Lidl, Blackwater. Planning & Retail Statement. On behalf of Lidl UK. June gva.co.uk

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Lidl, Blackwater Planning & Retail Statement 65 Gresham Street London EC2V 7NQ T: +44 (0)20 7911 24 68 F: +44 (0)20 7911 25 60 On behalf of Lidl UK June 2016 gva.co.uk

Contents 1. Introduction... 1 2. The Site and Surroundings... 2 3. Proposed Development... 4 4. Planning Policy Framework... 6 5. Appraisal of Blackwater Town Centre... 12 6. The Sequential Test... 14 7. Other Planning Considerations... 16 8. Conclusions... 19 Prepared By: Peter Atkin Authorised by: Adam Bunn / Caroline Marginson Status: Final Date: February 2016 For and on behalf of GVA Grimley Ltd February 2016 gva.co.uk/planning

1. Introduction 1.1 Bilfinger GVA has been appointed by Lidl UK to prepare a Planning and Retail Statement in support of a planning application for the erection of a replacement Lidl foodstore at 21 London Road, Blackwater, Camberley. The proposal seeks the demolition of the existing Lidl store, and erection of a replacement larger Lidl store of 1,562 sqm net sales area. In addition, the proposal seeks alterations to access, parking and servicing, further details of which are provided in the Design & Access Statement which accompanies the application. 1.2 This Planning and Retail Statement has been prepared to assess the application against the relevant provisions of the statutory development plan and other material planning guidance, particularly the National Planning Policy Framework (NPPF). The scope and level of detail provided here is proportionate to the nature of the proposal under consideration, in accordance with National Planning Practice Guidance (PPG). Where relevant, we make reference to the Council s recently-published retail and town centres evidence base, specifically the findings of the Retail, Leisure and Town Centres Study prepared by Nathaniel Lichfield & Partners (NLP) in 2015. 1.3 The store functions as part of Blackwater district centre and emerging local policy indicates that the store operates an in-centre location in sequential terms. This means that there is no explicit policy requirement to demonstrate compliance with the sequential and impact tests set out at paragraphs 24 and 26 of the NPPF. However, for completeness, as part of our Planning & Retail Statement we have considered whether there are any alternative sites in the district centre which could accommodate the proposed development. 1.4 Our report is structured as follows: Section 2 describes the location and physical characteristics of the site and surrounding area and provides more detail on the proposed development; Section 3 highlights the proposed development, the Lidl business model and the application package; Section 4 reviews the planning policy framework and material considerations; Section 5 provides an appraisal of Blackwater District Centre; Section 6 sets out the case in respect of the sequential approach in accordance with Paragraph 24 of the NPPF; Section 7 reviews the other relevant planning considerations; and Section 8 sets out our conclusions. February 2016 gva.co.uk/planning 1

2. The Site and Surroundings 2.1 In this section we describe the location and physical characteristics of the application site and the surrounding area, and review the relevant planning application history for the site. Location 2.2 The application site is located in the centre of Blackwater, within the administrative area of Hart District Council (HDC). Blackwater is situated approximately 400m to the west of Camberley, approximately 3.5km east of Yateley and approximately 7.5km north-east of Fleet in the county of Surrey. Site Description 2.3 The site is bound by London Road (A30) (north), by residential properties on New Road (South), residential properties and business units on Vicarage Road (east) and a public car park on Green Lane (west). The application site extends to approximately 0.75 ha. The existing development on the site comprises a Lidl foodstore (net sales area 1562 sq.m) with associated car parking (including a public car park) and servicing areas. The existing store is positioned in the south-east corner of the site, with the remainder of the site used for car parking (79 spaces), servicing and perimeter landscaping. The foodstore is single storey in height. 2.4 Pedestrian and vehicular access into the site is from London Road (A30) to the north, with parking to the front of the store. The site lies within Flood Zone 1 and is therefore at low risk of flooding. Foodstores are categorised as less vulnerable uses and the proposal is therefore wholly acceptable within Flood Zone 1. environmental or heritage designations. Furthermore, the site is not subject to any 2.5 Local bus services are available along London Road directly opposite the entrance to the application site and provide connections to Reading, Aldershot, Camberley and Yateley. Blackwater rail station, which lies on the Reading to Gatwick Airport line, is also a short distance (180m) away. Surrounding Area 2.6 The existing foodstore lies directly to the south of the district centre boundary as currently defined on the HDC Proposals Map, however for reasons that we set out in full in this report, we consider the site to form part of the Blackwater district centre and accordingly function as an in-centre store. February 2016 gva.co.uk/planning 2

