view - Breckland Council

THE FORMER TULIP FACTORY SITE, 

LONDON ROAD/CAXTON WAY, 

THETFORD IP24 3SA 

RETAIL & PLANNING STATEMENT 

February 2012 

Our Ref: JLL0435 

RPS 

14 Cornhill 

London 

EC3V 3ND 

Tel: 020 7280 3200 

Fax: 020 7283 9248 

Email: rpslp@rpsgroup.com 

rpsgroup.com/london

CONTENTS 

1 INTRODUCTION ............................................................................................................................................ 1 

2 RELEVANT FACTUAL BACKGROUND......................................................................................................... 3 

3 PLANNING POLICY CONTEXT ..................................................................................................................... 6 

4 EMPLOYMENT LAND.................................................................................................................................. 15 

5 EXISTING SHOPPING PATTERNS............................................................................................................. 21 

6 SEQUENTIAL ASSESSMENT ..................................................................................................................... 25 

7 RETAIL IMPACT .......................................................................................................................................... 29 

8 CONCLUSIONS ........................................................................................................................................... 41 

DOCUMENTS 

Document 1: Planning History 

Document 2: Study Area 

Document 3: Sequential Assessment 

Document 4: Thetford Town Centre Health Check 

Document 5: Trade Draw Assessment 

Document 6: Alton Appeal Decision

1 INTRODUCTION 

1.1 This Retail Statement has been prepared by RPS Planning and Development Ltd (RPS), on behalf of 

Location 3 Properties Ltd in support of a planning application for the redevelopment of the former Tulip 

factory site, Caxton Way/London Road, Thetford. The development comprises a 5,249m² (56,500ft²) 

(gross) foodstore (Class A1), with both customer and servicing access (separate) from London Road. 

The application is submitted in outline, with all matters reserved save access. 

1.2 There is known interest from major foodstore operators in this location who are not currently represented 

in the Thetford market. No occupier has, however, been secured at this stage. 

1.3 This Statement forms part of the following suite of documentation submitted in support of the application 

and should be read in that context:- 

Design & Access Statement, prepared by RPS; 

Transport Assessment and Framework Travel Plan, prepared by Motion Transport Planning; 

Pre-planning Tree Survey, prepared by Land Lizard; 

Statement of Community Involvement, prepared by The Remarkable Group; 

Contamination Report, prepared by Georisk Management; and 

Flood Risk Assessment and Drainage Strategy, prepared by Stuart & Harris. 

1.4 This Statement assesses the application proposals against relevant planning policy and, in particular, 

demonstrates that the proposals meet the relevant ‘tests’ embodied in Planning Policy Statement 4: 

Planning for Sustainable Economic Growth (PPS4). At the outset, however, it is important to recognise 

the current Government’s clear commitment to sustainable economic growth and the expectation that 

‘the answer to development and growth should whenever possible be ‘yes’ except where this would 

comprise the key sustainable development principles set out in national planning policy.’ 

1.5 The application proposals would deliver real and tangible benefits for the residents of Thetford – these 

would include:- 

Investment of some £15M. 

Genuine choice and competition in the grocery market. Across the primary catchment area 

Thetford retains just 59.7% of the main food spend – residents are leaving Thetford for their 

grocery shop. 

Jobs – Circa 250 in total. 

Regeneration of a redundant site that has been vacant since 2009. 

Former Tulip Factory Site, London Road/Caxton Way, Thetford Page 1 

Retail & Planning Statement, February 2012

1.6 The Statement is structured in the following way:- 

Section 2 sets out the relevant factual background, including a description of the site and 

surrounding area, a summary of the planning history and an explanation of the application 

proposals. 

Section 3 of the Statement summarises the planning policy context in terms of both national policy 

and the Statutory Development Plan. 

Section 4 considers the proposals in the context of the ‘General Employment Area’ allocation for 

the site. 

Section 5 explains the existing shopping patterns in Thetford with reference to an up-to-date 

household survey undertaken in December 2011. 

Section 6 then assesses the proposals against the first ‘gateway’ test of PPS4, namely the 

sequential assessment. 

Retail impact is considered in detail in Section 7. 

Finally, conclusions are drawn at Section 8. 

1.7 Throughout this report where monetary values are used they are in constant 2008 prices. This is the 

same price base as the NLP Breckland Retail and Town Centre Study 2010 and therefore assists 

comparison with that document. 



2 RELEVANT FACTUAL BACKGROUND 

a) Site and Surrounding Area 

2.1 The application site is located c.1km to the south-west of Thetford Town Centre. The site extends to 

2.09ha and is occupied by a vacant factory unit, with ancillary office block and substantial areas of hard 

standing and unmarked car parking. In total the site comprises c.7,600m² (gross) of floorspace. 

2.2 The site forms part of the Caxton Way Industrial area which comprises predominately former food 

production facilities alongside ancillary storage and associated office buildings. The majority of these 

were once owned by Tulip International (bacon, beef and pork product producers) who announced the 

closure of their Thetford operations in 2007 and closed this site in 2009. 

2.3 The site is located adjacent to the Forest Retail Park to the west, which is occupied by Sainsbury’s, 

Currys, McDonalds, Store Twenty One, Carpetright, B&Q, Pets at Home and Brantano. A Topps Tiles, 

Kwik Fit, Goodprint UK, Smart Bargain Warehouse unit, as well as Wickes are located on the opposite 

side of London Road to the south of the site. To the immediate north of the site are the 2 Sisters Food 

Group; whilst to the east is Caxton Way, beyond which is Baxter Healthcare Ltd. 

2.4 In the wider London Road/Burrell Way Industrial Estates (to the south of the site) are a variety of uses 

ranging from strict employment uses, sui generis uses and retail uses. Beyond Burrell Way to the south 

is Stephenson Way Industrial Estate, which comprises a mix of industrial and warehouse uses including 

occupiers such as AFS Animal Care Ltd, Waste Recycling Group, Goodprint UK and Thetford Finishing 

Limited. 

2.5 The site is accessible by public transport. There are four bus services running within close proximity of 

the site. They run from Thetford Bus Station in the town centre and serve the towns and villages 

surrounding Thetford. Coach services operate routes T1 and T1A which serve the site twice an hour. 

The closest bus stops to the site are located along London Road. Additional bus services are also 

available from Forest Retail Park, which is to the west of the site. 

2.6 The principal existing vehicular access to the site is from Caxton Way, with secondary access from 

London Road. 

2.7 There are two Tree Preservation Orders in respect of the site; TPO 2009 no.30 includes two groups of 

Scots Pine on the London Road; whilst TPO 2012 no.1 covers 6no. London Plane within the existing car 

park. 

b) Relevant Planning History 

2.8 Planning permission was granted for the existing factory, office and warehousing buildings (Use Classes 

B1, B2 and B8) on the site in April 1996 (Council Ref: 3/96/0277). This planning application involved 

adaptation of the premises for Tulip International Limited. However, there has been a factory use on the 

site since the 1960’s. 



2.9 Two further applications were subsequently submitted. The first, approved in March 1999 (Council Ref: 

3PL/1999/0132), related to the siting of a waste energy recovery unit and vertical chimney flue; the 

second was for an amendment to the external front elevation of the building (approved in April 2002, 

Council Ref 3PL/2002/0285). 

2.10 A summary of the full planning history of the site, which dates back to 1963, is set out in Document 1. 

The planning history establishes that the lawful use of the site is B1 (Business), B2 (General Industrial) 

and B8 (Storage or Distribution). 

Document 1 

2.11 It is of relevance that planning permission was approved on 13 th June 2011 (3PL/2010/1249F) for the 

erection of a new Lidl foodstore with a net sales area of 1,280m² on 0.54ha of employment land adjacent 

to London Road (to the south west of the site). The Lidl site is approximately 100m from the current 

application site. 

2.12 The Officer’s Committee Report identified the main considerations in respect of the application to be the 

sequential assessment and the potential for impact on the vitality and viability of Thetford Town Centre, 

i.e. essentially the ‘gateway tests’ of PPS4. In terms of the first ‘test’, it was accepted that there were no 

sequentially preferable sites; the Report to Committee concluding that: 

“With regard to vacant properties none of the units in the town centre 

are large enough to accommodate Lidl’s business model. There were 

also overriding constraints with regards to the six sites identified in 

Appendix 6 of the NLP report. These constraints included inadequate 

size of the site, availability, existence of Listed Buildings and current 

occupation (the details of constraints on each site are outlined in the 

PPS4 Assessment, November 2011, prepared by GVA Grimley). It 

should be noted that a further location, the Council owned Bridges 

Street/Anchor site, was considered at a later date but was not 

available solely for food retail as the Council is hoping to provide a 

mixed-use development on the site.” 

2.13 This finding is important as the Lidl proposal was significantly smaller in size than the current proposal. 

It was less than a quarter of the size of the proposed store. 

2.14 In considering the second ‘test’ of impact, Officers also concluded that the proposal would not result in 

an unacceptable impact on Thetford Town Centre. Given the scale of the Lidl proposal (below the PPS4 

‘threshold’ for an impact assessment), only limited impact evidence was required and therein submitted. 

Retail impact has, however, been assessed in full in Section 7 of this Statement. 

2.15 The Lidl proposal together with the recently completed Wickes DIY store, also located on London Road, 

establishes the acceptability of retail use in this general location (subject to the demonstration of the 

above). 

c) Proposed Development 

2.16 Planning permission is sought in outline for the construction of a foodstore (Class A1) with associated 



petrol filling station, car parking, servicing and access. All matters are reserved for future determination 

(as Reserved Matters), save access. 

2.17 The proposed foodstore would comprise 5,249m² (56,500ft²) (gross) floorspace located on the western 

part of the site, with its entrance orientated towards Caxton Way. The petrol filling station with 

associated kiosk and forecourt would be located in the south east corner of the site. 

2.18 The scale of the building is reserved for future determination, however, in accordance with Part 2(4) of 

the Town & Country Planning (Development Management Procedure) (England) Order 2010 the 

following parameters are proposed:- 

Height: min 8m; max 11m 

Width: min 76m; max 80m 

Length: min 60m; max 68m 

2.19 Customer access to the site is proposed from London Road. Servicing access would be from the 

existing access to the site from London Road; all servicing is accommodated on site, which includes a 

28m turning area, i.e. all vehicles will enter and exit the site in forward gear. 

2.20 The proposals provide car parking to the front of the store for 313 vehicles, including 18 disabled and 18 

parent and child spaces located close to the store entrance. 13 spaces for staff are proposed to the rear 

of the store parallel to the service access road. 

2.21 Landscaping is reserved for future determination (as a Reserved Matter), however, the proposed 

indicative site plan demonstrates the ability of the scheme to accommodate a wide landscape margin 

along the site boundaries (notably London Road). Those trees covered by TPO 2009 no.30 (i.e. the 

Scots Pine on London Road) will be retained as part of the proposals. 



3 PLANNING POLICY CONTEXT 

3.1 This section of the Statement sets out, and provides commentary on, those policies that are relevant to 

the determination of the planning application. It principally deals with national planning policy contained 

in PPS4: Planning for Sustainable Economic Growth and those policies that form part of the statutory 

Development Plan. 

a) National Planning Policy 

3.2 The National Planning Policy Framework (NPPF) was published in July 2011 – it establishes a very 

clear presumption in favour of sustainable development, outlining that:- 

“The Government is committed to ensuring that the planning system 

does everything it can to support sustainable economic growth. A 

positive planning system is essential because, without growth, a 

sustainable future cannot be achieved. Planning must operate to 

encourage growth and not act as an impediment. Therefore, 

significant weight should be placed on the need to support economic 

growth through the planning system.” (paragraph 13) 

3.3 It further establishes (paragraph 19) that the default answer to development should be ‘yes’, except 

where this would compromise the key sustainable development principles set out in the NPPF. 

b) Planning Policy Statement 4: Planning for Sustainable Growth 

3.4 In December 2009, the Government published Planning Policy Statement 4: Planning for Sustainable 

Economic Growth (PPS4). Importantly, for the purposes of policies in PPS4, ‘economic development’ is 

expressly defined (paragraph 4) as development within B use classes, public and community uses 

including all forms of retail development (our emphasis). 

3.5 The Government’s objectives in terms of achieving sustainable economic growth through planning are 

set out in paragraph 10 of PPS4 and include, inter alia, to: 

a) Deliver more sustainable patterns of development, reduce the need to travel, especially by car and 

respond to climate change. 

b) Promote the vitality and viability of town and other centres as important places for communities. 

To do this, the Government wants: 

i. New economic growth and development of main town centre uses to be focused in existing 

centres, with the aim of offering a wide range of services to communities in an attractive and 

safe environment and remedying deficiencies in provision in areas with poor access to 

facilities. 

ii. Competition between retailers and enhanced consumer choice through the provision of 

innovative and efficient shopping, leisure, tourism and local services in town centres, which 

allow genuine choice to meet the needs of the entire community (particularly socially 



excluded groups). 

iii. The historic, archaeological and architectural heritage of centres to be conserved and, where 

appropriate, enhanced to provide a sense of place and a focus for the community and for 

civic activity. 

3.6 Policy EC10.1 of PPS4 emphasises that local planning authorities should adopt a positive and 

constructive approach towards planning applications for economic development. It continues (at Policy 

EC10.2) to set out a series of ‘impact considerations’ against which all planning applications for 

economic development should be assessed. These are as follows:- 

“a) Whether the proposal has been planned over the lifetime of the 

development to limit carbon dioxide emissions and minimise 

vulnerability and provide resilience to, climate change. 

b) The accessibility of the proposal by a choice of means of 

transport including walking, cycling, public transport and the car, 

the effect on the local traffic levels and congestion (especially to 

the trunk road network) after public transport and traffic 

management measures have been secured. 

c) Whether the proposal secures a high quality and inclusive design 

which takes the opportunities available for improving the 

character and quality of the area and the way it functions. 

d) The impact on economic and physical regeneration in the area 

including the impact on deprived areas and social inclusion 

objectives. 

e) The impact on local employment.” 

3.7 Policy EC14 of PPS4 establishes the type and level of supporting evidence required for applications for 

main town centre uses. Policy EC14.3 and EC14.4 deal specifically with the requirement for a 

sequential assessment and impact assessment, stating that:- 

“EC14.3: A sequential assessment (under EC15) is required for 

planning applications for main town centre uses that are not in an 

existing centre and are not in accordance with an up to date 

development plan. 

EC14.4: An assessment addressing the impacts in Policy EC16.1 is 

required for planning applications for retail and leisure developments 

over 2,500m² gross floorspace or any local floorspace threshold set 

under Policy EC3.1.D not in an existing centre and not in accordance 

with an up to date development plan.” 

3.8 The proposed retail floorspace (which totals 5,249m²) exceeds the threshold or ‘trigger’ for an impact 

assessment established by PPS4. A robust impact assessment has therefore been undertaken. That 

assessment is consistent with Policy EC14.7 which advises it to be ‘proportionate to the scale and 

nature of the proposal and its likely impact’. 



3.9 Policy EC15 of PPS4 sets out the approach that local planning authorities should take in considering the 

sequential assessment. Specifically, it seeks to:- 

“a) Ensure that sites are assessed for their availability, suitability 

and viability. 

b) Ensure that all in-centre options have been thoroughly assessed 

before less central sites are considered. 

c) Ensure that where it has been demonstrated that there are no 

town centre sites to accommodate a proposed development, 

preference is given to edge of centre locations which are well 

connected to the centre by means of easy pedestrian access. 

d) Ensure that in considering sites in or on the edge of existing 

centres, developers and operators have demonstrated flexibility 

in terms of: 

i) Scale: Reducing the floorspace of their development; 

ii) Format: More innovative site layouts and store 

configurations such as multi-storey developments with 

smaller footprints; 

iii) Car Parking Provision: Reduced or reconfigured car 

parking areas; and 

iv) The scope for disaggregating specific parts of a retail or 

leisure development, including those which are part of a 

group of retail or leisure units, onto separate, sequentially 

preferable, sites. However, local planning authorities 

should not seek arbitrary sub division of proposals.” 

3.10 Policy EC15.2 clarifies that, in considering the flexibility required above, local planning authorities should 

take into account any ‘genuine difficulties which the applicant can demonstrate are likely to occur in 

operating the proposed business model from a sequentially preferable site, for example where a retailer 

would be limited to selling a significantly reduced range of products’. 

3.11 Where retail impact needs to be addressed, PPS4 (at Policy EC16.1), establishes a set of impacts, 

against which planning applications for main town centre uses which are not in a centre should be 

considered. These are as follows:- 

“a) The impact of the proposal on existing, committed and planned 

public and private investment in a centre or centres in the 

catchment area of the proposal; 

b) The impact of the proposal on town centre vitality and viability, 

including local consumer choice and the range and quality of the 

comparison and convenience retail offer; 

c) The impact of the proposal on allocated sites outside town 

centres being developed in accordance with the development 

plan; 

d) In the context of a retail or leisure proposal, the impact of the 

proposal on in-centre trade/turnover and on trade in the wider 



area, taking account of current and future consumer expenditure 

capacity in the catchment area up to five years from the time the 

application is made, and, where applicable, on the rural 

economy; 

e) If located in or on the edge of a town centre, whether the 

proposal is of an appropriate scale (in terms of gross floorspace) 

in relation to the size of the centre and its role in the hierarchy of 

centres; 

f) Any locally important impacts on centres under Policy EC3.1.E.” 

Note: Policy EC3.1.(e) simply requires regional planning bodies and local 

planning authorities to, as part of their economic vision for an area, define 

any locally important impacts on centres which they would want tested 

under Policy EC16 

3.12 Finally, Policy EC17 of PPS4 sets out the way in which – in the context of the policies outlined above – 

planning applications for development of town centre uses in out-of-centre locations should be 

considered. It states that such applications should be refused where:- 

1. The applicant has not demonstrated compliance with the requirements of the sequential approach; 

or 

2. There is clear evidence that the proposal is likely to lead to significant adverse impacts in terms of 

any one of the impacts set out in policies EC10.2 and 16.1 (the impact assessment) taking account 

of the likely cumulative effect of recent permissions, developments under construction and 

completed developments (our emphasis). 

3.13 Where no significant adverse impacts have been identified, Policy EC17 goes on to require planning 

applications to be determined taking account of the positive and negative impacts of the proposal in 

terms of policies EC10.2 and 16.1 (i.e. those impacts that exist but are not considered to be significant), 

any other material planning considerations and the likely cumulative effect of recent permissions, 

developments under construction and completed developments. In terms of the extent and significance 

of any impacts, Policy EC17.3 states that such judgements should be informed by the development 

plan, where this is up to date. 

3.14 In short, an applicant must demonstrate compliance with the sequential approach and provide evidence 

that there will be no significant adverse impact. Should both of these ‘gateway tests’ be satisfied, then 

local planning authorities should go on to take account of both positive and negative impacts of the 

proposal and any other material considerations – there is essentially a two stage approach to any 

assessment. 

c) Development Plan Policy 

3.15 The Statutory Development Plan for Thetford comprises the East of England Plan (May 2008), those 

‘saved’ policies of the Breckland District Local Plan (September 1999) and The Breckland Adopted Core 

Strategy and Development Control Polices Development Plan Document (December 2009). Only six 



Local Plan Policies have been saved; none are relevant to the assessment of the application proposals. 

