CPO 2004 Enquiry - Documents Submitted by Bath & North East Somerset Council

 Proof of Evidence of John Adams on behalf of Bath and North East Somerset Council

1. Qualifications and Experience

1.1 John Adams will say: I am a Partner of Drivers Jonas, a Member of the Royal Institution of Chartered Surveyors and have a BSc (Hons) in Land Management from the University of Reading.

1.2 I joined Drivers Jonas in 1985 and have specialised in providing planning consultancy advice to landowners, investors, corporate occupiers and local authorities in respect of major commercial and residential development.

1.3 I moved from London to open the Manchester office of Drivers Jonas in 1993, and I am one of the Partners responsible for leading the firms planning and development consultancy across the UK. The Manchester office is now 60 strong, and the planning team has 21 planners and chartered surveyors.

1.4 In particular I am involved with major city centre and retail and leisure based development throughout the UK.

1.5 I have advised on major retail and mixed use developments, which have either secured planning permission or resolutions to grant planning permission in the historic city centres of Bath (Southgate), Cambridge (The Grand Arcade), and Chester (Northgate).

1.6 I have also been involved in regional scale developments in the metropolitan city centres of Birmingham (Martineau Galleries), Leeds (Trinity Quarter), Manchester (Spinningfields, and many others) and Liverpool (Paradise Street Development Area).

1.7 These assignments have involved assessing the long term economic needs of the city centres, and advising on the challenges of accommodating retail, leisure, new public transport interchanges and other city centre uses in historic centres.

1.8  A common thread of this work has been the economic assessment of the need for, and implications of, retail, leisure and other city centre uses, urban design, public realm and architectural quality, environmental assessment, and the relationship with planning policy, in particular regional and local planning potices. Often compulsory purchase orders have been required to provide a basis for comprehensive and co-ordinated redevelopment in accordance with a vision and masterplan for a wide area of a city centre.

1.9  I first advised on the redevelopment of the Southgate area during the preparation of the Adopted Local Plan. The Southgate Centre was at that time owned by the Prudential, and discussions with the then City Council identified the need for a comprehensive redevelopment of the Southgate area, primarily for retail uses.

1.10  I was then instructed by General Accident (now CGNU and Morley Fund Management its wholly owned subsidiary and property fund manager) to advise on proposals for the redevelopment of the Southgate area in 1996.  Since then I have been involved in the testing of options for the site, the preparation of a brief and the submission of an application for planning permission. I was responsible for the preparation of the Environmental Statement, which accompanied the application, and the Economic Assessment, which included an assessment of the retail capacity and economic impact of the proposals. I advised CGNU on negotiations with the Council and the evolution of the scheme to the proposals that secured planning permission in 2003.

2. Scope of Evidence

2.1 My evidence to the lnquiry is concerned with the quantitative need, in retail planning terms, for the development that will be facilitated by the Order.

2.2 In my capacity as adviser first to the Prudential and then to CGNU one of my responsibilities has been assessing and monitoring the retail capacity for new retail development in Bath City Centre. Drivers Jonas undertook its own retail assessment as part of the application for planning permission in 1997. This was updated at various points during the consideration of the application.

2.3 In my evidence I have adopted the definitions and abbreviations set out in the Glossary of Key Terms submitted as CD 10.9.

2.4 In 2000 Bath and North East Somerset Council (The Council) commissioned Nathaniel Lichfield and Partners (NLP) to undertake a retail assessment on behalf of the Local Planning Authority. The City and Town Centres Study informed the Council's decision to grant planning permission. Because the NLP 2000 work was based on a household and street survey and was more up to date than the original Drivers Jonas work, we adopted its main findings and key assumptions.

2.5 1 have been asked to give evidence on retail capacity to this Inquiry because I have personally been involved in advising on this issue for over 10 years and have been responsible for assessing the turnover and trading characteristics of the Scheme as it has evolved through the local plan and planning application processes.

