Thursday 15 December 2011

Objections in relation to the Retail & Planning Statement


Objection to the Planning Application on the grounds that the Retail and Planning Statement submitted with the application contains statements which are untrue, misleading or quoted out of context thus ‘sexing up’ the case for Planning Consent.

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Tesco have provided a Retail and Planning document to justify the Need for, the Scale of and the Benefits that will accrue to Little Lever as a result of the proposed development.

Some of their statements require closer inspection.

Point No 1 - Does it meet the Bolton Core Strategy?

The Retail and Planning document states the following:-


“Policy P2 of the Bolton Core Strategy states that the Council will plan for additional convenience floor space of up to 10,000 m2 in town, district and local centres where local communities have good access.”


However, Paragraph 4.14 of the Core Strategy (which leads up to Policy P2) qualifies this figure of 10,000 sq metres as follows.


“The Core Strategy proposes to increase the quantity of retail floor space in the borough, concentrated mostly in Bolton town centre. This reflects the objective of creating a transformed and vibrant town centre, as well as complying with Government advice contained in PPS4. This approach is supported by the findings of the council’s Retail and Leisure Study. This identifies a requirement up to 2026, of between 9,200 and 11,000 square metres for ‘convenience’ goods and between 74,300 and 134,600 square metres for ‘comparison’ goods, in addition to schemes that already have planning permission. This additional floor space should be developed after 2016.”

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The findings of the Retail and Leisure study actually lay out the requirements for addition floorspace in periods of five years. 2011-2016, 2016-2021 and 2021-2026.


If we examine the figures in the Retail and Leisure survey we can find the Convenience Floorspace Requirement for the whole of the Borough at each of the five year points in this plan ie 2011, 2016, 2021, and 2026.

There are two sets of figures. The second set includes an allowance for overtrading at existing stores.

These are as follows:-

Without an allowance for overtrading:-




































YearNet floorspace requ’dInGross floorspace requ’d



























2011- 476 sq metres- 733 sq metres
2016- 1,256 sq metres- 1932 sq metres
2021+ 2,726 sq metres+ 4,195 sq metres
2026+ 6,510 sq metres+ 10,016 sq metres




With an allowance for overtrading:-




































YearNet floorspace requ’dInGross floorspace requ’d



























2011+ 793 sq metres+ 1,220 sq metres
2016- 24 sq metres- 37 sq metres
2021+ 3,922 sq metres+ 6,034 sq metres
2026+ 7,671 sq metres+ 11,801 sq metres




These figures take into account the Sainsbury’s development at Cricketers Way (which is now trading) and the proposed Tesco development at Central St (Back of the Old Post Office and Victoria Hall) which has outline planning permission for a 7,973 sq metre food store but has yet to be built.

They do not take into account the Tesco Longcauseway development which is shortly to open. This development contains net convenience floorspace of 2,792 sq metres.

They do not take into account the Tesco Kearsley development or any recent or proposed increases in convenience floorspace at Middlebrookor indeed the opening of the Spar store in Little Lever.
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Summary of what the above means:-


(Adding in the Longcauseway figures and allowing for overtrading)




































YearNet floorspace requ’dInGross floorspace requ’d



























2011- 1,999 sq metres







2016- 2,768 sq metres







2021+ 1,130 sq metres







2026
















This means:-

2011 - The Borough already has 1,999 sq metres of convenience retail floorspace more than it requires

2016 - The Borough will still have 2,768 sq metres of convenience retail floorspace more than it requires

Between 2016 and 2021, the Borough will require an additional 1,130 sq metres of convenience retail floorspace.

Please note that these figures do not take any account of reduction of projected turnover due to the recession.
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Conclusion to Point No 1

The Bolton Core Strategy is saying that there is no need for additional Convenience retail floorspace until after 2016.

Thereafter – between 2016 and 2021 there is a need for an extra 1,130 sq metres.

This is 598 sq metres less than the proposed 1,728 sq metres proposed for Pennine Pets.

The statement in the Retail and Planning document fails to qualify the figure of 10,000 sq metres with the time frame and the additional capacity already built (by Tesco) since the Retail and Leisure Report. It is therefore misleading.

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Point No 2

The Retail and Planning document variously states the following:-


“The evidence base behind this policy, which is the 2008 Bolton Leisure and
Retail Study, states that there is a quantitative and qualitative deficiency in convenience floor space in Little Lever which results in a low localised retention rate for convenience retailing.”


