the Council, the

expansion of town centres outside the Borough would result in residents of the Borough being

disadvantaged and an increase in unsustainable patterns of movement.

69. Is the proposed mix of uses on the town centre site at Waltham Cross Northern High Street

(policy WC2) justified, or should there be a greater focus on redevelopment for retail uses?

The original proposal for the redevelopment of Waltham Cross Northern High Street was a retail-

based development of two major floor plate stores of c. 3,500 square metres and smaller retail

units. The two stores were targeted at a food retailer and a comparison outlet and alternative

configurations were possible. However, despite this proposal being pursued for c. three years there

was little market interest. The finalised Waltham Cross Town Centre Strategy therefore encapsulated

the current Local Plan proposal for a mixed use redevelopment of main town centre use ground

floors along the alignment of Waltham Cross High Street and residential above and on the remainder

of the site (the current site of the Homebase store). Of the two proposals, the current policy is

considered to be far more viable, commensurate with the commercial scale of Waltham Cross town

centre and will introduce more residents into the town centre, adding to its vitality.

70. Paragraph 3.12 of the Plan states that “in the event that there are difficulties in

implementation of the development strategy, contingency planning will focus on bringing forward

… the Waltham Cross Area Action Plan (policy WC3)”. Is it likely that additional main town centre

uses could be developed during the plan period in that part of Waltham Cross either in advance, or

following the preparation, of an AAP?

Yes. The Local Plan policy enables the redevelopment of Waltham Cross Northern High Street in

advance of the preparation of the AAP and other significant developments that would contain town

centre uses are proposed that could come forward in advance of the AAP – notably at the Pavilions,

the Gala Bingo site and Fishpools. These developments would need to be generally in accordance

with the approved Waltham Cross Town Centre Strategy as well as the draft/adopted Local Plan.

Whilst the AAP would include the town centre within its boundaries, the focus will be on the lands


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around the station in support of Crossrail 2. Decision making within the town centre will of course be

cognisant of the intention to produce the AAP and of its probable content.

71. If identified needs for main town centre use development cannot be accommodated within

existing or expanded town centres, are there other accessible locations well connected to town

centres in the Borough or elsewhere that could meet help meet those needs?

No, as noted in our response to Q68, Brookfield has been identified to meet the identified retail and

commercial leisure needs following a sequential site assessment. Furthermore, no parties have

identified any alternative sites in sequentially preferable locations well connect to the town centre in

the Borough to accommodate the identified main town centre use development needs.

In terms of meeting the Borough’s retail and commercial leisure needs on potential sites in

accessible locations well connected to town centres outside the Borough, as previously explained in

our response to Q68, this would result in residents of the Borough being disadvantaged and an

increase in unsustainable patterns of movement.

72. Would accommodating identified needs for additional main town centre uses within

Broxbourne Borough contribute to achieving sustainable patterns of development and ensuring

the viability and vitality of town centres in the Borough and wider sub area including in Enfield,

Harlow and Welwyn Hatfield?

From the initial concept of a mixed-use town centre linked with a new residential community,

through subsequent masterplanning stages, Brookfield has been carefully planned to maximise

opportunities to foster sustainable patterns of development. Relocation of the Council offices and

co-location with a range of services and facilities is proposed to enable linked trips. Further details

are set out in the draft transport strategy (evidence library document T2).

It is the Council’s position that there is no other more sustainable strategy available to meet the

identified needs for the Borough. If the identified needs are not met in Brookfield, given that there

are no alternative sequentially preferable sites in the Boroughs town centres, it is likely that planning

applications for unsustainable out-of-centre retail and commercial leisure development will come

forward in the plan period. Such development will not be able to provide the substantial social,

economic and environmental benefits that Brookfield would deliver.