2.7 Blackwater is defined as a district centre in HDC s most recent planning policy documents, and provides a mix of uses either side of the A30 which bisects the centre. On the northern side of the A30 are predominantly retail uses, including an Aldi store, but also include some office space, financial and professional services, community uses, as well as limited car parking. On the southern side of the A30, the commercial offer comprises a garage, public house, some warehousing as a spill-over from the industrial estate (to the east) and a small amount of retail (including the application site) and professional services. Beyond the district centre lies low density residential estates to the north, west and south. Planning History 2.8 We have undertaken a desk-based review of planning history for the site; a summary of relevant planning applications is set out in Table 2.1. The foodstore which currently occupies the application site was granted under planning permission ref 02/00943/FUL (approved January 2002), for the Erection of a foodstore (Use Class A1) with associated car parking. Subsequent applications for store extensions were granted in 2013, but have not been implemented. 2.9 There have been a number of further minor implemented planning permissions related to the site, the majority of which are advertisement consents. Table 2.1: Relevant Planning History Reference Status Description of Development 00/00749/FUL Refused 19 th October 2000 Erection of a foodstore use class A1, with associated car parking and environmental improvements 01/00799/COU 02/00943/FUL Appeal Allowed 11 th January 2002 Granted 17 th January 2002 Change of use from former car showroom (sui generis) and petrol filling station forecourt to A1 retail with ancillary car parking Erection of a foodstore ( Use Class A1) with associated car parking 13/00012/FUL Granted 5 th March 2013 Erection of single storey front extension and cladding to fascias and soffits 13/00803/FUL Granted 20 th June 2013 Erection of single storey front extension and cladding to fascias and soffits. Source: HDC planning applications database Pre Application Consultation 2.10 On the 27 th April 2016, representatives from Lidl attended a pre application meeting with Planning Officers and Highways Officers from Hart District Council and local councillors to discuss the proposals. The proposed development has been amended to reflect comments made at this meeting. February 2016 gva.co.uk/planning 3

3. Proposed Development 3.1 The planning application seeks the demolition and redevelopment of the existing Lidl foodstore and the construction of a replacement foodstore which will continue to be operated by Lidl. The proposed replacement foodstore is to be reconfigured on a north-westsouth east axis as opposed to the existing north-west south-east orientation. The replacement foodstore will have a gross internal area of 2,563 sq. m and a net sales area of 1,562 sq. m, an increase in 554 sq. m of net sales area over the existing store. 3.2 Surface car parking will also be reconfigured to provide 104 spaces (including 6 disabled and 3 parent and child spaces) representing an increase of 25 spaces overall. Pedestrian and vehicular access, including servicing access, to the new store will remain via London Road to the north. Further details are provided in the Transport Assessment which accompanies this application. 3.3 Associated landscaping is to be incorporated along the north, east and southern boundary of the site. The Lidl Business Model 3.4 Lidl has a successful and proven retail format which is based on simplicity and maximum efficiency, offering high quality products from a limited range of exclusive own brand labels at the lowest prices. 3.5 Verdict classifies Lidl as part of the deep or hard discount sector of the convenience market. Deep discounters have a number of operational characteristics which distinguish them from the more mainstream retailers (such as Tesco, Sainsbury s, Morrisons, Asda, Co- Operative etc) and influence the way they trade, including: Relatively basic product lines with only a few recognised brands are sold in store; Limited type of convenience goods and services offered. For instance, Lidl stores do not include a fresh meat counter, fresh fish counter, delicatessen/cheese counter, hot food, pharmacy, dry cleaning services, post office services, photograph shop, mobile phone shop, or café/restaurant. Lidl also do not sell cigarettes or tobacco; and Restricted number of lines stocked in store. For instance, a standard Lidl store stocks between 1,800 core product lines with around 70 and 100 seasonal non-food special items, whereas a similar sized foodstore operated by a mainstream convenience retailer will offer between 10,000 and 15,000 lines of mainly branded goods, with larger convenience stores often offering in excess of 30,000 lines. February 2016 gva.co.uk/planning 4

