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GVA - Assessment of Retail Planning Policy: Retail Development Proposals, Hayle, Cornwall Cornwall Council October 2015

This is a text version of the report (and has been run through an OCR - please check the original) - the link below is to the original http://angarrack.info/files/Hayle%202015%20application%20FINALv3%201.pdf

Assessment of Retail Planning Policy: Retail
Development Proposals, Hayle, Cornwall
Cornwall Council
October 2015


GVA
St Catherine’s Court
Berkeley Place
Bristol
BS8 1BQ

gva.co.uk

CONTENTS
1. Introduction ..........................................................................................................................................3
2. The Rugby Club Application ...............................................................................................................6
3. The Cranford Application ....................................................................................................................8
4. Planning Policy Context ....................................................................................................................10
5. The Retail Planning Policy Issues: Cranford .....................................................................................14
6. The Retail Planning Issues: the Rugby Club Proposal .....................................................................38
7. Cumulative Impact............................................................................................................................41
8. Summary and Conclusions ...............................................................................................................47

Appendices:
Appendix A:

retail impact analysis (applicable to both the Cranford and Rugby Club proposals)

Appendix B:

cumulative impact analysis

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

1.

Introduction
Scope and Purpose

1.1

This report has been prepared by GVA for Cornwall Council (‘CC’) in relation to retail
planning policy issues associated with two planning applications for retail development
in Hayle. The two proposals comprise:

An outline application by Hayle Community Rugby Facilities Ltd for the
redevelopment of land at Hayle Rugby Club for up to 15,549sq m of Class A1 and
A3 retail floorspace and associated development (‘the Rugby Club application’);
and


A full planning application by Cranford (Hayle) LLP for the development of land at
Marsh Lane for 15,539sq m of Class A1 and A3 retail floorspace and associated
development (‘the Cranford application’).

1.2

Whilst the detail of each application is set out in the following sections of this report, it is
salient to note from the outset that the rugby club application was submitted to CC in
March 2014 and determination of the application was deferred at CC’s Strategic
Planning Committee (‘SPC’) in December 2014. The Cranford application is the second
application for retail development at the Marsh Lane site since 2014, with the previous
application refused by CC at the same SPC meeting in December 2014.

1.3

Bilfinger GVA has provided retail planning policy advice to CC on the rugby club
application in December 2014 and advice on the previous Cranford proposal in
November 2014.

1.4

The purpose of this advice report is to provide CC with an updated set of advice on the
rugby club application and to provide advice on the latest Cranford application.

1.5

In accordance with our instructions from CC, we have carried out a review of the
supporting documentation which has been submitted in support of these applications.
The identity of this documentation is outlined in the next two sections of this advice
report.

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1.6

In line with our previous advice, these proposals have been considered in the context
of the development plan for the area and other material planning policy
considerations such as the National Planning Policy Framework (‘NPPF’). A summary of
the salient parts of the development plan and other material planning policy
considerations is provided in Section 4 of this report.

1.7

In addition, and given that this advice report seeks to provide an update on retail
planning policy matters since November/December 2014, the contents of this
document will make reference to additional evidence base information which has
been published in the interim, such as the Cornwall Retail Study Update 2015, which is
an evidence base document supporting the new Local Plan Strategic Policies
document. Similarly, we will also make reference to other recent retail proposals and
commitments in the surrounding area (including Newquay, Penzance, Hayle, Truro and
St Austell). Therefore, whilst this report provides additional information in relation to
retail impact and policy issues, it doesn’t necessarily supersede all of our previous
advice which generally remains relevant.

Therefore, we would recommend that

officers and members continue to take into account the contents of our November
and December advice reports alongside this latest advice.
1.8

From the outset of this report, it should be noted that our advice is intended to help
officers and members of the SPC reach a conclusion in relation to the salient retail and
town centre planning policy issues. In particular, it provides advice in relation to the
sequential test and the impact upon defined town centres in the Council’s retail
hierarchy, although it is for the SPC to determine whether these proposals comply with
prevailing policies and balance their judgement on these issues with all other salient
material planning considerations for each application.

Contents of Report
1.9

The remainder of this report is structured in the following manner:

Section 2 provides an update on the contents of the Rugby Club application and
the controls that have been offered by the application.

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Section 3 provides a summary of the latest Cranford proposal, including the
controls that have been offered by the applicant and a comparison between the
latest application and the application that was refused by CC in December 2014.


In Section 4 we provide a summary of salient planning policy complex facing the
proposed developments, including the development plan and other material
planning policy considerations. This section also provides an overview of the latest
evidence base information in the Cornwall Retail Study Update 2015.


Section 5 provides advice on the relationship of the latest Cranford application to
the sequential and impact tests.


Section 6 provides an update to our previous (December 2014) advice on the
Rugby Club proposal in relation to the sequential and impact tests.


We assess the cumulative impact of the Rugby Club and Cranford proposals
(alongside existing commitments) in Section 7.


A summary of the key issues and our conclusions are set out in Section 8 including
the relationship of the proposed developments to the development plan for the
area and other material considerations (including the NPPF).

1.10

All plans, statistical tables and other documents referred to in the text of this report can
be found in appendices at the rear of this document.

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2.

The Rugby Club Application

2.1

Since its submission, the Rugby Club application has remained as an outline
application, with some matters reserved, for development of up to 15,549sq m (gross)
retail development (A1/A3), associated infrastructure, access arrangements, servicing,
parking and landscaping.

2.2

At the time of our December 2014 advice, the application was supported by indicative
layout plans showing the proposed retail floorspace although page 2 of that advice
letter indicated that no controls had been offered in terms of: the range of goods to be
sold from the development; the number of retail units; and, the minimum/maximum
sizes of those units.

2.3

The lack of detail regarding the controls over the proposed retail floorspace was a
point of discussion at the SPC meeting in December 2014 and led to one of the three
reasons for deferring determination of the application.

2.4

Since that time, the applicant has written1 to CC to propose a series of controls over
the retail floorspace. These proposed controls are as follows:

A maximum net sales area of 10,211sq m;


Control of units 1, 2, 8 & 9 to Class A3 use only;


Control of Unit 12 to Class A1 non-food use (including an ancillary restaurant),
including no sub-division of that unit and a minimum unit net sales area of 3,500sq
m;


Control of units 4 and 5 to Class A1 non-food use.


Control of units 3, 6, 7, 10 & 11 to Class A1 non-food use, including no less than 65%
of the net sales area of each unit to be used for the sale of fashion goods; and


A definition of fashion goods.

1 See letter from Amethyst Planning to CC, dated 5th May 2015, accompanied by plan reference 1879.001 Rev D which
should be treated as being indicative only

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2.5

This set of controls is similar to the set of controls that was offered in relation to the
previous Cranford proposal on Marsh Lane is 2014, particularly in terms of the total net
sales area, control over the number of Class A3 units and the controls over the majority
of Class A1 retail units in relation to the types of goods to be sold and the lack of
control over future sub-division and amalgamation.

As will be set out in the next

section of this advice report, these previously offered controls are proposed to be
carried forward into the latest Cranford application.
2.6

However, there are some subtle differences between the Rugby Club and Cranford
schemes:

whilst

they

are

only

initial

controls

(due

to

the

lack

of

sub-

division/amalgamation conditions), the layout and size of the Cranford retail units is
fixed, whilst the Rugby Club units are not.
2.7

We will return to the issue of both the proposed controls and our recommended
additional controls later in this advice report. However, the controls that have been
offered by the applicant to date have been used to guide our assessment of the
impact of the Rugby Club development and its compliance with the sequential test.

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3.

The Cranford Application

3.1

As set out in the introductory section of this advice report, the latest full planning
application by Cranford for new retail floorspace at Marsh Lane is the second
application for a similar form of development since the start of 2014. The previous
application was refused by the Council in December 2014 for three reasons.

3.2

However, importantly, none of these three reasons given by CC related to retail and
town centre planning policy matters. This will no doubt be a material consideration for
CC in relation to the determination of this application. However, it should also be
noted that the circumstances surrounding retail and town centre planning policy issues
have evolved since December 2014 and therefore we consider that it is important that
CC re-examines these salient issues in light of the body of evidence and analysis that
exists at the time of determining this current application.

3.3

In relation to the proposed Class A1 and A3 retail floorspace, the current application is
almost, but not completely identical to the previous proposal. In particular:

The total gross Class A retail floorspace remains the same;


The amount of floorspace devoted to Class A3 use2 has reduced slightly and this
reduction has been transferred into a slightly increased amount of Class A1
floorspace3;


Units 1-4 in the previous proposal have been replaced by Units A-C in the current
proposal. In the previous application, the assessment of impact (by the applicant
and Bilfinger GVA) assumed that these would be Class A3 use only. However, the
officer’s report departed from that principle (and allowed the units to be A3 or A1
use) and this has followed through into the set of proposed controls for the current
application. This is not the basis for the Bilfinger GVA assessment and we would
recommend that Units A-C are controlled to A3 use, otherwise an updated
assessment will be required.

2

As set out on the submitted application form

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3.4

In addition, it should be noted that we based our previous assessment on the largest
units in the development (Unit 9 in the previous scheme and Unit G in the current
scheme) being occupied by a fashion-led retailer. Indeed, whilst we did not rely on a
named retailer in our assessment of the previous application it should be noted that
Debenhams were the likely first occupier for this unit.

This did not translate into a

proposed condition/control for this fashion-led type of retailer although we would
recommend that such a control is imposed and, for the avoidance of doubt, it is on this
basis that we provide out advice on the latest Cranford scheme.
3.5

We will return to the issue of whether there are any additional and/or alternative
controls which should be imposed on the Cranford application later in this advice
report.

3

as set out on the submitted application form

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4.

Planning Policy Context

4.1

The salient parts of the development plan for the application sites have not changed
since our November/December advice to CC.

Therefore, the development plan

comprises the saved policies in the Penwith Local Plan 2004 and the relevant retail and
town centre policies are TV16 and TV17.
4.2

In addition, and in line with CC’s previous consideration of retail development
proposals in Hayle, an important material planning consideration for these applications
will be the National Planning Policy Framework (‘NPPF’). For the avoidance of doubt,
there have been no salient changes to the NPPF (or the supporting National Planning
Practice Guidance) since our previous advice in November/December 2014. As a
consequence, the contents of Section 2 of the NPPF and the ‘ensuring the vitality of
town centres’ section in the NPPG are salient.

4.3

However, one factor which has changed in circumstance since our previous advice
(and the SPC meeting in December 2014) is the progress being made with the
emerging Cornwall Local Plan Strategic Policies document. Therefore, the remainder
of this section concentrates upon the emerging Local Plan document.
Cornwall Local Plan Strategic Policies

4.4

The Cornwall Local Plan Strategic Policies document is currently subject to an
Examination. The initial stage of Examination hearings were completed earlier in 2015
and this process has been formally suspended whilst further evidence base work is
undertaken.

4.5

The February 2015 version of the draft Local Plan (which incorporates the proposed
submission version plus focused changes) contains a policy dealing with retail
development (Policy 4) which notes that development will be permitted where it
supports the vitality and viability of town centres. Policy 4 also outlines the need for
proposals to accord with the sequential approach to site selection and to demonstrate
that there will not be a significant adverse impact upon the health of town centres.