Furthermore, a quantum and critical mass of retail and commercial leisure floorspace at Brookfield is

required which is able to clawback a proportion of the shopping and leisure trips lost from the

Borough and in turn encourage more sustainable shopping and leisure patterns. In the absence of

any sequentially preferable sites, the allocation of a number of separate out-of-centre sites in the

Borough would not meet the objective of providing an accessible sustainable town centre capable of

clawing back the lost expenditure from the Borough. A strategy to identify a number of a separate

out-of-centre sites in the Borough to meet the identified needs is also likely to result in the centres

of Harlow, Enfield and Welwyn Garden City maintaining their attractiveness to residents in the

Borough and in turn encourage an increase in unsustainable travel patterns.


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73. Is the proposal to make provision for around 40,000 sqm of new retail development in the

Borough (policy DS1), including around 30,000 sqm of net retail comparison floorspace and 3,500

sqm of retail convenience floorspace at Brookfield Riverside, consistent with the available

evidence about the need for such development, justified, and consistent with national policy

relating to the location of main town centre uses?

Yes, we respond on each matter in turn below.

Consistency with available evidence and justified – The available evidence, which identifies the

relevant retail and commercial leisure uses needs for the Borough in the plan period, is provided in

the 2015 Retail & Leisure [RT3], 1st addendum [RT2] and 2nd addendum [RT3A]. The level of

convenience and comparison goods floorspace planned for Brookfield accords with the findings of

the evidence base documents. For convenience goods, RT3A identifies £63.4m (before

commitments) / £57.7m (after commitments) of quantitative need by the end of the plan period

(after commitments). The planned convenience goods floorspace at Brookfield is estimated to have

a turnover which falls within the identified quantitative need (estimated at up to circa £36.0m @

2026).

In terms of comparison goods floorspace, RT3A identifies, under a constant market share approach,

quantitative need of £137.0m (before commitments) / £124.4m (after commitments) by the end of

the plan period. The evidence identifies that a significant proportion of residents in the Borough are

travelling distances to other centres/facilities outside the Borough for comparison goods (circa 45%

of comparison goods expenditure ‘leakage’) and that there is potential to recapture some of this

expenditure to help stem some of this leakage, reduce travel distances, encourage more sustainable

travel patterns, and make sure the needs of the residents of the Borough are met locally and are

accessible. RT3A identifies, assuming a hypothetical uplift in Broxbourne’s comparison goods

market share (15% increase in study area market share (25.2% to 28.9%)), comparison goods

quantitative need could increase to £234.1m (before commitments) / £221.5m (after commitments).

The planned comparison goods floorspace at Brookfield is estimated to derive a turnover of up to

£131.7m-£175.6m depending on the sales density scenario. The planned comparison goods

floorspace is intended to meet the identified needs however it should be noted that in doing so it

will only claw back a small proportion (between circa 5-10% from Zones 1-4 (Broxbourne Borough))

of the comparison goods expenditure leakage. The assessed impacts on the town centres of Harlow,

Enfield and Welwyn Garden City, albeit not at a significant adverse impact level, needs to be

considered/balanced against the benefits of recapturing expenditure leakage and the provision of a

sustainable and accessible new town centre to meet the needs of Broxbourne residents. If the

identified needs for the Borough are not met locally at Brookfield, and centres outside the Borough

continue to improve their retail and leisure facilities, unsustainable travel patterns will increase and

residents in the Borough will continue to be disadvantaged.

Consistency with National Policy – As noted in our response to Q62 and Q64, the methodologies and

approach adopted in the Broxbourne Retail & Leisure Study [RT3, RT2, RT3A] and Brookfield Retail &

Leisure Impact Assessment [RT1, RT1A] are fully in accordance with the NPPF and NPPG and adopt

industry accepted standards for such evidence base documents.

Furthermore, as noted in our response to Q68, Brookfield has been identified in accordance with the

sequential approach to site selection. There are no other sequentially preferable or more


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sustainable and accessible sites able to accommodate the identified retail and commercial leisure

needs for the Borough.

74. Is the proposal for up to 10,000 sqm of leisure floorspace, a hotel, and a civic centre at

Brookfield Riverside justified and consistent with national policy relating to the location of main

town centre uses?