3.6 Non-food (comparison) goods normally account for around 15% of floorspace in Lidl stores, most of which are concentrated on household cleaning and health and beauty products. Lidl stores receive a twice weekly delivery of what are known as non-food specials, which are sourced on a pan European scale and are thus able to achieve very competitive pricing. These items are provided on a when it s gone it s gone basis. Due to the limited and constantly changing offer, the potential for impact upon other retailers is negligible. 3.7 Due to the nature and scale of provision at Lidl stores, customers tend to purchase only part of their main grocery shop in store and visit other retailers to purchase other specialist or branded goods. Indeed, it is not unusual to find Lidl stores in close proximity to other foodstore operators, highlighting the complementary role that deep discounters play to more mainstream main food and top-up convenience shopping destinations. 3.8 Due to strict operational requirements needed to allow Lidl s full range of goods to be sold, stores are generally between 1,063 1,689 sq.m (net). As a result of the limited size and due to the nature of goods sold, Lidl stores only tend to serve residents within a five minute drive time catchment area of their stores. Supporting Documentation 3.9 The Application is supported by a suite of technical assessments and documents, which confirm that the application will not result in any adverse impacts. These documents include: Design and Access Statement; Flood Risk Assessment; Landscaping Plans; Lux Plans; Transport Assessment; Noise Impact Assessment; and Existing and proposed plans including Street Scene elevation. 3.10 These documents have all been submitted separately as part of the planning application however we provide a non-technical summary of the headline findings from these assessments in Section 7. February 2016 gva.co.uk/planning 5

4. Planning Policy Framework 4.1 In accordance with Section 38(6) of the Planning and Compulsory Purchase Act (2004), planning applications should be determined in accordance with the development plan, unless material considerations indicate otherwise. 4.2 For the purposes of this application, the development plan comprises of the following: Hart District Local Plan (Replacement) 1996-2006 and First Alterations to the Hart District Local Plan (Replacement) 1996-2006 Saved Policies (April 2009); and Policy NRM6: Thames Basin Heaths Special Protection Area of the South East Plan 4.3 The National Planning Policy Framework (NPPF) and the National Planning Policy Guidance (NPPG) are both material considerations in planning decisions. National Planning Policy Framework (NPPF) 4.4 The NPPF was formally adopted in March 2012 and replaces the suite of national Planning Policy Statements, Planning Policy Guidance notes and some Circulars with a single, streamlined document. It requires Local Planning Authorities (LPAs) to adopt a positive approach to decision-taking and to apply a presumption in favour of sustainable development. The NPPF makes clear the Government s commitment to securing economic growth in order to create jobs and prosperity and to ensure that the planning system does everything it can to support sustainable economic growth. 4.5 In terms of retail policies, the NPPF maintains the general thrust of the old Planning Policy Statement 4. It advocates a town centres first approach, and requires planning policies to positively promote competitive town centre environments and manage the growth of centres over the plan period. Paragraphs 24-27 confirm that applications for new retail floorspace on sites that are not in a town centre location and not in accordance with an up-to-date development plan must: demonstrate compliance with the sequential test ; and undertake an impact assessment if the development is over a proportionate, locally set threshold or a default threshold of 2,500 sq.m. National Planning Policy Guidance (NPPG) 4.6 On 6 March 2014 the Department for Communities and Local Government (DCLG) launched online planning policy guidance, which cancelled a number of previous planning practice guidance documents, including the Practice Guidance on Need, Impact and the Sequential February 2016 gva.co.uk/planning 6

Approach (2009). The web-based resource provides guidance on the application of the NPPF retail (sequential and impact tests) and how they should be used in decision-making. However, as we have stated above, under the terms of the NPPF there is no requirement for the application scheme to demonstrate compliance with these tests, we do not assess the NPPG in any further detail. Local Planning Policy Local Plan 4.7 HDC withdrew its emerging Local Plan: Core Strategy 2011-2029 on 30th September 2013. As a result, the saved policies of the Hart District Local Plan (Replacement) 1996-2006 and First Alterations to the Hart District Local Plan (Replacement) 1996-2006 (April 2009) remain in force and provide the broad policy framework for guiding and determining new development in the District. 4.8 In accordance with paragraph 215 of the NPPF, due weight should be given to relevant policies in the Local Plan according to their degree of consistency with the NPPF (i.e. the closer the policies in the plan to the policies in the Framework, the greater the weight that may be given). 4.9 The Borough has a well-established network of town centres and the Local Plan identifies Blackwater as one of the Rural Centres. The withdrawn Core Strategy identified Fleet as the only town centre in the District, with Blackwater defined as a district centre. Although HDC s Core Strategy has now been withdrawn, for the purposes of our report we continue to refer to Blackwater as a district centre for ease of reference. 4.10 The HDC Proposals Map illustrates land use designations across the Borough. An Extract of the Proposals Map covering the application site is provided at Figure 4.1 below which identifies that the application site is currently dissected by the existing district centre boundary, with the existing foodstore located adjacent to, but outside the defined district centre boundary. It therefore occupies an edge-of-centre location, when assessed against the HDC Proposals Map. February 2016 gva.co.uk/planning 7