4.6

The Examination Inspector has now issued his preliminary findings and has indicated
that the new retail capacity figures associated with the Retail Study Update (see

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below) should be presented in a table associated with Policy 4.

In addition, the

Inspector’s preliminary findings also make reference to part of the Submission draft
Local Plan where future retail capacity is identified in the text of the plan for various
CNAs and it is stated as capacity available to the in-centre, edge of centre and out of
centre locations (e.g. paragraph 4.18 and elsewhere). The Inspector has noted that:
“I have not seen any evidence to indicate that edge of centre/out of centre
locations are required to accommodate retail growth in all the towns referred to,
especially on the basis of the modest future capacity figures now applicable to
most centres. Accordingly, such references undermine the centre first/sequential
approach of national policy and should be deleted”.
4.7

This is a clear statement from the Inspector and reinforces the need for the Council to
rigorously apply the sequential test in the identification of sites for new retail
development. We would wish to highlight that there have been no objections from the
Inspector to the contents of the Retail Study Update and it would appear that, subject
to the changes being proposed by the Council, the retail strategy in the Local Plan is
considered sound. However, the weight to be placed on the Local Plan, bearing in
mind it is still currently being examined, is a matter for the Council and this should be
clearly explained when determining both of these applications.
Evidence Base

4.8

Earlier in 2015, the Cornwall Retail Study Update (‘the Retail Study Update’) was
published by the Council and is being used as an evidence base study for the Cornwall
Local Plan Strategic Policies document. The main purpose of the study is to update the
retail floorspace capacity forecasts contained within the 2010 Cornwall Retail Study
(‘the 2010 Retail Study’). In order to provide these updated forecasts, the Retail Study
Update is supported by a new survey of household shopping survey patterns
(conducted in 2014) and these results have been used to inform our advice to the
Council on this planning application.

4.9

The Retail Study Update provides updated retail floorspace capacity predictions for
convenience and comparison goods floorspace in the main settlements including, in
West Cornwall, Hayle, Penzance, Helston, Falmouth and Camborne/Pool/Redruth.

4.10

The comparison goods retail floorspace capacity forecasts for these towns are as
follows:

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Table 4.1: comparison goods retail floorspace capacity forecasts for the main
settlements in West Cornwall (floorspace capacity in square metres net sales area)
2014

2021

2026

2031

Hayle

-7352

-5906

-3889

3348

Penzance

-4776

-3914

-1951

579

CPR

-7352

-5906

-3889

3348

Helston

0

-325

134

721

Falmouth

-9559

-4246

-2249

328

Source: Cornwall Retail Study Update 2015

4.11

Whilst the requirement to demonstrate that a need exists for out-of-centre retail
development is no longer part of national planning policy, we consider that the
availability of retail expenditure to support new retail floorspace is still a material factor
as it can contribute to the overall examination of the sequential test and also help to
assess the severity of the impact on the of health of, and investment within, defined
town centres. On this basis, it is salient to note that the above capacity figures indicate
that there is not sufficient surplus comparison goods floorspace capacity in either Hayle
or all of the above settlements combined to accommodate either or both of the
proposed developments.

As a consequence, the only way of potentially finding

sufficient capacity to accommodate the proposed developments is via clawback from
settlements further afield although the ability to achieve a sufficient level of surplus
expenditure appears unlikely in light of the amount of retail floorspace which the
Council has resolved to grant planning permission for in these settlements.
4.12

In addition, it should be noted that the capacity figures in the Retail Study Update show
that there has been a reduction in the level of capacity for additional convenience
and comparison goods floorspace, across many parts of Cornwall. There are several
reasons for the changes in floorspace capacity projections, including updated
economic projections, the use of the results of the 2011 Census, changes to shopping
patterns and also the decision by the Council to grant planning permission for a
number of retail development projects.

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4.13

Indeed, it should be noted that the capacity figures shown in the Retail Study Update
will also now need to take into account further proposals in St Austell4, Threemilestone5
and Truro6 for which the Council has resolved to grant planning permission.

These

proposals will reduce the capacity figures outlined in the study although their primary
effect will be on capacity levels in these settlements rather than settlements in West
Cornwall.

Higher Trewhiddle Farm
Maiden Green Farm, Willow Green Farm and West Langarth
6 Truro City Football Club
4
5

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5.

The Retail Planning Policy Issues: Cranford
Introduction

5.1

Given the out of centre location of the application site and the lack of an allocation
for the proposed retail use in an up-to-date development plan, there is a need to
assess whether the latest Cranford proposal complies with the sequential test. There is
also a need to assess the scale of impact on existing nearby town centres. For the
avoidance of doubt, this same approach was adopted in relation to the previous
Cranford proposal on this site.

Application of the Sequential Test and the Need to Demonstrate
Flexibility
5.2

Given that the current Cranford proposal is of the same scale and format as the
previous scheme, with the same controls over the sale of goods and use class, we
consider it salient to repeat the contents of our previous (November 2014) advice:
“4.5
Given the location and planning policy status of the application site
there is a need to assess the proposed development against the sequential
approach to site selection. Having regard to national planning policy contained
within the NPPF, along with guidance within the NPPG and Policy TV-16 of the
adopted Local Plan, this requires not only an assessment of whether the proposed
development can be accommodated on sequentially preferable in-centre, edge
of centre or more accessible out of centre sites within the catchment area of the
proposed development, but also an assessment of the flexibility employed by the
applicant in relation to scale and format.
4.6
Having undertaken a thorough review of the information supplied by the
applicant, we have reached the conclusion that insufficient information has been
presented to the Council to demonstrate that the applicant has been flexible in
terms of the scale and format of the proposal.
The analysis has largely
concentrated upon one retailer and does not properly explain how, if any, flexibility
has been employed in formulating this proposal. The need for a demonstration of
flexibility is a requirement of the NPPF and NPPG, and is also a key issue raised in
recent Court judgements. For this reason, we consider that the applicant has not
satisfied this aspect of the sequential test as outlined in paragraph 24 of the NPPF
and Policy TV-16 in the adopted Local Plan, although Council officers and
members will need to consider whether they share this view regarding the
applicant’s flexibility.

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4.7
We have, however, on a without prejudice basis, considered alternative
sites in Hayle and surrounding settlements. The majority of our assessment has
considered whether, in the absence of flexibility, alternative sites can
accommodate the precise form of development proposed by the applicant. For
the avoidance of doubt, this is not an approach we support, but nevertheless, on
this basis, there are not any suitable alternative sites in the catchment area of the
proposed development. We have also considered the ability to accommodate a
smaller scale of development on the South Quay and North Quay sites in Hayle.
South Quay can be discounted, due to the scale of development which can be
accommodated. North Quay can accommodate a significant amount of retail
development, around two-thirds of the scale of the current application proposal,
although the Council will need to consider whether larger format retail units fits in
with the Council’s and owner’s aspirations for this site”.

5.3

In relation to the search for alternative sites, we are not aware of any changes to the
sites that were assessed by the applicant, CC and Bilfinger GVA, nor are we aware of
any additional sites that now require fresh consideration.

5.4

It is also salient to note that whilst we did not place particularly significant weight on the
views of retailers solicited by the applicant in relation to the previous application, as the
permission sought was for comparison goods floorspace which is not tied to a particular
retailer, that same information (or similar alternative information) has not been
submitted with the current proposal. As a consequence, with no certainty over the
retailers who will occupy the proposed development, this simply reinforces our previous
conclusions regarding the issue of ‘flexibility’.

5.5

However, that said, it is important to note that members of the SPC, at their meeting in
December 2014, did not raise any concern over the compliance of the previous
Cranford proposal with the sequential test which, bearing in mind the similar form of
development (and proposed controls) is a material factor for this current proposal. As
a consequence, unless officers and members of the SPC consider that matters have
changed in relation to the applicant’s demonstration of flexibility and the consideration
of alternative sites or the weight to be given to the draft Cornwall Local Plan, they
would appear entitled to reach the same conclusion and, in the absence of any
concerns over the sequential test, conclude that the current proposal complies with
paragraph 24 of the NPPF, Policy 4 of the draft Cornwall Local Plan and Policy TV16 of
the Penwith Local Plan.

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Impact
5.6

Given the location and planning policy status of the application there is, in line with the
previous proposal, a need to consider the impact of the latest Cranford proposal on
existing, committed and proposed town centre investment and also the impact of the
proposal on the health of nearby town centres.

5.7

As a starting point for the assessment, it is useful to bear in mind the following:

Whilst the previous Cranford proposal was refused by CC, a reason relating to
‘retail impact’ was not given. As a consequence, it can reasonably be assumed
that members of the SPC did not have a particular concern over the scale and
severity of the impact of the proposal on the health of (and investment in) nearby
town centres.


The current Cranford proposal, in terms of the scale and format of retail floorspace
(including the controls proposed by the applicant), is very similar to the previous
application – although there may be a need to ‘tighten-up’ the controls over the
proposed floorspace.

5.8

As a consequence of the above, the Council’s conclusions in relation to the previous
proposal are materially relevant to the current application (given the similarities
between the two schemes from a retail perspective), although officers and members
must consider whether (A) there have been any material changes in circumstance
since December 2014; and (B) whether these changes in circumstance the Council to
reach a different view on retail impact issues. This is the focus for the remainder of this
section of our advice report.

5.9

When considering the separate issues of ‘impact on town centre investment’ and
‘impact on town centre health’, as required by paragraph 26 of the NPPF, we consider
it important to consider the following changes in circumstance since December 2014.

5.10

First, further progress has been made on the Local Plan Strategic Policies document. In
relation to the impact test element of Policy 4 of the draft Local Plan, this has not
changed since the previous of the draft Local Plan (which was available toward the
end of 2014). However, the retail and town centres strategy in the draft Local Plan has

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been examined and has not faced any significant criticism from the presiding
Inspector.
5.11

However, the Inspector has recommended that the retail floorspace capacity
forecasts from the 2015 Cornwall Retail Study Update are included in the Local Plan
and it will be noted that the scale of the Cranford proposal is significantly in excess of
the forecast capacity. The main reason for this difference is that floorspace capacity
figures in the Retail Study are based upon the continuation of current market share
levels for comparison goods shopping in Hayle and the current Cranford proposal, like
the previous proposal before it, will have a significant effect upon shopping patterns in
West Cornwall.

5.12

Whilst the underlying data for the retail study’s capacity assessment is of particular
relevance to the assessment of financial impact (which is discussed later in this section),
the relationship of the Cranford proposal to the retail and town centres strategy in the
emerging Local Plan is a separate ‘policy compliance’ issue. As a consequence, one
salient factor for officers and members of the SPC to consider is the relationship of this
proposal with the emerging Local Plan. In our view, the Cranford proposal departs
from the strategy insofar as it does not generally conform with the retail floorspace
capacity forecasts and there is not a current proposed strategy to (A) claw back
expenditure which is being lost from West Cornwall to other centres further afield, and
(B) no strategy to amalgamate and transfer the capacity of the defined town centres
in West Cornwall to a single out-of-centre location in Hayle. However, this is our own
view and officers and members of the SPC will need to reach their own views on the
relationship of the proposals with the Local Plan strategy and the weight to be placed
on the current version of the Local Plan Strategic Policies document.