The justification for the leisure floorspace is set out within the Council’s response to Question 67. In

seeking to create a sustainable, mixed used town centre at Brookfield, the Council has also sought to

introduce other main town centre uses, including a civic centre and an hotel. Historically, the main

civic functions were undertaken within the three main Broxbourne centres of Hoddesdon, Cheshunt

and Waltham Cross. However, that is no longer the case with the Council’s own offices located

within an out of town centre location that is not easy to access for many members of the

community. None of those centres has the primacy or centrality to provide more centralised and

accessible civic functions for the borough. Brookfield, however, would contain those characteristics

if delivered in the manner set out within the Local Plan. The main user within a civic centre would be

the Borough Council and that is likely to be accompanied by a primary health centre and a police

presence. Other civic uses will also be considered to create a true civic hub within Brookfield and

that would be a key component of the new town centre. The Local Plan promotes various sites for

hotels within the borough and an hotel would be a natural accompaniment to the range of retail,

leisure, civic, business and residential uses being planned for Brookfield Riverside.

75. Are the proposals in policy INF14 for hotel developments at Park Plaza and High Leigh Garden

Village justified and consistent with national policy relating to the location of main town centre

uses?

The proposal for a hotel at Park Plaza is reflects the anticipated need for a hotel primary to service

the business traveller market arising from the development of the proposed business campus as

described in Policy PP1. The proposal for a hotel at High Leigh Garden Village reflects an existing

planning permission which forms part of the extant planning permission.

76. (a) Are the proposals for a total of around 150,000 sqm of B1 floorspace at Brookfield and Park

Plaza West (policies BR1 and PP1), and further B1 uses at Park Plaza North and South (policies PP2

and PP3) and other employment areas (policy ED2) consistent with national policy relating to the

location of main town centre uses, and (b) what effect would they have on the vitality and viability

of town centres in the Borough or elsewhere?

a) The proposed B1 floorspace is a qualitatively different ‘product’ to the local town centre office

market both in Broxbourne and the surrounding area. It should not be thought of as a town centre

use, but aims requires a highly visible location on the strategic road network suitable to attract

inwards investment from larger businesses which would not otherwise look to invest in town centres

in either the borough or the wider area. This is a distinct and complementary proposition to the local

office market provision. As stated in the Employment Land Study, at a local office market level,

office-based employment will continue to play a role in supporting small and medium sized

businesses in Broxbourne: “the (low) forecast change in floorspace demand is therefore more

reflective of a supply position which is relatively constrained with few sites able to attract or cater for

businesses seeking sites to build out large, high quality office space.” (ELS, page 97, paragraph 6.5.7).


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The overall approach is consistent with the requirement in Paragraph 21 of the NPPF that Local Plans

should “set out a clear economic vision and strategy for their area which positively and proactively

encourages sustainable economic growth.”

b) The effects on town centres would be neutral at worst for the reasons set out above relating to

the difference between the strategic and local office markets, but there is significant potential for a

positive effect on the vitality and viability of surrounding town centres. As has been shown in recent

years, significant development of office floorspace by existing occupiers (such as VolkerVessels or

MSD) could lead to improved perceptions of the area including its town centres as a place for

business growth. The town centre office market in the wider area beyond the borough is also largely

comprised of SMEs, and it is not anticipated that such businesses would be attracted from their

existing locations by the strategic business parks.

77. Would the main town centre use development proposed at Brookfield Riverside, along with

existing retail uses, be likely to lead to the creation of a new “town centre” in that location as

proposed in RTC1 and described in paragraphs 5.4-5.11 of the Plan?