Figure 4.1 Proposals Map Extract Source: HDC Proposals Map, 2009 4.11 There are two saved Local Plan policies which are of particular relevance to the development. Saved Policy URB10 (Out of Centre Retailing) states that proposals for large scale retail development (over 2,500 sq.m) outside the defined town centres, district shopping centres and local centres will not be permitted unless there is an identified need for additional shopping provision which cannot be met in the commercial centre, in which case the sequential approach to site selection will be adopted. This means that town centre sites are the first preference for the location of large-scale retail units, followed by edge of centre sites, followed by district or local centres (serving residential areas). Only as a last resort will an outof-centre site be considered. The policy continues that all sites must additionally satisfy the following criteria: i) The proposal is capable of serving the area without adversely affecting the character, vitality and viability of nearby centres, either as a result of the individual proposal or of the cumulative impact of several such proposals or developments; and ii) The proposal would not cause a local shortage of land for business, industrial, distribution or other uses; and iii) The site is easily accessible by public transport, walking and cycling. 4.12 Policy B1 (Blackwater Town Centre: Retention of Retail Uses) states that in order to safeguard the vitality and neighbourhood shopping function of the district centre, development proposals involving the loss of retail uses from the existing shopping area (fronting the northern February 2016 gva.co.uk/planning 8

side of the A30, between The White Swan Public House and the supermarket on the corner of Rosemary Lane inclusive) will not be permitted. The application site is not covered by this policy. Material Considerations 4.13 As set out above, HDC withdrew its previous Local Plan: Core Strategy in 2013 and has since been working towards the preparation of a new Local Plan. It is anticipated that the Council will undertake Regulation 18 consultation on their preferred approach to future development in the district in Summer 2016. 4.14 As part of its evidence base to inform the emerging Local Plan, HDC commissioned a Retail, Leisure and Town Centres Study prepared by Nathaniel Lichfield & Partners (NLP). The Study consists of two parts Part 1 Development Needs (February 2015) and Part 2 Town Centres (May 2015). The Retail Study Part 1 states at paragraph 4.43 that: The level of expenditure attracted to Blackwater is surprising given the relatively limited provision of convenience good stores in the centre, however the household survey results showed a high proportion of trips to the existing Aldi store, which suggests that this store in particular is trading at a level significantly above national average. 4.15 The information presented in Table 6B of the Retail Study Part 1 indicates that the Blackwater Aldi s total turnover ( 8.48m) is approximately three times greater than Lidi s ( 2.96m). 4.16 The Retail Study Part 1 provides the following recommendations (set out in Table 4.1 below) for suggested new convenience floorspace demand in HDC to be delivered in the emerging plan period i.e. up to 2032, based on ONS Population and Strategic Housing Market Assessment (SHMA) projections. February 2016 gva.co.uk/planning 9