5.13

In relation to other factors which have evolved since the SPC meeting in December
2014, we consider that the following are of relevance:

Hayle.

Since the consideration of the Cranford and Rugby Club proposals in

December 2014, the Council refused planning permission (at the same SPC
meeting) for an enlargement in the amount of comparison goods to be sold in the
ASDA supermarket at South Quay. An appeal was lodged against that refusal and
was subsequently allowed. In addition, the Council has recently granted planning
permission for a change in the other previously approved retail units at Foundry

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Yard in Hayle. This change involves the amalgamation of the approved units and
the sale of convenience goods alongside the previously permitted sale of
comparison goods.

Penzance. The Council has now granted planning permission for a The Range store
at Long Rock. This store, which will extend to 2,322sq m net sales, will sell a wide
range of comparison goods. Whilst this store will also have an effect on stores and
centres outside of Penzance, of particular importance will be the additional
financial impact that this store will have on Penzance town centre (in addition to
the Hayle proposals).


Truro. Since the December 2014 SPC meeting, the Council has resolved to grant
planning permissions for a significant amount of new retail floorspace in Truro and
Threemilestone. These include: Willow Green Farm (ASDA supermarket), Maiden
Green Farm (supermarket and non-food floorspace), West Langarth (unrestricted
large-scale convenience and comparison goods floorspace) and Truro City FC
(restricted large-scale comparison goods floorspace)7.

In addition, another

commitment, which was known at the time of making our previous assessment, is
the Waitrose supermarket.

St Austell. CC has resolved to grant planning permission for an unrestricted largescale convenience and comparison goods retail development at Higher
Trewhiddle Farm8.


Fraddon. The Council has resolved to grant planning permission for the
redevelopment of part of the existing Kingsley Village complex to provide 10,000sq
m of Class A1 retail floorspace.


Newquay. Prior to the SPC meeting in December 2014, the Council had resolved to
grant planning permission for retail development at Newquay Growth Area,
Treloggan Road and Trevithick Manor.

These remain as commitments and the

Council, in October 2015, has resolved to grant permission for the expansion of the
Treloggan Road permission.

7 the TCFC and West Langarth proposals have been referred to the National Planning Casework Unit. A decision as to
whether the Secretary of State will call them in for his own determination is awaited.
8 This scheme has also been referred to the NPCU and a call-in decision is awaited.

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5.14

The final area where there has been new evidence base material has been in relation
to the publication of the 2015 Cornwall Retail Study Update. The 2015 study provides
further up-to-date evidence of shopping patterns and store/town centre turnover levels
across Cornwall. This evidence, which was not publicly available at the time of our
advice and the SPC meeting in December 2014, provides a useful contribution to the
assessment of financial impact and the wider overall effect on the health of defined
town centres. Again, whilst we consider it a useful addition to the evidence base
available to officers and members of the SPC, it will be for officers and members to
determine the weight to the placed on the Retail Study Update when determining
these applications.

5.15

In addition to the matters which have either changed, or for which new information
and evidence is available, it is also useful to note the matters/evidence which has not
changed:

Town centre health information.

Since December 2014, there has not been any

additional information on town centre health, across the West Cornwall towns.
Therefore, we continue to rely on the information provided by Cranford in their
Planning and Retail Statement (May 2015) which repeats the town centre health
information gathered in 2013 for the previous Cranford proposal and also the
contents of our own November 2014 advice report to the Council which highlights
the information which we consider salient on town centre health issues.

The Cranford survey of non-food shopping patterns. Whilst the 2015 Cornwall Retail
Study Update provides an up-to-date set of evidence for retail shopping patterns
(based on a survey of households undertaken in Autumn 2014), the household
survey commissioned by Cranford earlier in 2014 also remains relevant to the
consideration of impact issues.

5.16

We have also decided to re-examine our previous trade diversion assessment in light of
two factors.

First, the evidence data gathered by the household survey for the

Cornwall Retail Study Update 2015 indicates a relatively high proportion of internet
shopping in some parts of Cornwall, including West Cornwall. As a consequence, we
have considered whether a higher proportion of trade to the Cranford proposal will be

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transferred from internet shopping. Clearly, such a transfer may be limited as shoppers’
decisions to use the internet for comparison goods shopping are unaffected by the
quality and extent of ‘physical’ shops in a particular area. However, it would appear
that internet shopping is potentially higher in areas without easy access to a wide
range of stores and this could suggest that proposals in Hayle could draw part of their
future trade from internet shopping.
5.17

Second, we have also revisited the turnover of the Cranford proposal. In the previous
assessment, both the applicant (Cranford) and Bilfinger GVA assumed an average
sales density for the proposed comparison goods floorspace apart from the largest
store which the applicant relied on being occupied by Debenhams, which resulted in a
lower sales density for this unit. In this latest application, Cranford do not rely on any
retailers and therefore we consider it prudent to about their average sales density of
£5,000/sq m across all of the proposed comparison goods floorspace.

5.18

With regards to our updated assessment of solus and cumulative impact, this is
presented in Tables 8a and 8b at Appendix A. In the interests of comparison with the
previous analysis, the contents of these tables can be compared with the contents of
Table 8 in our November 2014 advice report for the Cranford application. Table 8a
provides an assessment of the impact of the Cranford application based on the
evidence base data provided by the survey of household shopping patterns
commissioned by Cranford in 2014. Table 8b provides a similar assessment but based
on the evidence provided by the survey commissioned to inform the 2015 Cornwall
Retail Study Update. Both tables follow the same structure and, as will be outlined
elsewhere in this advice report, are equally applicable to the Cranford and rugby club
proposals9.

5.19

With this information in mind, we now turn to our updated assessment of the impact of
the Cranford proposal on town centre investment and town centre health.

9

Assuming that the same controls are applied to both proposals

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Impact on town centre vitality and viability
5.20

Within our previous assessment of the impact of the Cranford proposal, our advice to
CC focused upon the following aspects:

A critical review of the applicant’s own impact assessment;


Conducting our own assessment of financial impact based upon the results of the
Cranford 2014 household survey;


An assessment of the impact of the Cranford proposal on the health of each
relevant town centre including analysis of: the scale of trade loss of the centre, the
health and financial performance of the centre over time, and the extent of
trading overlap between the proposal and the main retail sectors in the centre.

5.21

We remain with this approach for our updated assessment, and build into this
assessment the additional impact of newer committed developments and the
additional evidence provided by the 2015 Cornwall Retail Study Update.
Hayle

5.22

Hayle’s two town centres, at Foundry and Copperhouse, are the two closest defined
centres to the proposed development. Within our previous advice report, we found
that the Cranford proposal, due to its size and location next to the existing West
Cornwall Shopping Park had the potential to become a third quasi-town centre for
Hayle and that the impact of an unrestricted Cranford development, alongside the
cumulative impacts associated with the South Quay commitment, had the potential to
exhibit a significant adverse impact upon the health of Hayle’s town centres.

5.23

However, the advice went on to note that if the development was restricted to the sale
of fashion goods and a smaller amount of other comparison goods, then the severity of
the impact on the centres could be reduced to an adverse scale of impact. This
advice was based upon the retail offer of the two defined town centres in Hayle and
the acknowledgement that whilst the town as a whole has seen an increase in its
market share for clothes and fashion shopping over recent years (and this trend is also
now supported by the evidence in the 2015 Cornwall Retail Study Update), a large
majority of this rise is likely to be due to the out-of-centre West Cornwall Shopping Park.

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5.24

In our view, these conclusions remain valid, although it is worth highlighting that the
Council is clearly sensitive to the impacts of some retail development in Hayle, as
shown by the refusal of planning permission (subsequently over-turned at appeal) for
the additional comparison goods sales in the ASDA supermarket.

5.25

In relation to the potential for an impact on town centre investment from the Cranford
proposal, this was an original concern from the promoters of the South Quay and
Foundry Yard developments (ING) although these objections were withdrawn during
the course of considering the previous application. We are not aware of any further
objections which relate to the issue of investment in the context of the latest
application and note that whilst ING are continuing to promote new retail
development at Foundry Yard, no further objections have been received from ING.
Truro

5.26

Turning to Truro, our previous (2014) advice highlighted the following issues:

There is evidence that, in relation to shopping patterns for clothing and fashion
goods, Truro city centre’s market share had held up well over the past several
years.


There is evidence that the turnover of the city centre has fallen in recent years.


Truro is currently a healthy centre which is able to attract a significant number of
shopping trips from across a large part of Cornwall.


Due to its current popularity, Truro is expected to experience a reduction in its
turnover due to commitments in Truro, Newquay and other surrounding towns10.


On the basis that the Cranford proposal was controlled to primarily clothing and
fashion goods, it was expected that a large part of the turnover of the proposal
would be diverted from the city centre due to its prominent role in this type of
shopping.


On this basis, our previous advice predicted that the Cranford scheme would have
a 3.4% solus impact upon the comparison goods sector in Truro city centre, which

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would rise to 7.4% when the impact of commitments (at that time) were taken into
account.

Around one fifth of all retailers in the city centre and one third of all comparison
goods retailers are clothing and fashion retailers, which is clearly an important
characteristic when the impact of the fashion-led Cranford was being considered.


That there was a growing cumulative impact upon Truro city centre as a
consequence of the number of commitments for retail space in Truro and
surrounding settlements such as Newquay, Fraddon and St Austell.

5.27

Much of this information and analysis remains valid although it is important that our
updated analysis takes into account the growing cumulative impact (as a
consequence of additional commitments) and also the market share and turnover
information from the 2015 Cornwall Retail Study Update.

5.28

In our previous advice report, Table 3.7 provided a comparison of Truro’s market share
for clothing/fashion shopping across the area covered by Cranford’s 2014 household
survey and the 2008 survey informing the 2010 Cornwall Study. That table is reproduced
below and expanded to include the data from the 2014 household survey informing
the 2015 retail study update.

For the avoidance of doubt, this refers to those commitments that were in place at the time of providing our previous
advice on the Hayle proposals in November/December 2014.

10

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Table 5.1 – comparison of Truro’s market share in first and second choice
clothing/fashion shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

15.5%

43.4%

27.4%

57.4%

35.7%

50.4%

53.3%

69.0%

70.3%

86.5%

2nd choice

47.7%

29.6%

29.7%

25.3%

45.7%

21.6%

31.8%

25.5%

18.4%

11.8%

2008 survey

2014 survey (Cranford)
1st choice

33.3%

42.7%

24.7%

37.2%

46.4%

50.5%

56.6%

51.8%

65.6%

84.4%

2nd

26.7%

31.2%

30.4%

26.2%

36.0%

22.7%

25.5%

34.0%

31.6%

18.8%

choice

2014 survey (Cornwall Retail Study Update)
1st choice

17.0%

34.2%

22.3%

43.5%

37.4%

47.5%

45.8%

51.6%

56.3%

76.2%

2nd

17.0%

34.2%

22.3%

43.5%

37.4%

47.5%

45.8%

51.6%

56.3%

16.3%

5.29

choice

The above data confirms that whilst Truro continues to have a good market share
across the whole of West Cornwall, there are signs of the erosion of this share of
clothing and fashion goods shopping trips in some zones.