3.16 As part of the emerging Local Development Framework, the Thetford Area Action Plan (TAAP) was 

submitted to the Secretary of State (SoS) on 18 th November 2011. The EiP is scheduled for 6 th to 9 th 

March 2012. Although of limited weight, we nonetheless deal with those relevant policies of the TAAP in 

the sub-section below. 

i. East of England Regional Spatial Strategy 

3.17 The East of England Plan was published in May 2008. As the Regional Spatial Strategy (RSS) it 

technically forms part of the Statutory Development Plan. However, the Coalition Government’s 

intention to abolish RSS’ is an important material consideration. The Localism Bill which contains a 

clause to abolish and revoke RSS’ received Royal Assent on 15 th November 2011. We do not therefore 

deal with the policies in the RSS in this section. 

ii. The Breckland Core Strategy and Development Control Policies DPD 

3.18 The Breckland Core Strategy and Development Control Policies Development Plan Document (‘the Core 

Strategy’) was adopted in December 2009. The overall Spatial Strategy for Breckland (reference Policy 

SS21 of the Core Strategy) identifies that ‘Thetford will be the focus for growth in Breckland’, delivering 

6,000 homes and 5,000 new jobs to the end of the plan period (2021). Policy CP3 of the Core Strategy 

outlines that, in order to achieve the delivery of employment, the following will be required:- 

Development proposals that contribute to the creation and retention of a wide range of jobs, 

educational and re-skilling opportunities; 

The protection and promotion of existing employment sites which have been identified as fit for 

purpose in the Employment Land Review. These sites are defined as General Employment Areas 

on the Proposals Map; 

The intensification and more efficient use of existing employment sites and premises where they 

are either not fully used or utilised to modern business needs; and 

The protection and promotion of town centres as the focus for retail, leisure, office and tourism 

development. In particular, the town centre of Thetford will be regenerated to provide a significant 

uplift in town centre related employment. 

3.19 The application site itself forms part of a General Employment Area – the relevant policy (DC6) in the 

Core Strategy states that:- 

“Sites that are identified as General Employment Areas on the 

proposals map will be protected for employment use. Proposals to 

accommodate new employment development (1) will be permitted on 

General Employment Areas where: 

a. It is not a town centre use, unless the location is sequentially 

preferable and need has been demonstrated; and 



. It will not undermine the function of the wider employment area.” 

(1) B1, B2 and B8 uses 

3.20 Policy DC6 recognises that subject to satisfying the tests of need and sequential approach, there are 

instances where retail proposals can be appropriate in a General Employment Area. The following 

sections of this Statement fully address the sequential assessment and retail need (in the context of 

impact); in Section 4 we demonstrate that the proposals would neither undermine the function of the 

wider employment area or the objectives of the employment policies; namely to deliver jobs. 

3.21 The site also forms part of an area within the Special Protection Area Buffer (Stone Curlew), to which 

Policy CP10 states, inter alia, that: 

“The Council will require that an appropriate assessment is 

undertaken of all proposals for development that are likely to have a 

significant effect on the Breckland Special Protection Area (SPA) and 

will only permit development that will not adversely affect the integrity 

of the SPA. In applying this policy the Council has defined a buffer 

zone that extends 1,500m from the edge of those parts of the SPA that 

support or are capable of supporting store curfews, within which:- 

(a) Permission may be granted for the re-use of existing buildings 

and for development which will be completely masked from the 

SPA by existing development; alternatively 

(b) Permission may be granted for development provided it is 

demonstrated by an appropriate assessment the development will 

not adversely affect the integrity of the SPA.” 

3.22 Criterion (a) above is applicable; there is significant intervening development between the application 

site and the SPA. 

3.23 Policy CP7 of the Core Strategy identifies the shopping hierarchy for Breckland as follows: Thetford (Key 

Centre for Development and Change); Dereham (Main Town and Administrative Centre serving mid- 

Norfolk); Attleborough (Town Centre serving a wide rural catchment); Swaffham and Watton (Mid-size 

Town Centres – serving local need). It further identifies the following comparison and convenience 

floorspace requirements (according to centre):- 

Table 1: Breckland District Council Updated Retail and Town Centre Study (2007) 

Town Hierarchy Net Comparison 

Floorspace 

Requirement (m²) 

2007-18 

Thetford Key Centre for Development and 

Change 

Dereham Main Town and Administrative Centre 

serving mid-Norfolk 

Attleborough Town Centre serving a wide rural 

catchment 

Net Convenience 

Floorspace 


2007-18 

7,000 – 7,500 2,000 – 2,500 

7,750 – 8,500 2,000 – 2,500 

2,250 – 2,750 1,750 – 2,250 



Town Hierarchy Net Comparison 

Floorspace 


2007-18 

Net Convenience 

Floorspace 


2007-18 

Swaffham Mid-size Town Centres – serving local 1,000 – 1,500 0 

Watton 

need 

250 – 500 0 

Totals 18,250 – 20,750 5,750 – 7,250 

3.24 The above illustrates a convenience floorspace requirement for Thetford of up to 2,500m² (net) to 2018. 

This capacity estimate, it should be noted, is based on the 2007 Retail Study and not the more recent 

2010 Study. 

3.25 In terms of the enhancement and maintenance of the vitality of the town centres, Policy CP7 states that 

retail development will be addressed by, inter alia: 

“(c) Restricting retail development, except extensions under 200m 2 gross 

floorspace, outside the defined centres, unless it can be demonstrated 

that there is a need for the development, there are no sequentially 

preferable sites and no negative impact on the vitality and viability of the 

town centre” 

3.26 Again, this essentially comprises the key ‘gateway tests’ of PPS4 and are dealt with in the proceeding 

sections of this Statement. 

3.27 Policy DC14 of the Core Strategy promotes and supports sustainable building forms and construction. It 

requires all new development above 1,000m² to supply at least 10% of the energy they require through 

on-site and/or decentralised renewable sources subject to a detailed viability appraisal. As outlined 

elsewhere, no occupier has yet been confirmed for the development. The applicant is however 

committed to a sustainable development. 

3.28 Finally, Policy DC16 states that all new development should aim to achieve the highest standards of 

design in accordance with a number of key design criterions. The design philosophy behind the 

application proposals is dealt with in the Design and Access Statement, prepared by RPS and Hulme 

Upright, which accompanies the application. 

iii. Thetford Area Action Plan Proposed Submission DPD (TAAP) 

3.29 The TAAP was submitted to the SoS in November 2011. Given the relative infancy of the document 

only limited weight should be attached to it. We nonetheless deal with those relevant policies below. As 

an overview of the TAAP it is worth noting the following:- 

5,000 new homes and 5,000 jobs are to be created within the town; 

The majority of Thetford’s housing allocations are to take place to the north of the town by way of a 

new urban extension alongside the A11; and 



The TAAP allocates some 40 hectares of new employment land, again to the north of the town, as 

part of the urban extension. 

3.30 Policy TH1 of the TAAP establishes an approach to Thetford Town Centre – it states that, inter alia:- 

“The primary shopping area as identified on the proposals map will be the 

focus for new comparison and convenience retail and commercial leisure 

uses. Complementary office, cultural, educational and community-related 

uses will be appropriate given the need to strengthen Thetford town centre.” 

3.31 The policy identifies the following key sites for ‘development and change’ in the Primary Shopping Area: 

The Camerie Rooms; 

Tanner Street Car Park; 

Riverside Walk; 

Minstergate; and 

The Riverside Regeneration Area (Bridge Street Car Park) 

3.32 It further identifies that elsewhere within the town centre a further key site is the Thetford Retail Park; 

this is an area where the intensification of retail activity and new commercial leisure will be permitted. 

3.33 Policy TH2 of the TAAP deals with new retail development, stating that:- 

“In the period up to 2016, additional convenience floorspace capacity (around 

330m 2 net) will be directed to sites within the town centre. 

Breckland Council will consider the need to identify sites to meet Thetford’s 

medium to long-term retail needs in accordance with the sequential 

approach. The identification of any sites to meet this long-term need will be 

considered through future reviews of this AAP. Other retail proposals in 

Thetford will be considered against the policies contained within the adopted 

Core Strategy and the requirements of national planning policy. 

Out-of-centre retail proposals that jeopardise the potential to provide the 

comparison shopping provision identified within the urban extension and/or 

undermine the vitality and viability of the town centre will not be permitted.” 

3.34 The sub-text to Policy TH2 explains that the retail capacity estimates that informed the TAAP are 

derived from the updated 2010 Retail Study carried out by NLP. That Study which is based on a 

Household Survey suggests less capacity. We comment on the NLP 2010 Study and its capacity 

implications in Section 5 of this Statement. Suffice to say, we consider it underestimates capacity and 

that it is too narrowly drawn. As a consequence we have commissioned our own Household Survey is 

which specific to Thetford and its immediate hinterland. Again, this is explained in Section 5. 

3.35 The TAAP identifies an Urban Extension to the north of Thetford which is intended to deliver some 5,000 

homes and 22ha of employment land adjacent to the A11. Policy TH30 of the TAAP promotes two new 

local centres within the Urban Extensions; these are intended to deliver c.500m² (net) comparison goods 

or other ‘A’ Class floorspace and c.1,200m² (net) new convenience floorspace. The preference in terms 



of the latter is for it to be provided as small foodstores of under 500m² (net) to meet local needs. The 

policy requires the development of the local centres to be phased for completion post 2016 as significant 

new housing and population growth takes place. 

3.36 An outline planning application has been submitted by the Crown Estate and Kilverstone Estates for the 

Urban Extension (LPA Ref. 3PL/2011/0805/0). This, as the TAAP policy envisages, would deliver 2.5ha 

of commercial uses (A1 – A5) over a phased period of time. The Design & Access Statement submitted 

in support of the application states that ‘the retail (A1) gross floor area (gfa) will be limited to one unit of 

500m² in the primary centre and 170m² per unit in all, other areas, as well as additional provision in the 

primary centre.’ 

3.37 Policy TH18 of the TAAP seeks to deliver a BREEAM ‘very good’ rating for all new non-residential 

development above 1,000m², unless such requirements would render a particular development 

economically unviable. As explained, elsewhere the end user (although expected to be a national food 

retailer) is not known at this stage; this would, however, be assessed at the Reserved Matters stage. 



4 EMPLOYMENT LAND 

4.1 As outlined in Section 3 of this Statement, the application site forms part of a General Employment Area. 

Core Strategy Policy DC6 seeks to protect such areas for ‘employment use’; this section of the 

Statement serves to justify the loss of this site to traditional (‘B’ use classes) employment use. It is 

structured in the following way:- 

First, we explain the context within which retail applications should be considered in terms of the 

emphasis of Government guidance. 

We then review the employment land position in Breckland with reference the site and wider 

industrial estate, the Breckland Employment Land Review (October 2006) and emerging planning 

policy. 

Finally, we outline the employment benefits in terms of job creation associated with the application 

proposals. 

a) Context 

i. Planning Policy Statement 4 (PPS4) 

4.2 PPS4 (published in December 2009) expressly defines retail development (as a main town centre use) 

as ‘Economic Development’ i.e. it provides employment opportunities, generates wealth, and generates 

an economic output. 

4.3 In terms of the Plan Making Policies of PPS4, the guidance (at Policy EC2.1(h)) is clear that:- 

“Existing site allocations should not be carried forward from one version 

of the development plan to the next without evidence of the need and 

reasonable prospect of their take up during the plan period. If there is no 

reasonable prospect of the site being used for the allocated economic 

use, the allocation should not be retained, and wider economic uses or 

alternative uses should be considered.” 

4.4 PPS4 very clearly establishes a ‘positive and constructive’ approach towards planning applications for 

economic growth – Policy EC10 specifically requires that ‘planning applications that secure sustainable 

economic growth should be treated favourably’. 

ii. National Planning Policy Framework (NPPF) 

4.5 A Ministerial Statement issued to coincide with HM Treasury’s ‘Plan for Growth’ in March 2011 

emphasised that the Government’s top priority in reforming the planning system is to promote 

sustainable economic growth and jobs. The statement makes it clear that local planning authorities 

must take account of it with immediate effect. Importantly, the Government’s expectation is that ‘the 

answer to development and growth should whenever possible be ‘yes’ except where this would 

compromise the key sustainable development principles set out in national planning policy’. 



4.6 This commitment to economic growth has very recently (in July of 2011) been re-emphasised in the draft 

NPPF. Although we recognise it is in draft form, it nonetheless demonstrates the direction of travel of 

government policy. 

4.7 Paragraph 13 of the draft NPPF sets out the Government’s commitment to ensuring that the planning 

system does everything it can to support sustainable economic growth. It comments that, without 

growth, a sustainable future cannot be achieved and that planning must operate to encourage this 

growth, not act as an impediment. Paragraph 19 goes on to state that:- 

“Decision takers at every level should assume that the default answer 

to development proposals is ‘yes’, except where this would 

compromise the key sustainable development principles set out in 

national planning policy.” 

4.8 In terms of employment allocations, paragraph 75 of the NPPF states that planning policy should avoid 

the long-term protection of employment land and that applications for alternative uses of designated land 

should be treated on their merits having regard to market signals and the relative need for different land 

uses. 

b) Employment Land Supply 

i. Caxton Way Industrial Estates 

4.9 Caxton Way/Burrell Way are located either side of the A11 (London Road) to the south west of Thetford 

Town Centre, within the Saxton Ward. The application site forms part of the Caxton Way Industrial 

Estate which comprises predominately former food production facilities alongside ancillary storage and 

associated office buildings. The majority of these were once owned by Tulip International (bacon, beef 

and pork product producers). Tulip finally ceased the last of their operations within Thetford in 2009. 

4.10 Existing occupiers at Caxton Way Industrial Estate include: 2 Sisters Food Group (Food Production); 

Baxter Healthcare (Medical Products and Services); Trox UK Ltd (Air conditioning and ventilation); 

Rowlinson Packaging (Packaging); and Thetford Diaries (Dairy Products). There are, however, a 

number of vacancies on the Estate – of significance these include:- 

The Saxton Site (formerly a food production unit) c.2.78ha. 

Room 29, Caxton Way (industrial – warehouse) c.53,000ft² (see photographs below). 



Existing Vacant Employment Space at Caxton Way (Former Saxton Site) 

Existing Vacant Employment Space at Caxton Way (Former Room 29) 



ii. Thetford Employment Land Review 

4.11 Roger Tym & Partners and GVA Grimley were instructed by Breckland District Council to undertake an 

employment land assessment in 2006 that involved:- 

An audit of existing employment sites; 

An assessment of the demand for and supply of employment land (according to market segments) 

to 2021; 

An appraisal of market conditions and the quality of existing sites and allocations; and 

Advice on how to take forward the findings in terms of policy, existing sites and the likely 

requirements for new sites. 

4.12 The Employment Land Review (ELR) has informed the Breckland Core Strategy, Thetford Area Action 

Plan and Site Specific Policies and Proposals DPD. 

4.13 As part of the ELR the market requirement for industrial/warehousing and office space (based on 

existing business needs and employment forecasts) was forecast and compared to planned supply 

(allocations and vacant space surplus to requirements). That work demonstrated the following:- 

The projected demand for employment floorspace 2021 would be:- 

Table 2: Employment Floorspace Demand in Thetford to 2021 

Floorspace Type Net Change in Occupied Stock (m²) 2001-21 

Industrial -31,053 

Warehouse 89,902 

Office 41,257 

Source: Table 6.2 of ELR 

In short, there is projected to be a significant decline in demand for industrial floorspace. 

The above demand equates to a requirement for an additional 25ha of overall employment land (all 

B Class). 

Whilst the total quantum of employment land supply has remained at around 180ha, on average 

less than 10ha per annum has been developed (1998 – 2005), i.e. there is at least an 18 year 

employment land supply. 

In quantitative terms there is an over-allocation of employment land which will not be taken up over 

the plan period. 



4.14 The adopted Breckland Core Strategy and Development Control Policies DPD makes provision for the 

delivery of at least 6,000 jobs in the District to 2021; it allocates 30-40ha of strategic employment land 

within the A11 corridor (the details and delivery to be determined through an Area Action Plan). This 

included 18ha of employment land at the Thetford Enterprise Park (which already benefits from planning 

permission originally granted in 1990 for c.600,000ft² employment floorspace) and 22ha of land within 

the Thetford Urban Expansion. 

4.15 The Thetford Area Action Plan (TAAP) identifies the indicative proposed phasing of employment land 

provision, as follows:- 

Table 3: Thetford Urban Extension Employment Land Phasing 

Phase 1 

2013-2015 

Phase 2 

2016-2018 

Phase 3 

2019-20 

Phase 4 

2021-24 

Phase 6 

2025-26 


Retail & Planning Statement, February 2012 

Total 

4.0ha 14.5ha 2.5ha 6.5ha 0.7ha 28.2ha 

4.16 Although not expected to be determined until Easter 2012, the outline planning application submitted by 

the Crown Estate and Kilverstone Estate is consistent with the TAAP in terms of the total quantum of 

employment land proposed. There is nothing to suggest that this phased release of employment land 

will not be delivered. In short, there is a significant supply of employment land in Thetford; the loss of 

the application site to a non-B Class use would in no way undermine the objective of the Core Strategy 

to deliver c.6,000 jobs in the District. 

c) Jobs 

4.17 The employment policies in both the adopted Core Strategy and emerging TAAP are jobs driven – they 

seek to provide for 5,000 – 6,000 net new jobs. The two biggest employment sectors in Thetford (based 

on ONS statistics for all Thetford Wards) are: ‘manufacturing’, and ‘wholesale and retail trade, repairs’. 

Retail is therefore, already an important employer in the town – the value of retail jobs should not be 

underestimated. This is particularly relevant given that in November 2011, 4.2% of the working age 

population within the application site’s immediate ward (Thetford – Saxton) is claiming Job Seekers 

Allowance, compared to an average 2.93% for Breckland District (source: Department for Work and 

Pensions). 

4.18 A foodstore of the size proposed would employ around 250 staff in total. The types of jobs created will 

range from managerial positions, to check-out and shop floor staff, as well as support services such as 

cleaning and security positions. The nature of the employment opportunities is such that the majority of 

the new employees will live locally; with flexible working hours offered. 

4.19 The role and importance of retail to the economy is highlighted in research undertaken by DTZ in 

consultation with Business in the Community and the British Council of Shopping Centres in 2009 

(‘Retail-led Regeneration: Why it Matters to Out Communities’) – this states that:-

In 2007 the retail sector was worth £68 billion, approximately 6% of UK Gross Valued Added 

(GVA) at basic prices. 

Retail is the third largest service sector employer in the UK, employing around 3 million people in 

full-time employment (2007). 

Of the 3 million employees in the sector (1 in 10 of the UK workforce), 1.89 million are women 

which represents 14.4% of the female workforce in the UK. Further, there are 1.75 million parttime 

employees of which 1.3 million are female. 

Crucially the sector is predominately made up of a younger workforce; retail workers are much 

more likely to be aged between 16 and 24 years (accounting for more than 30% of all workers, 

twice the UK average). This workforce includes those who are possibly still in education or have 

just left education, which supports the view of retail being a gateway to other jobs. 

For every 100 retail jobs created nationally, an additional 50 indirect and induced jobs will be 

created elsewhere. 

4.20 In 2010, the Homes and Communities Agency commissioned Drivers Jonas Deloitte to produce a guide 

to Employment Densities. Based on these average employment densities, the existing ‘employment’ 

floorspace on the application site (7,600m²) would deliver the following number of full-time equivalent 

staff. 

Table 4: Employment Generation of Existing Floorspace 

Use Class Area per FTE (m²) Total FTE (1) 

B2 General 36 211 

B1(c) Light Industry 47 162 

B8 General 70 109 

B8 Large-scale and High Bay Warehousing 80 95 

B1(a) Business Park 10 760 

(1) Based on existing floorspace of 7,600m² 

4.21 As the above demonstrates, save for a B1(a) Business Park, a foodstore would deliver significantly more 

jobs than traditional B Class uses. Indeed, when occupied by Tulip the site only employed between 100 

and 200 people. The proposal thereby delivers exactly what the Core Strategy (a TAAP) seeks to 

achieve – jobs. 