Table 4.1: Blackwater Convenience Goods Retail Floorspace Projections Projection Additional Convenience Retail Floorspace (sq.m gross) 2014-2018 2018-2022 2022-2027 2027-2032 Total 2014-2032 ONS 3,385 185 259 249 4,078 Population SHMA Population 3,420 202 290 288 4,200 Source: NLP, Retail Leisure and Town Centres Study Part 2 Town Centres (2015) 4.17 The baseline capacity forecasts indicate that Blackwater could therefore support the proposed additional net sales area of 554 sq.m put forward in this application. 4.18 Significantly, the Retail Study Part 2 recommends at paragraph 3.44 that: The town centre boundary should be extended to include the Lidl store to the south of London Road. It is not essential to define a separate PSA [Primary Shopping Area] for Blackwater, however the area identified under Policy B1 could be redefined as a PSA. If so, this should be extended to include the Lidl store. Alternatively, this could be defined as primary shopping frontage, with the remainder of the frontages within the centre boundary defined as secondary shopping frontages. (our emphasis) 4.19 The Council s most recent evidence base study therefore makes a clear policy recommendation that the Lidl store should form part of the defined centre boundary for Blackwater. We have also undertaken informal discussions with HDC policy officers which indicate a commitment from HDC to carry forward the Retail Study s recommendations within the emerging Local Plan to extend the Blackwater district centre boundary to include the existing Lidl store which is now proposed for redevelopment. Summary of planning policy framework The National Planning Policy Framework (NPPF) sets out the Government s planning policies for England. It replaces the suite of national Planning Policy Statements, Planning Policy Guidance and some Circulars with a single, streamlined document. At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decisiontaking. The NPPF advocates a town centres first approach, and requires planning policies to positively promote competitive town centre environments and manage the growth of centres over the plan period. February 2016 gva.co.uk/planning 10

The application site lies adjacent to, but outside the defined Blackwater district centre boundary. Accordingly, for retail purposes, the application site is situated within an edgeof-centre location. However, it is clear that the store functions as part of the commercial offer of the district centre and this is reflected in the policy recommendations contained within the Council s most recent evidence base study. In accordance with the saved Local Plan policies the Council will seek to achieve sustainable development by preserving and enhancing the existing network of town centres and require a sequential approach to site selection to be adopted before out-ofcentre and/or edge-of-centre sites may be considered for new retail provision. HDC are currently preparing a new Local Plan and have commissioned a Retail Study to inform the evidence base. The Retail Study highlights that sufficient capacity exists within Blackwater to accommodate the proposed development and also recommends that the district centre boundary be extended to include the Lidl store in its entirety. Informal discussions with HDC Policy Officers have identified a commitment to carry forward the findings of the Retail Study within the emerging Local Plan. In light of the above, it is necessary to undertake a sequential test to confirm that no other sequentially preferable sites are available within the district centre to accommodate the proposed development, although the emerging policy position also represents a significant material consideration in favour of the proposed development. February 2016 gva.co.uk/planning 11

5. Appraisal of Blackwater Town Centre 5.1 Blackwater is situated to the north-east of Hart District and, as we have previously identified, is designated as a Rural Centre in the saved policies of the HDC Local Plan. HDC s abandoned Core Strategy defines Blackwater as a district centre. Blackwater is a linear centre primarily comprising existing units on the northern side of the A30 (London Road) and extending from the border with the railway lines at the eastern end of the centre to the Aldi Store to the west, as well as incorporating elements to the south of the A30 (London Road) and Green Lane. The centre lacks clear definition and is within close proximity to neighbouring Camberley, in the adjoining borough of Surrey Heath. 5.2 The centre is focused on London Road and includes: Convenience shopping including Aldi and Lidl supermarkets as well as newsagents and general store; Comparison shopping limited provision, largely focussed on day-to-day shopping needs; Services limited to hairdressers and beauty parlours; Entertainment including a pub and music venue. Diversity of Uses & Retailer Representation 5.3 Blackwater has a total of 29 retail/service units. The diversity of uses present in the centre in terms of the number of units is set out in Table 5.1 compared against the national average. Table 5.1: Blackwater Use Class Mix by Unit Type of Unit Units 2015 % of Total Number of Units Blackwater % UK Average Comparison Retail 9 31.0 36.0 Convenience Retail 4 13.8 8.1 A1 Services 5 17.2 14.1 A2 Services 2 6.9 12.1 A3/A5 6 20.7 14.7 A4 pubs/bars 2 6.9 2.9 Vacant 1 3.4 12.1 Total 29 100.0 100.0 Source: NLP, Retail, Leisure and Town Centres Study Part 2 (2015) 5.4 As identified in the Retail Study, Blackwater s mix of units shows that representation of comparison retailers is below the national average, and the proportion of convenience retailers is above. However, this is to be expected from a district centre as these typically serve fairly limited catchment areas. The lack of comparison goods retailers in the centre is February 2016 gva.co.uk/planning 12