5.30

In relation to the financial impact of the Cranford proposal, Tables 8a and 8b set out
our updated analysis. Table 8a uses the Cranford survey to calculate the proportionate
impact on town centre trade and, in an update to our previous November 2014
advice, includes the new commitments that have been outlined earlier in this section.
Table 8a indicates that, based on the Cranford survey, there will be a 3.4% impact on
the comparison goods sector in Truro city centre. This is the same as previously assessed
notwithstanding the need to take into account the possibility that the Cranford
proposal could divert some of its trade some commitments in the Truro/Threemilestone
area.

5.31

However, whilst the solus (i.e. individual) impact of the Cranford scheme may be the
same, there is a growing cumulative impact on the comparison goods sector in Truro
city centre due to the decisions of the Council during 2015 to grant planning permission
for circa 40,000sq m of new floorspace in Truro/Threemilestone, 10,000sq m of
floorspace in St Austell (Higher Trewhiddle Farm) and 10,000sq m of floorspace at

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Fraddon (partial redevelopment of Kingsley Village).

Table 8a indicates that the

cumulative impact on Truro’s comparison goods sector will be 19.2%.
5.32

Table 8b undertakes the same exercise but bases the proportionate impact on the
turnover of the city centre as predicted by the Cornwall Retail Study Update 2015. This
suggests that the solus impact of the Cranford proposal on the city centre’s
comparison goods sector will be 4.3% and the overall cumulative impact will be 23%.
This method of assessing impact is in line with our advice to the Council for the recent
schemes in Truro, Threemilestone, St Austell and Newquay.

5.33

The above analysis outlines a number of similarities with our previous analysis in terms of
the individual financial impact associated the Cranford proposal and also the general
level of trading overlap between the proposal and the retail offer in the city centre.
However, our latest analysis has brought some clarity to the overall level of cumulative
financial impact upon Truro city centre which was an issue raised in our previous advice
which noted11:
“Given that it is unclear at present whether any of the retail proposals in
Truro/Threemilestone will be approved, and given that the new Cornwall-wide
household survey has yet to be analysed, it is impossible to predict with any
certainty the severity of the solus and cumulative impacts on Truro city centre. It
is clear that the impact of the Cranford proposal will be adverse, and there is
the potential for a significant adverse impact, but this can only be fully
understood alongside the impacts of the other proposals”.

5.34

Now that the evidence in the retail study update has been analysis and the Council
has decided to support a number of large-scale retail schemes in Truro, Threemilestone,
St Austell, Fraddon and Newquay, it has become clear to us that the combined impact
of the Cranford proposal and these commitments will be significant adverse impact
upon the health of Truro city centre. As has been previously documented, Truro has
enjoyed a very good trading position over many years and has grown to become the
preeminent comparison goods shopping location in Cornwall. However, we consider
that the combined effect of these proposals and commitments will be to affect this role

11

Paragraph 3.103

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and as comparable out of centre facilities are provided elsewhere and which are
designed to attract retailers who will compete with Truro and enable shorter shopping
trips for different types of comparison goods.
5.35

These effects clearly also have some benefits, including the ability to shorten the length
of shopping trips to, for example, Truro and also possibly farther afield such as
Plymouth12. It will also enable, in the case of the Cranford proposal, a better range of
comparison goods retail facilities to be provided in West Cornwall. However these
benefits will be associated with an out of centre retail facility adjacent to the A30
rather than in a town centre, which the Council’s adopted and emerging Local Plan
documents seeks to maintain and enhance.

5.36

Indeed, a decision to support a proposal such as the one being promoted by Cranford
could be seen as a clear departure from that strategy. This is, however, a strategic
decision for the Council to make and the Council must consider how approval of this
application will relate to its emerging Local Plan Strategic Policies retail and town
centres strategy.
Penzance

5.37

In our previous advice report, we outlined our concern that the Cranford proposal had
the potential to exhibit a significant adverse impact upon the health of Penzance town
centre. Our reasons for reaching this conclusion were as follows:

the strong likelihood that the proposal will provide direct competition with a key
retail sector in Penzance’s town centre;


the falling turnover and market share of Penzance in recent years13;


the scale of the direct impact upon the comparison goods sector in the town
centre (which is likely to remove a large proportion of the centre’s comparison
goods turnover – i.e. a 9% solus impact and a 10% cumulative impact); and

we anticipate that up to £1.0m of comparison goods expenditure could be diverted from stores in Plymouth,
partiucularly the city centre
13 there are likely to be a number of reasons for this fall in market share/turnover, including: the increasing influence of
internet shopping on comparison goods sales, the increasing attractiveness of West Cornwall Retail Park in Hayle and
the continued strong performance of Truro over the past several years
12

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the contribution that the comparison goods sector makes to the overall vitality and
viability of Penzance town centre, including the potential for spin-off benefits and
linked trips.

5.38

We have re-visited these conclusions with particular reference to the new household
survey information and the additional commitments in the local area.

5.39

With regards to the shopping patterns information from the 2015 retail study update,
Table 5.2 below repeats the information in Table 3.9 in our previous advice and adds in
the latest survey data.

Table 5.2 – comparison of Penzance’s market share in first and second choice clothing/fashion
shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

67.4%

26.5%

33.1%

3.6%

0.5%

5.4%

0.8%

0.9%

1.4%

1.1%

2nd choice

18.6%

22.2%

23.0%

13.1%

0.0%

14.9%

9.1%

7.3%

2.6%

0.0%

1st choice

39.6%

26.0%

23.7%

3.2%

0.0%

2.0%

2.0%

0.0%

0.0%

0.0%

2nd choice

22.7%

19.5%

23.2%

11.5%

1.3%

12.0%

5.5%

6.4%

3.5%

1.6%

2008 survey

2014 survey

2014 survey (Cornwall Retail Study Update)
1st choice

47.3%

21.6%

20.3%

2.9%

0.0%

0.5%

1.0%

1.5%

0.0%

0.0%

2nd choice

47.3%

21.6%

20.3%

2.9%

0.0%

0.5%

1.0%

1.5%

0.0%

0.0%

5.40

The above table indicates that there is a general conformity between the two 2014
household surveys although the Council’s survey suggests that Penzance town centre
has not lost as much market share in first choice clothes/fashion shopping trips in its own
zone (Zone 1) as the earlier 2014 Cranford survey would suggest and that it has also
been able to increase its share of second choice clothes/fashion trips in the same zone.

5.41

In relation to the turnover of comparison good stores in Penzance, the three sets of
data indicate that:

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As outlined in the previous advice report, there has been a fall in the town’s overall
comparison goods turnover (using the data in the 2010 Cornwall Retail Study and
the 2014 Cranford household survey);


Analysis of the data in the 2015 retail study update reveals that the predicted 2019
turnover for Penzance is similar to the forecasts using the applicant’s survey
(£111.6m, as opposed to £108.8m).


In relation the turnover of the town centre, the retail study update survey indicates
a similar turnover to the Cranford survey (£96.6m and £95.0m respectively).
However, whilst both of these 2014 survey estimates are similar, there remains a
large drop in the financial performance of the town centre, from the forecasts
within the 2010 retail study.


Within our previous advice we noted that, based on the applicant’s survey
evidence, 18% of all comparison goods expenditure in Penzance was attributable
to clothing/fashion goods. An examination of the 2015 retail study reveals that that
proportion had risen to 23% (£20.6m out of £90.8m) whilst the proportion in the town
centre was higher at 26% (£20.5m out of £78.6m).

5.42

As a consequence of the above, and bearing in mind no change in the available
evidence on other town centre factors, we consider that it is appropriate to remain
with our previous conclusions given the evidence confirms: a falling turnover for the
town centre and a significant overlap between the clothing and fashion goods that will
be sold from the proposed development and the contribution that expenditure on
these goods makes to the viability of Penzance town centre.

5.43

This conclusion is reinforced by the likelihood that the financial impact on Penzance
town centre will grow as a consequence of the recent planning permission for The
Range store at Long Rock which was not taken into account by either the applicant or
Bilfinger GVA when undertaking our previous impact assessments.

5.44

In our view, The Range store could divert around £1.8m of comparison goods
expenditure from Penzance town centre and this level of diversion is unlikely to be
diluted by the additional cumulative impact associated with the Cranford proposal.
Indeed, a further issue regarding the cumulative impact on Penzance to be taken into

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account is impacts associated with the Truro and Threemilestone commitments which
will further add to the pressure on the town centre.
5.45

Our updated financial impact analysis is contained at Tables 8a and 8b. The analysis
at Table 8a is based upon the town centre turnover levels forecast by the applicant’s
own household survey and indicates that the solus impact of the Cranford proposal on
Penzance town centre will be 10.2%, rising to 13.8% when the cumulative effects of
other commitments are taken into account. Table 8b provides an alternative analysis
based upon the town centre turnover levels in the retail study update and indicates a
very similar solus impact of 10.3% and a cumulative impact of 14%.

5.46

On this basis, we remain of the view that the Cranford proposal will have a significant
impact upon the health of Penzance town centre.

The basis for this conclusion is

outlined above and, of course, it will be for officers and members to consider whether
they agree with our advice in terms of (A) the factors that are relevant to the
assessment of impact on Penzance town centre, and (B) the weight to be placed on
those salient factors. However, notwithstanding the important acknowledgement that
this is a decision for members of the SPC to make in due course, it is our view that the
Cranford proposal will have a significant impact upon the role and function of
Penzance town centre in serving the needs of West Cornwall.
Camborne
5.47

In our previous advice to the Council, we raised a concern over the impact on
Camborne town centre. This concern was based upon a falling comparison goods
turnover for town centre, a falling market share, a rise in vacant units, a fall in the
number of comparison goods retailers and the relatively large contribution that
spending on clothes and fashion goods makes to the overall viability of the centre.

5.48

In terms of the additional factors to consider, there are a number of small additional
retail commitments in the Camborne/Pool/Redruth area although they are unlikely to
materially affect the cumulative impact assessment. Therefore, the only change to the
financial impact assessment is to take account of our re-examination of the diversion of
internet shopping and the results of the retail study update.

Table 8a, bases the

assessment of impact on the Cranford household survey results, indicates a solus
impact of 4.2% on Camborne town centre’s comparison goods sector, which will rise to
5.1% when the cumulative impact of commitments is taken into account.

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5.49

The analysis in Table 8b indicates a slightly higher solus impact on the town centre of
5.1%, and a cumulative impact of 6.1%, which is due to the retail study update
predicting a lower current comparison goods turnover for Camborne town centre.

5.50

By way of comparison with the above updated figures, our previous advice indicated
a 3.8% solus impact and a 4.1% cumulative impact on Camborne town centre’s
comparison goods sector. As a consequence, the latest financial impact data shows a
small increase over the previous assessments by Bilfinger GVA placed before the
Council.

