Sites and Policies Plan Consultation Draft

Comment ID 8133281//1
Document Section Sites and Policies Plan Consultation Draft Retailing, Town, District and Local Centres DM64-69 [View all comments on this section]
Respondent Sainsbury's Supermarkets Ltd. [View all comments by this respondent]
Agent Deleted User
Response Date 19 Apr 2013

We have concerns about the requirement in Policies DM65 and WSM5 for Retail Impact Assessments (RIA) to accompany all applications for retail development in out-of-centre locations exceeding 200 sq m net.  This figure is significantly below the default threshold of 2,500 sq m set out in the NPPF at para 26.  Indeed, the proposed threshold is even below the typical size for a local convenience store (generally 250-280 sq m net).  Paragraph 21 of the NPPF states that investment in business should not be “over-burdened by the combined requirements of planning policy expectations”.  To require all retail development above 200 sq m to submit an RIA, in the absence of evidence to justify such a threshold, does place an unreasonable burden on smaller retail development which could unnecessarily act as a deterrent to sustainable economic growth.


Should the Council wish to set a local threshold for the requirement of a RIA, it is necessary to collect the evidence having regard to the size, scale and nature of centres in the area in order to set a realistic and proportionate local threshold.  This evidence is currently not available.  Accordingly, in the absence of such evidence, we recommend the default NPPF threshold of 2,500 sq m should be set.