2.6 During this time I have also discussed these issues with Dr Raggett of CBRE (previously CB Hillier Parker) and have been able to draw on work and advice that he has given on the health of the City Centre and the likely implications of the redevelopment of the Southgate area.

2.7 The health of the City Centre and the qualitative need for the proposals are addressed in Dr Raggett's evidence.

2.8 Mr Guy sets out the retail planning policy context (national, regional and local) that supports the redevelopment of the Southgate area in his evidence.

2.9 My evidence is set out under the following Chapter headings:

• Assessment of Retail Capacity;
• Response to Objectors; and
• Conclusions.

2.10 My evidence demonstrates that there is a pressing need for the redevelopment of the Order Land supported by existing and future retail spending power of residents within Bath's catchment area.

2.11 This need has been identified in the Adopted Local Plan and the emerging Draft Replacement Local Plan Review, both of which support the allocation of the Order Land for major retail development and has been a material consideration in the grant of the Main Scheme Planning Consents.

3. Assessment of Retail Capacity

3.1 The need for additional comparison retail floorspace in the City Centre, and the role of Southgate in meeting that need, has been recognised since 1989 when the Council commissioned the "Bath Shopping Needs Study" which was undertaken by Nathaniel Lichfield & Partners. The study concluded that there could be an additional 6,317 sq m (68,000 sq. ft) net floor space provided by 1996 and 14,771 sq m (159,000 sq. ft) by 2001. This recommendation was incorporated into Policy R2 of the Adopted Local Plan. It also underpinned policy R3 of the Local Plan, which allocated Southgate for comprehensive redevelopment, primarily for shopping.

3.2 In making this allocation for additional comparison shopping, the special characteristics of Bath were recognised at paragraph 7.08 of the Adopted Local Plan:

"These limitations are designed to allow a growth of retail floorspace in Bath to ensure that the City continues to meet the needs of local shoppers. Bath is considered to be a special case in so far as an over-provision of shopping floorspace could impair the viability of existing shops which provide the means of economic support for many of the City's listed buildings and the potential consequential demand for extra road space and car parking cannot be appropriately met within an historic city centre.  These retail floor space requirements are intended to maintain the position of Bath in the shopping hierarchy, and are an indication of potential retail floorspace requirements and not an absolute figure. In view of the dynamic nature of retailing activity and the economic climate, the City council will continue to monitor these figures."

3.3 The retail requirement first identified in 1989 remains unmet. Since then there has been sustained national growth in retail expenditure particularly in comparison goods but very limited redevelopment in Bath City Centre. Outside the City Centre development has also been limited, in accordance with Adopted Local Plan policies, to food shopping facilities and retail warehousing primarily selling household goods.

3.4 The application for planning permission for the redevelopment of Southgate, submitted in 1997, fell within the recommended additional comparison retail floorspace in Policy R3.

3.5 Drivers Jonas prepared an Economic Assessment that accompanied the application. The retail analysis demonstrated that there was substantial capacity for additional comparison retail floorspace in the City Centre, and that the estimated increase in turnover attributable to the 1997 proposals for the Southgate area would fall well within the identified capacity. I have not included this and earlier Drivers Jonas assessments as they have been superseded by more recent NLP studies undertaken on behalf of the Council. My instructions from CGNU have included reviewing the studies by NLP and where possible I have adopted their work.

2000 Assessment

3.6 Bath and North East Somerset Council commissioned Nathaniel Lichfield & Partners in 2000 (CD 10.4) to prepare an assessment of the four main retail centres within the authority area, namely Bath, Keynsham, Midsomer Norton and Radstock. The study involved four main stages of work as follows:

• Stage 1 - Data collection including household and street interviews
• Stage 2 - Retail capacity assessment and centre health checks
• Stage 3 - Identification of potential development options
• Stage 4 - Strategy formulation

3.7 The main study objectives were to:

• Establish the comparison and convenience retail floorspace requirements up to 2011 for the city and town centres;
• Assess the vitality and viability of these centres based on the measures listed in PPG6;
• Identify the capacity of each centre to accommodate retail growth and to undertake an examination of the impact that potential growth may have on the centres in terms of vitality and viability, environmental policy and traffic generation;
• Consider locations for future retail floorspace provision on a sequential basis; and
• Determine if the viability and vitality of each centre can be increased.

