TESCO PLANNING APPLICATIONS

REVIEW OF RETAIL ISSUES

1.0 RELEVANT DOCUMENTS

(i) Mole Valley Town, District, Local and Village Centres Study November 2007 –

Roger Tym & Partners (RTP 07)

(ii) Tesco First Application (MO/2008/1127):

 Retail Assessment July 2008 (including supplementary note) – G L Hearn

(GLH 08)

 Review of Retail Assessment February 2009 – Roger Tym & Partners

(RTP 08)

 Planning Officers‟ Report (PR 2008)

(iii) Tesco Second Application (MO/2009/1322):

 Retail Assessment November 2009 – G L Hearn (GLH 09)

 Review of Retail Assessment January 2010 – Roger Tym & Partners

(RTP 09)

 Planning Officers‟ Report (PR 2009)

2.0 OVERVIEW

2.1 This review contains observations and analysis of the above documents with a
view to critically examining:

 the retail impact of the proposed Tesco store (second application) on the
local independent retailers in Ashtead; and

 determining whether the impact should be considered detrimental to the

character, vitality and viability of Ashtead.
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2.2 From a reading of this review, it will become evident that a critical
examination of the retail impact of Tesco‟s second application upon existing Ashtead
convenience retailers also requires an examination of each of the above documents,
as the underlying principles and data predominantly originate from RTP 07 and then
flow through each of Tesco‟s applications, and the reviews and comments on them
by Roger Tym & Partners and MVDC Planning Officers. Unsurprisingly, the bulk of
the observations and analysis relate to GLH 09 and RTP 09 (7.0 and 8.0 below).

2.3 In very brief outline, the key points from the observations and analysis
contained in this review are:

 RTP 07, which relies heavily for its statistical justification on a telephone
household survey of a catchment area which includes a part Epsom,
recommends greater retail convenience floor space in Ashtead. The
survey focuses only on supermarkets and does not seek information on
shopping in local independent retailers, leaving a significant gap in
relevant information from which to readily determine the retail impact
upon the existing Ashtead convenience retailers.

 GLH 08 was lodged (as part of Tesco‟s first application), drawing largely
upon the underlying premise and data from RTP 07 to justify its case.

 RTP 08 agrees with the principle of a supermarket (hardly surprising given

the RTP 07 recommendation), but includes its own analysis to show there
would be a significant impact on “smaller shops” and that “this may put
some or all of them at risk of closure”.

 PR 2008 recommends refusal of Tesco‟s first application, fundamentally

because of its very significant impact on local independent retailers and
the consequent detrimental effect on the vitality and viability of Ashtead.

 PR 2008 contains significant criticism of the fundamental premise and

underlying statistical basis for RTP 07 and notes the information gap
regarding the local independent retailers in the underlying survey.
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 RTP 07 was incorporated into MVDC‟s Core Strategy in October 2009.

 GLH 09 was lodged (as part of Tesco‟s second application) again drawing
largely upon the underlying premise and data from RTP 07 to justify its
case.

 RTP 09 again agrees with the principle of a supermarket and includes

analysis which this time shows minimal impact on local retailers. RTP 09
thus concludes there are no grounds for refusal on this issue.

 Examination of the impact analysis in RTP 09 indicates:

(i) it is estimated that £1.18 million (17%) of the combined turnover of
the local retailers (£6.95 million) would be captured by the proposed
store;
(ii) it is estimated that only £0.12 million (10%) of the £1.18 million
would be captured from the local independent retailers, representing less
than 5% of their combined turnover;
(iii) the basis of estimating the amount of turnover captured by the
proposed store from the local retailers appears fundamentally flawed;
(iv) the basis of apportionment of turnover captured from the local
retailers to the local independent retailers changes very significantly from
that used in RTP 08 (no explanation or justification is given); and
(v) the result of (i) and (ii) is a very significant underestimate of the
turnover captured from the local independent retailers by the proposed
store.

 Calculations (based upon RTP 07 and RTP 09 data) indicate that:

(i) the turnover impact on the local retailers is £2.82 million (not £1.18
million);
(ii) the turnover impact on the local independent retailers is perhaps 10
times higher than that estimated in RTP 09; and
(iii) even using mid-point calculations, the turnover impact on the local
independent retailers is 5 times higher than estimated in RTP 09.
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 From these calculations it is evident the turnover impact on local

independent retailers is very significant and it seems reasonable to
conclude some or all of them would be at risk of closure.

 Calculations (using RTP 09 data) show the proposed store would have:
(i) a 67% share of the local food market;
(ii) a turnover of 2 times that of all other local retailers combined; and
(iii) a turnover of 3½ times that of the local independent retailers
combined;

 It therefore seems reasonable to conclude that the proposed store would

dominate local food retailers.

 Overall, it is reasonable to conclude Tesco‟s second application should be

refused on the same grounds as their first application.

 PR 2009 accepts RTP 09‟s (incorrect) conclusion on retail aspects even

though it again notes the information gap regarding local independent
retailers and makes the extraordinary statement that the Planning Officers
“are uneasy” about placing reliance upon “some of the statistics of both
consultants, but they are the best available”.

3.0 RTP 07

3.1 RTP 07 was commissioned by MVDC and effectively adopted by MVDC into its
Core Strategy in October 2009.

3.2 Underpinning RTP 07 are “a telephone household survey across the study
area, visitor surveys and retailer surveys ....” (Para 1.2). Data extracted and
conclusions drawn from these surveys in RTP 07 are used throughout Tesco‟s first
and second applications and it is essential to analyse and understand RTP 07 in
order to be able to critically examine Tesco‟s applications.

3.3 The “comprehensive telephone survey of households” was used to assess

shopping patterns in the study area (Para 3.1).
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3.4 The telephone household survey area was divided into 8 zones (Para 3.2)
based upon post code areas, with Ashtead being in Zone 4. The setting of the
boundaries of Zone 4 has an enormous impact on the interpretations placed on, and
inferences drawn from, the survey data. Zone 4 contains no large supermarkets, yet
there are large supermarkets adjacent to, but outside of, Zone 4‟s boundaries (Tesco
in Leatherhead, Waitrose and Sainsbury‟s in Epsom) – thus survey results indicate
people are travelling outside their local area to shop, when in fact large numbers of
those people are actually shopping in what for them are their local supermarkets.
Geographically, Zone 4 is the smallest zone and is located at the edge of the study
area (Figure 3.1). This results in relatively short shopping journeys by residents in
Zone 4 being treated as journeys outside the local area when much longer journeys
within other zones are treated as within the local area. It could be said, at least for
Zone 4, that the survey results do not reflect shopping reality.

