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.