The BRLS identifies that a new store of an appropriate scale would increase the convenience expenditure retention rate from 38.4% to 60%.


At the time of the study, Aldi was reportedly looking for a site of 1,500 m2 (gross). This would equate to a net floorspace of some 1,000m².


The BRLS concluded that the development of this additional floorspace, in addition to the existing convenience offer, would increase the convenience retention rate to 60%.


This assumed the existing Tesco Metro (464m2 net) would remain.
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These various statements fail to distinguish between Zone 6 (including Asda Burnden) to which the 38.4% retention rate relates and Little Lever itself, where the retention rate is 13.52%

Zone 6 comprises those areas with a post code BL3 1 & BL3 2. as shown below




This extends from Little Lever through to Moses Gate and down to Burnden Park incorporating a big chunk of Great Lever to the left of Manchester Rd
.
The net increase of 12,674 sq metres (Pennine Pets opens, Tesco Metro shuts) is equivelant to an increase spend of £12.87million. (This assumes the optimum sales density of £10,181 per sq metre per annum as per the BRLS)

This money is not new additional money – it has to come from somewhere and can only come from the other stores where it is currently spent.

The chart below shows the major stores where the convenience spend of Zone 6 residents is located.























































































Main locations of Zone 6 Convenience expenditure% of totalValue £m















Asda Burnden24.57%£7.89m
Other stores – Little Lever13.52%£4.34m ****
Asda Farnworth9.15%£2.94m
Asda Radcliffe12.15%£3.9m
Sainsbury Trinity St8.36%£2.69m
Morrisons Blackhorse St6.63%£2.13m
Other stores Bolton5.81%£1.87m
Morrisons Mornington Rd4.74%1.52m
Tesco Horwich2.16%£0.69m
Tesco Bury3.79%£1.22m
Tesco Walkden0.95%£0.30m















Totals of above91.83%£29.49m
Balance spent elswhere8.17%2.62m


Without boring you with the calculations the new store would affect retention rates as follows.

  • If the increased spend of £12.87million was drawn solely from other major stores outside Zone 6 ( None from Asda Burnden) then the Zone 6 retention rate would increase from 38.4% to 64.65%
  • If the increased spend of £12.87 million was drawn from all the other stores in proportion to existing spends, the Zone 6 retention rate would increase from 38.4% to 54.81%
  • The retention rate for Little Lever itself would increase from 13.52% to 40.1% wherever it was drawn from.
All this is based upon the premise and assumption that the residents of Little Lever would cease to do their Weekly shop at the other stores mentioned above and instead would patronise the Pennine Pet’s store to the tune of £12.87million.

This is one hell of an assumption

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For this to happen then necessarily the Pennine Pets store would have to offer an equivelant shopping experience to the other stores.

The common feature of the major locations for expenditure shown above is that these stores offer ‘Comparison’ goods alongside ‘Convenience’ goods.

When it comes to ‘Primary shopping’ – ‘The Weekly Shop’ – The Big Shop’ or whatever you want to call it, this includes all the items a household may require – not just food.

It is a ‘no brainer’ to state that consumers have a continuing and regular need to purchase household items, clothes, small electrical household items and other non food goods.

It is the deficiency of the offer in Little Lever of these comparison items (amongst other reasons) that causes residents to travel out to the stores listed above so theycan be purchased alongside their convenience requirements in one trip.
 
The provision by Tesco of a larger ‘Food Only’ store will not alter the above need and is unlikely to result in a increased retention of spending within Little Lever as opposed to Asda Burnden or elsewhere.
Residents of Little Lever (for or against this development) are mystified as why this proposal in for a Food Store only.

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Conclusion to Point No 2
It is the lack of Comparison goods rather than the lack of Convenience goods on offer in Little Lever that is a major cause of trips out for the Weekly Shop.

With the refurbishment of the old Co-op into the Nisa brand and the refurbishment of the old Select and Save into the Premier brand (with a substantial widening of food products) as well as the opening of the Spar shop at the new petrol station alongside the Tesco Metro, Costcutter, Food and Tipple and all the smaller stores,

Little Lever needs more food like it needs another hairdressers !.

WE NEED SOMWHERE WHERE WE CAN BUY SOCKS AND KNICKERS AND SCHOOL UNIFORMS AND TOASTERS AND KETTLES etc.
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Point No 3

The retail and Planning document further states:--

“A benefit of a larger store is that it can provide an even greater retention rate that the 60% set out in the BRLS. This is confirmed in Table 4.15 of the BRLS which shows that with the exception of the three parts of the catchment area with the lowest retention rates, of which Little Lever is one, the majority of the retention rates in the other catchment areas are between 72.4% and 87.5%.”