Brookfield Riverside is planned to include a mix of town centre uses within a planned “town centre”

environment and it will function as a town centre. It is therefore the Council’s intention to create a

new town centre at Brookfield. There has been a long dialogue within the Council and between the

Council, the promoters of Brookfield Riverside and the Council’s retail advisors as to how Brookfield

should be defined. The original proposal promoted through the Broxbourne Core Strategy was for

Brookfield to be described as a borough centre which remains an accurate description of its planned

role in relation to the borough of Broxbourne. However, that term has no recognition within national

policy and retail hierarchies. In terms of the scale and proposed mix of uses within Brookfield and

the environment that will be created, it would fall most precisely within the town centre definition

and Policy RTC1 therefore proposes that eventuality. The Council has always been mindful that such

a definition could lead to unrestricted growth of main town centre uses to the detriment of other

town centres within and outside the borough. It is for that reason that Policy BR1 caps the allowable

floorspace on certain main town centre uses within Brookfield. The Policy requires a comprehensive

master plan that will ensure those floorspace limitations are respected and any planning permissions

will ensure that Brookfield is comprehensively delivered in accordance with that master plan.

78. Does the Brookfield Retail Impact Study 2017 [RT1] made realistic assumptions about (a)

existing and future turnover in town centres in the catchment area; (b) sales densities at

Brookfield; and (c) shopping patterns / trade draw across the catchment area and beyond?

(a) Existing & Future Turnovers – The existing and future turnovers of centres/facilities in the 2018

Brookfield Retail and Leisure Impact Study [RT1A] (which supersedes (in part) the 2017 Brookfield

Retail and Leisure Impact Study [RT1]) are derived from the 2018 Broxbourne Retail & Leisure Study

2nd Retail Addendum [RT3A]. The methodology adopted in deriving turnovers of centres/facilities is

an industry standard/NPPG compliant one. It applies the estimated relevant retail expenditure

derived from residents in each zone to the market share shopping patterns identified for each zone

by the household telephone survey. The 2018 Broxbourne Retail and Leisure Study 2nd Retail

Addendum [RT3A] updates the retail capacity/quantitative need previously updated in RT2 in RT3. It

takes in account the most recently published retail data/documents and Experian’s retail


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expenditure data and projections. It also updates the population and population projections data

and accords with the Council’s household projections. Whilst the household telephone survey which

informed the 2015 Retail & Leisure Study [RT3] has not been updated there is not considered to be

any material changes in circumstances which would warrant a new household survey to be

undertaken.

The turnovers of town centres outside the Borough have been estimated based on the neighbouring

Council’s latest Local Plan retail study evidence base documents.

(b) Sales Densities for Brookfield - we refer you to our response to Q63.

(ci) Shopping Patterns - we refer you to our response to Q62

(cii) Trade Draw – The pattern of retail trade to the planned retail floorspace for Brookfield has been

assessed having regard to the trade draw patterns of existing retail facilities in Brookfield. Existing

comparison goods retailers, complemented by a number of food and drink operators, include M&S,

Next, Outfit (including TopShop/Top Man/Dorothy Perkins, Evans, Burton, Miss Selfridge, Wallis,

Oasis, Warehouse), River Island, New Look, Boots, JD Sports, Argos, Tesco Extra, and Clarks. The

pattern of trade draw to the planned floorspace has been assessed on the basis that Brookfield will

provide similar ‘high street’ retailers to that already provided in Brookfield and to that currently

contained in the larger town centres outside Broxbourne (Harlow, Enfield and Welwyn Garden City).

To put the assessed trade draw patterns into context, the retail impact assessment robustly assumes

that 51% of the planned Brookfield comparison goods retail floorspace is derived from residents

outside the Borough of Broxbourne (Zones 1-4). Given that the planned comparison goods

floorspace at Brookfield is seeking to meet the identified comparison goods retail capacity needs for

residents within the Borough in addition to seeking to clawback a small proportion of the

comparison goods expenditure currently ‘leaking’ from the Borough to other centres (circa 45%

(£157.6m @2018) of comparison goods expenditure from the Borough) the trade draw patterns are

considered to be reasonable.