not, therefore, an indication that the centre suffers from poor vitality and viability. The Council s Retail Study highlights that the Aldi supermarket is trading very well, significantly above the national average. 5.5 Blackwater has a good range of non-retail service uses, with all categories present apart from estate agents / valuers and travel agents. There are a number of cafes, fast food takeaways and hairdressers / beauty parlours trading in the centre. Vacancies 5.6 Table 5.1 shows that as of 2014 (the time of the survey which supported the NLP study) there was just one vacant unit in Blackwater, equating to a vacancy rate of 3.4%. This is significantly below the national average of 12.1%, highlighting a robust level of demand for units within the centre, and confirming that the centre exhibits generally positive signs of vitality and viability. Environmental Quality 5.7 The environmental quality of Blackwater is generally functional and somewhat dated in parts, with no defining features and a poor public realm. The busy main road dissects the centre, which compromises the environmental quality of the centre. Accessibility 5.8 Blackwater railway station is situated at the eastern edge of the district centre on London Road and provides regular services to Reading and Gatwick Airport. Blackwater is also served by several bus services connecting the centre with areas including Reading, Aldershot, Camberley and Yateley. 5.9 Our assessment of Blackwater has identified that: The centre can be considered to be performing generally well in respect of vitality and viability, and the diversity of uses in the centre is such that residents day to day shopping needs can readily be met. The centre has a mix of uses which is orientated towards convenience retailers and services. Representation from foodstores in the centre is particularly strong with existing foodstores helping to drive footfall throughout the centre. The comparison offer of the centre is more limited, but this is not unusual in smaller centres such as Blackwater. The overall vacancy rate is well below the national average. The environmental quality of the centre is generally functional; however the proposed development will make a positive contribution to this relative to the current position. Further details of this are provided in the Design & Access Statement which accompanies the application. February 2016 gva.co.uk/planning 13

6. The Sequential Test 6.1 In line with national and development plan policies. it is necessary to demonstrate that there are no sequentially-preferable sites which can accommodate the proposed development within Blackwater district centre. 6.2 As set out in this report, the application site is located adjacent to, but outside the boundary of Blackwater District Centre, as defined by the Council s Local Plan Proposals Map. It is therefore edge of centre when assessed against the Proposals Map. However, the store clearly functions as part of the district centre and the Council s most recent retail evidence base (NLP, 2015) agrees with this position. 6.3 Paragraph 24 of the NPPF confirms that local planning authorities should apply a sequential test to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan (our emphasis). Annex 2 to the NPPF defines main town centre uses as including retail development. Annex 2 to the NPPF also defines town centre as: Area defined on the local authority s proposals map, including the primary shopping area and areas predominantly occupied by main town centre uses within or adjacent to the primary shopping area. References to town centres apply to city centres, town centre, district centres and local centres but exclude small parades of shops of purely neighbourhood significance 6.4 Annex 2 of the NPPF defines edge of centre as: For retail purposes, a location that is well connected and up to 300 metres of the primary shopping area 6.5 It is clear from the Proposals Map extract (Figure 4.1) that the application site is adjacent to the defined district centre boundary and within 50m of the primary shopping frontage on the north side of the A30 (London Road). The application site is therefore considered to comprise an edge of centre location as defined by the NPPF. However, as our analysis has demonstrated, to all intents and purposes the site functions as part of the district centre. 6.6 Blackwater district centre is limited in size and based on our visits to the centre and examination of local policy documentation there are no sequentially preferable sites available within the centre to accommodate the proposed development as the physical space required does not exist. There is no requirement under the NPPF to consider sites which are too small and therefore not suitable for the proposed development. February 2016 gva.co.uk/planning 14

The Rationale for Development 6.7 The rationale for the proposed development will provide customers of the Blackwater store with an improved shopping experience, with enhanced circulation space, better stock availability, and additional car parking facilities. Therefore, any alternative site would need to be able to deliver the same operational benefits to Lidl as that proposed by the application scheme. A site which failed to deliver these operational benefits would not be suitable for Lidl as there would be no merit in the company relocating from its existing premises. 6.8 As we have set out in Section 3, Lidl stores draw the majority of their trade from a five-minute drive-time. The proposed scheme is location-specific, designed to improve the shopping experience for customers in what is currently a successful trading. There is an established network of Lidl foodstores in the surrounding area, including in Camberley and Crowthorne, and therefore it is not appropriate to consider opportunities in locations other than Blackwater district centre. 6.9 In considering the compliance of the application scheme with the sequential test it is also necessary to have regard to the fall back position. In the unlikely event that the Council were to refuse the application on sequential grounds, Lidl would not seek to develop a smaller store elsewhere in Blackwater district centre, given the presence of the existing store at the application site. The existing store would simply continue to trade. Identification of Sites 6.10 We are not aware of any potentially available or suitable sites which have been identified as having the potential for redevelopment, and that would be sequentially preferable to the application site. As we have set out above, the application site is in the most sequentially preferable location to accommodate the proposed development. February 2016 gva.co.uk/planning 15