5 EXISTING SHOPPING PATTERNS 

5.1 In this Section we consider where residents of Thetford and the surrounding area are currently 

undertaking their food shopping purchases. We do so having regard to both our own household survey 

and that carried out to inform the Core Strategy. 

5.2 In 2010, NLP on behalf of the Council, produce the Breckland Retail and Town Centre Study. The Study 

looked at shopping patterns across the whole district which it broke down into six zones. Thetford falls 

in Zone 1; its host zone. The Study was informed by a Household Survey (of 1,002 households) and the 

corresponding results fed through directly to NLP’s floorspace capacity estimates, which, in turn, have 

been carried through to the TAAP. 

5.3 As part of the Household Survey residents of the six zones were asked where they currently undertook 

their food shopping. The results area amalgamated in Table 4B which effectively shows retention rates 

for convenience shopping for the District’s principal towns. For Thetford, the position is:- 

Table 5: Convenience Shopping Penetration Rates 2010 - Thetford 

Centre/ 

Facility 

Sainsbury’s, 

Thetford 

Tesco, 

Kilverston 

Road, 

Thetford 

Other, 

Thetford 

Thetford 

Sub-Total 

Zone 1 

Thetford 

Zone 2 

Dereham 

Zone 3 

Swaffham 

Zone 4 

Watton 

Zone 5 

Attlesborough 

Zone 6 SE 

Breckland 

% Inflow 

24% 0% 1% 3% 1% 8% 10% 

27% 0% 0% 2% 7% 15% 10% 

14% 0% 0% 0% 1% 3% 10% 

65% 0% 1% 5% 9% 26% N/A 

1. Extract from Table 4B of Breckland Retail and Town Centre Study 2010 

5.4 The results of the Household Survey are interesting. In particular:- 

Thetford is only retaining 65% of the available convenience spend of its host zone; Zone 1. This is 

a low retention rate for a town in Thetford’s position (namely freestanding with an immediate rural 

hinterland). We would expect a town like Thetford to achieve a much higher retention rate (75% to 

85%) for food shopping. 

Of the 35% of residents in Zone 1 not choosing to shop in Thetford for food shopping, the vast 

majority (32%) are choosing to leave the district altogether. This suggests residents are making 

relatively long and unsustainable trips for food shopping. From our own work (notably the public 

exhibition) it is clear the Morrisons at Diss and Asda at Bury-st-Edmunds, are popular destinations. 

Far higher, and more normal retention rates are achieved across the other zones surveyed. For 

example, within Zone 2, Dereham retains 78% of its host zone’s available spend. In Zone 2, 79% 

of the spend goes to either Dereham or Swaffham and in Zone 3, 83% of the host zone’s spend is 

spent at either Dereham or Watton. Localised retention rates of this order (i.e. 75% to 85%) are 



more like what we would expect to see. 

5.5 To check the findings of the NLP work in respect of Thetford and its immediate catchment area, we have 

commissioned our own Household Survey specific to Thetford and the immediate surrounding area. 

The purpose was to obtain a better and more up-to-date survey sample of where residents are choosing 

to do their food shopping (both main food shopping and top-up food shopping). The survey area (shown 

on Plan RPS1, Document 2) was broken down into a primary catchment area and a secondary 

catchment area. The primary area is that geographic area where Thetford should look to be the 

principal and main choice for food shopping. The secondary area is a wider area where Thetford would 

look to attract some customers but would not always be the first choice for food shopping for everyone. 

The two areas are defined by postcode sectors and are:- 

Table 6: RPS Household Survey: Primary and Secondary Catchment Areas 

Area Postcode Sectors 

Primary IP24 1, IP24 2, IP24 3, IP26 4, IP26 5, IP27 0 and IP27 9. 

Secondary IP22 2, IP31 1, IP26 6, IP28 8, PE33 9, IP25 7, NR17 1, NR17 2 and NR16 2. 

5.6 The primary area above corresponds to Zone 1 in the NLP Study. 

Document 2 

5.7 Across both areas households were asked where they undertook their main and top-up food shopping 

trips. The number of respondents from each area were weighted so that 60% of respondents were in 

the primary area and 40% in the secondary. Weighting to reflect the population of the respective 

postcode areas was also applied. 

5.8 For the primary catchment area the Survey showed residents undertook their main and top-up food 

shopping in the following locations. 

Table 7: Main Food and Grocery Shopping 

Store/Centre Primary Catchment 

Area 

Secondary Catchment 

Area 

Aldi, Thetford 8.8% 1.0% 

Sainsbury’s, Thetford 22.7% 2.0% 

Tesco Express, Norwich Road, Thetford 3.3% 0.5% 

Tesco, Kilverstone Lane, Thetford 22.7% 2.0% 

Farm Foods, Lime Kiln Lane, Thetford 0.3% 0.0% 

Iceland, The Burrells, Thetford 1.6% 0.0% 

Local Shops, Thetford 0.3% 0.0% 

Thetford Total 59.7% 5.5% 



5.9 For the secondary catchment area the results were:- 

Table 8: Top-Up Food and Grocery Shopping 

Store/Centre Primary Catchment 

Area 

Secondary Catchment 

Area 

Aldi, Thetford 3.6% 0.5% 

Sainsbury’s, Thetford 9.2% 0.5% 

Tesco Express, Norwich Road, Thetford 3.5% 0.0% 

Tesco, Kilverstone Lane, Thetford 7.4% 1.0% 

Farm Foods, Lime Kiln Lane, Thetford 1.0% 0.0% 

Iceland, The Burrells, Thetford 2.3% 0.0% 

Local Market, Thetford 0.7% 0.0% 

Local Shops, Thetford 2.9% 0.0% 

Thetford Total 30.6% 2.0% 

5.10 The surveys again reveal that Thetford fails to retain significant proportion of its available food spend. 

Indeed, it shows even lower retention rates than the NLP Survey. For example, across the primary 

catchment area the town as a whole retains just 59.7% of the main food spend and 30.6% of the top-up 

spend. For a freestanding market town such as Thetford these retention rates are surprisingly low. 

5.11 The survey also reveals that residents are not using the town centre for their food shopping (either main 

or top-up). Across the primary catchment area just 1.9% of residents cite town centre stores for their 

main food shop. For top-up shopping it is just 5.9% of residents. 

5.12 The findings of our Survey are not dissimilar from the findings of NLP in their 2010 Study with regard to 

retention rates in Thetford: 

5.13 In a situation of a freestanding market town with an immediate rural hinterland convenience shopping 

retention rates of 75% to 85% are far more usual and to be expected than a retention rate of 60% to 

65%. In short, Thetford’s low convenience shopping retention rate of 60% to 65% should be a cause for 

concern. It has the following immediate consequences:- 

People are travelling longer distances than necessary for their food shopping trips. This is 

unsustainable. 

Once, lost to Thetford for food shopping, residents are also likely to undertake other shopping and 

related purchases (cafes, restaurants, etc.) in those other towns they are visiting. This is to the 

detriment of Thetford’s, other retailers and the town as a whole. 

Low retention rates are indicative of poor existing food shopping provision or dissatisfaction with it. 

This runs counter to the Government’s support for choice and competition in shopping (PPS4, 

paragraph 10%). 



5.14 All of the above are, as we say, a cause for concern in land use planning terms and warrant action; 

namely improved and increase food shopping choice in Thetford with the aim of improving retention 

rates. 

5.15 From NLP’s 2010 work the TAAP makes comment on the need for additional food floorspace provision 

in Thetford over the plan period. In particular:- 

That the 2010 Study suggested less capacity than the earlier 2007 Study. 

What capacity there is should be directed to the new urban extension in the form of a small local 

supermarket. 

Any residual capacity (estimated at 330m² (net) convenience floorspace should be directed to the 

town centre. 

5.16 Against this emerging policy background it is worth noting that:- 

Retail capacity or ‘need’ no longer forms part of the policy test for retail proposals at national level. 

The capacity estimates are based on maintaining/not increasing market share. In short, the 

capacity estimate presumes Thetford will continue to retain just 65% of the available spend from 

Zone 1. 

5.17 In respect of the second point above, it is highly significant that Thetford and Zone 1 achieves a very low 

overall retention rate when compared against other zones and centres. So:- 

Within Zone 2 (Dereham) - 78% of residents do their convenience shopping in Dereham. 

In Zone 3 - 79% of residents do their food shopping in either Swaffham or Dereham. 

In Zone 4 - 88% of residents do their food shopping in Dereham, Swaffham or Watton. 

5.18 In our opinion Thetford should positively plan to increase its market share. By doing so it will retain 

shoppers in the town, which can only be to the benefit of other retailers in the town. Secondly, it will 

help to reduce unsustainable shopping trips to more distant towns (e.g. Diss). 

5.19 We consider Thetford should strive to achieve food shopping retention rates closer to those achieved 

across the other zones (i.e. 75% to 85%). Doing so would increase retail capacity. For example, if 

Thetford were to achieve the lowest of the above retention rates (78%) it would suggest a further 

£13.30M (2008 prices) of capacity at 2016. 



6 SEQUENTIAL ASSESSMENT 

6.1 As identified in Policy EC14.3 of PPS4 (see Section 4 of this Statement) a sequential assessment is 

required for all planning applications for main town centre uses (in out-of-centre locations) (over 200m²) 

that are not in accordance with an up-to-date development plan. Policy EC17 of PPS4 goes on to 

establish that such planning applications should be refused where the applicant has failed to 

demonstrate compliance with the requirements of the sequential approach. 

6.2 As such, a thorough sequential assessment has been undertaken in respect of the application proposals 

and this has had specific regard both to the requirements set out in PPS4 and the advice given in 

‘Planning for Town Centres: Practice Guidance on Need, Impact and the Sequential Approach’ 

(December 2009). Consistent with the advice of PPS4 we have assessed each of the sites against the 

tests of availability, suitability and viability as potential alternative locations for the proposed foodstore. In 

doing so we have had due regard to the PPS’s advice on the need to also show flexibility. 

a) The Search Area 

6.3 The DCLG’s Practice Guidance identifies that the first stage of the sequential assessment is to establish 

an area of search; it comments, at paragraph 6.22, that: 

“When considering applications, LPAs will need to consider the extent of the 

catchment area likely to be served by the proposal, and to then identify 

alternative sites located in existing centres within the catchment area. This 

will determine whether sites in other nearby centres may represent more 

appropriate locations in which to accommodate the scale and form of 

development proposed.” 

6.4 The extent of the study area is shown on the plan enclosed at Document 2 and described in detail in the 

preceding Section; it essentially comprises Zone 1 of the NLP Study. As agreed with Officers, the 

sequential assessment only considers sites (or vacant units) within, or on the edge, of Thetford town 

centre (as the ‘Key Centre for Development and Change’). 

b) Flexibility and the Scope for Disaggregation 

6.5 Policy EC15.1 of PPS4 requires that, in considering sites in or on the edge of existing centres, 

developers and operators demonstrate flexibility in terms of the scale of their proposals, their format; car 

parking provision; and the scope for disaggregation. It is, however, recognised in that policy (and 

reiterated at paragraph 6.30 of the Practice Guidance) that in the case of a single retailer or leisure 

operator, it is not the purpose of national policy to require development to be split into separate sites 

where flexibility in their business model and the scope for disaggregation has been demonstrated. Our 

assessment has had regard to this advice. 

6.6 This said, it is important to recognise that there is a critical mass or size of foodstore that must be 

achieved if it is to compete with and offer a realistic alternative to the other main foodstores, where 

residents are currently choosing to do their main food shop. If the foodstore is too small it simply will not 

provide a realistic alternative option. This would run counter to the Government’s long held support for 



choice and competition in shopping. By way of illustration some of the closest principal foodstores to the 

site are:- 

Table 9: Existing Foodstore Provision 

Store Approx. Net Convenience Floorspace (m²) 

Sainsbury’s, Thetford 2,267 

Aldi, Thetford 595 

Asda, Bury-st-Edmunds 2,100m² 

Morrisons, Diss 3,400m² 

Morrisons, East Dereham 2,268 

Sainsbury’s, Attleborough 1,324 

Sainsbury’s, Bury-st-Edmunds 2,800m² 

Tesco, Thetford 3,195 

6.7 The net convenience floorspace of the proposal would be circa 2,204m², i.e. it is of a size capable of 

competing, most importantly, with the Sainsbury’s and Tesco in Thetford; therein providing genuine 

choice and completion for residents. 

c) Site Assessment 

6.8 Consistent with Policy EC14.8 of PPS4, which advises applicants to discuss their proposals prior to 

submission and ‘seek to agree the type and level of information that needs to be included’ it has been 

agreed with officers from the Local Planning Authority that the scope of the sequential assessment 

extends to the consideration of the following:- 

Vacant premises in the town and within the PSA boundary of Thetford Town Centre. 

The six opportunities in Appendix 6 of the Breckland Retail and Town Centre’s Study (NLP, August 

2010). 

6.9 Sites have been considered on the basis of the PPS4 Practice Guidance advice regarding availability, 

suitability and viability, as set out in paragraph 6.37: 

“Availability – whether sites are available now or are likely to become 

available for development within a reasonable period of time (determined on 

the merits of a particular case, having regard to, inter alia, the urgency of 

need). Where sites become available unexpectedly after receipt of an 

application, the local planning authority should take this into account in their 

assessment of the application. 

Suitability – with due to regard to the requirements to demonstrate flexibility, 

whether sites are suitable to accommodate the need or demand which the 

proposal is intended to meet. 



Viability – whether there is a reasonable prospect that development will occur 

on a site at a particular point in time. Again, the importance of demonstrating 

the viability of alternatives depends in part on the nature of the need and the 

timescale over which it is to be met” 

i. Vacant Premises in the Town and within the PSA Boundary 

6.10 There are no vacant units within the PSA large enough to accommodate a retail foodstore of the scale 

proposed. This was accepted in respect of the Lidl proposal for a 1,612m² (gross) foodstore on London 

Road – in reporting that the application to Committee in June 2011 Officers concluded that ‘with regard 

to vacant properties none of the units in the town centre are large enough to accommodate Lidl’s 

business model’. No new units have become available to the market since that time. 

ii. Nathaniel Lichfield and Partners – Breckland Retail and Town Centre Study identified 

Development Sites 

6.11 Appraisal sheets for each of the six sites identified in Appendix 6 of the NLP report are set out within 

Document 3. However, for ease our conclusions on each site are set out below. 

Document 3 

6.12 Site 1: Community Hall, Well Street, Thetford: The site is too small at 0.2 ha to accommodate the 

application proposal. Furthermore, the Breckland Retail and Town Centre Study advises that the site 

could accommodate up to 8 small retail/A3 units. A single large format retail unit would clearly be at 

odds with this aspiration. Moreover, the site is in multiple ownership and is unavailable in the short term, 

as any development would be dependant upon relocation of the existing community facilities. For these 

principal reasons the site is neither suitable nor available for the development proposal. 

6.13 Site 2: Minstergate/Burrell Museum/Poundstretcher, Thetford: The Breckland Retail and Town 

Centre Study 2010 envisages development to the area to the north of Ministergate and adjacent to the 

Burrell Museum to include small specialist shops, Class A3 and D2 leisure uses. It further recognises 

that any development will have to be of high quality design and utilise the existing listed buildings. The 

TAAP further recognises the sensitivity of the site in terms of the existing listed buildings and envisages 

a focus on cultural and commercial uses, with the intensification of existing, rather than new retail uses. 

6.14 Given the need to retain and deal sympathetically with listed buildings, the site is unsuitable for the type 

of development proposed. Moreover the site is only said to be available in the medium to long-term 

which corresponds with the length of time left on the leases held by the main occupiers. The site is not, 

therefore, available for development within a reasonable period of time. 

6.15 Site 3: Bridge Street Car Park and Anchor Hotel, Thetford: At only 0.7ha the site is far too small to 

accommodate the proposed foodstore even when regard is had to flexibility in terms of format, etc. The 

Breckland Retail and Town Centre Study 2010 explains that the likely type of development for this site is 

small/medium scale A1 or A3 units along the river frontage. It also promotes alternative uses such as 

educational use or the retention of the surface car parking and bus station. The Study also outlines a 



number of development constraints associated with the site such as a proposed educational use, where 

render the site unavailable for retail development. Other constraints identified include the impact on the 

river setting, the need to replace lost car parking spaces, archaeology and flood risk issues. It is neither 

a genuinely suitable nor available alternative site. 

6.16 Site 4 Riverside Walk, Thetford: The site is too small (only 0.9ha) to accommodate the proposed 

development. The majority of the site also remains in active retail and commercial use and therefore is 

not currently available. It is unlikely to become available until the medium or long-term. The site is 

neither genuinely available or suitable for the application proposals or a flexible format of them. 

6.17 Site 5 Tanner Street Car Park. At approximately 0.2ha this site is too small to accommodate the 

proposed development or a flexible format of it. The Breckland Retail and Town Centre Study 2010 

acknowledges that comprehensive redevelopment would only deliver about 500m² of floorspace (in a 

single unit). The redevelopment of the site would also result in the loss of a number of car parking 

spaces which in themselves are seen to form an important function in terms of the Town Centre’s overall 

attractiveness to shoppers. The site is not, therefore, a suitable alternative to the application site. 

6.18 Site 6 Thetford Retail Park. Although there is one vacant unit (of only 428m²) on the site, the 

remainder of floorspace is already in quasi-retail use and is not available for redevelopment. Even if the 

site were available, it is too small to accommodate the proposed retail floorspace with car parking even 

allowing for a reasonable level of flexibility. The site is therefore both unsuitable and unavailable for the 

development. Furthermore, the site is in an out of centre location and, as such, is no more sequentially 

preferable than the application site. 

iii. Sequential Assessment Conclusions 

6.19 In accordance with PPS4, we have undertaken a thorough assessment of all vacant and potential 

development sites within Thetford Town Centre that are capable of accommodating the application 

proposals or a flexible interpretation of them. This assessment has clearly demonstrated that there are 

no suitable, available or viable sites to which the application proposals could otherwise locate. 

6.20 The absence of any sequentially preferable sites has been confirmed by virtue of the Lidl consent of 

June 2011; here Officer’s concluded that ‘there were also overriding constraints with regard to the six 

sites identified in Appendix 6 of the NLP report. These constraints included inadequate size of the site, 

availability, existence of Listed Buildings and current occupation.’ There has been no change in 

circumstance since that time. Further, the work undertaken by RPS in respect of the sequential 

assessment was submitted to Nick Moys, Principal Planner (Major Projects) at the pre-application stage. 

In an email, dated 19 th October 2011, Mr Moys states that ‘as requested, I have considered the 

submitted assessments of alternative sequential sites and can confirm that I would not wish to take 

issue with your conclusions on their suitability/availability. I am not aware of any other sequentially 

preferable sites that should be considered at the present time.’ The first ‘gateway test’ of PPS4 is, 

therefore, satisfied. 



7 RETAIL IMPACT 

7.1 In this section of the Statement we consider the question of retail impact. We do so in the context of the 

advice on impact provided in PPS4 and its accompanying Practice Guidance of December 2009. 