Notwithstanding this, given the representations received in relation to the assessed comparison

goods trade draw patterns, an additional quantitative retail impact sensitivity scenario is provided in

the 2018 Brookfield Retail & Leisure Impact Study Retail Addendum [RT1A] testing a higher level of

comparison goods trade diversion from the surrounding town centres of Harlow, Enfield, and

Welwyn Garden City (New Sensitivity Testing 3). The sensitivity testing identifies that even assuming

a higher unrealistic level of trade diversion from these centres all are anticipated to still benefit from

an increase in retail turnover in the impact assessment period.

79. Does the Brookfield Retail Impact Study 2017 [RT1] accurately predict the impacts on (a)

turnover and (b) investments in town centres in the catchment area?

Yes, responding to each in turn:

(a) Impacts on Retail Turnover - The methodological approach that has been adopted in the

2017 Retail & leisure Impact Study [RT1] and 2018 Retail Impact Study Addendum [RT1A]

accords guidance in the NPPG. The steps undertaken in predicting impact on centre

turnover are set out in Section 4.3 of RT1. Our response to Q63 provides further details in


14

relation to the sales density/turnover estimated for the planned Brookfield whilst Q78

provides further explanation in relation to trade draw and shopping patterns that have been

adopted. A number of trade draw scenarios are provided to sensitivity test the impact on

centre turnover. In all scenarios the assessed level of quantitative impact the turnover of

relevant centres assessed is not considered to be at a level that would, constitute ‘significant

adverse’ and would be refused if Brookfield came forward as a planning application

proposal.

(b) Impact on In-Centre Investment – information regarding in-centre investment was sought

from the relevant local planning authorities. A site was identified by Harlow Council in their

representations to the Pre-submission Local Plan (Regulation 19 Stage). This site (Harlow

Town Centre North Site) was assessed in Section 3 of the 2018 Retail & leisure Impact Study

Addendum [RT1A]. No other sites have been identified by neighbouring Councils and, more

importantly, no representations from neighbouring Councils have been made specifically

stating that the planned retail and leisure floorspace at Brookfield would result in significant

adverse impact on in-centre investment in their administrative areas. The assessments of in-

centre investment in the 2017 Retail & Leisure Impact Study [RT1] and 2018 Addendum

[RT1A] are fully compliant with both the NPPF and NPPG (paragraph 17) and relevant

Secretary of State appeal decisions. Of particular relevance to the assessment of impact on

in-centre investment is how advanced a project/scheme needs to be able to be classified as

‘planned investment’. The Inspector in the Scotch Corner, North Yorkshire appeal decision

(endorsed by the Secretary of State) confirms:

“This part of the impact test [impact on existing committed and planned in-centre

investment] is, in my view, clear and straightforward. As the first bullet point of the

Framework paragraph 26 sets out and as confirmed by PPG, it is only existing public

and/or private investment that has been made, committed or is planned that requires to

be tested. Existing and committed investment are straightforward terms. Whilst what

constitutes planned investment is not specifically defined by either the Framework or PPF,

paragraph 16 of PPG identifies that the key considerations will include, (i) the policy status

of the investment i.e whether it is outlined in the development plan; (ii) the progress made

towards securing investment, e.g. if contracts are established and; (iii) operator

demand/investor confidence. These indicate to me that to be considered as planned

investment a project has to be at a very advanced stage”

Appeal Reference APP/S1530/W/16/3147039, IR Paragraph 11.16, Scotch Corner, North

Yorkshire

Notwithstanding that the impact assessments contained in RT1 and RT1A are consistent with

the above approach and identify no significant adverse impacts arising as a result of the

planned Brookfield development, as noted at paragraph 1.2.6 of the 2018 Brookfield Retail

& Leisure Impact Study (RT1A), the NPPG (paragraph 14) identifies that in plan-making the

impact test may be “useful” in determining whether proposals in certain locations would

impact on existing, committed and planned public and private investment, or on the role of

centres. Firstly, it should be noted that the NPPG identifies that if the Local Plan is based on

meeting the assessed need for town centre uses in accordance with the sequential approach

(which in our opinion the Broxbourne Local Plan is) issues of adverse impact should not

arise. Secondly, it should be noted that the NPPG identifies that the impact test may be


15

useful and does not specifically identify that an assessment of impact is a requirement.