3.8 The report, dated July 2000 (CD 10.4), also provided an up to date assessment of retail capacity against which the planning application for the redevelopment of the Southgate area would be formally assessed as it was reported to Committee between 2000 and 2003, and finally granted planning permission in 2003.

3.9 Drivers Jonas submitted an Economic Assessment as part of the Environmental Statement accompanying the Southgate application. The Economic Assessment was updated between 1997 and 2001 and the 2001 update drew upon the retail capacity assessment contained within the City and Town Centres Study (July 2000). The 2000 study was therefore the basis for the Council's conclusion that the redevelopment of the Southgate area was needed to meet retail capacity within the Bath catchment area. It is also the quantitative basis for ensuring that there will be adequate expenditure to support the City Centre as it adjusts to the major redevelopment of the Southgate area, with the inevitable movement of retailers within the City Centre and changes in pedestrian flow that will result.

3.10 In this section, I highlight the key findings of the retail capacity assessment undertaken by Nathaniel Lichfield & Partners in 2000.

3.11 I also refer to the City & Town Centres Study undertaken by Nathaniel Lichfield in 2004, published in October 2004, which re-affirms the quantitative need for the redevelopment of the Southgate area.

Study Area

3.12 The study area used in the assessment is based on a 30 minute drive time from Bath City Centre, although it extends slightly further to the east to include parts of western Wiltshire, and excludes parts of Bristol that are within 30 minutes drive time. A plan is included at Appendix A of Core Document 10.4. The surveys conducted by Research & Marketing during the study indicate that there are a number of different customer groups who shop in the town centres within Bath & North East Somerset (B&NES), as shown in Table 1 below.

Table 1: Customer Groups in B&NES

Customer Type	Survey Comments
Residents Within B&NES	Most visitors to the four centres live in B&NES i.e. Bath 62%, Keynsham 66% Midsomer Norton 78% and Radstock 82%.
Residents in Neighbouring Authorities	Most other visitors (with the exception of Bath) live in neighbouring authority areas, e.g. West and North Wiltshire, Mendip and Bristol.
Those who work in B&NES	Between 8% and 10% of visitors to the three smaller centres work within the towns. 18% of visitors work in Bath.
Domestic Visitors from the UK	Bath attracts tourist and shopping visitors from across the UK.  Approximately 20% of visitors came from outside the study area
International Visitors	Bath is on the main tourist route for international visitors. The Council's 1999 visitor survey indicated that 31% of tourists were from overseas.

Source: Research & Marketing Visitor Surveys 2000 and B&NES Visitor Survey 1999

Source: Bath  & NE Somerset City & Town Centre Study, Final Report July 2000

Socio-Economic Characteristics Within B&NES

3.13 The socio-economic characteristics of the study area are compared with the national average in Table 2 below.

Table 2: Socio-Economic Characteristics in the Study Area

Characteristic	% Households B&NES Study Area	GB Average
Car Ownership
Two or more	36%	23%
One	49%	44%
None	15%	33%
Occupation Chief Wage Earner
AB	23%	18%
C1	29%	24%
C2	29%	28%
DE	18%	29%
Unemployment*	2.2%	4.1%

Source Bath & NE Somerset Clty & Town Centre Study, Final Report July 2000

3.14 The study area has a higher proportion of households within the most affluent socio-economic group (i.e. classes A, B and C1 including professional, managerial and white collar workers) than the national average.