3.5 The telephone survey had 100 completed household responses from each
area, making 800 in total – approximately 1% of households in the study area. It is
stated (Para 3.4) that “a sample size of 0.4% is usually considered statistically valid
for a telephone survey and so this is a robust sample size”. However, one key
question in the household survey (Q4: “where does your household undertake most
„top-up‟ food and grocery purchases? – Appendix 1) has been put to only 67 people.
The statistical validity of the responses to this question should perhaps be
considered, particularly as these responses form an important element of RTP 07
and flow through to the retail impact assessments in both Tesco applications.

3.6 “For food and groceries the results of the two types of shopping trip questions
(main and top-up) were then merged “(Para 3.7) and the result is a ratio of 70:30
for main:top-up shopping. Despite the brief explanation, it is not clear how the
70:30 ratio was obtained. As this ratio is used in, and is crucial to, many aspects of
Tesco‟s applications (including the retail impact assessments), a more robust
justification/explanation is warranted.

3.7 The stores with the highest market share of expenditure by residents of Zone
4 (Figure 3.4, Para 3.13) are shown as Tesco Leatherhead 25% and Waitrose Epsom
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19%. To these could be added Sainsbury‟s Epsom 19% (Table 10, Appendix 5). A
total of 63% of the market share of expenditure from residents of Zone 4 goes to
these three supermarkets just outside the boundaries of Zone 4, but close to the
homes of the people in Zone 4 who shop in them.

3.8 It is noticeable that, in capturing market shares and Zone 4 convenience

expenditure, there is no attempt to identify expenditure in non-supermarkets ie
butchers, bakers etc in Ashtead. This leaves an important gap in the data which has
significant implications for impact assessments on local Ashtead shops and which is
later acknowledged by Roger Tym & Parners.

3.9 “The retention level is the percentage of expenditure in each zone which is
spent in the stores within that zone” (Para 3.17). Zone 4 is shown as having the
lowest retention level (12%) and it is stated that “a high proportion of residents .....
travel to other centres to shop in supermarkets” (Para 3.19). This is a gross
misrepresentation of the facts. The reality is a high proportion of the residents in
Zone 4 shop at their local supermarkets which just happen to be adjacent to, but
outside, the boundaries of Zone 4. In other words they are shopping in their local
centres, not travelling to other centres. The implication that there is a problem is
therefore largely false. The point is effectively noted in PR 2008 (Page 10) “that
about a third of the population and expenditure within (Zone 4) are within Epsom.
They might be expected to look to Epsom town centre.....and other facilities in the
locality”. A similar situation exists at the other side of Zone 4 in relation to
Leatherhead. As will be seen in the further analysis below, this issue goes directly to
the question of where people will shop, where turnover will be captured from by the
proposed store and thus the extent of the impact of the proposed store on the
turnover of the existing Ashtead convenience retailers.
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3.10 It is noted again (PR 2008, Page 12):

3.11 Further, it is noted (PR 2008, Page 13):

3.12 Perhaps a valid question to ask is what is the relevance of the Zone 4
boundaries (based on post code areas), or indeed any boundaries, to shopping
patterns?

3.13 Section 6 of RTP 07 discusses the visitor and business survey results from
Ashtead. For the former, a total of 126 people were questioned in the survey; 65 at
Craddocks Parade and 61 in The Street. A person with local knowledge of Ashtead
would know that answers to some questions would be expected to be completely
different, depending at which location the question was asked.

3.14 Of those surveyed in Ashtead, 67% travelled by car, 33% on foot and less
than 1% by public transport (Q1, Appendix 2). This is not surprising given the very
limited bus services (Para 6.45) and the location of the railway station, especially in
relation to The Street (Para 6.44).
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3.15 A total of 55% of people indicated (Q4 and Q5, Appendix 2) they were in
Ashtead to shop. Contrary to the comments (Paras 6.5 to 6.7), this would appear to
be a healthy indicator of retail activity in Ashtead.

3.16 Dislikes about Ashtead are mentioned (Para 6.9), but conspicuous from these
(but very relevant to the rationale behind RTP 07) is that only 1.6% of people
disliked the “lack of a larger supermarket” (Q7, Appendix 2).

3.17 When asked “how could Ashtead best be improved for shopping?” (Q8,
Appendix 2), only 3.2% of people chose “a better/bigger supermarket”, but this fact
is not mentioned. However, the 17% who chose “a better choice of shops” is
mentioned (Para 6.10). Reading the two statements together (rather than only the
latter) would quite conceivably leave a reader of RPT 07 with a significantly different
perspective of what the people were actually suggesting.

3.18 It is stated (Para 6.22) that “the main problems with Ashtead were considered
by the businesses surveyed to be a poor range of multiple/national retailers”. This
statement is not supported by the underlying survey responses (Q14 Ashtead,
Appendix 3). These show that of the 21 businesses that responded, 6 chose “seek
to improve the number of national retailers” whereas 17 chose “seek to increase the
number of speciality retailers”.

3.19 The overall conclusion from the “consultation event findings” (Para 6.24)
again does not appear to be supported by the underlying survey responses. As
indicated above, responses from both Ashtead individuals and businesses were
shown to be looking for more choice of speciality shops, and there is no indication of
a strong feeling for a large “anchor store” in The Street.

4.0 GLH 08

4.1 GLH 08, which supports Tesco‟s second application, draws heavily upon the
contents of RTP 07 and its underlying survey (Sections 4 to 8) with similar
emphasis/omissions. Comments made at 3.0 above regarding RTP 07 are therefore
also relevant in respect of GLH 08.
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4.2 Comment is made (Para 4.19) that “footfall in the town centre is moderate”.
This conflicts with RTP 07, which indicates (Para 6.49) “relatively high” or better
pedestrian flows.

4.3 The conclusion is reached (Para 4.40) that “the centre (Ashtead) lacks focus
and requires stronger retail provision to enhance attraction and improve its
performance”. This statement does not appear to be supported by the survey data
where 42% of people indicated they disliked “nothing in particular” about Ashtead
(the only significant dislikes being road congestion and parking), 30% liked the
“selection/choice of independent shops/specialist shops”, 28% liked the
“character/atmosphere” and only 3.2% chose “a better/bigger supermarket” as the
best way to improve shopping in Ashtead. In fact, the survey results could easily
lead to a conclusion that it is the particular diversity of independent retailers in
Ashtead that is its attraction.

4.4 The discussion on retail need (Section 5) cites the analysis and conclusions in
RTP 07 as support for Tesco‟s application.

4.5 An additional Note on Retail Impact (NRI) was prepared by G L Hearn to

supplement GLH 08. There are no paragraph numbers in the NRI which, once
again, draws heavily on RTP 07.