Thirdly, and finally, it does not make any mention, or set out any requirement, for Councils

to undertake a quantitative and qualitative impact assessment on town centre vitality and

viability. The Council consider these are important matters that the Inspector should take

into account when considering the submitted retail and leisure impact assessments

contained in RT1 and RT1A.

80. Overall, what would be the cumulative effects on the vitality and viability of existing town

centres in the Borough and elsewhere of the proposals in the Plan for main town centre use

developments?

The Council’s conclusions on the cumulative effects of Brookfield and relevant commitments on the

vitality and viability of existing town centres in the Borough and elsewhere are set out in Section 7 of

the 2017 Brookfield Retail & Leisure Impact Study [RT1] and in Section 4 of the 2018 Brookfield

Retail & Leisure Study Addendum [RT1A]. The assessment identifies that the cumulative effects on

the vitality and viability existing town centres within and outside the Borough would not be

“significant adverse”.

Issue 5.3: Development Management Policies relating to Retail and Town

Centres 81. Is the sequential test described in policy RTC1(II)(b) consistent with that set out in NPPF

paragraph 24 and, if not, is it justified?

Policy RTC1(II)(b) is inconsistent with paragraph 24 of the NPPF in that it does not reflect the

sequential test, instead indicating equal weight is given to ‘existing centres or on edge of centre

sites’. The paragraph also includes references to the historic environment which do not form part of

paragraph 24 and also refers to retail rather than the full range of ‘main town centre uses’ defined in

the Glossary to the NPPF.

The Council therefore considers that a number of main modifications to policy RTC1 are required,

including those necessary to address the above but also to amend inconsistencies in relation to the

approach to local parades, which are excluded from the national definition of defined centres. For

the avoidance of doubt, maps showing the defined Local Centres to which Policy RTC1 applies are

provided as an appendix to this hearing statement.

Furthermore, given that Brookfield Riverside is not yet a town centre a modification is proposed to

remove it from the existing retail hierarchy set out in RTC1. It is instead identified as an emerging

town centre. A town centre boundary for Brookfield Riverside will be defined, and the centre will be

included in the retail hierarchy, as part of a review of the Local Plan, once the likely extent of the

town centre is known.

82. Is the approach to directing retail uses to “main retail centres” and “local centres” as set out in

policy RTC2 consistent with national policy and, if not, is it justified?

As set out above, the Glossary to the NPPF includes local centres within the overarching definition of

town centres. The NPPF refers to ‘main town centres’ rather than ‘main retail centres’. A further


16

inconsistency in this policy has been identified in part II b), which refers to ‘shopping centre’. This

word implies a limited focus on retail which is not present in the NPPF emphasis on a range of ‘main

town centre uses’. Potential modifications to policy RTC2 are proposed below to remedy these

inconsistencies.

83. To be effective and consistent with national policy, should RTC1, RTC2 or other policies in the

Plan set out a sequential test for main town centre uses in addition to retail?

The Council suggests that it would be appropriate to incorporate the sequential test within Policy

RTC1 which sets the context for subsequent policies. Potential modifications are set out in the table

below.

84. Is the Council’s proposed main modification to add a clause to policy RTC2 requiring

development to have regard to relevant town centre strategies necessary and adequate to ensure

that the Plan is effective?

For reference the proposed new clause within RTC2 is shown in the table of potential modifications

below. The Council considers that the modification is necessary to provide a framework for the

consideration of the context for planning applications within the designated centres.

Document EXAM6 includes modifications to policies WC1, HOD1, and CH3 for each of the designated

centres and the accompanying reason states: “Change required to ensure that the intended outcome

of the policy is clear and to make clear how a decision maker should react, in accordance with NPPF

paragraph 154. In order to make the policy effective a modification will be made to the Policies Map

to delineate the policy area and the status of the town centre strategy will be secured by insertion of

additional wording into Policy RTC2: Development within Designated Centres.”