3.15 Local expenditure estimates for the study area obtained from Maplnfo also suggest that consumer expenditure per capita is above the national average by 3% for comparison goods and by 2% for convenience goods.  There are variations within the study area, particularly for comparison expenditure.

Existing Shopping Patterns

3.16 The street survey demonstrates that residents visit a range of shopping areas within and outside B&NES, as shown in Table 3:

Table 3: Other Non-Food Shopping Destinations

Centres % of Visitors in Each Centre

Centres		% of Visitors in Each Centre
	Bath	Keynsham	Midsomer Norton	Radstock
Bath	N/A	36%	58%	68%
Keynsham	5%	N/A	5%	2%
Radstock	2%	1%	11%	N/A
Bristol	27%	55%	16%	17%
Cribbs Causeway	14%	10%	2%	2%
Chippenham	9%	1%	*	1%
Trowbridge	9%	*	8%	9%
Swindon	6%	*	*	2%
Longwell Green	4%	13%	*	*
Kingswood	2%	17%	*	*
Wells	*	*	9%	10%

Source: Bath & NE Somerset City &Town Centre Study, Final Report July 2000

3.17 Bristol and Cribbs Causeway attract customers from across the Council's area, but Bath is the main comparison shopping destination for Midsomer Norton and Radstock.

3.18 Respondents were asked where they normally go to shop for different types of non-food goods. The main shopping destinations for each type of nonfood goods are shown in Tables 4-8 below.

Table 4: Clothing and Footwear Shopping Destinations

Destinations	% Study Area
Bath City Centre	50%
Other B&NES Centres/Stores	4%
Bristol City Centre	16%
Trowbridge	10%
Chippenham	5%
Cribbs Causeway	3%
Swindon	2%
Other	10%

Source: Bath & NE Somerset City & Town Centre Study. Final Report July 2000

Table 5: CDs, Tapes, Videos, Books & Stationery Destinations

Destinations	%Study Area
Bath City Centre	40%
Other B&NES Centres/Stores	4%
Bristol City Centre	12%
Trowbridge	10%
Chippenham	5%
Others/Don’t Do	29%

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

Table 6:Electrical Shopping Destinations

Destinations	%Study Area
Bath City Centre	28%
Other B&NES Centres/Stores	6%
Trowbridge	16%
Bristol City Centre	9%
Chippenham	8%
Longwell Green	6%
Cribbs Causeway	5%
Brilington	5%
Others/Don't Do	17%

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

Table 7: Furniture and Carpets Shopping Destinations

Destinations	%Study Area
Bath City Centre	16%
Other B&NES Centres/Stores	6%
Trowbridge	12%
Bristol City Centre	10%
Cribbs Causeway	6%
Other Bristol	5%
Melksham	4%
Chippenham,	4%
Brislington	4%
Longwell Green	3%
Others/Don't Do	30%

Source Bath & NE Somerset City & Town Centre Study, Final Report July 2000

Table 8: DIY Shopping Destinations

Destinations	%Study Area
Homebase Bath	17%
Great Mills Paulton	4%
other B&NES Centres/Stores	8%
Trowbridge	17%
Chippenham	10%
Longwell Green	10%
Brislington	7%
Bristol City Centre	4%
Others/Don’t Do	23%

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

3.19 Bath City Centre was the main destination for all categories of non-food shopping with the exception of DIY goods.

3.20 The City Centre attracts a particularly high share for clothing and footwear (50%), compared with only 16O/0 for furniture and carpets. Bristol City Centre, Trowbridge and Cribbs Causeway were the main shopping destinations outside B&NES for most types of shopping.

3.21 Many visitors in Keynsham go to Bristol (including Cribbs Causeway) for non food shopping (43%) compared with 23% going to Bath.

3.22 In Bath over 40% of respondents regularly shop in Bristol and Cribbs Causeway.

3.23 In light of the scale, quality and range of shopping facilities available in Bristol and Cribbs Causeway, this outflow of comparison shopping trips is likely to continue in the future, regardless of the provision of new comparison shopping facilities in Bath. Nevertheless, the redevelopment of the Order Land will claw back some of this lost expenditure to the City Centre.