4.6 The NRI again cites RTP 07 as support for a supermarket to be located on the
vacant site in The Street (Page 6).

4.7 It is asserted (Page 5) that the proposed store will reduce the turnover of
existing Ashtead retailers by less than 5%. No details are given to support this
assertion.

5.0 RTP 08

5.1 It is stated (Para 2.4(d)) that “the catchment area identified for the proposed
Tesco store is considered to be in line with the size and function of the Ashtead
centre”. This is not surprising as it conforms to the catchment area in RTP 07.
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However, in PR 2008 (page 12) this comment is implicitly criticised and contradicted
as follows:

5.2 It is pointed out (Para 4.18) that the RTP 07 household survey did not show
how many households use non-supermarkets for their top-up shopping. A total of
21.7% of people surveyed either indicated „other stores‟ (ie not supermarkets) or
„did not know/varies‟ as their choice for top-up shopping and a large number of
these are likely to be shopping in Ashtead.

5.3 It is stated (Para 4.20) that 40% of the top-up shopping turnover of the
proposed store would come from other Ashtead shops, with the other shops losing
between 20% and 36% of their turnover. It is important to note the proposed store
“will not contain meat, fish or delicatessen counters” (PR 2008, Page 11).

5.4 It is stated that the impact on smaller shops “would be significant and, in our
view, put some or all of them at risk of closure. We recognise there would be some
positive spin-offs from the proposed new store through new linked trips, though we
suspect these will be negligible” (Para 4.22).

5.5 RTP 08 conclusions (Para 7.1) are:

 Need - assessment broadly follows best practice.

 Scale - broadly appropriate.

 Impact - trade diversion from existing shops will be substantially greater

than suggested and that this is grounds for refusal.

 Accessibility - dealt with in transport assessment.

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6.0 PR 2008

6.1 PR 2008 is the report, conclusions and recommendation of the Planning

Officers on Tesco‟s first application. The main retail planning issue is whether the
“principle of a supermarket and of the proposed size are acceptable” (Page 8).

6.2 The discussion on this aspect is stated (Page 11) to draw largely on RTP 08
which, as indicated above, in turn draws heavily on RTP 07.

6.3 The following discussion is highly relevant (Page 12):

6.4 As are the following comments (Page 13):

6.5 In making the above comments, PR 2008 is implicitly criticising the

fundamental basis of RTP 07 on which GLH 08 is substantially based.

6.6 It is noted in PR 2008 that the proposal would result in 40% of the whole
District‟s retail need (2800 sq m as identified in RTP 07) being allocated to Ashtead,
a small District Centre, whilst Dorking, a higher order centre, is “clearly in urgent
need of improved food shopping” (Page 12).
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6.7 It is noted (Page 12) that Ashtead is an appropriate location for a

supermarket but “it does not follow that it is appropriate for a supermarket to be of
the proposed size”.

6.8 Concerns expressed in RTP 08 regarding turnover diverted from other

Ashtead convenience retailers are noted (Page 13). It is also noted the proposed
store turnover would be about 2.5 times the combined turnover of other Ashtead
convenience retailers.

6.9 It is noted that if “the opening of the proposed new store was to have such
an impact on existing shops that they were to close this would provide grounds for
refusal, on the basis this would have a negative impact on the health of the centre”
(Page 14).

6.10 It is noted that the positive spin-offs through new linked trips are likely to be
negligible (Page 14).

6.11 It is noted that “the new store would be likely to dominate convenience goods
shopping in (Ashtead) significantly lessening consumer choice because independent
convenience stores would potentially close. Consequently, it would have the
opposite effect that Tesco claim” (Page 14).

6.12 The following comments are highly relevant (Page 14):

6.13 The conclusion on the retail planning issue is as follows Page (15):
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7.0 GLH 09

7.1 GLH 09, which supports Tesco‟s second application, again draws heavily on
RTP 07 and its underlying survey, with similar emphasis/omissions. Comments
made in 3.0 above regarding RTP 07 are, therefore, also relevant in respect of GLH
09.

7.2 GLH 09 is also stated to draw upon a household survey carried out in October
2008 for Tesco in support of a planning application for a new large store in Epsom.
The results of this later survey are stated to support the RTP 07 survey, but only
brief details are given.

7.3 As in GLH 08, the comments on footfall (Para 4.23) conflict with RTP 07.

7.4 The comment on bus services (Para 4.24) makes no mention of the very
limited nature of the services.

7.5 As in RTP 07, the results of the question in the household survey asking what
people dislike about Ashtead (Para 4.30) omit to mention that only 1.6% chose the
“lack of a larger supermarket” and that 42% indicated there was “nothing in
particular” they disliked (3.17 above).

7.6 As in RTP 07, the stated responses (Para 4.31) to the survey question “how
could Ashtead best be improved for shopping” omit the fact that only 3.2% of
people chose “a better/bigger supermarket”. This omission gives a misleading
perspective of what the people were actually saying (3.18 above).

7.7 As in RTP 07, the conclusion (Para 4.47) that “the centre (Ashtead) lacks
focus and requires stronger retail provision to enhance attraction and improve its
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performance” is not supported by the survey responses. In fact, it could be

concluded from the responses that it is the particular diversity of independent
retailers in Ashtead that is its attraction (3.19 and 3.20 above).

7.8 As in RTP 07, great weight (Para 5.7) is placed on the fact that the retention
level for expenditure on convenience goods is around 12%. As discussed above (3.4
and onwards), the determination of Zone 4 boundaries has a huge bearing on this
figure and brings into question the fundamentals of retention/leakage between
artificially imposed zones which bear no relation to practical reality.

7.9 Perhaps the sensitivity of the issue can best be illustrated by the following:

Total convenience goods expenditure of £39.6million by residents of Zone 4 is

broken down as follows (using market shares from RTP 07, Q1 and Q4, Appendix 1),
assuming about 50% of the „other stores/did not know/varies‟ expenditure relates to
Ashtead (a reasonable assumption and one supported by the turnover levels of the
existing convenience stores in Ashtead) and also assuming a 70:30 ratio of
main:top-up expenditure:

Main Top-up Total

% £m % £m £m

Epsom 42 11.6 29 3.5 15.1

Leatherhead 39 10.8 12 1.4 12.2

Ashtead 1 0.3 41 4.9 5.2

Internet 7 1.9 - - 1.9

Other 11 3.1 18 2.1 5.2

100 27.7 100 11.9 39.6

7.10 Approximately 33% of the residents of Zone 4 live in Epsom and could,
therefore, be expected to do their shopping in Epsom (PR 2008, Page 10). It is also
the case that “top-up shopping is largely undertaken close to people‟s homes” (RTP
2008, Para 4.20) and it would therefore not be expected that top-up shopping would
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significantly leak from a particular locality with adequate convenience shops. Thus,
the market shares for top-up shopping (29% for Epsom and 12% for Leatherhead)
could be said to provide a very crude indication of the household spread in Zone 4.
On this basis, and assuming expenditure by Zone 4 residents who live in Epsom or
close to Leatherhead should more accurately be described as retained expenditure
(since it is expenditure actually incurred by residents in their local shops), the
retention level could perhaps be more realistically determined (using figures from
the table at 7.09 and assuming) as:

£m

Ashtead total expenditure 5.2

Epsom + Leatherhead top-up expenditure (3.5 + 1.4) 4.9

Epsom main expenditure (29/42 x 11.6) 8.0

Leatherhead main expenditure (12/39 x 10.8) 3.3

£21.4m

The retention level then becomes (21.4/39.6) 54%. This is very close to the 55% –
70% range which is considered healthy (RTP 07, Para 3.17). Indeed, if internet
shopping is also considered to be retained, then the retention level becomes
(23.3/39.6) 59%. These figures are simply intended to highlight the flaw in RTP 07
regarding shopping habits which ultimately flows through to the analysis of impact of
the proposed store on the turnover of the existing Ashtead convenience retailers.

7.11 Whilst the above calculations are somewhat crude, they are no more
unrealistic than the concept of determining retail needs by reference to shopping
habits within an artificial grouping of post codes which takes no account of practical
realities, particularly the shops located just outside the chosen area, which are
naturally the local shops for those residents within the chosen area closest to them.
The point here is that people shop where it is convenient (eg Epsom residents shop
in Epsom) and thus the RTP 07 analysis (relied upon by GLH 09) is flawed in that it
did not recognise this point when using the survey data to assess the impact of the
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proposed store on the existing Ashtead convenience retailers. The analysis below
adjusts the available data so as to eliminate the expenditure that will be retained in
Epsom and Leatherhead and thus provide a more realistic estimate of the
expenditure available for capture by the proposed store and from where it is
available for capture.

7.12 It is stated (Para 5.18) that the catchment area (based on the post codes
KT18, KT21 1and KT21 2) was confirmed as appropriate in RTP 08 in relation to
Tesco‟s first application for the larger store. However, it is stated in PR 2008 (Page
13) “officers consider that the catchment area and population used for the statistical
justification of the need for the store is too large. It exaggerates the case for a
supermarket of the proposed size”. If the catchment area/population for the
proposed bigger store were considered too large, how can they be appropriate for
the proposed smaller store?

7.13 As in GLH 08, a ratio of 70:30 main:top-up expenditure is “considered

appropriate” (Para 5.26). This ratio appears to be taken from RTP 07, where
minimal justification is given for its adoption, although its genesis presumably is the
anecdotal evidence obtained from the household survey where no specific question
was asked on this point.

7.14 Great emphasis is placed (Paras 5.29 to 5.31) on the available expenditure
capacity within Zone 4 after taking account of the existing shops in Ashtead and the
proposed new store – the figure quoted for 2011 is £25.18 million. This is used to
show there is ample capacity within Zone 4 to accommodate the proposed store. As
indicated below (basically a re-analysis of the figures in the table at 7.9 between
expenditure that will be retained where presently incurred and thus not be available
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for capture and expenditure that will be available for capture), the position is not
that simple:

Main Top-up Total

£m £m £m

(a) Turnover of proposed store 5.99 2.57 8.56

Expenditure by Zone 4
residents that will continue
unchanged and will not be
available for capture:

- Epsom 8.0 3.5 11.5

- Leatherhead 3.3 1.4 4.7
- Ashtead (note below) - - -
Other expenditure
Internet expenditure 1.9 - 1.9
13.2 4.9 18.1
Total expenditure by Zone
4 residents 27.7 11.9 39.6
(b) Available expenditure
capacity 14.5 7.0 21.5

Available expenditure
capacity that must be
captured by proposed store
(a)/(b)% 41% 37%

Note: It is assumed all expenditure in Ashtead and all Other expenditure is available
for capture by the proposed store.

7.15 To meet its projected turnover level, the proposed store must capture around
40% of the available main shop expenditure capacity. This could be problematical
for several reasons, including:

 “The existing supermarkets that Ashtead residents use in Leatherhead and

Epsom are not far away” (PR 2008, Page 12).
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 “Main food shopping is almost always undertaken in „higher order‟ centres”

(PR 2008, Page 12).

7.16 The proposed store will also need to capture around 40% of the available
top-up expenditure capacity of £7.0 million, made up of £4.9 million of expenditure
in Ashtead and £2.1 million of other expenditure (7.9 above). It is most likely a
large amount of this latter sum is actually being spent in Ashtead. This is pointed
out in RTP 08 (Para 4.18). Given that top-up shopping generally takes place locally
it is reasonable to conclude that the bulk of expenditure will be captured by the
proposed store from existing top-up expenditure in Ashtead. Even assuming the
whole of the other unspecified expenditure is outside Ashtead (unlikely) and that the
proposed store will capture 37% of that expenditure, it means that £1.8m (£4.9m x
37%) of expenditure will be captured by the new store from existing Ashtead shops.
This would represent about 33% of their estimated turnover – considerably more
than the 8% projected in GLH 09 (Para 7.13 and Table 10, Appendix C).

7.17 It is stated (Para 7.15) that as it is not intended the store will have “meat,
fish or delicatessen counters” the proposed store “is not anticipated to significantly
divert trade or impact upon specialist convenience stores within the town centre”.
In fact such stores “are expected to benefit” from the proposed store as it “will
attract more shoppers” and “provide significant potential for linkage between the
store and the specialist convenience retailers”. It should be noted that:

 The statement regarding “meat, fish or delicatessen counters” is one of

intent only, and intentions can change at any time and, in any case, it is
acknowledged (NRI, Page 6) that “such goods will be available pre-packed
from chiller cabinets”;

 Tesco has said that it would not accept a condition precluding meat, fish
or delicatessen counters (PR 2008, Page 14).

 Any benefit from linkage (or linked trips) is considered in RTP 08 (Para
4.22) “to be negligible” and this view is endorsed in PR 2008 (Page 14).
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7.18 It is again stated (Para 7.16) that Ashtead “lacks focus and requires stronger
retail provision to enhance attraction and improve performance”. Once again, no
justification is given for this statement, nor is it supported by any survey data. In
fact, it would reasonably be concluded that the survey shows the exact opposite.

7.19 It is stated (Para 7.19) that the “modest” diversion of trade within Ashtead
“will be more than compensated for by an increase in visitor numbers to the centre
and the spin-off linked shopping trip benefits”. No evidence is given to support this
statement, which is effectively contradicted in RTP 08 and PR 2008 (7.17 above).