7.2 The impact test of PPS4 is enshrined in Policy EC17. That policy establishes that where an out-ofcentre 

proposal (not in accordance with an up-to-date development plan) would lead to significant 

adverse impacts in terms of any of the impacts identified in EC10.2 or EC16.1 then planning consent 

should be refused. The key here is that the test is one of significant adverse impact. Where the 

significant adverse threshold is not breached the policy requirement (again Policy EC17) is that the 

overall positive and negative impacts of a proposal (again by reference to EC10.2 and EC16.1) together 

with any local considerations should be weighed or balanced in forming a judgement about the proposal. 

7.3 In considering the impact test the Practice Guidance at paragraph 5.10 provides the following advice: 

“….In assessing whether an impact is significant, it should be 

remembered that any new development involving town centre uses 

will lead to an impact on existing facilities, and as new development 

takes place in one town centre this will enhance its competitive 

position relative to other centres. This is a consequence of providing 

for efficient modern retailing and other key town centre uses, and 

promoting choice, competition and innovation.” 

7.4 This is important overarching guidance. Nothing in PPS4 detracts from the Government’s support for an 

effective, innovative and competitive retail sector. Rather the PPS reiterates the Government’s 

commitment to it. The test or challenge for local planning authorities is to ensure that in providing for 

such an innovative retail sector, which inevitably will include proposals such as encompassed in this 

application, there should not be an unacceptable significant adverse impact on any relevant centre. 

7.5 A second obvious point here is that the impact test relates to impact on the defined centre, in this case 

Thetford town centre. It is not and never has been the Government’s objective to protect existing out-ofcentre 

retailers from commercial competition from their competitors. This is highly relevant in the case 

of Thetford given most food shopping occurs at out-of-centre locations. 

7.6 Within this overarching context we assess the proposals against the various ‘tests’ in Policy EC10.2 and 

EC16.1 of PPS4 and the guidance in the SSRA. The assessment is all within the context of the advice 

(at paragraph EC14.7) that ‘the level of detail and type of evidence and analysis required in impact 

assessments should be proportionate to the scale and nature of the proposal and its likely impact’. In 

looking at the question of impact, in the following paragraphs we utilise wherever possible the data 

contained within the NLP 2010 Retail Study. 

7.7 The following paragraphs deal with each of the impacts of PPS4 (policies EC10.2 and EC16.1) in turn 

below. First, however, we establish the turnover that the proposed foodstore could be expected to 

achieve. 



a) Turnover of New Floorspace 

7.8 It is anticipated that the proposed foodstore will be operated by an, as yet unconfirmed, national food 

retailer. That said, the two main national retailers not already represented in Thetford are Asda and 

Morrisons. The latest company average turnover rates (Retail Rankings 2010) for these two operators 

shows that Asda has a convenience goods sales density of £14,603m² and comparison goods sales 

density of £8,374m². The corresponding figures for Morrisons are £13,171m² and £6,462m². For the 

purpose of this Impact Assessment we have assumed turnover rates which are an average of the two; 

namely £13,887m² for convenience goods and £7,418m² for comparison goods. 

7.9 The proposed store will have a gross floorspace of 5,249m². Assuming a 60% net to gross ratio this 

would indicate a net sales area of 3,149m² of that sales area, we have assumed that 2,204m² will be 

devoted to convenience goods and 945m² to comparison goods, i.e. a 70%/30% split. Applying the 

average turnover rates to the net sales area suggest the proposed store would have a total turnover of 

approximately £37.62M of this £30.61M would be convenience goods and £7.01M comparison goods. 

b) Policy EC10 

7.10 Policy EC10.2 of PPS4 is applicable to all planning applications for economic development. It 

establishes a series of ‘impact considerations’ against which all development proposals should be 

judged. These criteria with our comments in respect of the application proposals are:- 

i. Whether the proposal has been planned over the lifetime of the development to limit carbon 

dioxide emissions, and minimise vulnerability and provide resilience to, climate change 

7.11 The proposed foodstore would have a wholly beneficial impact with regard to this criterion. The store 

itself will be designed to minimise its energy requirements and utilise renewable sources where possible. 

Appropriate measures to reduce energy demand and incorporate renewable sources will be determined 

at the detailed design stage, once an occupier has been secured. 

ii. Accessibility by a Choice of Means of Travel 

7.12 The site is well located in terms of pedestrian and cycle facilities. There are wide footways on either 

side of London Road that form connections with Thetford town centre, as well as nearby residential 

areas. These locations are also accessible by a number of ‘off-road’ and ‘traffic free’ cycle routes. The 

application site is also served by several bus routes (T1, T1A, 200/2 and 84) that operate from the bus 

stops at Forest Retail Park and St Martin’s Way. 

iii. High Quality Inclusive Design 

7.13 This criterion requires the proposal to secure a high quality and inclusive design, taking the opportunity 

to improve the character and quality of an area. At present, the site is vacant, comprising a part brick, 

part blue clad factory building that makes no contribution to the character and appearance of either 

Caxton Way or London Road. 



7.14 The appearance of the foodstore has been reserved for future determination. However, the Design and 

Access Statement submitted in support of the application explains the design rationale behind the 

development and includes a perspective of how the proposed foodstore could look. It shows that the 

comprehensive redevelopment of the site with a modern high quality building would only serve to 

enhance the character and quality of the area. 

7.15 The design of all foodstores have regard to the need to be inclusive and all stores are fully accessible 

and DDA compliant. 

iv. Economic and Physical Regeneration 

7.16 Again, the proposals are wholly positive with respect to this criterion. They will deliver very significant 

economic and physical regeneration on a vacant site which makes no contribution to Thetford’s 

economy. In summary, the proposals would:- 

Enable a food retailer not currently represented in Thetford to enter the market. This will clearly be 

to the benefit of consumer choice and competition and is important in terms of social inclusion. 

The proposals would represent a total investment figure of approximately £15M 

The proposals would deliver in the region of 250 jobs, which would be made available to local 

people. In addition, employment will be created during the construction of the store. By providing 

jobs for people who live locally the proposals will assist in the overall economic regeneration of 

Thetford. 

v. Local Employment 

7.17 The proposals will be positive in terms of impact on local employment. Currently, the application site 

yields no jobs, nor has it done so since 2009. It is understood from the previous occupier (Tulip Ltd) that 

the site previously employed between 100 and 200 people. 

7.18 In contrast, the proposed retail development will deliver an estimated 250 jobs in addition to which there 

will be jobs created during the construction of the proposal and for its ongoing maintenance (for 

example, cleaning, landscape maintenance, etc). The jobs created will be across a range of skill sets 

and will include managerial and admin positions, sales staff and back-up staff. The jobs created at the 

application site will be available to local people. This is particularly important given the high proportion 

(4.2%) of residents in the Thetford-Saxon Ward claiming Job Seekers Allowance (relative to the 

Breckland District average of 2.93%). In short, the proposed development will deliver real and tangible 

employment benefits that should carry very significant weight. 

b) Policy EC16 

7.19 Policy EC16 of PPS4 comprises the ‘Impact Assessment’ against which applications for main town 

centre uses that are not in a centre and which proposed in excess of 2,500m² (or any other threshold set 

out in a development plan) should be assessed. The proposals are in excess of the 2,500m² threshold 



and accordingly we set out in the following paragraphs an assessment of the scheme against the criteria 

of EC16.1. In considering the proposals against the various criteria in Policy EC16, we have also had 

regard, where appropriate, to the Practice Guidance. 

i. The Impact of the Proposal on Existing, Committed and Planned Public and Private 

Investment in a Centre or Centres in the Catchment Area of the Proposal 

7.20 At the outset it is worth noting that the proposals would represent significant private investment by the 

applicant in Thetford – this would have a tangible and immediate positive impact on the local economy. 

7.21 In terms of impact on in centre investment, the PPS4 Practice Guidance explains (at paragraph 7.17) 

that where a local planning authority or the private sector has identified town centre development 

opportunities and is actively progressing them, the impact on that investment will be material. The key 

considerations in assessing the effect on this planned investment (as set out in the Practice Guidance) 

and the way in which the proposals relate to these considerations are as follows:- 

What stage have they reached, e.g. are they contractually committed? Although opportunity sites 

have been identified in Thetford Town Centre through the Thetford Area Action Plan (TAAP) any 

scheme is at the very early stages in the development process. There is no known JV 

arrangement or development agreement in place with Breckland to deliver any of the site’s within 

the short term. 

The policy ‘weight’ attached to them, e.g. are they a key provision of the Development Plan? The 

opportunity sites are identified in the TAAP that has been submitted to the SoS and the EiP is 

scheduled for March. At this stage, the TAAP can only be afforded limited weight. 

Whether there is sufficient need for both? The opportunity sites, if they are to achieve the desired 

enhancement of Thetford’s overall retail offer, will primarily provide for higher order comparison 

retailing. The NLP Retail Study identifies capacity for 4,000m² gross new comparison floorspace 

across the district up to 2016 (paragraph 11.59) with, should the Thetford Urban Extension 

proceed, further capacity of 15,200m² of comparison floorspace by 2026. Given, particularly the 

new planned housing growth and the limited comparison offer of the proposals, there is ample 

need to still support the town centre sites. 

Whether they are competing for the same market opportunity or key retailers/occupiers? The 

intention of the Thetford Town Centre development sites must be to attract high order retailers 

(such as fashion) who will drive footfall. This is clearly a different area of the retail market to that 

which the application proposals seek to satisfy, which is a predominately convenience offer. 

Whether there is evidence that retailers/investors/developers are concerned? There is nothing to 

suggest there is concern regarding future investment. To the contrary, significant private sector 

investment in Thetford must be seen as positive in terms of investor confidence. 



ii. The Impact of the Proposal on Town Centre Vitality and Viability, including Local Consumer 

Choice and the Range and Quality of Comparison and Convenience Retail Offer 

7.22 Annex D of PPS4 establishes a series of indicators in respect of the health of a town centre; these have 

been given due regard in assessing the vitality and viability of Thetford town centre. Our detailed health 

check for Thetford appears as Document 4. In summary, however, it shows that:- 

The centre predominately comprises comparison retailers (25% of total units), including a number 

of major national multiples such as Argos, Boots, New Look and WH Smiths. 

The convenience offer in Thetford is more limited (Iceland and Roys in the town centre and Aldi 

and Farm Foods on the Thetford Retail Park, which is out-of-centre), although there are also a 

number of small independent European convenience stores in the centre itself. 

Yields in Thetford have remained consistent (c.9%) since 2000. 

There are early signs of investment in the town, such as the replacement bus exchange and new 

Thetford Forum building. 

There are 15no. vacant units (10% of total) in the centre, which are relatively dispersed and 

predominately in the secondary shopping frontages. The number of vacant units has decreased 

since the time of the NLP Survey (2009). 

Document 4 

7.23 In summary, Thetford performs well relative to the PPS4 indicators – this is confirmed by the 2010 NLP 

Study which identifies the following strengths:- 

Thetford is a historic market town with numerous listed and period buildings. It is the largest 

shopping and commercial centre in the southern half of Breckland. The household survey results 

indicate that 36% of residents normally use Thetford town centre for non-food shopping in the 

Thetford study area zone. 

The town centre also provides a range of service facilities including banks and building societies, 

restaurant and bars. 

The central shopping area is pedestrianised providing a traffic free shopping environment, and 

there is a natural circuit for pedestrians. There is good paving and street furniture throughout the 

centre. 

The vacancy rate for the town centre is below the national average which suggests demand for 

premises is relatively strong, and there are fewer vacant units in the centre than there were at the 

time of the 2004 Study. ” 



iii. The Impact of the Proposal on the Allocated Sites outside Town Centres being developed in 

accordance with the Development Plan 

7.24 As outlined in Section 3 of this Statement, an outline planning application has been submitted by The 

Crown Estate and Kilverstone Estate for the Thetford Urban Extension; this is the principal allocation in 

both the adopted Breckland Core Strategy and the emerging TAAP. Although that application envisages 

a quantum of local retail units (to serve the local population) the scheme is residential (500 houses) and 

employment (22ha) led. The application proposals would in no way prevent this scheme from being 

delivered. 

iv. In the context of a retail or leisure proposal, the impact of the proposal on in centre 

trade/turnover and on trade in the wider area, taking account of current and future consumer 

expenditure capacity in the catchment area up to five years from the time the application is 

made, and, where applicable, on the rural economy 

7.25 Again, the PPS4 Practice Guidance gives a helpful explanation as to the way in which this impact should 

be assessed. Importantly, paragraph 7.29 of that Guidance states that: 

“It will be necessary to balance the desirability of maintaining and enhancing 

the turnover of existing centres with the benefits of improved consumer 

choice, competition and access to new facilities. In this respect, there are no 

meaningful benchmarks of what constitutes an ‘acceptable’ level of trade 

diversion resulting from such proposals. The relevant factors will depend on 

the circumstances of each case.” 

7.26 It goes on, at paragraph 7.32, to advise that: 

“Where a centre is experiencing falling rents, high levels of vacancy and 

declining footfall, even modest levels of trade diversion can have significant 

adverse impacts. Where centres are vital and viable, and existing 

retailers/leisure operators are achieving high levels of turnover, they may be 

able to withstand high levels of trade diversion resulting from a proposal, 

although this does not mean in itself that such impacts are acceptable. In 

most cases, unless there is clear evidence of a significant impact on turnover 

likely to undermine the vitality and viability of the centre, the negative effect 

of trade diversion needs to be balanced against any positive town centre or 

wider impacts as part of reaching an overall judgement.” 

7.27 NLP’s analysis certainly does not suggest Thetford is a weak or vulnerable centre and that is confirmed 

by our own health check. 

7.28 Annex D of the PPS4 Practice Guidance sets out a framework for making judgements about the likely 

extent of trade diversion – where possible, this framework has been adopted in the following analysis. 

Step 1: Establish the Base and Design Years and Define the Catchment Area 

7.29 Paragraph D.2 of the Practice Guidance advises that for site specific proposals the design year should 

normally be taken as one to two years after the likely completion of a development. Mindful of this 

advice and assuming completion of the development by the end of 2013, we have taken a design year 



of 2016. This is consistent with one of the study years adopted in the NLP Study and, as such, assists 

comparison. It is also a design year that is consistent with the Practice Guidance advice which suggests 

studies should not look more than five years ahead. 

7.30 The primary catchment area for the purposes of the study comprises Zone 1 of the NLP Retail Study. 

This represents Thetford’s host zone; namely that area for which the town should reasonably look to 

serve every day shopping needs. We have also defined a secondary catchment area. This area 

beyond the primary is the area from which some shopping trips to Thetford can be expected but for 

which Thetford will not be the prime or necessarily first choice destination. The extent of the catchment 

area is shown on the plan at Document 2. 

Step 2: Examine ‘no development’ Scenario 

7.31 The Practice Guidance, at paragraph D.6, advises that two considerations need to be taken into account 

in examining the ‘no development’ scenario, as follows: 

Commitments/cumulative impact i.e. schemes with planning permission, the likelihood of them 

being implemented and their potential scale and significance (in addition to the proposals). 

The ‘fallback’ scenario, i.e. whether there is an extant permission or permitted development rights. 

7.32 In the context of the above advice it is relevant that:- 

There is an unimplemented commitment within Thetford. As discussed earlier, Lidl have consent 

for a 1,280m² (net sales) new discount foodstore on London Road, Thetford. We see no reason to 

believe this will not go ahead and hence we have accounted for it in our analysis. 

We have similarly allowed for the consented extension to the Tesco store. 

There is no relevant ‘fall back’ position with the site. The site does not benefit from existing use 

rights for retail purposes. 

Step 3: Assess Turnover and Trade Draw 

7.33 In terms of the turnover of the proposed floorspace, the Practice Guidance (at paragraph D.14) 

recognises that use of average turnover levels derived from company accounts can provide a basis 

upon which to gauge possible turnover of a development. As set out earlier, in this case, the net sales 

floorspace proposed is 3,149m². Applying an average turnover rate as detailed in paragraph 7.8, the 

total turnover of the development would be circa £37M of this the convenience turnover would be 

£30.6M 

7.34 At Document 5 to this Statement, we set out our trade draw assessment. It essentially illustrates from 

where the store will draw its convenience trade. Therein, it shows the likely impact of the additional 

floorspace on Thetford town centre. This assessment has been drawn up with reference to the NLP 

Household Survey and our own more recent Household Survey. Both provide snap shots of residents’ 



existing food shopping habits. In the Table at Document 5 the available expenditure at 2016 and the 

turnover of existing retailers (in the absence of a new store) are derived directly from the NLP 2010 

Study (Table 7B). The only judgement we have made, based on the two household surveys, is how 

shopping patterns would change with the proposed store. 

Document 5 

7.35 From our most recent Survey certain features emerge about current shopping patterns in Thetford (and 

indeed were apparent from the NLP Survey). In particular:- 

Thetford as a whole is only retaining about 60% of the PCA’s main food spend. For top-up 

shopping it retains only 30% of the spend. 

Unsurprisingly, the out-of-centre Tesco and Sainsbury’s stores are the principal locations where 

people do food shopping (both main and top-up). 

Of the 60% of people who do their main food shop in Thetford, 45% go either to Tesco or 

Sainsbury’s. 

The next most popular store, attracting just under 9% of the main food spend is the Aldi. This 

again is an out-of-centre store. 

Thetford town centre itself attracts just 1.9% of the main food spend and 5.9% of the top-up spend. 

7.36 Mindful of the above characteristics, we summarise in the table below where the principal impacts 

(convenience spend) of the new store will fall. 

Table 10: Trade Draw of the Proposed Store, 2016 

Centre or Store Turnover per 

the Proposed 

Store £M 1 

Trade Draw to 

Proposed Store 

% 

Trade Draw 

£M 

Post Impact 

Turnover £M 

Impact % 

Sainsbury’s 32.40 30% 9.18 23.22 28.3% 

Tesco 39.77 20% 6.12 33.65 15.4% 

Other Thetford Retailers 17.80 5% 1.53 16.27 8.6% 

Retailers Beyond 

Thetford but in the PCA 

Inflow from beyond the 

PCA 

- 35% 10.71 

- 10% 3.06 

Total - 100% 30.61 

Source: 1 Table 7B, NLP 2010 Study 

7.37 None of the above impact levels are sufficient to cause concern nor come close to constituting a 

‘significant adverse impact’. Indeed it is highly telling that the principal impacts will fall on the town’s 

existing two out-of-centre foodstores; Tesco and Sainsbury’s. In planning terms impact on those stores 

is of no concern. This is because:- 



They are out-of-centre stores and therein not deserving of policy protection. 

Providing a new store to compete with those existing stores will add to consumer choice and 

competition in retailing which is supported by the Government. 

Both of the out-of-centre stores trade well and, in our opinion, are well placed to withstand the 

competition. 

7.38 Beyond the Sainsbury’s and Tesco, impact on the other Thetford retailers (both in centre and out-ofcentre) 

is predicted to be £1.53M or 8.6%. In respect of this it is worth noting that:- 

The bulk, we estimate £1.22M, will fall on the Aldi and proposed Lidl. Both again are out-of-centre 

stores and impact on them is not a planning concern. 

Actual impact on the town centre retailers excluding Aldi and Lidl (both out-of-centre) is just 

£0.31M or 3.5% (note: this includes impact on Tesco Express and Farm Foods which are 

technically out-of-centre). This is in no way a cause for concern and certainly does not amount to 

significant adverse impact. 

Even allowing for our predicted impact, the town’s retailers (excluding Sainsbury’s and Tesco) will 

still achieve a combined turnover of £16.27M. This compares against their benchmark turnover 

(NLP Table 1A plus Lidl) of £13.27M . In short, they will remain in a very healthy trading position. 