Methodology

3.24 In order to assess the capacity for new retail floorspace, Nathaniel Lichfield & Partners use the survey to estimate the market share of shops in each of the four B&NES centres within the study area. The assessment of market shares was based on a range of factors, including:

• Information from the household and visitor surveys;
• Information from the 1999 Bath tourist and visitor survey;
• The level and quality of retail facilities within competing centres; and
• The relative distance between shopping centres and study area zones.

3.25 Turnover estimates derived from the survey are then compared with company average turnover to sales floorspace densities in order to identify potential capacity for new retail floorspace. This is one of the accepted approaches for estimating capacity. I have looked at the figures from a number of points of view, testing various assumptions, and I am satisfied that there is ample capacity to support the proposed redevelopment of Southgate.

Expenditure Growth

3.26 Expenditure growth was projected at 4.06% per annum over the study period to 2011.

3.27 The population within the study area is estimated to increase from 401,272 in 1996 to 430,237 in 2011.

3.28 Total comparison goods spending was forecast to increase from £791 m in 2000 to £ 1,286m in 2011. These figures relate to real growth and exclude inflation. They are expressed in 1996 prices.

3.29 An allowance was made for expenditure inflows based upon the results of the town centre surveys.

Comparison Trading Levels in 2000

3.30 The level of comparison expenditure available to shops in the study area in 2000 was estimated to be £734m (including an allowance for outflows of expenditure to surrounding centres and inflows from residents from outside the Catchment Area and Tourist visitors). The benchmark turnover of comparison shops within the study area was estimated to be £710m. These figures suggest that comparison shops within the study area are on average trading around the assumed benchmark turnover level.

Table 9: Cornparison Trading Levels in 2000

Centre	Available Expenditure	Benchmark Turnover	Difference
Bath	£376.36m	£354.26m	+£22.1m
Keynsham	£17.02m	£15.07m	+£1.95m
Midsomer Norton/Radstock	£28.55m	£27.09m	+£1.46m
Other shops in study area	£311.85m	£314.01m	+£2.16m
Total	£733.78m	£710.44m	+£23.35m

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

3.31 The outflow of expenditure from the study area to competing centres such as Bristol, Cribbs Causeway and Swindon was estimated to be £192m.  This outflow is higher than the estimated level of expenditure inflow into the study area of £135m. This suggests there is a net outflow of comparison expenditure of £57m. However, over half of the expenditure outflow is leakage from the east Bristol part of the study area (zones 11 and 12). I would expect Bristol to exert a strong influence over this part of the study area.

Comparison Spending and Turnover in 2006 and 2011

3.32 The level of expenditure available to comparison shops in the study area is expected to increase by £495m between 2000 and 2011. The level of available comparison expenditure growth available to shops in B&NES at 2006 and 2011 is shown below

Table 10: Comparison Expenditure Growth Available to Shops in B&NES

Centre	Additional Comparison Expenditure
	2000 to 2006	2000 to 2011
Bath	£112.5m	£232.2m
Keynsham	£4.92m	£10.15m
Midsomer Norton/Radstock	£8.7m	£17.95m
Total	£126.12m	£260.3m

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

Source: Tables 11 to 14 Appendix C

3.33 The table assumes the market share of the City Centre remains constant.

Quantitative Capacity for Comparison Floorspace

3.34 The total level of actual available comparison goods expenditure for shops in B&NES in 2006 and 2011 is summarised in the table below. The benchmark turnover of existing comparison shops in B&NES has been subtracted from the estimates of available expenditure, which provides surplus expenditure estimates.