Taken together, the modifications to the above policies and the status given to the relevant

strategies is considered adequate to provide a clear basis for decision-making.

Potential Main Modifications

Policy Proposed modification Q. no

Paragraph 23.4 Development within Retail Defined Centres

The Policies Map shows the boundaries of the Borough’s main shopping centres: Hoddesdon Town Centre; Waltham Cross Town Centre; Cheshunt Old Pond District Centre; and Brookfield Retail Centre., as well as seven local centres.

181

New paragraph 23.5

National policy sets out ‘main town centre uses’ which are considered appropriate within these defined centres as follows:

retail development (including warehouse clubs and factory outlet centres);

leisure/entertainment facilities/the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls);

offices;

arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).

181

5.10 This new development will bear all the hallmarks of a town centre and Brookfield will therefore ultimately assume town centre status within the retail hierarchy, alongside Hoddesdon and Waltham Cross.

181

Policy RTC1: Retail Hierarchy

Policy RTC1: Retail Hierarchy and Main Town Centre Uses I. The Council will permit new retail town centre use development within town

181, 183


17

Policy Proposed modification Q. no and district the defined centres, as shown on the Policies Map, that is compatible with their function and position within the retail hierarchy below: • Town Centres: Brookfield Riverside, Hoddesdon Town Centre and Waltham Cross Town Centre; • District Centre: Cheshunt Old Pond District Centre; and • Neighbourhood Centres, Local Centres and Parades.: High Street, Cheshunt; High Road, Broxbourne; High Street, Waltham Cross (Nos 228-286 and 229-267); Crossbrook Street ( Nos 99-137); Goffs Oak; Wormley; and Rye Road. The NPPF sets out a sequential test for retail uses, which applies the hierarchy, set out above. II. Brookfield Riverside is identified as a broad location for a proposed new town centre where main town centre uses will be acceptable if delivered in accordance with an integrated masterplan as set out in Policy BR1. A town centre boundary will be defined as part of a review of the Local Plan, once the extent of the town centre is known. III. Retail Main town centre use development will not be permitted elsewhere in the Borough unless otherwise provided for in this plan or where: (a) need can be demonstrated which is not adequately met within the Borough at present: and (b) following a sequential test, it is demonstrated that the requirements of development cannot be physically accommodated within existing centres; or on edge of centre sites or the existing centres cannot accommodate the development without damage to their historic or architectural character or overall environment: (a) it satisfies, where applicable, national policy requirements relating to a sequential approach and impact assessment; and (c)(b) the proposals would not have a material significant adverse impact upon existing, committed and planned investment in a centre or centres or on the vitality and viability of town, district and local centres.

Policy RTC2: Development within Designated Centres

Policy RTC2: Development within Designated Centres I. Retail uses, excluding small convenience shops must be directed in the first instance to the Borough’s main retail centres as shown on the Policies Map, i.e. Hoddesdon Town Centre, Waltham Cross Town Centre, Cheshunt Old Pond District Centre and Brookfield Centre. If these locations are unavailable or unsuitable, retail uses will be directed to the Borough’s local centres. II. I. The following criteria will be used to consider the acceptability of new development proposals, including extensions, alterations, and changes of use within the Borough’s centres at Hoddesdon, Waltham Cross, Cheshunt Old Pond, and Brookfield Riverside, as defined on the Policies Map: (a) whether the development enhances the historic character of the centre (where relevant) and the public realm; (b) the role of the shopping centre and services it provides; …… III. Planning applications for new development, including changes of use, within the designated centres should have regard to the relevant Council strategy, namely the town centre strategies for Hoddesdon or Waltham Cross, or the district centre strategy for Cheshunt Old Pond.

182, 184 EXAM6

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Documents

Local Plan Examination in Public Council Hearing Statement