5.51

In relation to the additional evidence on shopping patterns and turnover levels
provided by the 2015 retail study update, Table 5.3 below provides market share
information from the 2008 household survey and the applicant’s own 2014 survey
(previously provided in our November 2014 advice report), which is now supplemented
by the survey information from the 2015 retail study update.

Table 5.3 – comparison of Camborne’s market share in first and second choice
clothing/fashion shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

0.0%

0.0%

8.1%

2.4%

0.0%

21.7%

3.3%

5.2%

1.4%

1.1%

2nd

0.0%

3.7%

8.1%

1.0%

0.9%

10.8%

11.4%

3.6%

5.3%

2.9%

1st choice

0.0%

0.0%

3.2%

0.0%

1.0%

20.2%

7.1%

0.0%

0.0%

0.0%

2nd

4.0%

3.9%

4.3%

0.0%

1.3%

20.0%

9.1%

14.9%

8.8%

3.1%

2008 survey
choice

2014 survey

choice

2014 survey (Cornwall Retail Study Update)
1st choice

0.0%

1.2%

1.1%

0.3%

1.0%

12.4%

4.2%

1.5%

1.1%

0.0%

2nd

0.0%

1.2%

1.1%

0.3%

1.0%

12.4%

4.2%

1.5%

1.1%

2.3%

5.52

choice

The above data shows that, leaving aside Zone 6 for one moment, the Council’s 2014
household survey confirms the results of Cranford’s survey in that there has been a
general deterioration in Camborne’s clothes/fashion goods market share. However, in
contrast to the Cranford 2014 survey, the Council’s survey shows a reduction in

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Camborne’s market share in first choice clothing/fashion shopping trips from Zone 6
residents (which is the zone in which Camborne sits).
5.53

Whilst there is no evidence to doubt either of the 2014 surveys, the available data
indicates uncertainty over the strength in the comparison goods sector with Camborne
is likely to compete with the Cranford proposal.

In one scenario the town’s local

market share has remained static and in the other its penetration rate has dropped
significantly.

Therefore, on the above basis, it would appear than our previous

conclusions remain valid and which noted that:
“we have a concern over the harmful impact of the proposed development on
the vitality and viability of Camborne town centre. Whilst the direct financial
impact upon the comparison goods sector is lower that other towns such as
Penzance, the centre appears to be in a declining state of health. The
proposed development has the potential to worsen this trend and the clear
adverse impact upon the centre is close to becoming a significant adverse
impact”.
Redruth
5.54

Within our previous advice, we advised the Council that the impact on Redruth town
centre was likely to be adverse but, in light of the town’s circumstances, is likely to be
less severe than the impacts on Penzance and Camborne.

We have revisited this

conclusion with reference to our updated assessment of financial impact and also an
examination of the household survey results from the Cornwall Retail Study Update
2015.
5.55

Table 3.13 on page 49 of our November 2014 advice set out the market share of
Redruth town centre in relation to clothes/fashion shopping. That table is reproduced
below and expanded to include the results of the retail study’s household survey.

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Table 5.4 – comparison of Redruth’s market share in first and second choice
clothing/fashion shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

0.0%

0.0%

0.8%

0.0%

0.5%

0.0%

13.3%

9.5%

2.7%

0.0%

2nd

0.0%

0.0%

0.0%

2.0%

0.0%

0.0%

2.3%

16.4%

5.3%

8.8%

1st choice

0.0%

2.1%

0.0%

0.0%

0.0%

0.0%

12.1%

25.9%

13.3%

1.0%

2nd

0.0%

1.3%

1.4%

1.6%

0.0%

5.3%

18.2%

21.3%

15.8%

6.3%

2008 survey

choice

2014 survey

choice

2014 survey (Cornwall Retail Study Update)
1st choice

0.0%

0.0%

0.0%

0.5%

0.0%

0.7%

7.6%

14.1%

13.9%

0.0%

2nd

0.0%

0.0%

0.0%

0.5%

0.0%

0.7%

7.6%

14.1%

13.9%

2.7%

5.56

choice

The above table shows that the Council’s own household survey also indicates an
improvement in Redruth’s market penetration rate for clothes/fashion goods shopping
in a small number of zones, including its own ‘home zone’ (Zone 8). In some cases, the
increase is not as large as the Cranford survey, although there has nevertheless been
an increase. The exception to this is Zone 7 (Pool) where there may have been a fall in
the town centre’s market share.

5.57

Tables 8a and 8b show the updated assessment of financial impact on Redruth town
centre’s comparison goods sector. In our previous (November 2014) assessment, we
forecast a 4.3% solus and cumulative impact for the town centre.

The solus and

cumulative impact forecasts were the same at that time as there were not any
committed retail developments that were likely to have an additional impact on
Redruth.
5.58

However, as outlined in Table 8a at Appendix A to this report, whilst the solus impact of
the Cranford scheme remains at about 5% (based on the Cranford survey turnover
data), the cumulative impact on Redruth town centre rises to 8% due to the Truro and
Threemilestone commitments.

In our alternative analysis in Table 8b, these

proportionate solus and cumulative impacts are slightly higher at 7.2% and 11.6%
respectively, due to the lower existing town centre turnover forecast by the Cornwall
Retail Study Update.

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5.59

Therefore, it will be important for the Council to take into account this change in
circumstances for Redruth town centre when re-examining the impact of the Cranford
proposal and reaching a conclusion as to whether this scale of impact represents a
significant adverse impact.

Whilst the final decision on this matter rests with the

Council, it is our view that this level of impact, coupled with the trading overlap
between the proposal and the town centre does not represent a clear significant
adverse impact although the gap between this ‘adverse impact’ conclusion and a
‘significant adverse impact’ level is now relatively small.
Helston
5.60

For Helston town centre, our previous advice indicated that, in our view, the impact of
the Cranford proposal would not result in a significant adverse effect. This view was
based upon a small 3% impact on the centre’s comparison goods sector and a
relatively small clothing/fashion offer in the centre.

5.61

In terms of an update to this position, we have examined the shopping patterns data
from the retail study update and also re-visited our assessment of financial impact.
Table 5.5 below re-provides the market share data from Table 3.15 of the November
2014 advice report and adds in the retail study update market share data. The table
reveals that the Council’s household survey is suggesting that the increase in the town’s
clothing/fashion goods market share has not risen by as much as the Cranford survey
suggests.

However, the Council’s survey does still reveal an increase in market

penetration in Zone 4, which is the zone in which Helston lies.

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Table 5.5 – comparison of Helston’s market share in first and second choice
clothing/fashion shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

0.0%

0.0%

0.8%

11.2%

0.5%

0.0%

0.0%

0.0%

0.0%

0.0%

2nd choice

1.2%

0.0%

1.4%

11.1%

0.9%

0.0%

0.0%

0.0%

0.0%

2.9%

1st choice

0.0%

0.0%

3.2%

25.5%

0.0%

1.0%

0.0%

0.0%

0.0%

0.0%

2nd choice

0.0%

0.0%

0.0%

21.3%

2.7%

0.0%

0.0%

0.0%

0.0%

1.6%

2008 survey

2014 survey

2014 survey (Cornwall Retail Study Update)
1st choice

0.0%

0.0%

0.0%

14.7%

0.4%

0.7%

0.0%

0.0%

0.8%

0.0%

2nd choice

0.0%

0.0%

0.0%

14.7%

0.4%

0.7%

0.0%

0.0%

0.8%

0.0%

5.62

For the updated assessment of financial impact, Tables 8a and 8b indicate that Helston
town centre is unlikely to receive a higher cumulative impact as a consequence of
other recent retail commitments.

Therefore, based upon an assessment using the

Cranford survey data, the impact of the Cranford scheme on the centre’s comparison
goods sector remains at 3%. Moreover, given that the retail study update is predicting
a similar level of pre-impact turnover for the centre, the assessment at Table 8b also
predicts a 3% solus and cumulative impact.
5.63

In light of the above, we see no reason to change our advice to the Council in relation
to the impact on Helston town centre. In particular, whilst there will be a 3% impact on
the centre’s comparison goods retail sector, we do not consider that this is of scale to
warrant particular concern over the future health of the centre, bearing in mind the
retail offer of Helston town centre.
Falmouth

5.64

The final centre for examination is Falmouth. In our previous advice, we raised concern
over the cumulative impact of the Cranford proposal alongside the impact of the
committed replacement Sainsburys store (and conversion of the existing store to nonfood use). Indeed, we considered that the scale of cumulative impact upon the town
centre was sufficiently large to warrant a concern of the significant adverse nature of

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this impact. However, the advice report did raise the possibility that the Sainsburys
permission would not be implemented due to the state of the grocery retail sector and
Sainsburys intentions regarding its own store opening programme and this was a salient
factor for the Council to be taken into account by the Council.
5.65

The situation with regards to the Sainsburys permission has not changed since our
November 2014 advice and there remains little prospect that the replacement store will
be provided.

Therefore, whilst the Sainsburys permission should not be completely

ignored (as it remains a permission for the time being), we would recommend that the
Council places little weight on this commitment for the purposes of assessing
cumulative impact.
5.66

Exclusion of the Sainsburys commitment would, based upon our previous advice,
downgrade the scale of impact on Falmouth town centre from ‘significant adverse’ to
just ‘adverse’. However, in line with the other centres included within our assessment of
impact, there is a need to re-examine the scale of this impact in light of the new
market share and turnover information provided by the Cornwall Retail Study Update
and also the advent of new retail commitments in Truro and Threemilestone.

5.67

In relation to the market share of Falmouth for clothing/fashion goods, Table 5.6 below
includes the retail study update data alongside the 2008 shopping patterns survey and
the results of the Cranford survey.

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Table 5.6 – comparison of Falmouth’s market share in first and second choice
clothing/fashion shopping trips
Zone
1

2

3

4

5

6

7

8

9

11

1st choice

0.0%

0.0%

0.0%

4.7%

50.8%

1.6%

0.0%

3.4%

9.5%

1.1%

2nd

1.2%

0.0%

1.4%

24.2%

30.2%

8.1%

9.1%

12.7%

21.1%

0.0%

1st choice

0.0%

0.0%

1.1%

6.4%

33.0%

0.0%

0.0%

0.0%

3.3%

0.0%

2nd

1.3%

3.9%

1.4%

21.3%

34.7%

4.0%

10.9%

6.4%

10.5%

4.7%

2008 survey

choice
2014 survey

choice
2014 survey (Cornwall Retail Study Update)
1st choice

1.1%

0.0%

0.5%

3.1%

28.3%

0.0%

2.8%

0.5%

1.5%

0.7%

2nd choice

2.3%

0.0%

2.4%

12.9%

34.5%

2.4%

5.8%

5.6%

10.5%

2.3%

5.68

Table 5.? above reveals that the Council’s 2014 survey broadly confirms the results of
the Cranford survey in that there has been a fall in Falmouth’s market share of first
choice clothing/fashion shopping trips in Zone 5 (the zone in which Falmouth lies). The
latest survey also confirms the fall in Falmouth’s market share across a number of other
zones (in line with the Cranford survey).