Table 11: Surplus Comparison Expenditure in B&NES

	Additional Comparison Expenditure £M
	2006	2011
Total Available Expenditure	£                548.05	£                682.23
Benchmark Turnover of Existing Shops	£                420.82*	£                442.28*
Surplus Expenditure
Bath	£                112.80	£                213.32
Keynsham	£                    5.94	£                  10.36
Norton Radstock	£                    8.49	£                  16.28

*Benchmark turnovers are allowed to grow at 1% per annum

Source: Bath & NE Somerset City & Town Centre Study. Final Report July 2000

Surplus Expenditure in Bath City Centre

3.35 Surplus expenditure in Bath is estimated to be £113m in 2006 increasing to £213m in 2011. The table below assumes that the benchmark turnover of existing shops will increase in real terms in the future. A growth rate of 1% per annum has been assumed from a position in 2003 of £4,945 per sq m.

3.36 National trends indicate that comparison retailers will achieve some growth in trading efficiency.

Table 12: Additional Comparison Floorspace Projections

Type/Location	Surplus Comparison Expenditure £M
	2006	2011
High street shops in Bath	£89.46m	£170.65m
High street shops in Keynsham	£4.71m	£8.29m
High street shops in Norton Radstock	£6.73m	£13.02m
Bulky goods retail warehouses	£25.22m	£47.99m
Total	£126.12m	£239.95m
Type/Location	Turnover Density £ per sq m net
	2006	2011
High street shops in Bath	£5,095.00	£5,355.00
High street shops in Keynsham	£3,715.00	£3,905.00
High street shops in Norton Radstock	£3,715.00	£3,905.00
Bulky goods retail warehouses	£2,123.00	£2,231.00
Type/Location	Sales Floorspace Projection sq m net
	2006	2011
High street shops in Bath	17,711	31,867
High street shops in Keynsham	1,278	2,123
High street shops in Norton Radstock	1,828	3,334
Bulky goods retail warehouses	11,988	21,511

Source: Bath & NE Somerset City & Town Centre Study, Final Report July 2000

3.37 This shows capacity for around 17,711 sq m net of new floorspace in Bath City Centre in 2006, rising to 31,867 sq m net by 2011.

3.38 The most recent advice from Experian is to allow for existing comparison floorspace to increase its efficiency at an average of 2-2.5% per annum, depending on local circumstances.

3.39 As a cross check, I have rerun the capacity calculation allowing for existing floorspace in Bath to increase its efficiency at 2.5% from 2003 to both 2006 and 2011. On this basis, the capacity would be as follows:

Table 13: Comparison Floorspace Projection - 2.5% Floorspace Efficiency

Type/Location	Turnover Density £ per sq m net
	2006	2011
High street shops in Bath	£5,325.00	£6,025.00
High street shops in Keynsham	£3,883.00	£4,394.00
High street shops in Norton Radstock	£3,883.00	£4,394.00
Bulky goods retail warehouses	£2,219.00	£2,551.00
Type/Location	Sales Floorspace Projection sq m net
	2006	2011
High street shops in Bath	16,799	28,324
High street shops in Keynsham	1,213	1,887
High street shops in Norton Radstock	1,733	2,963
Bulky goods retail warehouses	11,363	19,111

3.40 There would still be ample capacity available to support the increase in net retail floorspace that the Scheme will provide.

3.41 Neither of these assessments of capacity allows for the City Centre to increase its market share across the catchment area to reduce leakage to other centres.

3.42 The Scheme will have a total retail floorspace of 37,567 sq m gross.

3.43 It will be fully open by 2010. Its first full year of trading will be 2010 - 2011, although earlier phases will have been trading since 2008. A test year of 2011 is therefore appropriate.

3.44 The Scheme will provide:

• A modern full range department store
• A full range flagship Boots store
• A modern city centre Foodstore
• Other Medium Sized Units suitable for modern high street occupiers.
• Unit shops of between 128 - 1564 sq m
• A range of boutique style unit shops to accommodate new up-market fashion retailers adjacent to the department store.