7.20 It is stated (Para 7.20) that the proposed store will increase consumer choice.
The following perhaps paints a different picture (using figures taken from Tables 6
and 7, Appendix C) – it should be noted that the Tesco Express store is actually
twice the size shown below (8.6 below), and that consequently Tesco‟s market share
is understated here:

Net sales Implied

m2 Turnover £m

Existing convenience stores in Ashtead

excluding Tesco Express 615 3.69

Tesco Express 125 125 1.43 1.43

Total Existing 740 5.12

Proposed store 750 750 8.56 8.56

Total existing + proposed 1490 13.68

Proposed store as percentage of:

 Existing excluding Tesco 122% 232%

 Existing 101% 167%

 Existing + proposed 50% 63%

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7.21 It can be readily seen from the above that the proposed store alone will have
a turnover of nearly 2½ times the combined turnovers of all other non-Tesco
convenience stores in Ashtead (before any capture of turnover by the proposed
store).

7.22 The word “dominant” is defined (New English Dictionary and Thesaurus –
Geddes & Grosset 1999 Edition) as “commanding; prevailing over others”. It is clear
that the proposed Tesco store will be in the dominant position for convenience
shopping in Ashtead. and it is difficult to see how the development of a new store of
the size proposed could be considered to be on a “level playing field” with existing
town centre retailers (Para 7.21).

7.23 It is stated (Para 8.6) that “the majority of the proposed store‟s trade is
anticipated to be diverted from those stores outside the catchment area which
currently attract a significant proportion of the catchment area‟s convenience
expenditure”. As indicated (7.9 and 7.14 above), this is clearly the case in relation
to main shopping expenditure, but clearly not the case for top-up shopping
expenditure where at least 70% (£4.9m/£7.0m) of the expenditure available to
capture occurs within Ashtead itself. It would thus seem clear that the majority of
top-up expenditure will be captured by the proposed store from existing Ashtead
convenience stores. This makes fundamental sense as top-up shopping is largely
carried out close to home (RTP 2008, Para 4.20) – evidenced by the high 41%
survey respondents who top-up shop in Ashtead – and it is the top-up shopping of
those living close to Ashtead which will be captured from the stores close to them (ie
the stores in Ashtead) by the proposed new store in Ashtead.

7.24 It is stated (Para 7.13) that 8% of the turnover of existing Ashtead

convenience shops will be captured by the proposed store, but no evidence is
produced to support this assertion. The impact on the other retailers is shown in
 21

Table 10, Appendix C. However, using the figures calculated above (7.13), the
position would perhaps be better shown as follows:

Implied Captured
Top-Up Expenditure by New Store
Available
For Capture £m % £m
Epsom - -
Leatherhead - -
Ashtead 4.9 37% 1.80
Internet - -
Other 2.1 37% 0.77
7.0 2.57

7.25 This calculation assumes an even distribution of the capture from Ashtead
and other expenditure. If, as is likely (but extent unknown), the other expenditure
actually largely represents top-up shopping in Ashtead (RTP 07, Para 4.18) there will
clearly be a greater impact on existing Ashtead convenience shops. Alternatively, if
a greater proportion of the captured expenditure comes from the available Ashtead
top-up expenditure, this will also produce a greater impact on existing Ashtead
convenience shops. There is a degree of sensitivity in this – if ½ of the other
unspecified expenditure is actually incurred in Ashtead then existing Ashtead
retailers would have 45% of their turnover captured by the proposed store.

8.0 RTP 09

8.1 RTP 09 fundamentally looks at the following retail matters (Para 2.26)
considered in GLH 09:

 Whether there is a need (not now required under PPS4).

 Whether the development is of an appropriate scale.

 Whether there are any unacceptable impacts on existing centres.

8.2 It is stated (Para 3.3) that the indicative turnover of the proposed store
should be £13,099/ sqm (not £11,410/sqm as in GLH 09).
 22

8.3 It is stated that differing floor spaces have been quoted (750 sqm in GLH 09
and 815 sqm on plans). Given it is recommended (Para 5.48) that “the net sales
area should be restricted to 750 sqm”, the following analysis has used the figure of
750 sqm and has drawn upon Table 5.5 of RTP 08 as the “most robust” source(Para
5.38).

8.4 Based upon a floor space of 750 sqm, the turnover of the store is (£13,099 x
750) £9.82 million (Para 3.3). Using a 70:30 ratio this indicates main shopping of
£6.87 million and top-up shopping of £2.95 million.

8.5 It is stated (Para 3.7) that the sales area of Tesco Express is 250 sqm (not
150 sqm as used in GLH 09).

8.6 Taking the above into account, the implied turnover of the existing
convenience stores in Ashtead in 2011 is now shown (Table RTP 3.2) as follows:

Sales Area sqm 2011 Turnover £m

Alldays 153 0.91

Local Stores – The Street 397 2.38

Local Stores – Craddocks 65 0.39

615 3.68

Tesco Express 250 3.27

865 6.95

8.7 It is stated (Para 4.4) that the proposed store of 750 sqm will be 15% of the
total Ashtead floor space of 5,115 sqm including the new store and that this is
significant but not dominant.

8.8 It is stated (Para 4.9) that “we are satisfied (the store) can be accessed by a
variety of modes of transport”. This statement is surprising given the comment in
RTP 07 (Para 6.45) that “bus services to and from Ashtead are very limited” and that
the railway station “is a further 15 minutes walk to (the store) and thus access from
the station ..... may be difficult for elderly or disabled visitors”. How can these two
positions be reconciled, as nothing has changed? The question might also be asked
 23

how will the store be accessed by bus on Sundays or after 6.00 pm when there are
no bus services, and on Saturdays when the already limited services are further
curtailed? In fact, the railway station is approximately 1¼ kilometres from the
proposed store and is further from the proposed store than the adjacent stations in
each direction are from larger stores (Epsom Waitrose and Leatherhead
Sainsbury‟s). As for bus times during weekdays:

 The 408 is a 2 hour service. Arriving from the Epsom direction, the next
return journey is 1½ hours later, and thus not viable just for a shopping trip;
arriving from the Leatherhead direction, the next return journeys are 24
minutes and 2 hours 24 minutes later; again not viable for shopping trips.
Furthermore, within 5 to 7 minutes of Ashtead on this bus route in both
directions are significantly larger supermarkets (Sainsbury‟s in Leatherhead
and Waitrose in Epsom).

 The 479 bus also serves Sainsbury‟s in Leatherhead and Waitrose in Epsom,
and so it is unlikely to be used for shopping at the smaller store in Ashtead.

 The 516 has only 3 services per day in each direction. The same comments as
for the 408 service apply in respect of times until return journey, and also in
respect of passing larger supermarkets in Leatherhead and Epsom.