This is completely untrue !!


There are only two Zones within the Borough which have retention rates of this order.

Zone 2 (Which covers a wide area containing Morrissons Mornington Rd, Asda Astley Bridge, and Morrissons Blackhorse St)(78.23%) and Zone 8 (Farnworth) (72.35%)

Apart from these there is only one area within the Borough with a larger retention rate than Zone 6 and that is Zone 3 (Harwood) with a figure of 42.88%

The 87.5% figure relates to Leigh and Atherton which have nothing to do with Bolton Borough.
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Conclusion to Point No 3

Again the document is trying to suggest that the retention rate in Little Lever (or rather Zone 6) could be and should be easily increased to match the better retention rates of the majority of the Zones within the Borough. This again is misleading and untrue.

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Point No 4   Clawback – Linked Trips – Impact on existing Independent food retailers.

The Retail and planning document further states:-


"By locating on an edge of centre site, the resulting clawback of trade will bring people back to the town for their primary shopping which would enhance the vitality and viability of the town-centre.”

The implication of this is that after visiting the new Tesco people will then visit and shop in other outlets in the Village Centre.

The impact of Large Foodstores on Town and District Centre is a matter of controversy and in some cases a matter of opinion.
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In September 1998, the Department for Communities and Local Government issued a report entitled Impact of Large Foodstores on Market Towns and District Centres”

This is available online at:-


The following are extracts from this document:-

  • The purpose of this study is to examine the impact of large foodstore development on market towns and district centres.
  • The responsibility for determining planning applications for large foodstore development, and developing policies to safeguard the vitality and viability of market towns and district centres, rests with local authorities.
  • We were alarmed at the number of local authorities (20%) which do not require retail impact assessments to be undertaken as a matter of course
  • The significant pressure from foodstore operators to increase their market share means that smaller centres have increasingly become the focus for new store development.
  • Our research identified impacts on market share of between 13%-50% on the principal food retailers in market towns and district centres as a result of large foodstores in edge-of-centre and out-of-centre locations.
  • These levels of impact on market share have directly and indirectly led to the closure of some town centre food retailers; increases in vacancy levels; and a general decline in the quality of the environment of the centre.
  • Our research shows that the development of large non-central foodstores can lead to a decline in the turnover of town centre foodstores (38% impact in the case of Tesco in Cirencester). This can and has led to the closure of some town centre food retailers
  • Impact is likely to be most significant for stores which are trading at marginal levels of profitability. Experience shows that foodstore retailers will review store performance, and where stores are performing below a particular turnover/ profitability threshold, these stores will be closed.
  • Even where town centre food retailers suffer an impact, but do not subsequently close, there may still be a concern that this will lead to a general decline in activity elsewhere in the centre, and adversely affect the vitality and viability of the centre.
  • …….the opening of an edge-of-centre or out-of-centre superstore is likely to lead to 'disinvestment' in the town centre (ie failure to reinvest in store refurbishments, etc). This has implications for the future viability of the individual retailer, and investment in the town centre as a whole.
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To be fair, subsequent to this report, a further study was carried out in Dec 2010 by the University of Southampton School of Geography which broadly speaking contradicted every assertion made in the 1998 report and almost sycophantically praised new supermarkets for their role in revitalizing declining centres.

This is available online at: - http://www.riben.org.uk/report/
This 2010 Southampton report was commissioned by and paid for by - (wait for it )- - -TESCO.
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Following this, a critical review of this Southampton report was published by The Oxford Institute of Retail Management. This was prepared by a Dr Thomas Hastings and is available online at :- 

 
Paragraph 4.2 of this review states the following.

“District Centre analysis.