7. Other Planning Considerations 7.1 The application is supported by a suite of technical assessments and documents, which confirm that the application will not result in any adverse impacts. These documents have all been submitted separately as part of the planning application however we provide a nontechnical summary of the headline findings from these assessments in this section. Design and Access 7.2 Lidl UK as an operator acknowledges that store format and design are important in terms of the wider built environment and the setting of the site in the broader context. The design therefore is sympathetic in scale and massing to existing development in the surrounding areas. 7.3 The design incorporates corporate branding in terms of format, layout, materials, finish, external environment and signage similar to other new stores. 7.4 The proposed store is positioned along the north eastern boundary of the site 90 degrees to the existing store location. The remaining parts of the site are laid out for customer car parking and a trolley enclosure. The trolleys will have the standard 1 system that is used across the country to ensure the safe return of trolleys to the enclosure. 7.5 Vehicular access into the site is via an improved junction off Green Lane made possible due to the inclusion of No 1 Green Lane within the overall site. Additional landscaping is proposed along London Road and the existing landscaping along the north east boundary will be maintained. Additional soft landscaping will be provided between the car parking and rear boundaries to No s 5 to 13 Green Lane 7.6 The car parking spaces provided are located to the south west of the proposed store. The layout has been arranged to make it safe and easy for customers to manoeuvre around the car park when looking for somewhere to park. A total of 104 car parking spaces are provided including 6 disabled spaces and 3 parent and child spaces located close to the main customer entrance to the store for ease and convenience. 7.7 The service area is located along the south eastern side of the building and carefully positioned to facilitate the manoeuvring of the delivery vehicle into the ramped area in front of the delivery doors. Tracking drawings have been prepared which confirm that delivery vehicles can service the store during trading hours with no impact on the car parking provision. February 2016 gva.co.uk/planning 16

Flood Risk Assessment 7.8 The site is located within Flood Zone 1 and is at low risk of surface water flooding. The Flood Risk Assessment has demonstrated that the proposed scheme will not create an unacceptable risk elsewhere, and confirms the suitability of the site for the proposed development. 7.9 As the proposed development will lead to an increase in impermeable area, Sustainable Drainage Methods are proposed to ensure that surface water is managed effectively. Surface water discharge from the proposed development will be limited to that from the existing site and attenuation storage will be provided to store run off from 100 yr storm events. Transport Assessment 7.10 The site is located close to public transport (bus and rail). In order to further improve accessibility and permeability, pedestrian and cycle links are proposed to connect the store with the surrounding area, including the A30 London Road. 7.11 The access proposals have been tested using AutoTRACK plots. This demonstrates that adequate geometry and mobility can be provided. The design of the internal layout will comply with standards set out by Hampshire County Council. 7.12 The site is also considered to be conveniently located for local residents to walk to and from the site. It is likely that a site travel plan will be secured by condition. It is considered that subject to planning conditions and for legal agreement, the transport assessment has demonstrated that there are no technical, operational or road safety reasons to preclude planning consent being granted. Sustainability 7.13 Lidl Food Stores have an environmental policy that represents a conscious effort to reduce carbon emissions through responsible and considerate operating procedures which include, but are not limited to: For energy conservation reasons, Lidl s chosen store heating systems are highly efficient condensing boilers which recover waste heat from the combustion process. All heating is regulated by sensors; Lidl aim for checkout areas to be heated to 21 C, sales area to 19 C, and welfare to 21 C and the storage area to 13 C.The average gas consumption is approximately 100,000 kwh per annum. The lighting in the storage and welfare areas is controlled by movement sensors, which means that lights are not left on unnecessarily. The sales area uses full lighting during February 2016 gva.co.uk/planning 17