 The 623 cannot be used for a return journey the same day (or even week),
except for travelling from the top of Greville Park Road to the store, which is
a 3 minute walk, and the time until the return journey is 3 hours.

The reality, therefore, is that there are no bus services which are likely to be used
for shopping at the proposed store and it is unrealistic to expect any use of trains to
access the proposed store.

8.9 It is concluded (Para 4.13) that “the proposed development is of an

appropriate scale subject to an investigation of wider impacts”.
 24

8.10 It is stated (Para 5.29) that residents of Zone 4 “are often travelling
substantial distances to undertake main food shopping”. No indication is given of
the meaning of „substantial‟ in this context. It is difficult to reconcile this statement
with the comment in PR 2008 (Section 1(h) Page 12) that “the existing supermarkets
that Ashtead residents use in Leatherhead and Epsom are not far away”. It is also
worth noting that some residents of Epsom would have to travel further to the
Sainsbury store in Kiln Lane, Epsom than some Ashtead residents would have to
travel to the Sainsbury‟s or Tesco stores in Leatherhead.

8.11 It is stated (Para 5.30) that the impact assessment on local shops contained
in GLH 09 is “a little simplistic” as it makes no distinction between main food and
top-up shopping. It is only the latter which is of relevance to the impact on local
shops in Ashtead.

8.12 It is noted (Para 5.33) that the survey results showed 11.6% of households
“identified a store which was not one of the identified major retailers” and 10.1%
who “did not know or advised that their choice of store for top-up shopping varies”.
It is suspected that a large proportion of this 21.7% of households is shopping at
some of the specialist stores in Ashtead and Craddocks Parade, such as the butcher,
greengrocer and fishmonger. The fact that the survey did not cover this aspect
leaves a very significant gap in the data.

8.13 However, the recalculated implied 2007 turnover amounts (Table RTP 3.2)
showing a total for Ashtead convenience retailers of £6.95 million and the estimated
percentage of top-up turnover in those retailers (Table RTP 5.5) indicate that
approximately 56% of the total expenditure by Zone 4 residents on top-up shopping
of £11.9 million (7.9 above) is incurred in Ashtead (ie £6.7m), leaving only 3%
(£0.3m) unaccounted for. The position in terms of top-up expenditure by the
proposed store now becomes:
 25

Implied Top-Up Captured by

Expenditure Available New Store

For Capture £m % £m

Epsom - - -

Leatherhead - - -

Ashtead 6.7 42 2.82

Internet -

Other 0.3 42 0.13

7.0 2.95

8.14 The proposed store will, therefore, capture at least £2.82m of the turnover of
the Ashtead convenience stores ie about 40% of their total turnover of £6.95 million.

8.15 Looking at main shopping, the turnover of the proposed store will be captured
from the following (using figures from 7.9 and 7.14 above):

Implied Main Captured by

Expenditure Available New Store
For Capture £m % £m

Epsom 3.6 47% 1.71

Leatherhead 7.5 47% 3.56

Ashtead 0.3 47% 0.14

Internet - 47% -

Other 3.1 47% 1.46

14.5 6.87

8.16 The proposed store must capture around 47% of the available main shop
expenditure capacity to meet its projected turnover level. As indicated above (7.15),
this may be problematic.

8.17 RTP 09 estimates (Para 5.35) that 40% of the proposed store‟s top-up
shopping turnover will be captured from existing Ashtead convenience retailers ie
£1.18 million (Table RTP 5.2). No explanation or analysis is provided in RTP 09 to
 26

support this estimate and it appears the basis of estimation (by reference to top-up
turnover of the proposed store) is flawed and that the more correct approach (taken
above) is to determine from where the top-up expenditure will be captured and how
much is available to capture. For the reasons explained above, the figure of £1.18
million appears to be a very significant underestimate of the impact of the proposed
store on existing Ashtead convenience retailers. The calculations (7.9, 7.14 and
8.14 above) indicate a figure of £2.82 million, approximately 2½ times the estimate
in RTP 09. See the further discussion on this below (8.21 to 8.24).

8.18 RTP 09 then seeks to apportion the captured turnover across the various
categories of Ashtead convenience stores. The basis of the apportionment is an
estimate by Tym (note 4, Table RTP 5.3). No analysis is provided to support the
basis for apportionment, except for the comment (Para 5.36) “... we recognise that
it is not intended that the proposed store would (sell) fresh meat, fish or
delicatessen from specialist counters. For that reason we assume that the impact
would fall most heavily on the existing Alldays and Tesco Express stores”. This
assumption would seem to be invalid as it is acknowledged (NRI, Page 6) “such
goods will be available pre-packed from chiller cabinets”. No support is provided for
this assumption or to the degree to which RTP 09 weights the captured turnover
impact across the stores. . Also, no consideration has been given to the impact on
local bakers and greengrocers.

8.19 The basis of apportionment of the top-up expenditure captured by the

proposed store from other local convenience retailers used in RTP 09 (Table RTP
5.5) is significantly different from that used in RTP 08 (Table RTP 4.1). No
explanation is given for this change in basis. Since the relevant underlying
circumstances have remained fundamentally unchanged, it is difficult to see why
such a change has been made. The following illustrates the different apportionment
bases used:
 27

Apportionment of Captured Top-up Expenditure %

RTP 08 RTP 09

Alldays, The Street 10.8 15.2

Local Convenience Stores, The Street 39.6 7.6

Local Convenience Stores, Craddocks 7.8 2.6

57.9 25.4

Tesco Express, Craddocks 42.1 74.6

100.0 100.0

8.20 As in RTP 09, RTP 08 uses an estimate of 40% of the proposed store‟s top-up
turnover to provide the amount (£1.9m) captured from existing Ashtead
convenience retailers (Para 4.20). It follows from this that however big or small the
size of the store, it will always capture 40% of its top-up turnover from existing
convenience retailers in Ashtead irrespective of the quantum of top-up shopping in
Ashtead – hence the amount of £1.18 million estimated (Para 5.35) in RTP 09. No
explanation or justification is provided in either RTP 08 or RTP 09 for this proposition
and it would appear difficult to provide such justification.

8.21 The amount of top-up expenditure captured from existing Ashtead

convenience retailers will be fundamentally determined by the amount of top-up
expenditure incurred in those stores ie top-up expenditure currently incurred in
Ashtead by people who will switch their top-up shopping to the proposed store.

8.22 Top-up expenditure will be captured by the proposed store from the top-up
expenditure available to be captured. Where the expenditure is actually captured
from will be determined by where the available expenditure is located. The amount
of top-up turnover of the proposed store is irrelevant in determining where the
expenditure will be captured from – it is relevant only in determining how much
expenditure will be captured. Thus, the first task is to establish where the existing
top-up expenditure is incurred. The second task is to establish how much is incurred
in each location. The third task is to identify how much (if any) top-up expenditure
incurred in each location is available for capture.
 28

8.23 A fall in projected top-up turnover of the proposed store will, therefore, not
result in an automatic drop in expenditure captured from local convenience retailers
if the whole (or substantially the whole) expenditure available to capture is that
incurred with those local retailers. This is the position which exists in Ashtead and
which is illustrated above (7.9, 7.23 and 8.13 above).