3.45 The Scheme will provide an addition in comparison sales area of up to 14,000 sqm net.

3.46 Drivers Jonas has estimated that the Scheme will have a total turnover of about £150m. This estimate is based upon Drivers Jonas's assessment of the likely tenant mix and the turnover levels expected to be achieved based on the actual trading performance of comparable stores. It equates to a turnover to sales ratio about 20% above the average for the city centre.

3.47 This represents a net addition of turnover in comparison goods (over and above the existing Southgate Centre) of about £90m.

3.48 This figure is consistent with the NLP report (Para 3.26 of Part V of CD7.1).

3.49 The table below compares the estimated capacity in Bath City Centre in 2011 (from the NLP Study 2000) with the proposed Southgate area in terms of additional floorspace and turnover.

Table 14: Capacity for Comparison floorspace in Bath City Centre in 2011 Compared with Southgate

	£m	Net Sales Area (Sqm)
Capactity in Bath City Centre in 2011	£170.65	31,867
Southgate Net Additional Comparison Turnover and Sales Area	£92.40	14,000

3.50 This demonstrates that the additional floorspace to be developed at Southgate will be well within the estimates of capacity for additional comparison retail floorspace in Bath City Centre in 2011.

Maximising the Potential of Southgate

3.51 In respect of the Southgate area, Nathaniel Lichfield & Partners conclude that it is important that the scheme maximises retail content within Southgate including some convenience shopping.

3.52 The Scheme has maximised retail content with trading on ground and first floors, and a three level department store. It also incorporates a replacement foodstore.

The Implications of "No" Southgate

3.53 The implications of the Scheme not happening are considered at paragraph 12.27 of the NLP report:

"If the Southgate redevelopment cannot be secured in the medium term, then there is a danger that Bath's position within the regional shopping hierarchy will decline, particularly following the Broadmead development in Bristol This decline may result in an increase in the level of expenditure outflow from BANES to competing centres, and a reduction in the size of Bath catchment area It may be appropriate to consider other options if the Southgate redevelopment is delayed for a considerable period Other city centre expansion opportunities and/or the redevelopment of non-bulky comparison retail facilities at Western Riverside should be explored However, we believe that the council's efforts should focus on securing the redevelopment of the Southgate centre as soon as possible. "

3.54 These views were echoed by the City Centre Management And Economic Development section of the Council in September 2000 in their comments that were included in the Committee Report on the Southgate application:

"The redevelopment of the Southgate area is a crucially important opportunity for Bath retail offer and regional competitiveness. It provides the only opportunity for significant growth in the city's retail floor area, including the provision of much needed modern large shop units. It also provides an opportunity for a desperately needed new, and good department store in the city centre. "

City and Town Centres Study, October 2004

3.55 The 2004 Study (CD10.5) is consistent with the 2000 Study in identifying a pressing need in quantitative retail terms for additional retail floorspace in Bath City Centre. At paragraph 15.10, it states that:

"Bath City Centre provides a good range and choice of comparison shopping facilities. The city centre benefits from its historic environment and pedestrianised streets. However, the lack of available large modern shop units and the absence of a major department store are clear weaknesses when compared with competing centres and - there is a general shortage of available shop units. The planned Southgate Centre redevelopment is expected to provide a range of modern units better suited to new occupiers. "

3.56 The 2004 Study allows for Southgate as a commitment. It identifies retail capacity over and above Southgate for new retail floorspace by 2011. How this additional retail capacity is met is a matter being debated at the Local Plan Inquiry, and in particular the application of the sequential approach in respect of the allocation of edge and out of centre sites and impact on the City Centre.

3.57 1 remain satisfied that the quantitative need identified in the 2000 study remains robust. The 2004 study identifies additional capacity over and above that identified in 2000. 1 am broadly in agreement with the 2004 quantitative assessment, however, there are some assumptions and matters with which I am not in full agreement. These are not significant in terms of the quantitative justification for Southgate. I am content to rely upon the 2000 study.