7.39 We turn now to the store’s non-food turnover. The comparison turnover of the store is predicted to be 

circa £7.01M (paragraph 7.9). Again, given existing shopping patterns and the propensity for 

supermarkets to compete most directly with other supermarkets the principal comparison impact will fall 

on the other two supermarkets. Accordingly, we have estimated that of the store’s comparison trade, no 

more than 5% (£0.35M) will be drawn from existing town centre retailers. 

7.40 The NLP 2010 Study (Table 2A) confirms that the net comparison floorspace of Thetford town centre is 

circa 6,400m². Earlier Table 12.2 at paragraph 11.34 confirms the average sales density of that 

floorspace is circa £4,206m². This suggests the total comparison turnover of the town centre is about 

£27M. 

7.41 On this town centre comparison turnover (£27M) the proposed store would have an impact of just 1.3%. 

Again, not a level that should give any cause for concern. 

Step 4: Assess Impact 

7.42 In assessing the impact of a proposal on the baseline position, the Practice Guidance advises, at 

paragraph D.30, that two factors need to be taken into account, as follows: 

“First, it will always be relevant to consider the character of the 

development proposed, to judge its likely trading impact. There is a 

general assumption that ‘like affects like’, so, for example, in an area 

already served by large modern foodstores, the effects of a new large 



food superstore are likely to fall disproportionately on the existing 

competing stores. Their proportionate impact on local independent 

retailers, or discount foodstores for example may be less. 

Second, it is relevant to consider distance, based on the assumption 

that generally consumers will seek to use the closest comparable 

facilities. So, for example, if in a given zone a relatively small 

proportion of trade is attracted to a facility which is similar to, but 

considerably further away from the proposal in question, it is likely to 

have a disproportionate effect on that facility.” 

7.43 With this advice in mind the following judgements were made in defining the likely trading impact of the 

proposed floorspace:- 

The majority of the store’s turnover would be drawn from comparable retailers, namely the other 

large supermarkets within Thetford. These are both in out-of-centre locations. 

Next a significant proportion of the store’s trade (we estimate 35%) will be drawn from retailers 

beyond Thetford. This is recaptured trade and, for example, will be derived from residents no 

longer driving to the likes of Morrisons at Diss or Asda at Bury-st-Edmunds. 

Finally, an element of trade will be drawn from Thetford’s existing town centre retailers. This, 

however, we consider will be small given few people are using the town centre for their main food 

shopping. 

Step 5: Consider the consequences of impact on existing centres and facilities 

7.44 Paragraphs D.31 to D.39 of the Practice Guide gives advice on the ‘final and most important step’ in the 

impact assessment stage, namely examining the consequences of that impact. The advice states that: 

A key factor likely to influence the significance of levels of impact is the current performance of 

existing centres. 

Impacts should be considered on the vitality and viability of the whole of a centre or centres, not 

simply on individual facilities which may be similar to the proposed development. 

The significance of any impacts will be a matter of informed judgement and depend on the 

individual circumstances of the locality and type of centre or facility. 

7.45 In the context of the above, we would comment as follows: 

The proposed floorspace would draw the largest proportion of its trade from comparable facilities, 

namely the large supermarkets. These stores are in out-of-centre locations and are afforded no 

policy protection and therefore impact is not a concern. 

The two principal supermarkets are trading at healthy levels. They are, as such, well placed to 

withstand the competition and indeed providing a new store will ease store congestion and add to 

customer choice. Both are objectives of Government guidance. 



Neither of the supermarkets will experience impacts such that there should be any fear about their 

continued successful trading. 

Overall, impact on Thetford town centre (both convenience and comparison) will be just 1.8%. This 

is not an impact level that can give any cause for concern. 

7.46 In respect of the third bullet point above (i.e. impact on Thetford town centre) some insight on what 

might or might not be an unacceptable impact level is provided by recent appeal decisions. In particular, 

in June 2011 consent was granted at appeal for a new Tesco foodstore on an out-of-centre site in Alton, 

Hampshire. The town already had an existing town centre Sainsbury’s supermarket and consent for a 

new Morrisons or Waitrose store (circa 1,673m²m²) on an edge-of-centre site. The Tesco store had a 

gross floorspace of 6,112m². 

7.47 The Inspector’s appeal decision appears as Document 6. From it, it is of note that:- 

The Town Council predicted impact on the town centre of 29.4%. 

The appellant’s corresponding figure was 24.7%. 

The main impact would fall on the town centre Sainsbury’s. 

Impact would also fall on the town centre M&S, Iceland and Co-op. 

The Inspector thought it likely one or more of the smaller foodstores (i.e. M&S, Iceland or the Coop) 

would close. 

7.48 Notwithstanding this the Inspector concluded that:- 

“30. Retail impact assessment is not a precise science and there is 

a need to exercise judgement. Whilst I do not attempt to 

identify a specific figure for trade impact, I do find that the 

cumulative impact of the appeal proposal together with one or 

two new stores in Alton would be likely to cause a significant 

level of trade diversion from the town centre, resulting in the 

potential closure of stores such as Co-op, Iceland and/or Marks 

and Spencer. Nevertheless, in view of the limited offer 

currently available in Alton, and the consequent problems 

identified by local residents, I agree with my colleague that 

there is a need for shoppers to have more choice in their 

purchase of convenience goods….”. 

Document 6 

7.49 Like Thetford, Alton is a freestanding market town serving a predominately rural hinterland. Equally, like 

Thetford, Alton is close to other towns (Basingstoke and Guildford) where residents are already 

choosing to undertake main food shopping trips, Tellingly, whilst smaller (population wise) than Thetford 

and without the planned significant growth of Thetford it was felt the town could support three large 

modern supermarkets without unacceptable consequences. 



7.50 The Alton position is mirrored in the Shropshire town of Oswestry, whose population is 18,300. In the 

summer of 2010 consent was granted there for the town’s third superstore on an out-of-centre site (the 

Smithfield) notwithstanding there was already a town centre Sainsbury’s and an edge-of-centre 

Morrisons. Again, retail impact was not considered an issue. Again, Oswestry did not have the same 

level of planned growth housing as Thetford. 



8 CONCLUSIONS 

8.1 The proposed development will deliver a new foodstore for Thetford on a site which has stood vacant 

since 2009 and for which there is no need or demand for employment use or development. There is 

other, better located, employment land across the town and in the absence of this development going 

ahead, the site would no doubt continue to lie idle for years to come. 

8.2 The proposal will deliver investment of circa £15M in the town and result in about 250 new jobs being 

created; the vast majority of which will be available to local people. 

8.3 There is overwhelming support for the proposal. From the Public Exhibition held in December 2011 and 

subsequent returned comments cards, some 90% of respondents confirmed that in principle they would 

support the scheme. In particular, the provision of job opportunities and further choice and competition 

in food shopping were seen as the key benefits of the scheme. 

8.4 Consistent with Policy EC15 and EC17.1 of PPS4, a full sequential assessment has been carried out in 

support of the planning application. It shows that there are no sequentially preferable sites which are 

genuinely available, suitable or viable to which the development might more appropriately locate. That 

sequential assessment has been discussed and agreed with Officers of the District Council before 

submission of this application. 

8.5 Our findings on the sequential approach are consistent with the findings when the Lidl application was 

considered in 2011. That proposal was for a foodstore with a net sales floorspace of 1,280m². In 

determining that application, Officers and the District Council were satisfied that there was no 

sequentially preferable site to which the Lidl store could locate. In sequential terms the position has not 

altered since then. 

8.6 Our Retail Assessment also addresses the second test of EC17.1; namely retail impact. We conclude 

that the proposal will not have a significant adverse impact on Thetford Town Centre. Indeed, the 

combined convenience and comparison goods impact of the proposal on town centre retailers will be 

just 1.8%. This is not an impact level that gives any cause for concern. 

8.7 Our conclusions on impact are not unsurprising given the existing shopping habits of Thetford’s 

residents as revealed in both the NLP 2010 Study and our own Household Survey. Those surveys show 

that few residents use the town centre for either their main food or top-up shopping; the respective 

percentages are 1.9% and 5.9%. Conversely, of those residents who do choose to do their main 

shopping in Thetford, the vast majority visit either the out-of-centre Tesco or the out-of-centre 

Sainsbury’s store. Impact on those retailers is not a planning concern. 

8.8 Thetford has a low retention rate for food shopping. The surveys reveal that of residents in Zone 1 

(Thetford’s host zone) only 60% to 65% choose to do their food shopping within the town. This is low 

and is a cause for concern. It means that residents are leaving the town for food shopping on 

unsustainable trips and that once lost to the town they are likely to undertake other purchases (for 

example, fashion purchases) whilst elsewhere. It is in the town’s interest to increase its market share 



and retain expenditure currently going to other towns. 

8.9 These proposals will do exactly that. They will improve choice and competition in shopping and thereby 

help to retain shoppers within Thetford. If these proposals are successful we estimate that Thetford 

would increase its market share to circa 75%. This is closer to retention rate achieved by other zones 

within the Breckland Retail Study Area, albeit still lower than those zones which are achieving retention 

rates of between 78% to 83%. 

8.10 For the above reasons we conclude that these proposals satisfy the policy tests of both national 

guidance (notably PPS4) and local planning policies. In those circumstances, planning consent can and 

should properly be granted to them. 



PLANNING HISTORY SCHEDULE 

Ref No. Proposal Decision Date 

T.660 Proposed erection of factory. Conditional 

Approval 

T.712 Proposed revisions to factory premises. Unconditional 

Approval 

T.1148 Proposed 48’0” high extension to existing Isley 

exhaust. 

T.1194 Proposed erection of suction tank and pump house 

for sprinkler installation. 

Unconditional 

Approval 

Unconditional 

Approval 

3/76/2232 Extension to vacuum flask factory and storage area. Conditional 

Approval 

3/78/3262 Single storey building for use as bank. Unconditional 

Approval 

3/84/0071 Additional loading bay. Unconditional 

Approval 

3/84/1362 Install heat recovery system. Conditional 

Approval 

3/96/0277 Erection of factory, office and warehouse buildings 

(Use Classes B1, B2 & B8) car parking & 

associated highway. 

3PL/1999/0132 Siting of waste energy recovery unit and vertical 

chimney flue. 

Conditional 

Approval 

Conditional 

Approval 

3PL/2002/0285 Amendment to external front elevation. Conditional 

Approval 

04.11.63 

01.04.64 

25.01.67 

07.06.67 

14.12.76 

23.01.79 

08.02.84 

13.11.84 

15.04.96 

31.03.99 

12.04.02

© Crown Copyright. All rights reserved. Licence number AR 161462. 

THETFORD RETAIL CATCHMENT AREA RPS 1 

Key 

Primary Retail 

Catchment Area 

Secondary Retail 

Catchment Area 

REF: JLL0435 

CHECKED BY: AT 

CLIENT: Location 3 Properties 

REVISION: 00 

DATE: February 2012 PREPARED BY: JP 

STATUS: Final 

FILE PATH ========> H:\Planning\Jobs Open\JBB8025\5 - JLM0435 Former Tulip Factory Thetford DandA 

SCALE: NTS 

14 Cornhill, London, EC3V 3ND 

T: 020 7280 3200 F: 0121 7283 9248 W: www.rpsgroup.com

SITE 1: COMMUNITY HALL, WELL STREET, THETFORD 

Site Area 

Existing and Adjacent 

Uses 

Distance from PSA 

Planning Policy 

Appraisal 

c.0.2ha 

The majority of the site is currently in community use, occupied by the Carnegie Room building which 

comprises three rooms for hire available for dances, meetings, wedding receptions etc. The building 

can hold a seated audience of c.350 people. On the northern corner of the site are the offices of 

Rudlings and Wakelam solicitors. 

Well Street comprises a number of independent retail units such as Waterman’s Jewellers, Finishing 

Touches Beauty Salon and St. Nicholas Hospice Care. To the south-east of the site is the Thetford 

Library and a commercial unit; while to the south-west lies the Mulberry Restaurant. To the west is the 

Guildhall Museum and Art Gallery (listed). 

Within the PSA. 

Core Strategy - The site is unallocated, however falls within the Thetford town centre boundary. 

Policy CP7 is, therefore, relevant which seeks to maintain and enhance vitality and viability by 

permitting appropriate retail, leisure, cultural and business proposals. 

The site is within a Conservation Area. 

TAAP - Policy TH1 identifies the site as a key site for development and change in the PSA. The PSA 

is the focus for new comparison and convenience retail and commercial leisure uses. Complementary 

office, commercial, educational and community-related uses would also be appropriate, given the 

aspiration to strengthen the role of Thetford Town Centre. 

The site is too small at 0.2 ha to accommodate the application proposal. Furthermore, the Breckland 

Retail and Town Centre Study advises that the site could accommodate up to 8 small retail/A3 units. A 

single large format retail unit would clearly be at odds with this aspiration. Moreover, the site is in 

multiple ownership and unavailable in the short term as any development would be dependant upon 

the relocation of the existing community facilities. For these principal reasons the site is neither suitable 

nor available for the development proposal, or a flexible format of them.

SITE 2: MINSTERGATE/BURRELL MUSEUM/POUNDSTRETCHER, THETFORD 

Site Area 


Uses 



Appraisal 

c.1.7ha 

The site is currently occupied by the Burrell Museum together with a number of retail units, including 

Poundstretcher, Wilkinson and Iceland. The site also includes the Bidwell Court flats, residential 

dwellings along Ministergate and a large public surface car park (c.150 spaces). There are 4no. 

vacant units on the site, including a large prominent listed building on the corner of London Road and 

Nicholas Street. In total, there are ten listed buildings on the site. 

The northern boundary of the site is formed by London Road, beyond which are residential units and 

the Cluniac Priory site. To the south-east is the Little Ouse River; whilst to the east is St Nicholas 

Street and the Breckland Council Offices. To the south of the site is the rear of retail and commercial 

units, many of which are also listed. 


Core Strategy – The site is not allocated, however, falls within the Thetford Town Centre boundary. 

Policy CP7 of the Core Strategy seeks to maintain and enhance the vitality and viability of the town 

centre through appropriate retail, leisure, cultural and business proposals. 

The western part of the site is within a Conservation Area. 

TAAP – Policy TH1 identifies the site as a key development opportunity in the PSA, which will be the 

focus for new comparison and convenience retail and commercial leisure uses. 

The TAAP explains that the Minstergate area will accommodate a new bus interchange, including 

sensitive redevelopment and repair of the listed buildings on St Nicholas Street. It also encourages the 

retention of the other listed buildings; with a focus on cultural and commercial uses, and the 

intensification of existing retail uses. The TAAP envisages that a Town Centre Masterplan will be 

prepared to provide detailed guidance on the future development of the area. 

The Breckland Retail and Town Centre Study 2010 envisages development to the area to the north of 

Ministergate and adjacent to the Burrell Museum to include small specialist shops, Class A3 and D2 

leisure uses. It further recognises that any development will have to be of high quality design and 

utilise the existing listed buildings. The TAAP further recognises the sensitivity of the site in terms of 

the existing listed buildings and envisages a focus on cultural and commercial uses, with the 

intensification of existing, rather than new retail uses. 

Given the need to retain and deal sympathetically with listed buildings the site is unsuitable for the type 

of development proposed. Moreover the site is only said to be available in the medium to long-term 

which corresponds with the length of time left on the leases held by the main occupiers. Therefore, the 

site is unavailable for development within a reasonable period of time.

SITE 3: BRIDGE STREET CAR PARK AND ANCHOR HOTEL, THETFORD 

Site Area 


Uses 



Appraisal 

c.0.7ha 

The site comprises a public surface car park and a vacant hotel. 

The site is bounded to the north-east by the Little Ouse River; to the north-west by Bridge Street and 

beyond this a church. To the south-west is Old Bury Road, beyond which is the Thetford Grange 

School. To the south-east is the Thetford Courthouse and residential units. 


Core Strategy – The site is not allocated, however, falls within the Thetford Town Centre boundary 

and a Conservation Area. 

TAAP – Policy TH1 identifies this site as a key site for development and change in the PSA, which will 

be a focus for retail, commercial, leisure and complimentary uses. The TAAP envisages detailed 

guidance coming forward through a Town Centre Masterplan. 

At just 0.7ha the site is far too small to accommodate the proposed foodstore even when regard is had 

to the need to show flexibility. The Breckland Retail and Town Centre Study 2010 notes that the likely 

type of development for this site is small/medium scale A1 or A3 units along the river frontage. It also 

promotes alternative uses such as educational use or the retention of the surface car parking and bus 

station. 

The Study also outlines a number of development constraints associated with the site such as the 

proposal for educational use, possibly rendering the site unavailable for retail development. Other 

constraints identified include the impact on the river setting, the need to replace lost car parking 

spaces, archaeology and flood risk issues. 

The site’s location within the conservation area and adjacent to the River, add to the uncertainty over 

its availability mean that it is neither a genuinely suitable nor available alternative site.

SITE 4: RIVERSIDE WALK, THETFORD 

Site Area 


Uses 



Appraisal 

c.0.9ha 

The site comprises a car park of c.80 spaces together with a number of retail outlets; namely Argos, 

M&Co Clothing and Specsavers, as well as independent retailers. Other commercial units include 

William Brown Estate Agency, Lloyd TSB Bank and the Nationwide Building Society. The site is 

bisected by Riverside Walk which acts as a gateway from the pedestrianised routes via King Street 

and Riverside Walk to the riverside. 

The site is bounded to the south-west by the Little Ouse River, to the south-east by Riverside Walk, by 

the Bell Hotel to the north-east and King Street to the north-west. 


Core Strategy – The site falls within the Thetford Town Centre boundary, where retail, leisure, cultural 

and business proposals are acceptable (Policy CP7). The site also falls within a Conservation Area. 

TAAP – The site is identified (Policy TH1) as a key area for development and change in the PSA which 

is the focus for new retail and commercial uses. Policy TH1 further specifically encourages proposals 

to redevelop or enhance the Riverside Walk development and the relationship of the site to the 

waterfront. 

The site is too small (only 0.9ha) to accommodate the proposed development. The Retail and Town 

Centre Study 2010 identifies the Riverside Walk development as a medium to long-term opportunity for 

either comprehensive redevelopment (up to 2,000m²) or as an extension to the existing development 

(into the car park to the rear of Argos). The loss of public car parking (which was c.80% utilised at the 

time of the RPS Survey) and cost of redevelopment are identified as development constraints. 

The majority of the site also remains in active retail and commercial use and therefore is not currently 

available. It is unlikely to become available until the medium or long-term. 

The site is neither genuinely available or suitable for the application proposals or a flexible format of 

them.

SITE 5: TANNER STREET CAR PARK, THETFORD 

Site Area 


Uses 



Appraisal 

c.0.2ha 

The site comprises a surface level public car park and community hall. 

The site is bounded to the north by the rear of a number of retail units which front King Street; to the 

east by the rear of retail units fronting Well Street and to the south by a public car park. The Methodist 

Church to the north-west is a Listed Building. 


Core Strategy – The site falls within the Thetford Town Centre boundary and a Conservation Area. 

TAAP – The site is identified as a key site for development and change within the PSA. Policy TH1 

seeks to focus new retail and leisure uses within these areas. 

At approximately 0.2ha this site is too small to accommodate the proposed development or a flexible 

format of it. The Breckland Retail and Town Centre Study 2010 acknowledges that comprehensive 

redevelopment would only deliver about 500m² of floorspace (in a single unit). The redevelopment of 

the site would also result in the loss of a number of car parking spaces which in themselves are 

important in terms of the vitality and viability of Thetford Town Centre. The site is not, therefore, a 

suitable alternative to the application site.

SITE 6: THETFORD RETAIL PARK 

Site Area 


Use 



Appraisal 

c.0.6ha 

The site forms part of the Thetford Retail Park and comprises an industrial/warehouse vacant unit 

(428m² gross), Centre Tyres, Tile Store and Thetford Town garage. 