8.24 It would appear the RTP 08 and RTP 09 approach to estimating the total top-
up expenditure impact on existing Ashtead convenience stores based upon a
percentage of the proposed store‟s top-up turnover is fundamentally flawed and
provides a misleading outcome. It is submitted that an approach based upon the
location of available expenditure is most appropriate and that the calculations above
(7.9, 7.23 and 8.13 above) provide a more realistic outcome.

8.25 The following tables illustrate the impact of the differing amounts of captured
expenditure and the differing bases of apportionment of that captured expenditure.

8.26 This table illustrates the RTP 09 basis of apportionment applied to the RTP 09
estimate of captured expenditure (it is basically Table RT 5.5 in RTP 09).

2011 Top-up Turnover Top-up Capture Turnover

Turnover % £m % £m Capture %

Alldays, The Street 0.91 95 0.87 15.2 0.18 20

Local Convenience
Stores, The Street 2.38 100 2.38 7.6 0.09 4

Local Convenience
Stores, Craddocks 0.39 100 0.39 2.6 0.03 9

3.68 3.64 25.4 0.30

Tesco Express,
Craddocks 3.27 90 2.93 74.6 0.88 27

6.95 6.57 100 1.18

 29

8.27 This table illustrates the RTP 08 basis of apportionment applied to the RTP 09
estimate of captured expenditure.

2011 Top-up Turnover Top-up Capture Turnover

Turnover % £m % £m Capture %

Alldays, The Street 0.91 95 0.87 10.5 0.12 13

Local Convenience
Stores, The Street 2.38 100 2.38 39.6 0.47 20

Local Convenience
Stores, Craddocks 0.39 100 0.39 7.8 0.09 23

3.68 3.64 57.9 0.68

Tesco Express,
Craddocks 3.27 90 2.93 42.1 0.50 15

6.95 6.57 100 1.18

8.28 This table illustrates the RTP 09 basis of apportionment applied to the
estimate of captured expenditure per 8.13 above.

2011 Top-up Turnover Top-up Capture Turnover

Turnover % £m % £m Capture %

Alldays, The Street 0.91 95 0.87 15.2 0.43 47

Local Convenience
Stores, The Street 2.38 100 2.38 7.6 0.22 9

Local Convenience
Stores, Craddocks 0.39 100 0.39 2.6 0.07 18

3.68 3.64 25.4 0.71

Tesco Express,
Craddocks 3.27 90 2.93 74.6 2.10 64

6.95 6.57 100 2.82

 30

8.29 This table illustrates the RTP 08 basis of apportionment applied to the
estimate of captured expenditure per 8.13 above.

2011 Top-up Turnover Top-up Capture Turnover

Turnover % £m % £m Capture %

Alldays, The Street 0.91 95 0.87 10.5 0.30 33

Local Convenience
Stores, The Street 2.38 100 2.38 39.6 1.12 47

Local Convenience
Stores, Craddocks 0.39 100 0.39 7.8 0.22 56

3.68 3.64 57.9 1.64

Tesco Express,
Craddocks 3.27 90 2.93 42.1 1.18 36

6.95 6.57 100 2.82

8.30 It can be seen from the above tables that:

 Using the RTP 09 estimate (£1.18m) of captured expenditure, the capture of

local convenience store turnover (excluding Alldays) ranges from 4% (8.26
above) to 23% (8.27 above).

 Using the estimate (£2.82m) of captured expenditure per 8.14 above, the
capture of local convenience store turnover (excluding Alldays) ranges from
9% (8.28 above) to 56% (8.29 above).

8.31 It is apparent the basis of apportionment of the captured expenditure is

critical to estimating the impact on the the local convenience stores.

8.32 No explanation or justification is provided in either RTP 08 or RTP 09 to

support the two bases of allocation adopted, which differ significantly. Both bases
clearly seek to weight the adverse impact on the local stores more towards Alldays
and Tesco Express. The difference is that RTP 09 seems to adopt the far more
extreme view that trade in the local stores would suffer only 10% of the total impact
whereas in RTP 08 the view was taken that they would suffer 47% of the total
 31

impact. The difference is largely accounted for by the increase in RTP 09 of the
adverse impact on Tesco Express from 42% to 75% ie almost a doubling of the
impact.

8.33 It is difficult to see the justification for such a significant change in the
relative impacts. The following underlying facts are essentially unchanged between
RTP 08 and RTP 09:

 The turnover of Tesco Express comprises 90% top-up shopping.

 Tesco Express is physically separated from the proposed store by a 10-15

minute walk.

 The location of Tesco Express makes it very convenient for people living in
Lower Ashtead and it benefits significantly from its proximity to Ashtead
station and to the top-up (and take-away) shopping made by commuters on
their journeys to/from the station.

 Tesco Express benefits significantly from shopping by families on school runs.

8.34 The difficulty in anticipating the turnover impact on the local convenience
stores is acknowledged but, having said that, it would seem highly unlikely that 75%
of the expenditure captured by the proposed store would come from Tesco Express
as assumed in RTP 09 (Table RTP 5.5). For the reasons detailed above, it seems
reasonable to conclude that the figures in the Table at 8.29 above represent the
more likely impact on local convenience shops.

8.35 However, so as to provide a mid-point between the RTP 08/RTP 09 based

figures (Tables at 8.26 and 8.27 above) and those figures calculated above (Tables
at 8.28 and 8.29 above), the following table adopts a mid-point position between the
two different bases of apportionment and the two different estimates of captured
expenditure:
 32

2011 Top-up Turnover Top-up Capture Turnover

Turnover % £m % £m Capture %

Alldays, The Street 0.91 95 0.87 13 0.26 29

Local Convenience
Stores, The Street 2.38 100 2.38 24 0.48 20

Local Convenience
Stores, Craddocks 0.39 100 0.39 5 0.10 26

3.68 3.64 42 0.84

Tesco Express,
Craddocks 3.27 90 2.93 58 1.16 35

6.95 6.57 100 2.00

8.36 For the reasons discussed above, it is not considered the figures shown in the
table at 8.35 above represent the more likely impact. These figures merely illustrate
that the mid-point between the two sets of calculations would still produce a very
significant impact on the local convenience stores.

8.37 It can be seen from the table at 8.35 above that the capture of local
convenience store turnover (excluding Alldays) ranges from 20% to 26%.