3.58 What is agreed by all parties is that the quantitative need for the redevelopment of the Southgate area is pressing and that if it cannot be secured, there is a real danger that Bath's position within the regional shopping hierarchy will continue to decline.

3.59 The Scheme has planning permission and can proceed once the site assembly process is complete.

Conclusions

3.60 I conclude that, based on work carried out by Nathaniel Lichfield and Partners for the Council and Drivers Jonas on behalf of CGNU there is sufficient capacity to support the redevelopment of the Southgate area, even without making any allowance for Southgate and its related improvements to public transport and highways infrastructure to increase the City Centre's market share.

3.61 In practice, I am confident that the Scheme will significantly improve the shopping experience in Bath - in terms of range, quality, new retail offer, enhanced environment and accessibility and will increase the City's market share.

3.62  I am satisfied that there is ample capacity to support the Scheme area and the rest of the City Centre over the period of the phased opening of Southgate, and to support the full turnover potential of the Scheme when it is complete and has built up its turnover in 2010/2011.

3.63 The Scheme will be well placed to attract and absorb growth in expenditure beyond 2011 due to its large, flexible shop units and excellent accessibility by all modes of transport.

4. Response to Objectors

4.1 Only one objector questioned the planning need for the redevelopment of the Southgate area - Stylo Barratt.

4.2 I am satisfied that my evidence demonstrates there is a significant quantitative retail capacity, and quantitative retail need for the Southgate proposals. Other witnesses have identified the other aspects of planning need that constitute a compelling case for the Scheme.

5. Conclusions

5.1 Overall, I conclude that the quantitative need for the redevelopment of the Southgate area has been identified, reviewed and reinforced by studies undertaken by NLP and Drivers Jonas over the past 10-15 years in the context of the Adopted Local Plan, the planning application and the Draft Replacement Local Plan Review.

5.2 The steady and projected continued growth in comparison spending power of residents in Bath's catchment area, together with the very limited supply of new retail floorspace in Bath, have combined to produce a pressing need for additional comparison shopping in the City Centre.

5.3 I am satisfied that the capacity estimates are robust. In particular the capacity has been calculated on the basis of the City Centre's market share remaining constant. I would expect Southgate to increase the market share of the City Centre throughout its primary catchment area. The redevelopment of Broadmead in Bristol will offset some of these gains, in particular to the west of Bath in areas such as Keynsham, but this will not affect the overall capacity for the redevelopment of Southgate.

5.4 I have not quantified the potential for any increase in market share, as there is ample capacity to support Southgate over the period that it is programmed to open, 2008 - 2010.

5.5 The studies to date have focused on the period to 2011 - which is the end of the Plan review period, and coincides with the established trading patterns post Southgate. Southgate will be well placed to absorb future growth in spending due to the large, flexible units that will be built and its new transport infrastructure.

5.6 Dr Raggett has provided evidence on the qualitative need for Southgate The combined quantitative and qualitative need in Bath represents one of the most compelling justifications for redevelopment that I have encountered.

5.7 I have not dwelt on the implications of Southgate not proceeding. There is agreement between the Council's advisors - NLP and CBRE - and Drivers Jonas that without the Scheme, Bath City Centre would decline as a regional centre, and the growth of Bristol, Cribbs Causeway and Swindon would substantially increase the leakage of trade from Bath's natural catchment area. Not only would this diminish the City Centre as a whole (in conflict with Government planning advice in relation to enhancing and promoting centres), but it would also be contrary to the objective of sustainable patterns of travel.

5.9 I am in no doubt that there is a quantitative retail need for this major redevelopment of the Southgate area, which combined with the qualitative, townscape, transport and regeneration benefits of the proposals merits the use of compulsory purchase powers by the Secretary of State to complete the assembly of the necessary land.

Return to list of Documents submitted by Bath & North East Somerset Council