The site is bounded by the north-west by Aldi; to the east by retail units including Halfords, Jollyes Pet 

Food Superstore, Farmfoods and associated surface level car parking. 

Within the Retail Park is a small site (c.450m²) that benefits from a retail consent for non-food goods; 

that consent has not been implemented and was recently renewed (application 3TL/2010/0045/TC). 

The site is in an out-of centre location as defined by PPS4, i.e. it is over 300m from the edge of the 

PSA. 

Core Strategy – The site is unallocated. 

TAAP – Policy TH1 of the TAAP identifies a series of key development opportunities in the PSA. It 

then goes on to state that ‘elsewhere within the town centre a further key site is the Thetford Retail 

Park. This will be an area where the intensification of retail activity and new commercial leisure will be 

permitted as well as improved walking and cycling walks.’ 

The Breckland Retail and Town Centre Study 2010 identifies the site for ‘large format retail warehouse 

units’ of up to 3,000m² (gross). 

Although there is one vacant unit (of only 428m²) on the site, the remainder of floorspace is already in 

quasi-retail use and is not available for redevelopment. There is also a development site located on 

site, which has the benefit of bulky goods retail consent. The existing vacant unit is more suited to a 

trade counter style use and even if it were available, it is too small to accommodate the proposed retail 

floorspace with car parking even allowing for a reasonable level of flexibility. The same can be said of 

the development opportunity which is also of insufficient size to accommodate the application 

proposals or a flexible form of them. 

Thetford Retail Park is therefore both unsuitable and unavailable for the development. Furthermore, 

the site is in an out of centre location and, as such, is no more sequentially preferable than the 

application site.

Overview of Thetford Town Centre 

THETFORD TOWN CENTRE HEALTH CHECK 

Thetford, which is Norfolk’s fourth largest settlement, is the principal retail, service and employment centre in the south of 

the District. Policy SS1 ‘Spatial Strategy’ of the Breckland Core Strategy and Development Control Policies DPD 

(adopted December 2009) identifies Thetford as the focus of growth within the Breckland District. It is anticipated that 

6,000 homes and 5,000 new jobs are to be delivered in the town up to the end of the plan period. 

Thetford is identified in Policy CP7 ‘Town Centres’ of the Core Strategy as a “key centre for development and change”. 

The maintenance and enhancement of the vitality and viability of the town is therefore a key priority of emerging planning 

policy within the area. 

The primary shopping areas of the town comprise King Street, Market Place, Guildhall Street, Well Street, and the north 

side of Riverside Walk. The secondary shopping frontages include Whitehart Street and Bridge Street. Surrounding land 

uses comprise a mix of uses such as open space/historic gardens to the north, south, east and west: residential to the 

north west and south west and the Thetford Retail Park to the north-east. 

Overall, Thetford has a reasonable range of retail and service uses for a centre of its size. 

Diversity of Uses and Retailer Representation 

Thetford Town Centre comprises a range of comparison, convenience and service sector floor space. However, 

comparison and service uses are the most prevalent. The principal retail areas in the centre are located around 

Minstergate, Riverside Walk and King Street. 

Photograph 1: Part of Thetford’s Principal Retail Area Located Along Kings Street 

The latest GOAD Town Centre Report for Thetford (May 2008) identifies that Thetford has approximately 73,061m 2 

(239,700ft²) of retail floorspace. The GOAD Plan was updated by RPS in November 2011 and is included as Appendix 

1. 

Appendix 1 

RPS’s survey indicated that Thetford Town Centre has a total of 151no. retail/service units. Table 1 below sets out the 

mix of uses in Thetford Town Centre, compared with the national averages. A full schedule of identified retail units within 

rpsgroup.com/london

the town is contained at Appendix 2. 

Table 1: Thetford Town Centre Use Class Mix by Unit 

Type of Unit Units 

% of Total Number of Units 

% National Average 

Comparison Retail 38 25 41.5 

Convenience Retail 13 9 8.83 

A1 Services 18 12 

35 

A2 Services 30 19 

A3 and A5 24 16 

A4 2 2 

Vacant 15 10 13.49 

Other 11 7 

Total 151 

Appendix 2 

As shown above, 25% of the units within the town are comparison retailers compared to a UK average of 41.5%. 9% of 

the units within the town are currently in use as convenience retailing which is broadly in line with the UK average. 10% 

of all town centre units are vacant - this is below the national average of 13.49%. 

Retailer Representation 

Comparison 

Although below the national average (in percentage terms), Thetford has a good selection of comparison shops reflecting 

the centres role as one of the main town centre uses in Breckland. Major national comparison retailers represented in the 

centre include: Argos; Boots the Chemist; Clintons Cards; New Look; Superdrug; WH Smith; and Wilkinson’s. Roys Ltd. 

is also a considerably large sized independent shop along the primary frontage of Guildhall Street and occupies 

approximately 1,300m² of comparison floorspace. The store also includes an element of convenience floorspace. 

Convenience 

There is only one small convenience retailer (Iceland) located within the PSA (on Minstergate Road). The Aldi is located 

within Thetford Retail Park which is in an out-of-centre location. 

A number of smaller independent European convenience shops (i.e. Thetford Food Centre and Labas International) are 

located along secondary frontages such as Whitehart Street, King Street, Bridge Street, and Guildhall Street. Thetford 

Food Centre is located at the northern end of King Street towards Market Place and has a limited floorspace (350m²). 

Photograph 2: Thetford International Food Centre – King Street 

2

Services/Facilities 

The centre is well served by a number of high street banks such as HSBC (King Street), Natwest (King Street), Barclays 

(Bridge Street) and Lloyds TSB bank (King Street). All of these banks are located within the PSA of the town. 

Significant cultural and civic buildings are also either within the town centre. These include the Guildhall and Art Gallery, 

Thetford Library, Thetford Snooker Centre and Breckland Bingo and Social Club. Thetford also has a number of services 

to help meet the needs of the local community, including the Learning Resource and IT Centre, (Riverside Walk) and the 

Job Centre, (Castle Street). The town also benefits from several independent recruitment consultancies. 

There are also a number of cafes/bars, eating places and one nightclub within the town centre. Most notably is the Bell 

Hotel and public house which occupies a large floorspace on the edge of Bridge Street and Kings Street. 

Table 2 below provides a breakdown of the identified comparison shop uses by goods categories. 

Table 2: Comparison Shops by Goods Category within Thetford 

Type of Unit 

Thetford 

%UK 

Units % 

Average 

Clothing and footwear 9 6 11 

Furniture, carpets and textiles 0 0 3.53 

Booksellers, arts, crafts and stationers 5 3 4.31 

Electrical, gas, music and photography 6 4 3.96 

DIY, hardware and home wears 0 0 2.49 

China, glass, gifts and fancy goods 0 0 1.62 

Cars, motorcycles and motor access 1 1 1.23 

Chemists, drug stores and opticians 2 1 3.87 

Variety, department and catalogue 5 3 0.60 

Florists, nurserymen and seeds men 1 1 0.94 

Toys, hobby, cycle and sport 0 0 2.21 

Jewellers 2 1 2.06 

Charity, 

retailers 

Pets and other comparison 

7 5 3.72 

Total 38 

Commercial Yields and Forthcoming Developments 

Yield figures are usually expressed as a percentage and can be compared with returns on other investments. Low yields 

indicate that there are good prospects for rental growth. 

The Valuation Office Agency’s (VOA) Shopping Centre Yields Report for the period between October 2000 and July 

2008, demonstrates that the yield for Thetford Town Centre has remained very consistent over the 8 year report period. 

The figures show that there has been a marginal improvement from 9.25% to 9%. No more recent information on yields 

is available from the VOA. 

There are several signs of investment in Thetford. These include the replacement bus exchange and the new Thetford 

Forum building located at the old Anchor Hotel and Bus Station adjacent to the River. The existing bus interchange at the 

old Anchor Hotel site is clearly no longer fit for purpose. It lacks the services expected by visitors and users of a modern 

bus interchange. Feasibility and land assembly work necessary to create a modern, fit-for-purpose replacement in a 

prominent gateway location are well advanced. The site selected for the replacement interchange is located between St 

Nicholas Street and Minstergate. The existing bus station is to be relocated and replaced with a mixed use riverside 

development incorporating an element of retail together with a hotel and cinema. 

3

Norfolk Country Council and Breckland Council have recently announced funding support to the proposed Riverside 

development to be supplemented through a £1million investment from the Norfolk Infrastructure Fund. Works are also 

being undertaken to the Anchor Hotel Site to generally improve the appearance of the area in the short term whilst 

providing further information with regards to the future development of the town. 

Photographs 3 and 4: Regeneration is evident within the town through works to the Anchor Hotel and Thetford Bus Exchange 

Vacancies 

There are currently 15 vacant units identified within the town (10%). The location of these units is shown on the attached 

plan included at (Appendix 3). 

Appendix 3 

Whilst the vacant units are relatively dispersed around the town centre, the majority are found along Riverside Walk. This 

is perhaps indicative of the secondary shopping function of Riverside Walk and the lack of commercial interest in this 

location due to significantly reduced pedestrian footfall when compared to King Street. 

Pedestrian Flows 

A high level of pedestrian flow was observed throughout the pedestrianised area of the PSA, particularly on the main 

shopping frontage of King Street, Market Place and Guildhall Street. However, footfall was notably lower along Riverside 

Walk. 

4

Photograph 5: Comparisons in pedestrian footfall along King Street 

From the site visit it was apparent that the town centre did not benefit from an active evening economy. The town centre 

felt deserted outside the principal shopping hours. However, it is acknowledged that there are proposals to re-open King 

Street to 9am and then again from 7pm for a trial 12 month period as a means of encouraging investment/spend within 

the town centre during the evening period. 

Accessibility 

Thetford Town Centre is easily accessible by car. The nearest major urban centres are the cities of Norwich (32 miles), 

Cambridge (35 miles) and the towns of Bury St Edmunds (12 miles) and Newmarket (20 miles). 

The A11 links Attleborough and Thetford with Norwich to the north and Newmarket and Cambridge in the south-west. 

The A11 is programmed to be completely dualled in the coming years and on this basis will be able to sustain further 

economic growth. 

A number of bus and coach services operate from Thetford from the towns bus station located off Bridge Street. These 

provide access to destinations such as Dereham, Downham Market, Kings Lynn, North Wold, Diss, Wattan, Bury St 

Edmunds, Milden Hall and Brandon. Bus services within the town centre, the primary shopping area and edge of centre 

are, however, limited with stops located along St Nichols Street, the bus station off Bridge Street and also at Market 

Place. 

The town centre is also served by Thetford railway station, with National Express and East Anglian running services 

between Norwich and Cambridge and East Midland Trains from Norwich to Liverpool (via Sheffield and Manchester). 

The main shopping street of the town centre (King Street) is also pedestrianised, however, there are plans to re-open the 

town to vehicular traffic, on a trial basis. 

When visiting the town centre no cyclists were seen and there appeared very few facilities for cyclists. 

In addition to on street parking, there are also a number of car parks (9 in total) which collectively serve the town centre 

and provide approximately 500 car parking spaces. These are convenient and well distributed within the town as well as 

on the edge of centre. The largest car park is Minstergate which provides over 150 spaces. 

Accessibility on foot is somewhat convoluted. The current system of signage combined with the historic network of 

streets, numerous car parks, one way streets and dispersed retail offer makes accessing Thetford Town Centre and then 

navigating around it difficult. 

Environmental Quality 

Thetford is a historic market town with numerous listed (182) and period buildings. The town provides a range of service 

facilities and an attractive pedestrianised area. However, a significant number of the buildings on Riverside Walk 

(1960’s/70’s), are vacant, unattractive and detract significantly from the overall attractiveness of the town centre. 

5

Street furniture throughout the town centre is of adequate quality and could be improved with newer more aesthetically 

pleasing and sustainable seating arrangements. The public realm along Riverside Walk and fronting the Little Ouse River 

has the potential to be improved with better linkages to the adjoining park. The centre lacks soft landscaping and there 

are opportunities for tree and shrub planting throughout the town centre. The built environment of key public spaces 

throughout the town centre can also be considered relatively harsh and lacking character. 

Photograph 6: Areas of the Town Centre exhibit poor environmental quality 

There are also unnecessary or duplicative signs and other street furniture within the town centre. For instance, where 

new signs have been introduced the signs that they have replaced have not been removed. This has the effect of making 

the town more confusing to navigate and inadvertently creates a poor visual environment. 

Crime and Safety 

Within the PSA there was an overall impression that the area is relatively crime free and safe. CCTV cameras were 

observed in the car park fronting the courthouse to the south of the town centre. 

Street lighting and natural surveillance from shops create a perception of security and personal safety within the central 

area. 

Generally, the centre appears to be a safe centre. The concentration of smaller units along Kings Street and Wells Street 

have created active frontages and overlooking of cafes/restaurants in the centre help to create a safe evening/economy. 

Vandalism and crime were not overly evident in the centre. 

A number of PCSO’s were observed to be patrolling the centre at the time of the site visit. 

The level of crime and anti social behaviour in the centre is below average (police.uk crime maps), when compared with 

the rest of England and Wales. 

Conclusions 

The town centre of Thetford can be said to be performing relatively well against the indicators of PPS4. It was noted in 

the Breckland Retail and Town Centre Study (2010) that there is a limited number of available retail units within the 

centre and that most vacant units are small premises and secondary shopping areas and there is a limited number of 

large modern retail units suitable for multiple retailers. 

The proposed Town Centre extension to the north of the site demonstrates that the town is attracting new development. 

Para 3.30 of the Core strategy notes that continued investment is coming forward in Thetford as follows; 

“Thetford is fortunate in that it has been awarded both Growth Point and Healthy Town status 

by central government. This means the government recognises the challenges and 

opportunities faced in Thetford and has been willing to help achieve the local vision and aims 

6

through £millions of investment.” 

The centre is well located and contains a high proportion of independent retailers that clearly provide an important local 

function. 

Overall, Thetford is a vital and viable town centre. 