trading hours and cuts back to one third lighting before and after trading hours to allow for the stocking of the store. Electricity consumption is approximately 150,000 kwh per annum. Water consumption is carefully monitored and on average is limited to 13 cubic metres per month, and therefore approximately 156 cubic metres per year. A Building Management System and LUX sensors control the external lighting. This means that lights are only on during hours of darkness and ensures that lights do not remain on later than 1 hour after the store closes. Noise Impact Assessment 7.14 The supporting Noise Impact Assessment has assessed activities associated with the development including plant and deliveries associated with the food store on nearby sensitive receptors. 7.15 The impact of the plant associated with the store has been assessed to British Standard 4142:2014. The plant rating sound level will result in a British Standard 4142:2014 assessment difference of 0 db at the most sensitive receivers and as such is estimated to be of a low impact and once all pertinent factors (i.e. context) are taken into account this impact does not change. 7.16 The impact of the unloading activities has been assessed to British Standard 4142:2014. The delivery rating noise level will result in a British Standard 4142:2014 assessment difference of -6 db at the most sensitive receivers and as such is estimated to be of a low impact and once all pertinent factors (i.e. context) are taken into account this impact does not change. 7.17 The impact of the arrival and departure has been assessed based on the change in noise level scale from the IOA/IEMA Working Party Consultation Draft (2002) which categorises the significant of a change in noise level. Based on this scale and the noise modelling the change in noise levels is expected to be a no adverse impact which would be imperceptible. February 2016 gva.co.uk/planning 18

8. Conclusions 8.1 The focus of this Planning and Retail Statement has been to consider the key policy issues raised by the proposal for the demolition and redevelopment of the existing Lidl foodstore and the construction of a replacement foodstore at London Road, Blackwater. The current store is dated, inefficient and failure to invest in the portfolio will result in Lidl falling behind its competitors. The proposed scheme is part of a nationwide programme 8.2 The planning application seeks the demolition and redevelopment of the existing Lidl foodstore and the construction of a replacement foodstore which will continue to be operated by Lidl. The proposed development foodstore will have a gross internal area of 2563 sq. m and a net sales area of 1,562 sq. m, an increase in 554 sq. m over the existing store. 8.3 The proposed replacement foodstore is to be reconfigured on a north west- south east axis as opposed to the existing north-west south-east orientation. Surface car parking will also be reconfigured to provide 104 spaces (including 6 disabled and 3 parent and child spaces) representing an increase of 25 spaces overall. Pedestrian and vehicular access, including servicing access, to the new store will remain via London Road to the north. Associated landscaping is to be incorporated along the north, east and southern boundary of the site. 8.4 This Planning and Retail Statement has been prepared to assess the application against the relevant provisions of the statutory Development Plan and other material planning guidance, particularly the National Planning Policy Framework (NPPF). The scope and level of detail provided here is proportionate to the nature of the proposal under consideration, in accordance with online National Planning Practice Guidance (PPG). Compliance with Policy and Material Considerations 8.5 The NPPF advocates a town centres first approach, and requires planning policies to positively promote competitive town centre environments and manage the growth of centres over the plan period. As the application site lies adjacent to the defined district centre of Blackwater it is necessary to demonstrate that there are no sequentially preferable sites within the district centre which could accommodate the proposed development. We are not aware of suitable sites within the district centre that could accommodate the proposed development, and it is not appropriate to consider sites in alternative centres. 8.6 Moreover, as established above the Council intend to extend the boundary of the district centre to include the entire application site within the emerging Local Plan, reflecting the fact that the Lidl store clearly functions as part of the district centre. The store plays an important role in contributing to the vitality and viability of the wider district centre, and the proposed February 2016 gva.co.uk/planning 19

development represents a positive investment in the centre by a leading national retailer which will further support the vitality and viability of the centre in the long term. 8.7 Accordingly, in light of the above, it is considered that the proposed development complies with the provisions of the NPPF. Principle of Development 8.8 The site is currently occupied by an existing foodstore, therefore the principle of development has been established. The site is located edge of centre when assessed against the proposals map, however, it is clear that the site functions as part of the district centre and the Council s most recent retail evidence base (NLP, 2015) agrees with this position. There are no sequentially preferable sites available within the centre to accommodate the proposed development as the physical space required does not exist. Conclusion 8.9 This Planning and Retail Statement has demonstrated that the proposed scheme is entirely acceptable when assessed against national planning policy and the Development Plan. The proposals will deliver significant private sector investment into the Blackwater area, and will contribute to and strengthen the vitality and viability of Blackwater district centre. proposals should therefore be viewed favourably and granted planning permission. The February 2016 gva.co.uk/planning 20