5.69

In relation to the turnover of the town centre, the analysis within the retail study update
suggests a pre-impact 2019 comparison goods turnover of £67.9m which is very similar
to the applicant’s survey which suggests a turnover of £67.4m. As a consequence, the
proportionate impact calculation for Falmouth town centre is likely to be the same
whichever evidence base is used.

5.70

In relation to the assessment of cumulative impact, we have already noted that the
Council should consider giving reduced weight to the Sainsburys commitment
although, in its place, there is a need to take into account the impact of commitments

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in Truro and Threemilestone14. This is shown in Tables 8a and 8b at Appendix A and
shows that the solus impact of the Cranford proposal on Falmouth town centre’s
comparison goods sector is 5.6% and which will rise to 9.1% when the impact of salient
commitments is taken into account.
5.71

It should be noted that this updated solus is slightly higher than previously advised in
November 2014 (5.3%) but noticeably lower than the previously advised cumulative
impact level of 13.4%. Therefore, given that our previous advice indicated that the
solus impact of the Cranford proposal did not amount to a significant adverse impact
on Falmouth and given that the cumulative impact on the town centre has been
reduced, we are able to update our view that the cumulative impacts associated with
the Cranford proposal and other salient commitments no longer, in our opinion,
constitutes a significant adverse impact.

14

TCFC and West Langarth

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6.

The Retail Planning Issues: the Rugby Club
Proposal
Introduction

6.1

Given the same policy status as the Cranford application site, there is also a
requirement to consider the compliance of the rugby club proposal with the sequential
test and also consider the scale of the impact of the proposal on town centre
investment and town centre health.

6.2

Within our previous advice, dated December 2014, we concluded that the applicant
had not demonstrated compliance with the sequential test and that the proposal at
that time had the potential to exhibit a significant adverse impact upon the health of
Penzance and Hayle town centres along with the possibility of a significant adverse
impact on Camborne town centre.

6.3

However, it should be noted from the outset that our previous (December 2014) advice
to the Council was at a point in time when the applicant had not offered any controls
over the proposed retail floorspace. Since that time, and the decision of the SPC to
defer determination of the application, the applicant has offered a series of controls
which have been summarised in Section 2 of this report.

These controls have guided

our re-assessment of the sequential and impact tests, which are outlined in turn below.

Sequential Test
6.4

As noted in Sections 2 and 3 of this report, the proposed controls over the Class A1 and
A3 floorspace now allow the rugby club proposal to be similar in scale and function to
the Cranford proposal. That said, because the rugby club proposal is submitted in
outline, there is possibly some additional flexibility in how it could be developed and
which may not exist in the Cranford scheme which is a full application. Whilst some
flexibility will always remain, due to its outline nature, we consider that control over the
number and size of units via suitable precise condition and reference to an approved
plan are appropriate. Indeed, if such controls are imposed, then we consider that the

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rugby club application would then be broadly consistent in terms of scale and format
with the Cranford scheme.
6.5

On this basis, we consider it appropriate that the conclusions reached in relation to the
Cranford scheme, in Section 5 of this report, should also apply to the rugby club
scheme also. Moreover, given that both sites occupy a similar location adjacent to the
A30, with similar distances to surrounding town centres, we consider that they are
sequentially equal and that the Council should not give preference to either site in the
sequential test.

6.6

As a consequence, on the basis that the Council concludes that the Cranford proposal
passes the sequential test, and assuming that further additional controls are placed on
the number and size of units in the development, we consider that the rugby club
application will also meet the provisions of the sequential test as set out in paragraph
24 of the NPPF, Policy TV16 of the Penwith Local Plan and Policy 4 of the draft Cornwall
Local Plan Strategic Policies document.

Impact
6.7

Our previous advice raised concerns over the potential impact of the proposed
development on the health of a number of town centres due to the lack of controls
over the proposed retail floorspace and the potentially very wide range of retail goods
which could be solved from the development. This was also a concern for the SPC in
December 2014 and one of the reasons for deferral of the application.

6.8

However, the controls which have now been offered by the applicant bring the rugby
club development into much closer line with the Cranford scheme in terms of the
range of retail goods that could be sold from the proposed floorspace.

Indeed,

subject to a further tightening of controls over the number of retail units and the size of
these units, then we consider that the overall trading effects of the proposed
development will be similar to the Cranford scheme.

Therefore, the financial impacts

shown in Tables 8a and 8b at Appendix A to this report are equally applicable to both
the Cranford and Rugby Club proposals.
6.9

Clearly, there is potential for some variances, particularly in the three retail units in each
scheme which are unrestricted in type and range of comparison goods which they

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can sell, although we consider it would be unreasonable to suggest that a definitive
distinction could be drawn between the two.
6.10

Therefore, based on the controls that have now been offered by the applicant for the
rugby club scheme, we consider it reasonable to conclude that the trading impacts of
the scheme will be similar to those observed in the previous section of the report for the
Cranford proposal.

6.11

Therefore, in summary, whilst the rugby club proposal will have an adverse impact
upon the health of a number of town centres in West Cornwall (including Camborne,
Redruth, Helston and Falmouth), the two centres of particular concern, particularly
when cumulative impact issues are considered, are Penzance and Truro. As noted in
the previous section of this report and also with reference to our previous advice, the
effect on the health of Penzance town centre is of particular concern due to the
proximity of the centre to the proposal, its worsening trading performance and overlap
in goods to be sold from the proposed development. Similar considerations apply for
Truro city centre, although of additional importance is the scale of cumulative impact
upon the financial performance of the city centre.

6.12

However, as noted in the previous section, the Council as decision-maker must
decided whether it agrees with our assessment of impact and will need to take into
account the following factors:

The information presented in relation to the health of nearby town centres,
including their performance over time;


The extent of trading overlap between the proposed developments and the retail
offer of town centres;


The scale of financial impact from either proposal on the current turnover of town
centres; and


The range of controls that have been offered in relation to the proposed retail
floorspace.

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7.

Cumulative Impact

7.1

One area of additional work which CC officers have asked Bilfinger GVA to undertake
is an assessment of the cumulative impact of both the Cranford and rugby club
proposals on the health of nearby town centres (also taking into account the
cumulative impacts associated with other commitments).

7.2

In order to provide this assessment, we consider that the following two factors should
be considered by the Council:

The combined financial impact of the two proposals; and


The overall attractiveness and scale of the existing and proposed retail floorspace
adjacent to the A30 at Hayle.

7.3

We consider each factor in turn below.
Combined financial impact

7.4

Of the two applicants, only Cranford has submitted information on cumulative impact
issues. This is contained in Section 5 of the May 2015 Planning and Retail Statement and
the main points raised are as follows:

An assessment of both schemes proceeding together in close succession is a worstcase scenario as, in reality, both schemes may not proceed or, if they do, they
might be some years apart;


An assessment of cumulative financial impact is provided based on the trade
diversion estimates from both applicants and assumes that each scheme trades at
80% of their standalone level (due to the mutual impact between both schemes).


On this basis, the Cranford assessment predicts the following cumulative impacts:

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Based upon the above figures, the Cranford assessment does not consider that any
of these impacts represents significant adverse harm to any of these town centres.

7.5

In response to the cumulative assessment offered by Cranford we would agree that the
inclusion of the impact of both schemes at 2019 represents a robust position as the
opening of the retail development on the rugby club site can only take place once the
existing rugby club facility has been relocated. In response to the comment that both
schemes may not come forward due to tenant demand, this issue is currently being
investigated by Bilfinger GVA and an update will be provided in due course.

7.6

We would also agree that an allowance should be made for the mutual impact
between the two proposals and agree that a reduction of 20% is a robust allowance.

7.7

We have therefore followed this same approach within our own assessment which is
contained at Tables 9a and 9b at Appendix A. This assessment uses the same data as
the individual assessment for each proposal, but models the combined impact of the
Cranford and rugby club schemes assuming that each trades at 80% of the expected
individual turnover level.

7.8

This indicates the following combined level of cumulative impact for each evidence
base scenario:

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Table 7.1: combined impact of Cranford and rugby club proposals, based on Cranford
and Cornwall Council evidence base data
Cranford household survey

Cornwall Retail Study Update

evidence base

2015 evidence base

Cranford &

Cranford &

Cranford &

Cranford &

Rugby Club

Rugby Club +

Rugby Club

Rugby Club +

commitments

commitments

Hayle

-16%

-21%

-13%

-17%

Falmouth town

-9%

-12%

-9%

-12%

Helston

-5%

-5%

-5%

-5%

Camborne

-7%

-8%

-8%

-9%

Redruth

-8%

-11%

-12%

-16%

Truro city centre

-6%

-21%

-7%

-25%

Penzance town

-16%

-20%

-17%

-20%

centre

centre
Source: Tables 9a and 9b, Appendix A

7.9

The above data indicates that there is an ‘across the board’ increase in financial
impacts on town centres. We have already concluded that the individual impact of
either scheme (along with commitments) is likely to contribute to a significant adverse
impact upon the health of Truro city centre and Penzance town centre.

As a

consequence, these increases in solus and cumulative impact will simply reinforce
these earlier conclusions.
7.10

In relation to other centres, the increases in impact on Camborne and Redruth town
centres and we consider that this scale of diversion will start to become close to a
significant adverse impact, particularly for Camborne which is closer to the application
sites and which accommodates a higher level of existing retail provision for
clothing/fashion goods.

7.11

Of the other centres, Falmouth returns to become a concern in our opinion. The scale
of cumulative impact on the town centre returns to a level which was highlighted in our
previous advice as being a future to the town centre, with Hayle becoming a much
stronger draw to shoppers within Falmouth’s natural catchment.

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7.12

In relation to Hayle, the impact also grows although the majority of this is likely to fall on
out-of-centre stores such as West Cornwall Shopping Park. Nevertheless, the impact on
the two town centres is likely to grow, particularly as the number of nonclothing/fashion units will double from two to four and these are the units which are
more likely to compete directly with stores in Hayle’s two town centres.
The overall attractiveness and scale of retail facilities adjacent to the A30 in Hayle

7.13

Alongside the likelihood that the financial impact on nearby town centres will grow
should both schemes be approved, we consider that there is a need to consider the
overall attractiveness of the retail facilities next to the A30 in Hayle.

7.14

At the present time, out-of-centre shopping in Hayle is dominated by West Cornwall
Shopping Park. This facility extends to circa 5,000sq m. Both of the current proposals
extend to circa 15,500sq m and therefore the amount of out of centre floorspace in this
area would grow to 20,000sq m if one scheme is approved and 35,000sq m if both
schemes are approved.

7.15

This level of floorspace should be compared with the size of the following town centres:

Penzance: 45,000sq m of total Class A floorspace and 28,500sq m of Class A1
floorspace.


Camborne: 34,000sq m of total Class A floorspace and 22,000sq m of Class A1
floorspace.


Redruth: 22,500sq m of Class A floorspace and 12,700sq m of Class A1 floorspace.


Truro: 77,100sq m of total Class A retail floorspace and 54,900sq m for Class A1
floorspace.


Helston: 24,000sq m of total Class A floorspace and 16,100sq m of Class A1
floorspace.


7.16

Falmouth: 35,500sq m of Class A floorspace and 23,000sq m of Class A1 floorspace.