7

APPENDIX 1

WILKINGSONS 

VACANT OTHER BUILDING 

VACANT 

INTERNATIONAL 

FOOD CENTRE 

VACANT 

VACANT 

DOMESTIC APPLIANCES 

CHEERS 

CRAFTS AND 

HABERDASHERY 

VACANT 

VACANT 

VACANT 

HOLISTIC THERAPY 

RECRUITMENT 

CONSULTANTS 

KSP MOBILITY 

VACANT 

VACANT 

VACANT 

WINE CELLAR 

VACANT 

COOPERATIVE 

TRAVEL AGENT 

VACANT 

JONES THE 

FAMILY BUTCHER 

VACANT 

DIGITAL 

PHONE COMPANY 

THETFORD 

GREG’S BAKERY 

SHOE ZONE 

CASH GENERATORS 

VACANT 

POUNDLAND 

YMCA CHARITY SHOP 

JAZZY D’S 

HAIR SALON 

CARD FACTORY 

THETFORD 

FOOD STORE 

HAND ME DOWNS 

KIDS CLOTHES 

PRETTY WOMAN 

CLOTHES & SHOES 

DOMINOS PIZZA 

VACANT 

VACANT 

VACANT 

PHOTOSTUDIO 

RECRUITMENT 

CONSULTANT 

VACANT 

PHONENIX 

HOUSE 

GALAXY 

PERSONAL 

LABAS 

INTERNATIONAL 

CONVENIENCE 

STORE 

COFFEE SHOP 

VACANT 

LABAS 

CONVENIENCE 

STORE 

INDIAN 

RESTAURANT 

VACANT 

POLISH 

RESTAURANT 

VACANT 

INTERNATIONAL 

GROCERS

APPENDIX 2

THETFORD TOWN CENTRE RETAIL SCHEDULE 

Retailer Address Description Use Class 

King Street 

1 Thetford Food Centre 1 King Street Convenience Shopping A1 Shops 

2 Peacocks Clothing 3 King Street Comparison Shopping A1 Shops 

3 Select ladies wear 5 King Street Comparison Shopping A1 Shops 

4 WH Smith 7 King Street Convenience Shopping A1 Shops 

5 Poundland 9 – 11 King Street Convenience/Comparison A1 Shops 

6 Cash Generators 13 King Street Services A2 Financial and Professional Services 

7 Greg’s Bakery 15 – 17 King Street Convenience Shopping A5 Hot Food Takeaway 

8 Yours ladieswear 21 – 23 King Street Comparison Shopping A1 Shops 

9 Newlook ladieswear 25 King Street Comparison Shopping A1 Shops 

10 Digital Phone Company 27 King Street Comparison Shopping A1 Shops 

11 Boots The Chemist 29 – 31 King Street Services A1 Shops 

12 Natwest Bank 33 King Street Services A2 Financial and Professional Services 

13 Lloyds TSB 35 – 37 King Street Services A2 Financial and Professional Services 

14 Staff Line Recruitment 39 King Street Services A2 Financial and Professional Services 

15 Savers Health and Beauty 39 - 41 King Street Comparison Shopping A1 Shops 

16 Rumbles Fish and Chips 43 – 45 King Street Services A5 Hot Food Takeaway 

17 William H Brown Estate Agent 47 – 48 King Street Services A2 Financial and Professional Services 

18 KSP Mobility 51 King Street Services A1 Shops 

19 Subway 2A King Street Services A3/A5 Restaurant/Hot Food Takeaway 

20 Halifax Bank 4 King Street Services A2 Financial and Professional Services 

21 Superdrug Health and Beauty 6 King Street Comparison Shopping A1 Shops 

22 British Heart Foundation Charity Shop 8 King Street Comparison Shopping A1 Shops 

23 Lloyds Pharmacy Chemist 10 King Street Services A1 Shops 

24 Clinton Cards and Gifts 12 King Street Comparison Shopping A1 Shops 

25 Game Zone Rear of 12 King Street Comparison Shopping A1 Shops 

26 Card Factory 14A King Street Comparison Shopping A1 Shops 

27 YMCA Charity Shop 14 King Street Comparison Shopping A1 Shops 

28 Norwich and Peterborough Building Society 16 King Street Services A2 Financial and Professional Services 

29 Shoe Zone 18 King Street Comparison Shopping A1 Shops 

30 Main way Estate Agents 20 King Street Services A2 Financial and Professional Services 

31 Tall Orders Café 24 King Street Services A3/A5 Café/Hot Food Take Away


32 Boots Opticians 28 King Street Services A1 Shops 

33 Hughes Electrical 34 King Street Comparison Shopping A1 Shops 

34 HSBC Bank 36 King Street Services A2 Financial and Professional Services 

35 Jones Family Butcher 38 King Street Convenience Shopping A1 Shops 

36 Co-operative Travel 40 King Street Services A2 Financial and Professional Services 

37 Thomson Travel Agent 42 King Street Services A2 Financial and Professional Services 

38 Wine Cellar Off License 44 King Street Convenience Shopping A1 Shops 

Giles Lane 

39 Saffron Indian Restaurant and Takeaway 17 St Giles Lane Services A3 Restaurant and Cafes 

Riverside Walk 

40 Argos Catalogue Showroom 2- 10 Riverside Walk Comparison Shopping A1 Shops 

41 Vacant 12 Riverside Walk N/A N/A 



44 Sue Ryder Charity Shop 18 Riverside Walk Comparison Shopping A1 Shops 

45 Spec-savers Opticians 20 Riverside Walk Services A1 Shops 


47 M & Co Clothing 11-19 Riverside Walk Comparison Shopping A1 Shops 

48 Nationwide Building Society 21 Riverside Walk Services A2 Financial and Professional Services 


50 Cancer Research Charity Shop 25 Riverside Walk Comparison Shopping A1 Shops 

51 Learn Direct Centre 27 Riverside Walk Community Facilities D2 Assembly and Leisure 

52 Special Thoughts Cards and Gifts 29 Riverside Walk Comparison Shopping A1 Shops 

53 USA Chicken/Kebab Takeaway 31 Riverside Walk Services A5 Hot Food Takeaway 

54 Haart Estate Agent 33 Riverside Walk Services A2 Financial and Professional Services 

55 Ice Night Club Entertainment Sui-Generis 

56 Barnados Charity Shop 39 Riverside Walk Comparison Shopping A1 Shops 


58 Vacant Riverside Walk N/A N/A 

Bridge Street 

59 Lawson’s Estate Agents 2 Bridge Street Services A2 Financial and Professional Services 

60 Barclay’s Bank 4 Bridge Street Services A2 Financial and Professional Services 

61 St Nicholas Charity Shop 6 Bridge Street Comparison Shopping A1 Shops 

62 Vacant 8 Bridge Street N/A N/A


63 International Food Centre 10 Bridge Street Convenience Shopping A1 Shops 

64 Studio Five – Photographic Goods and Kodak Film Centre 12 Bridge Street Comparison Shopping A1 Shops 

65 Chilterns Estate Agent 14 -18 Bridge Street Services A2 Financial and Professional Services 

Whitehart Street 

66 Hudson Estate Agent 1 Whitehart Street Services A2 Financial and Professional Services 

67 Marvellas Café Not Known Services A3 Restaurant and Cafes 

68 Purely You Ladieswear Not Known Comparison Shopping A1 Shops 

69 Cheers Restaurant (Opening Soon) 3 Whitehart Street Services A3 Restaurant and Cafes 

70 Domestic Appliances 5 Whitehart Street Comparison Shopping A1 Shops 

71 Star OK Kebab/Fast Food Restaurant 7 Whitehart Street Services A5 – Hot Food Takeaway 

72 Vacant 9 Whitehart Street N/A N/A 

73 TTS Office Equipment 11 Whitehart Street Comparison Shopping A1 Shops 

74 Crafts and Haberdashery 13 Whitehart Street Comparison Shopping A1 Shops 

75 Pizza Plus Takeaway 15 Whitehart Street Services A5 – Hot Food Takeaway 

76 Nimmi Indian Restaurant and Indian Takeaway 17-19 Whitehart Street Services A3 – Restaurant and Cafes 

77 The Ancient House Museum and Art Gallery 21 Whitehart Street Community Facilities D1 Non Residential Institutions 

78 Kings Head Public House 25-27 Whitehart Street Entertainment A4 Drinking Establishments 

79 Store 29 Whitehart Street N/A N/A 

80 Anglia Crime Team Solicitor 2 Whitehart Street Services A2 Financial and Professional Services 

81 Techniques Beauty Salon 4 Whitehart Street Services Sui-generis 

82 Portugal Delicatessen 6 Whitehart Street Convenience Shopping A1 Shops 

83 Recruitment consultants 8 Whitehart Street Services A2 Financial and Professional Services 

84 Holistic Therapy 10 Whitehart Street Services Sui Generis 

Minstergate 

85 British Heart Foundation- Furniture and Electrical Charity Shop Minstergate Comparison Shopping A1 Shops 

86 Iceland – Frozen Food and Electrical & Gas Appliances Minstergate Convenience Shopping A1 Shops 

87 Pound stretcher – Home and Garden Centre, Household Goods Minstergate Comparison Shopping A1 Shops 

88 Wilkinson’s Minstergate Comparison Shopping A1 Shops 

Well Street 

89 William Hill Betting Office 8 Well Street Services A2 Financial and Professional Services 

90 Coral Betting Office 10-12 Well Street Services A2 Financial and Professional Services 

91 Finishing Touches Beauty Salon 14 Well Street Services Sui Generis 

92 Pretty Woman – Women’s Clothing and Shoes 16 Well Street Comparison Shopping A1 Shops


93 Dominos Pizza 18 Well Street Services A5 Hot Food Takeaway 

94 Waterman’s Jeweller 20 Well Street Comparison Shopping A1 Shops 

95 Hand Me Downs Children’s Clothes 22 Well Street Comparison Shopping A1 Shops 

96 Coral Betting Office 24 Well Street Services A2 Financial and Professional Services 

97 Rudlings & Wakelam Solicitors Well Street Services A2 Financial and Professional Services 

98 Redlion Restaurant (Vacant) Well Street Services A3 Restaurant and Cafes 

The Shambles 

99 Thetford Kebab House 1 The Shambles Services A5 Hot Food Takeaway 

100 Lunch Break Sandwich Bar 2 The Shambles Services A3/A5 Café/Hot Food Takeaway 

101 Thetford Pizza Take Away 3 The Shambles Services A5 Hot Food Takeaway 

102 Clipper’s Hair Salon 4 The Shambles Services A1 Shops 

Market Place 

103 Post Office 1 Market Place Services A1 Shops 

104 Photostudio. 2 Market Place Service B1 Business 

Recruitment Consultant – Upper Floors 2 Market Place Service A2 Financial and Professional Services 

105 Vacant Office 3 Market Place N/A N/A 

105 Phoenix House – Chinese Takeaway 4 Market Place Service A5 Hot Food Takeaway 

107 Green Dragon Public House 5 Market Place Entertainment A4 Drinking Establishment 

108 Total Recruitment Employment Agency 6 Market Place Services A2 Financial and Professional Services 

109 Vacant 6A Market Place N/A N/A 

110 Swinton’s Insurance 7 Market Place Services B1 Offices 

111 Mobile Telephone Sales and Repairs Comparison Shopping A1 Shops 

112 Galaxy Personal 8 Market Place Services A2 Financial and Professional Services 

113 Labas – International Foods 

Former – Vacant Site Market 

Street 

Convenience Shopping A1 Shops 

114 Mr Chips – Fish and Chips Restaurant 9 Market Street Services A5 – Hot Food Takeaway 

115 The Town Barber 10 Market Street Services A1 Shops 

116 Norfolk Kitchen Café 12 Market Street Services A3 Restaurant and Café 

117 The Florin Amusement Arcade 14 Market Street Entertainment Sui Generis 

Earls Street 

118 Florist (Appears Vacant) 13 Earls Street Comparison Shopping A1 Shops 

119 Learning Centre 15 Earls Street Community Facilities D1 Non Residential Institution 

120 Thetford Snooker Centre Earls Street Entertainment D2 – Assembly and Leisure 

Doran’s Corner


121 Unique Hairdressing Doran’s Corner Services A1 Shops 

121 O Celeiro Deli Doran’s Corner Convenience Shopping A1 Shops 

122 Cafe Doran’s Corner Services A3/A5 Café/ Hot Food Takeaway 

123 Offices Doran’s Corner Services B1 Businesses 

124 Up to Scratch – Beauty Salon Doran’s Corner Services A1 Shops 

125 Tan and Tone Beauty Salon Doran’s Corner Services A1 Shops 

Castle Street 

126 Jewellers/Antiques 1 Castle Street Comparison Shopping A1 Retail 

127 Vacant 3-5 Castle Street N/A N/A 

128 Marcos Motorcycle Sales and Repairs 7-11 Castle Street Comparison Shopping Sui Generis 

129 Colonnade Insurance 4-6 Castle Street Services A2 Financial and Services 

130 Beauty Salon 14 Castle Street Services A1 Retail 

131 Blockbuster 20 Castle Street Services A1 Retail 

Magdalen Street 

132 DWG 2A Magdalen Street Misc Misc 

133 Indian Restaurant 2 Magdalen Street Services A3/A5 Restaurant/Hot Food Takeaway 

Tanner Street 

134 Jazzy D’s Hair Salon 2 Tanner Street Services A1 Shops 

Guildhall Street 

135 Roy’s Variety Store Guildhall Street Comparison/Convenience A1 Shops 

136 John Oliver Hairdressing 19 Guildhall Street Service A1 Shops 

137 Polish Restaurant 21 Guildhall Street Service A3 Restaurant and Café 

138 Vacant 23 Guildhall Street N/A N/A 

139 International Groceries 25 Guildhall Street Convenience Shopping A1 Shops 

140 Contract Personal 27 Guildhall Street Service A2 Financial and Professional Services 

141 Chinese Restaurant 29 Guildhall Street Services A3/A5 Restaurant/Hot Food Takeaway 

142 Breckland Bingo and Social Club Guildhall Street Entertainment D2 Assembly and Leisure 

143 Metcalfe Copeman and Pettefar Solicitor Corner of Cage Lane/Guildhall 

Street 

144 Scott’s Optician Corner of Cage Lane/Guildhall 

Street 

Services A2 Financial and Professional Services 

Services D1 Non-Residential Institution 

145 Southern Fried Chicken Take Away 2 Guildhall Street Services A5 Hot Food Takeaway 

146 Job Centre Plus 4-6 Guildhall Street Services A2 Financial and Professional Services 

147 Coffee Shop 8 Guildhall Street Services A1 Shops


148 Mini Market Baker and Coffee Shop 10 Guildhall Street Services A1 Shops 

149 Labas Convenience Store 16 Guildhall Street Convenience Shopping A1 Shops 

150 Labas Convenience Store 20 Guildhall Street Convenience Shopping A1 Shops 

151 Tanning Studio 22 Guildhall Street Services Sui Generis

APPENDIX 3

CONVENIENCE TRADE DRAW ASSESSMENT OF PROPOSED STORE AT 2016 

Turnover Pre Any 

New Store 1 

Trade Draw to 

New Store 

Turnover to New 

Store £M 

Resident Remaining 

Turnover 

Sainsbury’s, Thetford 32.40 30% 9.18 23.22 28.3% 

Tesco, Kilverstone Lane, Thetford 39.77 20% 6.12 33.65 15.4% 

Aldi, Thetford Retail Park 4.5 2 2% 0.61 3.89 13.5% 

Lidl, London Road, Thetford 4.5 2 2% 0.61 3.89 13.5% 

Other Thetford Retailers 8.8 2 1% 0.31 8.49 3.5% 

Retailers Beyond Thetford but in the PCA 35% 10.71 - - 

Inflow from Beyond the PCA 10% 3.06 - - 

TOTAL: 100% 30.61 

1 Turnover of existing stores and centres at 2016 derived directly from NLP 2010 Study (Tables 3B, 4B and 7B) 

2 Combined turnover equates to £17.80M as per Table 7B of NLP Study 

3 2008 Prices 

Impact

Appeal Decision 

Inquiry held on 10-12 May 2011 

Site visit made on 12 May 2011 

by Wendy J Burden BA DipTP MRTPI 

an Inspector appointed by the Secretary of State for Communities and Local Government 

Decision date: 10 June 2011 

Appeal Ref: APP/ M1710/A/10/2143427 

Unit 1-2 Mill Lane, Alton, GU34 2QJ 

• The appeal is made under section 78 of the Town and Country Planning Act 1990 

against a failure to give notice within the prescribed period of a decision on an 

application for planning permission. 

• The appeal is made by Tesco Stores Ltd against the decision of East Hampshire District 

Council. 

• The application Ref 22467/006, is dated 06 08 2010. 

• The development proposed is the demolition of existing buildings and erection of a 6112 

sq ms A1 (retail) foodstore at first floor level with undercroft parking, including 

associated landscaping and access improvements. 

Decision 

1. I allow the appeal, and grant planning permission for the demolition of existing 

buildings and erection of a 6112 sq ms A1 (retail) foodstore at first floor level 

with undercroft parking, including associated landscaping and access 

improvements at Unit 1-2 Mill Lane, Alton, GU34 2QJ in accordance with the 

terms of the application, Ref 22467/006, dated 06 08 2010, subject to the 

conditions set out in the attached schedule. 

Main Issues 

2. The main issues in this case are: 

i) the extent to which the provision of the additional bus service together 

with the improvements to pedestrian/cycling facilities proposed by the 

appellant would reduce reliance on the car for shopping trips and provide 

for any increase in the potential for linked shopping trips between the 

new Tesco and the shopping centre of Alton; 

ii) the extent to which the provision for linked trips would reduce any impact 

from the new store on the vitality and viability of the town centre; 

iii) whether there is a suitable alternative provision which is likely to be 

deliverable. 

Reasons 

Background 

3. An appeal into an identical scheme was determined in July 2010 

(APP/M1710/A/2122565). Having regard to the policies of the development 

plan and to the existing and proposed retail provision within the town, the 

Inspector found that “an additional large store in Alton is necessary to provide 

http://www.planning-inspectorate.gov.uk

Appeal Decision APP/ M1710/A/10/2143427 

proper and balanced consumer choice and range of goods.” He considered that 

the proposed Tesco would provide the necessary consumer choice. However, 

the location of the proposed Tesco store is such that it would not provide the 

opportunity for linked trips to the town centre in the same way as the existing J 

Sainsbury store. There would be a diversion of trade from J Sainsbury, and as 

a result the Inspector was concerned that the loss of linked trips would have a 

harmful effect on the vitality and viability of Alton town centre. The Inspector 

went on to consider that a proper and adequate bus service link between 

significant parts of the residential areas and the proposed Tesco site via the 

town centre would be essential in order to help replace the loss of linked trips. 

4. There is no change in development plan policy since the last appeal. The size 

and location of the proposed Tesco is the same, and it is generally agreed that 

the health of the town centre remains as found by the previous Inspector. 

Having spent time in Alton town centre in the course of the Inquiry, I have no 

reason to disagree that it is an attractive environment with a reasonable level 

of trade. The previous Inspector had before him the permission granted for a 

new Aldi store, together with a proposal for a new Waitrose or Morrisons at 

Station Road. He considered that neither the Aldi nor the Waitrose, alone or in 

combination, would meet the demand for new convenience provision which he 

identified. There has however been a change in circumstances in that planning 

permission has now been granted for a Waitrose store at Station Road. The 

permitted scheme is 20% larger in net floor area than the proposal under 

consideration at the time of the earlier appeal. 

5. The Council does not dispute the need for an additional food store in Alton. 

However, it considers that the larger Waitrose together with the Aldi store and 

the existing J Sainsbury would provide adequate consumer choice, and the 

addition of Tesco would result in a harmful cumulative impact on the vitality 

and viability of the town centre. 

i) the extent to which the provision of the additional bus service together with the 

improvements to pedestrian/cycling facilities proposed by the appellant would 

reduce reliance on the car for shopping trips and provide for any increase in the 

potential for linked shopping trips between the new Tesco and the shopping centre 

of Alton 

6. By means of the S106 agreement with Hampshire County Council, Tesco would 

provide any subsidy required to maintain a dedicated Alton Town bus service. 

This would replace two existing services (23/24) which serve the town but also 

travel beyond Alton, and would both extend and enhance the service currently 

offered. A dedicated bus service would be an improvement on the current 

service for a number of reasons. The most significant advantages are that it 

would not be subject to the delays which occur on services which travel beyond 

the town; it would follow a roughly figure of eight route which would pass 

within some 400m of 6784 properties and reach about 88% of the built up area 

of Alton; it would extend the weekday and Saturday hours of operation of the 

current 23/24 service to 20.00 hours, and it would introduce a Sunday bus 

service. 

7. The bus service is intended to serve the Tesco store and encourage linked trips 

between Tesco and the town centre. There is some dispute as to the 

practicality of doing a bulk food shop in Tesco and then travelling by bus into 

the town centre and I agree with objectors that could be an onerous 

undertaking. However, the improved bus service would ensure that shoppers 

http://www.planning-inspectorate.gov.uk 2


would have a number of options for their trips. For example, they could visit 

the town centre first, continue by bus to Tesco and then use a taxi to take 

them home when doing the weekly shop. Furthermore, with the bus service 

extended into more residential areas within Alton and linking those areas to the 

town centre, the use of the bus for shopping trips into the town centre, 

independent of a trip to Tesco, would become more convenient and attractive 

to residents. The bus route would also extend along Mill Lane to serve other 

employment sites and thus provide for work trips as well as shopping trips. 

8. The benefits which would result from the provision of the bus as required in the 

S106 therefore go beyond the original intention of providing for linked trips 

between the Tesco store and the town centre. By providing more attractive 

and frequent access into the town centre the bus would encourage more people 

to use the centre for shopping or other purposes, thus supporting its continuing 

viability. Through the provision of a regular service to Mill Lane the choice of 

means of transport to Tesco and other employment sites would be enhanced, 

thus reducing reliance on the private car as a means of transport. The use of a 

modern, energy efficient and fully accessible bus with regular drivers would 

also add to the attractiveness of the new bus service. 

9. In addition to the S106 with Hampshire County Council, a S106 has been 

completed with East Hampshire District Council which requires the payment of 

one million pounds to be used on improvements to the town centre within the 

town centre boundary of Alton. The contribution could include improvements 

to the route of the bus service to provide modern bus shelters with real time 

information on bus arrivals, which would further contribute to the attraction of 

the bus service as an alternative to the use of the private car. 

10. In view of the distance between the new Tesco store and the town centre, and 

the logistics of carrying heavy shopping bags, it is unlikely that improvements 

to pedestrian and cycle access to the Tesco site would contribute to any 

significant increase in the propensity for linked trips between Tesco and the 

town centre. However, some 26% of the residential properties of Alton would 

be closer to the new Tesco than to the existing Sainsbury store. It is from the 

eastern end of Alton and to the north east of Anstey Road that residents are 

most likely to cycle or walk to the site, and there is much support from the 

residents of Holybourne for a new store in this location. The appeal scheme 

includes measures within and in the vicinity of the site to make it more 

accessible to pedestrians and cyclists. A number of physical works are 

proposed to secure safe and convenient access to the site by foot or cycle, 

together with financial contributions to secure enhanced footways along Mill 

Lane. Improved signage would also be provided to direct cyclists between the 

new store and the town centre and station. In these circumstances the 

proposal would be likely to contribute to reduced reliance on the car for 

shopping trips by local residents. 

11. With the Travel Plan which is proposed to influence the means of access to the 

new store by employees, I am satisfied that the appeal scheme would make 

significant provision for choice of access to the new store by bus, walking and 

cycling. As a result the scheme would help reduce reliance on the car for local 

shoppers, both to the Tesco store and to the town centre. This would accord 

with Government policy as set out in PPG13, and accord with the requirement 

in PPS4 for out of centre sites which will be well served by a choice of means of 

transport. 



ii) the extent to which the provision for linked trips would reduce any impact from 

the new store on the vitality and viability of the town centre 

12. In the earlier appeal, the Inspector considered that when visiting J Sainsbury, 

shoppers were likely to undertake a linked trip into the town centre. Since it is 

generally agreed that the proposed Tesco would draw a significant level of 

trade away from the Sainsbury store, the propensity for linked trips would be 

reduced, with consequent effects on the vitality and viability of the town 

centre. In this appeal, the Council argue that with the added diversion of trade 

to a new Waitrose, (in addition to the permitted Aldi and the proposed Tesco) 

the level of impact on town centre stores would be significantly increased. 

13. Notwithstanding any disadvantages relating to the Station Road site, planning 

permission has now been granted for a new store of 1,673 sq ms net 

floorspace. With planning permission now in place for a new Aldi and a new 

Waitrose, I agree with the Council that it is appropriate to consider the 

potential cumulative impact of those stores together with the appeal proposal. 