  • A different set of issues relate to district centre case findings which risk undermining the key findings of the (Southampton) research especially those regarding positive spill—over effects of supermarket growth).
  • In particular the research suggests that Haydock and Whitefield were relatively unsuccessful in terms of generated linked trip activity – as only 16% of respondents always or frequently combined district centre and food store shopping in Haydock, compared with 63% who ‘never’ combined shopping.
  • Only 13.3% always/frequently combined shopping in Whitefield.
  • Whitefield in particular was highly unsuccessful in demonstrating the vitality benefits of supermarkets to areas such as this. Whilst 74% of residents previously ‘out-shopped’ this fell to just 68.3% after the opening of the supermarket.
  • In terms of pullpower, those from the outer catchment coming into Whitefield rose from 11.2% to just 12.9%.
· The Haydock and Whitefield cases alone are enough to raise serious question marks over the benefits of supermarkets in terms of ‘Pullpower’ and ‘Clawback’ for deprived district centres yet the summary and conclusion of the Southampton study downplay or avoid this fact.”
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Conclusion to Point No 4

1.      Apart from the above, commonsense tells us that the geographical remoteness of the shops along Market St and the Precinct area from the proposed site will not be conducive to pedestrians weighed down with their Weekly Shop to stagger across two arms of a busy junction and walk a further 200 yds to do more shopping.

Equally, for motorists, they are unlikely to pack the weekly shop into the boot on the Pennine car park and then drive up to the Centre and re-park to do more shopping.

To suggest that this would be the case would be to go against human nature, typified by the fact that many shoppers are too idle to even park on the main Tesco Metro car park and walk to the store and instead occupy the disabled and mother and child parking bays.

2. At the present time the existing Tesco Metro adjacent to the Village Centre Precinct does have the effect of linked trips to other shops in the centre.

This planning application fails to point out that these linked trips would be lost to the other businesses if the Metro closes and the overall result of the above points would be decreased footfall in the main shopping area of the Village to the detriment of the vitality and viability of the Village Centre

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Point No 5

Summary

The Application attempts to justify the need for this development both qualitative and quantitative.
In terms of ‘Qualitative need’, they have failed completely inasmuch as by their own decision they will not be offering the comparison goods which are as equally important to the ‘Big Shop’ as convenience goods and lack of which causes (amongst other reasons) trips outside the immediate area.

In terms of ‘Quantitative need’, they selectively quote from the Bolton Core Strategy and neglect to recognize or point out that the Borough is oversubscribed with Convenience floorspace until after 2016.

Their assumption that the development will draw back into Little Lever spending to the tune of £12.87million is theirs to make and their aspiration to increase retention rates to in excess of 70% is fanciful.
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In the absence of any real advantage for the residents of Little Lever and in my view the lack of commercial sense for the development, I suggest that the real reasons for this development are as follows.

1) Market Share

      Supermarkets’ primary motivation is to increase their Market Share

This is the chart from Point No 2 above.























































































Main locations of Zone 6 Convenience expenditure% of totalValue £m















Asda Burnden24.57%£7.89m
Other stores – Little Lever13.52%£4.34m ****
Asda Farnworth9.15%£2.94m
Asda Radcliffe12.15%£3.9m
Sainsbury Trinity St8.36%£2.69m
Morrisons Blackhorse St6.63%£2.13m
Other stores Bolton5.81%£1.87m
Morrisons Mornington Rd4.74%1.52m
Tesco Horwich2.16%£0.69m
Tesco Bury3.79%£1.22m
Tesco Walkden0.95%£0.30m















Totals of above91.83%£29.49m
Balance spent elswhere8.17%2.62m



This shows that Tesco retains just 6.9% of all the convenience spending of the residents of Zone 6. This compares to 30.5% across the country.

This development would increase their share of the Zone six spending to 24.11%

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2) Fear of development by a competitor

The following advert appeared in UK Land Directory eighteen months ago.

“Residential Development Land for Sale in Little Lever Bolton
Guide Price: £2,500,000
Size: 2 acres
Land Type: Residential Development
Planning Permission: Outline Planning Permission
Land Designation: Brownfield
Seller Last Active: Within the last 18 months
Summary: We have a prime piece of land for sale at the heart of Little Lever which is between Bury, Bolton and Radcliffe just outside Manchester, ideal for residential development or retails scheme such as an Adli type store.”
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The prospects of another supermarket chain aquiring and developing a store on the Pennine Pets site would no doubt send a shiver down the spine of Tesco given the threat it would pose to the existing Tesco Metro which is already undertrading.

Since supermarkets are no longer permitted to ‘Land Bank’, the only way in which Tesco could protect its interests in Little Lever would be for themselves to develop the site, irrespective of the doubtful commercial sense of such a project.

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Final Conclusion

In the battle for supermarkets’ ‘Market Share’ and protecting themselves from competition, there is no altruism.


This development isn’t about what Little Lever needs, it is about what Tesco wants and consequently I object to the Application.

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