The above data indicates that approval of both schemes would provide an out of
centre shopping destination which is:

Larger than the Class A1 retail sector in Penzance

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The same size as the whole of Camborne town centre


One third larger than the whole of Redruth town centre


Around half of the size of the whole of Truro city centre and two-thirds of the size of
the Class A1 retail sector in the city centre


7.17

The same size as the whole of the Falmouth town centre.

By way of further comparison, set out below is the scale of the Class A floorspace in the
Cranford and rugby club proposals alongside the scale of Class A floorsoace in other
recent retail proposals that have been considered by the Council’s SPC recently:

7.18


Cranford: 15,539sq m gross


Rugby Club: 15,539sq m gross


West Langarth, Threemilestone: circa 12,000sq m


Truro City FC: 14,000sq m


Hendra, Threemilestone: circa 8,700sq m


Redevelopment of part of Kingsley Village Fraddon: circa 10,000sq m


Higher Trewhiddle Farm: circa 10,000sq m

Whilst there is no longer a stand-alone test of ‘scale’, and we would advise against any
refusal of permission on the basis of ‘scale’ alone, the amount of retail floorspace in a
particular location will clearly be important in terms of how shoppers view that location
and the combined impact of these two proposals. For example, whilst West Cornwall
Shopping Park is already a well-used and successful shopping destination, and no
doubt each of the current proposals will also be similarly attractive, the combined
effect of these three schemes will be to rival the amount of space and the choice that
exists in town centres in the Council’s formal retail hierarchy. Indeed, the synergy and
the effect of the whole will, in our opinion, be greater that the sum of the different
parts, as the attractiveness of the A30 retail shopping area will provide more space
than a number of town centres. It will create a quasi-town centre outside of the formal
shopping hierarchy in Cornwall, providing modern large-scale flexible floorspace which
some town centres, particularly the mid-sized towns of Penzance and Camborne, in

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western Cornwall will find it hard to compete with. Truro, due to its size and strength,
may be able to offer more effective competition to the proposals in Hayle, although as
outlined above Truro’s health has the potential to be steadily eroded due to the large
number of commitments in other towns such as Truro itself, Newquay, Fraddon and St
Austell.
7.19

Not only is this important for the approach with the Council should take to the
assessment of the individual and combined effects of these two proposals, but is it also
important in terms of how the Council should assess these two proposals in terms of the
adopted and emerging retail and town centres strategy for Cornwall. In particular,
there is no place in either the adopted retail strategy for the size of retail floorspace
currently proposed on these sites and/or the creation of a retail destination which will
rival the size of existing centres.

7.20

Similarly, there is no place in the current version of the Local Plan Strategic Policies
document, a document which officers have confirmed should be given weight. In
particular, there is no suggestion that the future retail capacity which is available to
settlements such as CPR, Truro, Penzance, Helston and Falmouth should be transferred
and combined into one location in Hayle.

7.21

As a consequence of these factors, these proposals are contrary to that stated Council
strategy but no doubt officers and members of the SPC will reach their own reasoned
view on this aspect in due course and place weight on the emerging Local Plan
Strategic Policies document accordingly.
Conclusions

7.22

Overall, we consider that cumulative impact of approving both of these schemes is
likely to materially increase the pressure on the health of existing defined town centres
across West Cornwall and Truro.

Due to the combined scale of these two

developments, which will start to rival existing traditional town centres in terms of size
and choice of retail facilities, the existing concerns over Penzance and Truro are
reinforced and the potential for a significant adverse impact on Camborne, Redruth
and Falmouth becomes a real possibility.

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8.

Summary and Conclusions
Introduction

8.1

This advice report has been prepared by Bilfinger GVA in relation to two planning
applications for retail development close to the A30 at Hayle. These applications are:
? An outline application by Hayle Community Rugby Facilities Ltd for the
redevelopment of land at Hayle Rugby Club for up to 15,539sq m of Class A1 and A3
retail floorspace and associated development (‘the rugby club application’); and
? A full planning application by Cranford (Hayle) LLP for the development of land at
Marsh Lane for 15,539sq m of Class A1 and A3 retail floorspace and associated
development (‘the Cranford application’).

8.2

Bilfinger GVA has previously provided advice to Cornwall Council on the rugby club
application, which was deferred from Strategic Planning Committee (‘SPC’) in
December 2014 and a previous application on the Cranford site which is very similar (in
its retail content) to the current application.

8.3

This should be seen as an executive summary of our advice to Council officers and
members of the SPC, in order to provide a useful overview of both our own findings and
advice and also guidance to officers and members when seeking to reach their own
conclusions regarding these applications.

Policy Context
8.4

Both of these sites lie in out of centre locations and this requires the Council to consider
whether they meet the provisions of the sequential test and also consider whether they
will have a significant adverse impact upon investment in, and the health of, defined
town centres.

8.5

In addition to the compliance with these tests, it is also important to relate these
proposals to the adopted and emerging development plan strategy for Cornwall, not
least because the planning system is plan-led and encourages sustainable
development.

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8.6

In relation to the adopted Penwith Local Plan, the retail strategy does not include the
provision of a large amount of retail floorspace adjacent to the A30 in Hayle and
instead directs new retail development in the town to the harbour area. However, it is
also salient to note that the adopted Local Plan is now relatively dated and was
prepared before the NPPF.

8.7

In relation to the emerging Local Plan Strategic Policies document, there is also no
provision for a significant amount of retail development in out of centre locations in
Hayle and no strategy to amalgamate the retail capacity in West Cornwall into one
location. As we understand it, the Local Plan Inspector has not raised any significant
concerns over the plan’s retail and town centre’s strategy (although a number of
specific areas need to be addressed via changes and addition to the document).
Indeed, we understand that Council’s officers are recommending that significant
weight is given to the retail policies in the emerging Local Plan, although we would
expect officers to confirm the weight that should be given to the emerging Local Plan
within their report to committee.

8.8

As a consequence, and given that these two applications are likely to meet the needs
of West Cornwall in one out of centre location rather than in town centres, it is our view
that the proposed developments, individually or combined, are contrary to the
emerging Local Plan strategy. However, this is our own view and, no doubt, Council
officers and members of the SPC will reach their own reasoned view on this aspect in
due course.

The Cranford Proposal
The Sequential Test
8.9

Given the out of centre location of the Cranford application site, there is a need for the
Council to consider whether there are any sequentially-preferable in-centre, edge-ofcentre or more accessible/better connected out-of-centre sites within the catchment
of the proposal.

8.10

Within our advice on the previous Cranford application, we reached the view that
whilst the applicant had not demonstrated flexibility in line with the requirements of the
NPPF and NPPG, there were no alternative sequentially preferable sites in West
Cornwall which could at present accommodate the Cranford development as

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proposed by the applicant. Indeed, at the SPC meeting in December 2014, members
of the committee did not raise any concerns over the compliance of the Cranford
proposal with the sequential test.
8.11

Given that there has not been any change in circumstances since this previous advice
and the SPC meeting in December 2014, our advice to the Council remains the same
in relation to the sequential test.
Impact

8.12

In relation to the impact of the Cranford proposal, it is important to note from the outset
that members of the SPC in December 2014, whilst refusing the Cranford application,
did not raise any specific concerns over the impact of the development on defined
town centres in Cornwall’s retail hierarchy. Our advice to the Council at that time was
that the Cranford proposal was likely to have a significant adverse impact upon the
health of Penzance town centre, along with the potential for a significant adverse
cumulative impact on the defined centre’s of Truro and Falmouth when the cumulative
impact of commitments was taken into account. In relation to other town centres, we
found that there would also be a negative impact upon some of these centres,
including Hayle, Camborne, Redruth and Helston, but that impact was not so large as
to be classified as significant.

8.13

We have re-visited our assessment of impact, taking into account new commitments
for retail floorspace (supported by the Council) and the evidence base contained
within the Cornwall Retail Study 2015. Taking these factors into account, we remain of
the opinion that there will be a solus and cumulative significant adverse impact upon
the health of Penzance town centre and a cumulative significant adverse impact
upon the health of Truro city centre. Indeed, the Council has already concluded that
without the Cranford proposal, there is already likely to be a significant adverse impact
upon the health of Truro city centre although this acknowledgement does not appear
to have stopped the Council from granting permission for additional retail floorspace in
Newquay, Fraddon and St Austell. In relation to the other town centres, we consider
that the impacts on Camborne, Hayle, Redruth and Helston will remain adverse (but
not significantly adverse) and that the likely loss of the Sainsburys proposal in Falmouth
will mean that the impact on Falmouth town centre will be adverse.

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

8.14

It should be acknowledged that the Council does not always agree with the advice of
Bilfinger GVA in relation to the policy issue of ‘impact’. Therefore, given that it must
reach a conclusion in relation to the Cranford scheme, we would recommend that its
conclusion takes into account and acknowledges the evidence which has been
provided by both the applicant and Bilfinger GVA (including the Council’s own Retail
Study Update 2015 and its own Local Plan Strategic Policies retail strategy) and also the
following factors (which are salient to both the Cranford and rugby club applications):

The information presented in relation to the health of nearby town centres,
including their performance over time. In this regard to show a falling performance
of a number of centres in Cornwall which leaves them vulnerable to impacts from
large developments such as these.


The extend of trading overlap between the proposed developments and the retail
offer of town centres. The available evidence shows that there is a variable level of
trading overlap between these proposals and the comparison goods sectors in
town centres in West Cornwall.

The extent of this overlap is evidenced in this

advice and we would ask the Council to give particular regard to the relatively
large overlap with centres such as Truro, Penzance and Falmouth.

The scale of financial impact from either proposal on the current turnover of town
centres. The applicants and Bilfinger GVA have both presented information on the
financial impact of these proposal on the trading performance of town centres
across Cornwall. As noted by Cranford, the difference between many of these
forecasts is minimal although it is the interpretation of these impacts which is
important.

This is the reason why the other factors in this list need to properly

considered and we would recommend that the Council does so when reaching its
final decision on these applications. That said, due to the size of these proposals,
along with the decisions of the Council to grant permission for a large amount of
retail floorspace in recent years, the scale of financial impact on Cornwall’s town
centres is now starting to become considerable. This is, in our opinion, a key area
for concern and we would recommend that the Council gives particular weight to
the scale of financial impact now likely to be present on Cornwall’s retail hierarchy.

Solus and cumulative impacts. When judging the effect of these proposals, the
Council must consider the combined impact with retail commitments. This should
take into account the effect of commitments in Fraddon, St Austell, Truro,

October 2015 gva.co.uk

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

Threemilestone, Penzance and Newquay.

This advice has done so and we

recommend that the Council does the same.

Precedent and consistency. As noted above, the Council has in some instances
disagreed with the advice of Bilfinger GVA in relation to the scale of impact on
defined town centres in Cornwall. With regard to these instances, the Council will
need to take into account its own view of the impact of these proposals when
reaching a view on the overall combined impact of the Hayle proposals with these
other commitments.