The Council has produced detailed assessments of likely trade draw and 

impact, with which the appellant disagrees. Whilst there are a number of areas 

of the assessment in dispute, an important difference between the two 

approaches lies in the extent to which new trade would be drawn into Alton by 

the new stores. With a new Tesco of the scale proposed and in such proximity 

to the junction with the A31 Alton By-Pass, I accept that there would be a 

significant amount of trade drawn in from beyond the town which may 

currently be going to food stores in other competing centres. However, whilst I 

consider the figure put forward by the Council to be conservative, in view of 

the quality and location of other shopping centres in the area, it is unlikely to 

reach the very high levels implied by the appellant. In any event, if high levels 

of claw back were to be accepted, I would be concerned that changes in 

shopping habits of residents further from Alton could result in an increase in 

journeys by car. 

14. With the implementation of three new stores in Alton, the Council calculates 

that there would be a 29.4% reduction in Town Centre trading, or using the 

assumptions promoted by the appellant, this would be 24.7%. At the earlier 

appeal the Council assessed the impact of Aldi and Tesco at 17.4%. On the 

Council’s calculations therefore, the adverse impact of calculating the figures 

one year later and adding Waitrose results in a 69% increase in adverse 

impact. Having regard to the location of the Waitrose store in close proximity 

to the town centre, and the likelihood that the store would encourage linked 

trips to the town centre, I consider this increase in the assessment of adverse 

impact with the addition of Waitrose to be excessively high. 

15. Furthermore, if all three new stores were to be constructed, they would be 

trading against each other. As a result I would expect the new stores to 

achieve significantly lower turnovers than the benchmark for their companies, 

which must raise some doubt as to whether all three would be built. There is 

evidence to indicate that Waitrose is contractually committed to implement its 

permission, but there is no such evidence to show that Aldi is so committed. 

Whilst I accept that a significant level of trade would be diverted from existing 

shops in Alton town centre with the construction of the appeal proposal 

together with one new food store, the very high level of cumulative impact 

calculated by the Council is unlikely to occur. 



16. Turning then to the effect on the pattern of trading within the town, whether 

there are two or three new food stores, it is from similar stores both outside 

the town and within the town centre that most trade would be gained. There is 

no dispute that a high level of trade would be diverted from J Sainsbury. 

However, all the evidence indicates that J Sainsbury is trading very well, if not 

overtrading, so it is most unlikely that the store would close even if three new 

stores were to open in the town. The impact would also fall on Marks and 

Spencer, Iceland and the Co-op, and it is likely that one or more of those 

stores would close. There would also be some impact spread throughout 

smaller stores in the town centre from the sale of both food and non-food items 

in the new stores, with Tesco in particular offering a significant level (30% 

sales area) of comparison goods. 

17. Thus the appeal proposal together with one or two new stores at Alton would 

be likely to result in store closures. However, the benefits of a new store at 

Station Road would provide compensation for the loss of linked trips as a result 

of trade withdrawal from J Sainsbury, and for the closure of other stores within 

the town. In view of the location of the Waitrose site, it is most likely that 

shopping patterns in the town would change, with a boost to shops within the 

eastern part of the centre. The provision of the new town bus service would 

support those changes in shopping patterns, by providing improved access to 

the town centre as a whole. The appellant argues that those who transfer their 

custom from J Sainsbury to Tesco and who currently do linked trips would 

continue to do so. However those travelling by car out of the town centre to 

shop at Tesco could easily shop separately in a different centre, and it is not 

always practical to undertake linked trips for bulky food shopping using a bus 

service. 

18. Nevertheless, the new bus service would provide a much larger population with 

convenient access to the town centre. The elderly, the young and those who 

do not have access to cars would be able to carry out more frequent trips in to 

the centre with associated trade spin off. Whilst the bus service may not 

contribute significantly to shoppers linking trips to the town centre together 

with trips to Tesco, it would in its own right provide a significant improvement 

to the accessibility of the town centre. Furthermore, the appellant is 

committed to contribute one million pounds for enhancements to the town 

centre. Measures would include improvements to the public realm, grants to 

independent retailers and better bus shelters which in combination with the 

new bus service would make the retail offer within Alton more attractive and 

defensible. As a result I consider that the town centre would be in a good 

position to sustain its vitality and viability against the trade diversion and 

changes in shopping patterns which would result from the development of up 

to three new food stores. 

iii) Whether there is a suitable alternative provision which is likely to be 

deliverable. 

19. In the last appeal, the Inspector found that the Aldi and Waitrose proposals 

would not provide the size and choice necessary to compete with J Sainsbury in 

Alton. The Waitrose proposal at that time was for some 1400 sq ms net retail 

floor area. The larger Waitrose which now has planning permission would 

provide some 1,673 sq ms net retail floor area. 

20. The Council argues that since the Waitrose will include only 4% comparison 

goods floor area, the remaining 1600 sq ms of convenience floorspace would 



compare favourably with the 2200 sq ms of convenience floorspace which 

would be provided in the Tesco store with its 30% comparison goods floor area. 

However, reference is made in the previous Inspector’s decision to the need for 

a superstore in order to provide a proper level of competition and choice. 

Whether or not he intended to indicate that a store with normally in excess of 

2,500 sq ms trading floorspace was required, a store the size of the proposed 

Tesco would undoubtedly meet the need for a proper level of competition and 

choice against the existing superstore. A smaller store, even if it is a 

Waitrose, would inevitably have a more restricted choice of brands and 

products which would not match and provide effective competition to that 

currently on offer from J Sainsbury. 

21. There is a proposal for a larger store at the station site, but that does not have 

a planning permission, and since it would require the land which is currently 

under contract to Waitrose, it is unlikely to be an alternative which could be 

delivered. In these circumstances the Tesco proposal is the only development 

likely to deliver sufficient consumer choice together with a range of goods at 

competitive prices to meet the need for competition and choice in Alton. 

Other matters 

22. Adjacent to the appeal site, the land currently occupied by a Focus store is 

likely to become available for redevelopment and it was suggested that this 

could be an alternative site for a new superstore. However, there is no such 

proposal before me and it is not a material consideration in this case. 

Conditions and S106 Agreements 

23. Of the list of conditions put forward by the Council at the Inquiry, there is 

dispute as to condition 6 in terms of whether the net sales area should include 

checkouts as sought by the council. Having regard to the definition used by 

the Competition Commission and since goods are not on sale at the checkout, I 

consider that checkouts should be excluded for the condition to meet the tests 

of Circular 11/95. 

24. There is also dispute as to whether details of external floodlighting should be 

the subject of approval by the Council. I accept that levels of lighting by Tesco 

may be limited, but in view of the potential for future occupiers to change the 

lighting scheme, and in order to avoid excessive light pollution within the 

outskirts of the town, I agree with the Council that the condition is appropriate 

and justified. 

25. The appellant also contests the requirement for a condition to control the 

design and construction of internal roads and footpaths at the site, and one to 

control highways signage. However, whilst I have no doubt that the appellant 

would carry out construction and implement signage to the highest standards, 

ownerships could change and these conditions are necessary to ensure that the 

development has no impact on the highway network as a result of poor 

construction or inadequate signage. 

26. A condition is put forward by the appellant relating to employment for local 

people. The Council has no objection to the condition, and I understand the 

benefits that the objective of the condition would secure. However, Circular 

11/95 does require that any condition imposed on a planning permission should 

be necessary for the permission to be granted, and enforceable. The reason 

given for the condition is to secure mitigation for the loss of existing 



employment land. However the site is currently unoccupied and has planning 

permission for non-food retail use. Having regard to the jobs that would be 

provided in the Tesco store, I do not consider this condition to be necessary for 

planning permission to be granted. Furthermore, it could be difficult for the 

Council to monitor and enforce the objectives of the condition, and there is no 

reason why the appellant should not implement the programs for local 

employment put forward in this condition in any event. 

27. I have considered the remaining conditions put before me in the light of advice 

in Circular 11/95, and consider that they meet the tests listed in paragraph 14. 

I also consider that, otherwise than as set out in this decision and conditions, it 

is necessary that the development be carried out in accordance with the 

approved plans, for the avoidance of doubt and in the interests of proper 

planning. An appropriate condition should therefore be included. 

28. There are two completed S106 Agreements which would come into effect on 

the grant of planning permission. The agreement with East Hampshire District 

Council provides for the town centre contribution of one million pounds. This 

financial contribution is subject to a requirement that any sum which has not 

been used within 5 years after the date of receipt of the final instalment should 

be repaid on demand. The Council is confident that it would be able to make 

full use of the contribution for the measures specified in the Agreement within 

that period. I am therefore satisfied that the S106 Agreement is necessary to 

secure the long term well being of Alton town centre having regard to the 

impact which would arise from the development of the new store at Mill Lane. 

The provision is directly related to the new retail development; and having 

regard to the scale of the likely effects of the new store on the town centre, it 

is also fairly and reasonably related in scale and kind to the proposal. The 

provisions of the Agreement therefore accord with the tests set out in 

Regulation 122 of the Community Infrastructure Regulations 2010. 

29. The S106 Agreement with Hampshire County Council secures the provision of 

the Alton Town bus service, together with a Travel Plan and works required to 

the highway to deal with traffic generated by the new store. Having regard to 

Regulation 122 of the Community Infrastructure Regulations 2010, I am 

satisfied that the provisions of the agreement are necessary to make the 

development acceptable in planning terms; directly related to the development 

of the new superstore; and reasonably related in scale and kind to the 

development proposed. I therefore consider that the provisions of this 

Agreement comply with the statutory tests. 

Conclusion 

30. Retail impact assessment is not a precise science and there is a need to 

exercise judgement. Whilst I do not attempt to identify a specific figure for 

trade impact, I do find that the cumulative impact of the appeal proposal 

together with one or two new stores in Alton would be likely to cause a 

significant level of trade diversion from the town centre, resulting in the 

potential closure of stores such as the Co-op, Iceland and/or Marks and 

Spencer. Nevertheless, in view of the limited offer currently available in Alton, 

and the consequent problems identified by local residents, I agree with my 

colleague that there is a need for shoppers to have more choice in their 

purchase of convenience goods. The scheme which has now been permitted at 

the Station site is larger than in the last appeal. However, it would not be of 

sufficient scale, even when combined with the permitted Aldi store, to provide 



the range of goods at competitive prices which would provide effective 

competition to the existing superstore. 

31. In the absence of a scheme that would provide effective competition and 

consumer choice, the benefits of the Tesco proposal to the residents of Alton 

would be significant. Whilst my colleague in the earlier appeal was not 

satisfied that effective mitigation was put forward for the impact that would 

arise in the town centre, the proposal before me is linked to a significantly 

enhanced package of measures. The new Alton town bus service, together 

with the potential enhancements financed through the one million pound 

contribution, would provide significant support to the town centre. Whilst there 

would inevitably be changes in shopping patterns, and in the occupation of 

some premises within the town, the mitigation measures would strengthen the 

town centre and enable it to sustain its health and viability. 

32. With the mitigation proposed, the scheme would comply with PPG13 and PPS4, 

and it would accord with the spirit of the March 2011 Ministerial Statement 

“Planning for Growth”. Having regard to the need for a new large convenience 

store to serve Alton, and the benefits which would arise from the provision of 

the bus service and package of enhancement measures, I consider that the 

overall effect of allowing the development of the Tesco store would be of 

benefit to the town. 

33. For all the reasons set out above, I conclude that planning permission should 

be granted subject to the conditions and S106 Agreements which I have 

identified. 

Wendy Burden 

INSPECTOR 



Schedule of conditions 

1. The development hereby permitted shall be begun before the expiration of 

three years from the date of this planning permission. 

2. The development hereby permitted shall be carried out in accordance with the 

following approved plans: 

6475/PL01 Site location plan 1:1250 

6475/PL02 A Existing site plan 1:500 

6475/PL03 E Proposed site plan 1:500 

6475/PL04 E Proposed store level plan 1:500 

6475/PL05 D Proposed roof plan 1:500 

6475/PL06 A Proposed elevations 1:250 

6475/PL07 A Proposed sections 1:250 

6475/V01 View 1 

3. Notwithstanding any indication of materials that may have been given in the 

application or in the absence of such information, no development shall start 

on site until samples/details of all the materials to be used for external facing 

and roofing have been submitted to and approved in writing by the Planning 

Authority. The development works shall be carried out in accordance with the 

approved details. 

4. No development shall start on site until a fully detailed landscape and planting 

scheme for the site has been submitted to and approved in writing by the 

Planning Authority. The works shall be carried out in accordance with the 

approved details and in accordance with the recommendations of the 

appropriate British Standards or other recognised codes of good practice. 

These works shall be carried out in the first planting season after practical 

completion or first occupation of the development, whichever is earlier, unless 

otherwise first agreed in writing by the Planning Authority. 

Any trees or plants which, within a period of 5 years after planting, are 

removed, die or become seriously damaged or defective, shall be replaced as 

soon as is reasonably practicable with others of species, size and number as 

originally approved unless otherwise first agreed in writing by the Planning 

Authority. 

5. No development shall start on site, including demolition, until protective 

fencing has been erected around all trees, shrubs and other natural features 

not scheduled for removal and shall be retained for the duration of the works 

and shall be in accordance with the recommendations of the appropriate 

British Standards unless otherwise agreed in writing by the Planning 

Authority. 

No unauthorised access or placement of goods, fuels or chemicals, soil or 

other materials shall take place inside the fenced area. 

No burning of materials shall take place where it could cause damage to any 

tree or tree group to be retained on the site or on land adjoining. 

No soil levels within the root protection area of the trees/hedgerows to be 

retained shall be raised or lowered. 



6. No development shall start on site, including demolition, until details of any 

excavation within 5 metres of the north east application site boundary have 

been submitted to and approved in writing by the Planning Authority. The 

works shall be carried out in accordance with the approved details. 

7. This permission authorises a gross sales floor area of 6,112 square metres 

and a net, excluding checkouts, area of 3,600 square metres. 

Notwithstanding the provisions of the Town and Country Planning (General 

Permitted Development) Order 1995 (or any Order revoking and re-enacting 

that Order), there shall be no provision of retail floorspace in excess of the net 

area defined within the building without the prior express consent of the Local 

Planning Authority neither shall there be any subdivision of the sales floor, nor 

provision of ancillary or subsidiary retail units within that sales floor. The 

provision of a Post Office, dry cleaner or dispensing chemist is excluded. No 

more than 30% of the net sales floorspace of the store shall be used for the 

sale of comparison goods. 

8. The service yard hereby permitted shall be constructed and available for use 

before the foodstore hereby permitted is first used. 

9. Development shall not begin until a surface water drainage scheme for the 

site, based on sustainable drainage principles and an assessment of the 

hydrological and hydro geological context of the development, has been 

submitted to and approved in writing by the local planning authority. The 

scheme shall subsequently be implemented in accordance with the approved 

details before the development is completed. 

10. No infiltration of surface water drainage into the ground is permitted other 

than with the express written consent of the Local Planning Authority, which 

may be given for those parts of the site where it has been demonstrated that 

there is no resultant unacceptable risk to controlled waters. 

11. No development shall take place until a scheme for the enhancements to the 

ditch in accordance with Plan No. SK02 Rev C (Watercourse Enhancements) 

and section 4.9 of the Landscape Supporting Statement (October 2009), has 

been submitted to and agreed in writing by the local planning authority and 

implemented as approved. Thereafter the development shall be implemented 

in accordance with the approved scheme. 

12. No work shall commence on site until such time as a desktop study of the site 

(in order to assess the history of the site, the potential risk of contamination 

to the site, and surrounding land and local water resources) has been 

submitted to and approved in writing by the Local Planning Authority. 

Where a potential risk is identified the following components of a scheme to 

deal with the risks associated with contamination of the site shall each be 

submitted to and approved in writing by the Local Planning Authority: 

1) A site investigation scheme, based on the desktop study to provide 

information for a detailed assessment of the risk to all receptors that may be 

affected, including those off site. 

2) The site investigation results and the detailed risk assessment (1) and, 

based on these, an options appraisal and remediation strategy giving full 

details of the remediation measures required and how they are to be 

undertaken. 



3) A verification plan providing details of the data that will be collected in 

order to demonstrate that the works set out in (2) are complete and 

identifying any requirements for longer-term monitoring of pollutant linkages, 

maintenance and arrangements for contingency action. 

Any changes to these components require the written consent of the local 

planning authority. The scheme shall be implemented as approved. Should 

any further contamination be encountered that has not already been 

considered, a scheme to deal with the contamination shall be submitted to 

and agreed in writing by the Local Planning Authority in accordance with 

requirements 1 – 3 of this condition. No further development shall take place 

until remediation measures in the scheme have been agreed and 

implemented. 

13. Piling or any other foundation designs using penetrative methods shall not be 

permitted on site, other than with the express written consent of the Local 

Planning Authority, which may be given for those parts of the site where it 

has been demonstrated that there is no resultant unacceptable risk to 

groundwater. 

14. No development shall start on site until details of any external 

lighting/floodlighting of the food store, service yard and doc.com delivery 

parking area have been submitted to and approved in writing by the Planning 

Authority. The approved details shall be installed, operated, and maintained 

in accordance with the approved scheme. 

15. No development shall start on site until the following details have been 

submitted to and approved in writing by the Planning Authority. 

a) a specification of the type of construction for the roads and footpaths, 

including all relevant horizontal cross-sections and longitudinal sections 

showing the existing and proposed levels together with details of street 

lighting and the method of disposing surface water; 

b) a programme for making up the roads and footpaths. 

The development shall be carried out in accordance with the approved details 

before any part of the development is occupied unless otherwise first agreed 

in writing by the Planning Authority. 

16. The parking spaces and cycle storage shown on the plans hereby permitted 

shall be provided before the food store is first used and shall be marked out 

and retained for that use. 

17. Before any works commence, the details of the proposed highway signage for 

the internal road and parking layout shall be submitted to and approved in 

writing by the Local Planning Authority. The signage shall be provided in 

accordance with the approved scheme before the food store hereby permitted 

is first used. 

18. Details of the provisions to be made for the parking and turning on site of 

operatives and construction vehicles and the storage of materials during the 

construction period shall be submitted to and approved by the Planning 

Authority in writing and fully implemented before development commences. 

Such measures shall be retained for the duration of the construction period. 



APPEARANCES 

FOR THE LOCAL PLANNING AUTHORITY: 

Mr Leach Principal Solicitor EHDC 

He called 

Anthony Whitty District Team Manager 

Peter Wilks Director Nathaniel Lichfield & Partners 

FOR THE APPELLANT: 

Mr P Clarkson QC Instructed by Martin Robeson Planning Practice 

He called 

Robert Shrimplin Director Martin Robeson Planning Practice 

Philip Rust Technical Director Waterman Boreham Ltd 

INTERESTED PERSONS: 

Mrs Haddingham Local resident and shopper 

Mr Taylor For developers of Focus Store 

Mr Hepper The Alton Society 

Mr Eccles Local resident 

Mr Applegarth Local resident 

Mrs Lerew For Holybourne residents 

Mrs McCloud Local resident 

DOCUMENTS 

1 Bundle of Core Documents 

2 Bundle of written submissions and copy petition received from 

interested parties at the Inquiry 

3 List of agreed Plans 

4 Whitehill Borden Briefing Paper 

5 Foodstores within Alton catchment 

6 Bundle of correspondence concerning Discovery Properties and 

the Station Road site 

7 Opening submissions on behalf of Tesco 

8 Extract from 2008 Report from the Competition Commission 

9 Closing submissions on behalf of the Council 

10 Closing submissions on behalf of Tesco 

11 S106 Agreement between Tesco Stores Limited and East 

Hampshire District Council 

12 S106 Agreement between Tesco Stores Limited and Hampshire 

County Council

view - Breckland Council

Create successful ePaper yourself

Delete template?

Save as template?