Indeed, in relation to Truro, the Council has already

acknowledged that some retail commitments will have a significant adverse
impact upon the health of the city centre (although permission has been granted
due to the weight placed on other factors). Clearly, whilst the weight placed on
those other factors was important in those decisions, there remains an
acknowledged significant adverse impact from these committed schemes and this
will to be considered carefully by the Council in the context of the additional
financial impact that these schemes will have on the city centre.

The range of controls that have been offered in relation to the proposed retail
floorspace.

When considering the impacts of these proposals, the range of

controls which have been offered by the applicants should be taken into account,
including whether any additional controls are considered necessary to control the
operational impacts of the developments.

Other material considerations.

It is of course inevitable that retail proposals,

whether they be in or outside of town centres will take existing trade away from
existing retail businesses. This is because there is a finite level of retail expenditure to
support retail floorspace across Cornwall and a driving factor behind the retail
capacity forecasts in the Cornwall Retail Study 2010 and Cornwall Retail Study
Update 2015. However, alongside this diversion from town centres there are a
number of other material considerations to be taken into account by the Council.
Those which relate to retailing and economic factors include:

Jobs.

In order for the proposed retail stores to function, they will need

employees. The ability of the proposals to generate employment opportunities
should be seen as a positive factor associated with these developments,
although we recommend that the net impact of the development on
employment opportunities is given more weight than the gross jobs figure as

October 2015 gva.co.uk

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

there is clear potential for significant displacement of job opportunities from
other existing stores.

Shortening shopping trips.

A clear benefit of proposals such as these is the

ability to shorten some comparison goods shopping trips from residents of West
Cornwall which are currently ‘leaking’ to stores and centres further afield such
as those in Truro. The shortening of these trips, as shoppers switch their shopping
visits to stores adjacent to the A30 at Hayle, can be seen as a positive benefit
as it has the potential to cut journeys by private car and which can therefore
have a consequential benefit in terms of vehicle emissions. The extent of this
benefit will be dependent on the vehicle miles which the Council calculates as
being saved.

Choice in West Cornwall. A further benefit of the scheme which should be
acknowledged is the ability of the proposals to provide modern retail space in
West Cornwall which can attract national multiple retailers to the area. Whilst a
piece of work is currently being undertaken by Bilfinger GVA to establish the
level of retailer demand for retail space in the Hayle area, and it is also
important for the Council not to place weight on the identity of particular
individual retailers when making its decision on these applications, the general
benefit of bringing more choice to West Cornwall can be seen as a positive
benefit (albeit one which will not benefit town centres in the Council’s defined
retail hierarchy).

The Rugby Club Proposal
Sequential test
8.15

When the rugby club application was previously considered by the Council’s SPC in
December 2014, there was concern over the lack of proposed controls for the retail
floorspace, which prompted deferral of the application. Since that time, the applicant
has proposed a series of controls over the retail floorspace which would allow the
development to function in a similar manner to the Cranford proposal.

As a

consequence, we consider that these controls, along with some additional controls
over the number and size of retail units, allow the Council to conclude that rugby club
proposal has the same relationship with the sequential test as the Cranford application.

October 2015 gva.co.uk

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

Impact
8.16

Similarly, the lack of controls over the rugby club application, as submitted, raised
concerns over the impact of the development on the health of nearby defined town
centres. The controls which have now been proposed, along with the additional
controls suggested in this report, allow the rugby club proposal to broadly have the
same type of effect on comparison goods shopping patterns as the Cranford proposal.

8.17

Therefore, the conclusions regarding impact on defined town centres highlighted
above (for the Cranford scheme) apply equally to the rugby club scheme, including
our guidance as to how the Council should approach reaching a conclusion on the
overall impact of this scheme.

Cumulative Impact
8.18

We have also been asked by the Council to consider the effects surrounding the
cumulative impact of approving both of the Cranford and rugby club schemes.

8.19

Our analysis has found that:

Approval of both schemes is very likely to materially increase the pressure on the
health of existing defined town centres across West Cornwall and Truro.


Due to the combined scale of these two developments, which will start to rival
existing traditional town centres in terms of size and choice of retail facilities, the
existing concerns over Penzance and Truro are reinforced and the potential for a
significant adverse impact on Camborne, Redruth and Falmouth becomes a real
possibility.


The approval of both schemes will create a retail destination in Hayle which is one
of the largest in Cornwall, being larger than most town centres in the Council’s own
retail hierarchy.


Create a retail centre which is inconsistent with the development plan for the area
and also the Council’s own retail and town centres strategy in its Local Plan
Strategic Policies document.

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Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

Appendix A:

retail impact analysis (applicable to both the Cranford and Rugby Club
proposals)

October 2015 gva.co.uk

54

CORNWALL COUNCIL
RETAIL DEVELOPMENT PROPOSALS, HAYLE

TABLE 8a: COMPARISON GOODS IMPACT OF CRANFORD PROPOSAL, 2019 (based on Cranford survey data)
(N.B. THESE IMPACTS ARE ALSO GENERALLY APPLICABLE TO THE HAYLE RUGBY CLUB PROPOSALS)
TOTAL PRE-IMPACT
TURNOVER, 2019

DIVERSION TO
COMMITMENTS

RESIDUAL TURNOVER
AFTER COMMITMENTS

IMPACT OF
COMMITMENTS

DIVERSION TO
CRANFORD PROPOSAL

RESIDUAL
TURNOVER, 2019

SOLUS
IMPACT

CUMULATIVE
IMPACT

HAYLE

£33.9

£1.9

£32.0

-5.6%

£3.3

£28.7

-10.4%

-15.4%

FALMOUTH (town centre)

£67.4

£2.1

£53.6

-3.8%

£3.0

£50.6

-5.6%

-9.1%

HELSTON

£37.1

£0.0

£37.1

0.0%

£1.1

£36.0

-3.0%

-3.0%

CAMBORNE

£55.6

£0.5

£55.1

-0.9%

£2.3

£52.7

-4.2%

-5.1%

REDRUTH

£42.4

£1.4

£41.0

-3.3%

£2.1

£39.0

-5.0%

-8.2%

TRURO (city centre)

£562.0

£91.9

£470.1

-16.4%

£16.0

£454.0

-3.4%

-19.2%

PENZANCE (town centre)

£106.7

£4.3

£102.4

-4.0%

£10.4

£92.0

-10.2%

-13.8%

CORNWALL COUNCIL
RETAIL DEVELOPMENT PROPOSALS, HAYLE

TABLE 8b: COMPARISON GOODS IMPACT OF CRANFORD PROPOSAL, 2019 (based on Cornwall Retail Study survey data)
(N.B. THESE IMPACTS ARE ALSO GENERALLY APPLICABLE TO THE HAYLE RUGBY CLUB PROPOSALS)
TOTAL PRE-IMPACT
TURNOVER, 2019

DIVERSION TO
COMMITMENTS

RESIDUAL TURNOVER
AFTER COMMITMENTS

IMPACT OF
COMMITMENTS

DIVERSION TO
CRANFORD PROPOSAL

RESIDUAL
TURNOVER, 2019

SOLUS
IMPACT

CUMULATIVE
IMPACT

HAYLE

£42.4

£1.9

£40.5

-4.5%

£3.3

£37.1

-8.2%

-12.3%

FALMOUTH (town centre)

£67.9

£2.1

£53.6

-3.8%

£3.0

£50.6

-5.6%

-9.1%

HELSTON

£35.4

£0.0

£35.4

0.0%

£1.1

£34.3

-3.1%

-3.1%

CAMBORNE

£46.4

£0.5

£45.9

-1.1%

£2.3

£43.6

-5.1%

-6.1%

REDRUTH

£30.0

£1.4

£28.6

-4.7%

£2.1

£26.5

-7.2%

-11.6%

TRURO (city centre)

£469.3

£91.9

£377.4

-19.6%

£16.0

£361.4

-4.3%

-23.0%

PENZANCE (town centre)

£105.3

£4.3

£101.0

-4.1%

£10.4

£90.6

-10.3%

-14.0%

Cornwall Council
Proposed Retail Developments, Hayle, Cornwall

Appendix B:

October 2015 gva.co.uk

cumulative impact analysis

55

CORNWALL COUNCIL
RETAIL DEVELOPMENT PROPOSALS, HAYLE

TABLE 9a: CUMULATIVE COMPARISON GOODS IMPACT OF CRANFORD AND HAYLE RFC PROPOSALS, 2019 (based on Cranford survey data)
TOTAL PRE-IMPACT
TURNOVER, 2019

DIVERSION TO
COMMITMENTS

RESIDUAL TURNOVER
AFTER COMMITMENTS

IMPACT OF
COMMITMENTS

DIVERSION TO
CRANFORD & HAYLE RFC

RESIDUAL
TURNOVER, 2019

SOLUS
IMPACT

CUMULATIVE
IMPACT

HAYLE

£33.9

£1.9

£32.0

-5.6%

£5.3

£26.7

-16.6%

-21.3%

FALMOUTH (town centre)

£67.4

£2.1

£53.6

-3.8%

£4.8

£48.8

-8.9%

-12.4%

HELSTON

£37.1

£0.0

£37.1

0.0%

£1.8

£35.4

-4.7%

-4.7%

CAMBORNE

£55.6

£0.5

£55.1

-0.9%

£3.7

£51.3

-6.8%

-7.6%

REDRUTH

£42.4

£1.4

£41.0

-3.3%

£3.3

£37.7

-8.1%

-11.1%

TRURO (city centre)

£562.0

£91.9

£470.1

-16.4%

£25.7

£444.4

-5.5%

-20.9%

PENZANCE (town centre)

£106.7

£4.3

£102.4

-4.0%

£16.7

£85.8

-16.3%

-19.6%

CORNWALL COUNCIL
RETAIL DEVELOPMENT PROPOSALS, HAYLE

TABLE 9b: CUMULATIVE COMPARISON GOODS IMPACT OF CRANFORD AND HAYLE RFC PROPOSALS, 2019 (based on Cornwall Retail Study survey data)
TOTAL PRE-IMPACT
TURNOVER, 2019

DIVERSION TO
COMMITMENTS

RESIDUAL TURNOVER
AFTER COMMITMENTS

IMPACT OF
COMMITMENTS

DIVERSION TO
CRANFORD & HAYLE RFC

RESIDUAL
TURNOVER, 2019

SOLUS
IMPACT

CUMULATIVE
IMPACT

HAYLE

£42.4

£1.9

£40.5

-4.5%

£5.3

£35.1

-13.1%

-17.0%

FALMOUTH (town centre)

£67.9

£2.1

£53.6

-3.8%

£4.8

£48.8

-8.9%

-12.4%

HELSTON

£35.4

£0.0

£35.4

0.0%

£1.8

£33.7

-5.0%

-5.0%

CAMBORNE

£46.4

£0.5

£45.9

-1.1%

£3.7

£42.2

-8.1%

-9.1%

REDRUTH

£30.0

£1.4

£28.6

-4.7%

£3.3

£25.3

-11.6%

-15.7%

TRURO (city centre)

£469.3

£91.9

£377.4

-19.6%

£25.7

£351.7

-6.8%

-25.1%

PENZANCE (town centre)

£105.3

£4.3

£101.0

-4.1%

£16.7

£84.3

-16.5%

-19.9%

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