8.38 RTP 09 concludes (Para 5.4) that “even if the proposed development did
result in the closure of one or both (of Alldays and Tesco Express) the wider impact
on vitality would be relatively limited”. Even based upon the mid-point position
shown in the table at 8.35 above, this conclusion is obviously incorrect. In fact, it
would be reasonable to conclude that a reduction in turnover of between 20% and
26% is very significant and may well put some or all of the local convenience stores
at risk of closure. Added to this is the very real possibility of the closure of Alldays,
as it could reasonably be assumed that a reduction in turnover of around 30% would
make it extremely difficult, if not impossible, for Alldays to continue trading viably.
Of course, whether a reduction in turnover of around 35% would cause Tesco
Express to close is more difficult to judge, particularly as a closure of Alldays would
likely mean Tesco capturing 100% of Alldays‟ turnover and therefore increasing the
combined local convenience market share of the two Tesco stores to around 85%,
 33

after taking account of the turnover impact on the other stores and before taking
into account the possible closure of other shops. It is certainly not inconceivable
that Tesco could, within a relatively short period of time, capture close to 100%
market share.

8.39 Although not mentioned in RTP 09, there would seem to be no reason to
change the conclusion in RTP 08 that “there would be some positive spin-offs from
the proposed new store through new linked trips, though we suspect these will be
negligible” (Para 4.22). In other words, there would be minimal, if any, benefit to
the local convenience retailers from the proposed store, but a very significant
adverse impact.

8.40 RTP 09 finally concludes (Para 5.44) “the impact on specialist shops is likely
to be lower (than on Tesco Express or Alldays). For that reason we do not believe
that the overall impact on the vitality and viability of the centre is unlikely to be
significant enough to justify refusal of the application.” Even based upon the
position shown in the mid-point table at 8.35, this conclusion is obviously incorrect.
A reduction in turnover of existing local independent convenience shops of between
20% and 26% is certainly very significant and would most likely put some or all of
them at risk of closure. There is also the real possibility that Alldays will close. The
position would thus seem to be no different to that in Tesco‟s first Application, in
relation to which PR 2008 stated:

 “the applicants state in their own retail study (GLH 08, but also stated in GLH
09) „that the key consideration in assessing qualitative need is to provide
consumer choice‟. If permitted, the new store would be likely to dominate
convenience shopping in (Ashtead) significantly lessening consumer choice
because independent convenience stores would potentially close.
Consequently it would have the opposite effect that Tesco claims” (Page 14).

 “If, however, the opening of the proposed new store was to have such an
impact on existing shops that they were to close this would provide grounds
 34

for refusal on the basis that this would have a negative impact on the health
of the centre” (Page 14).

9.0 PR 2009

9.1 PR 2009 is the report, containing conclusions and recommendations, of the

Planning Officers on Tesco‟s second application. Relevant to retail issues, the main
planning issues considered (Page 14) include whether “the principle of a
supermarket and of the proposed size are acceptable” and whether “the
amendments to the scheme (ie from Tesco‟s first application) have overcome the
reasons for refusal for the previous scheme”.

9.2 It is made clear (Page 14) that the view expressed in RTP 09 is “set out and
has been taken into account in the officers‟ conclusions”.

9.3 The Mole Valley Core Strategy (Page 15) is a crucial factor in the
determination of Tesco‟s second application. The Core Strategy is based largely on
RTP 07.

9.4 The Core Strategy‟s vision for “Ashtead Village Centre” includes (Page 15)
“making provision for an increase in convenience shopping floor space that is
appropriate to the scale, nature and function of the centre and complements its
existing provision” (underlining added).

9.5 In discussing “the principle and size of supermarket” (Page 18), it is made
clear that PR 2009 “draws largely upon” RTP 09. Comments made at 8.0 above in
relation to RTP 09 are thus clearly relevant to PR 2009.

9.6 It is stated (Page 15) that Tesco‟s first application “was refused on the
grounds that the proposed food store would be too large for Ashtead village centre
and would dominate local food shopping and be likely to result in the closure of a
number of food shops that would detrimentally affect consumer choice and
character, vitality and viability of the shopping centre”. It is, therefore, clear that if
this description could be shown to apply to the proposed store in Tesco‟s second
application, the application should be refused.
 35

9.7 Whilst it is indicated (Page 20) that there is no longer any requirement to
consider the need for the proposed store (due to changes in planning legislation),
the need analysis in GLH 09 “does help to inform their impact assessment that is
required”.

9.8 The analysis used in, and conclusions drawn from, the GLH 09 assessment of
need (which then flow through to the assessment of impact on local convenience
retailers) is based largely on the premise and data underlying RTP 07. In PR 2008,
it was stated in relation to that underlying data in RTP 07 “officers consider that the
catchment area and population used for the statistical justification of the need for
the store is too large. It exaggerates the case for a supermarket of the proposed
size” (Page 13).

9.9 The same statistical data used in RPT 07 flows through to the impact
assessment on local shops in GLH 09. The very clear criticism in PR 2008 of the
data in GLH 08 would seem just as valid for GLH 09, particularly as the same data
now seeks to justify a smaller store. This fact has been recognised in PR 2009,
where the statement is made (Page 20) that “it should be noted that the catchment
area referred to as Zone 4 is wider than just Ashtead. About a third of the
catchment population and expenditure used by both consultants includes people
living in parts of Epsom. They would not be expected to look to Ashtead for their
main food shopping but to Epsom that is closer for many and offering several
supermarkets. Consequently, officers are uneasy about too much reliance being
placed upon some of the statistics of both consultants, but they are the best
available” (underlining added). However, the analysis above shows the data can be
used if analysed properly, but in so doing it clearly demonstrates that the impact of
the proposed store would be significantly detrimental to the other retailers.

9.10 As discussed and illustrated above, the major consequence from the way in
which the RTP 07 data has been used is that the amount and location of top-up
expenditure available to be captured by the proposed store are misrepresented.
This then leads to the impact on the turnover of existing Ashtead convenience stores
being very significantly understated. It therefore seems the officers in PR 2009 were
 36

correct to be “uneasy” about “too much reliance” being placed on the RTP 07 data
as used by the consultants.

9.11 As it was in PR 2008, it is again pointed out in PR 2009 (Page 21) that the
household survey (which underpinned RTP 07 and which forms the basis for the
assessment of the impact on local convenience shops) does not disclose “how many
of the households use other shops, such as the butcher, greengrocer and
fishmonger in Ashtead, for additional top-up shopping” (Page 21). Of course, what
this should refer to is „ butchers (2), greengrocers (2), fishmonger, bakers (2)‟, as
these are the actual independent convenience shops in The Street and Craddocks
Parade. It is also pointed out that the “Council‟s consultants suspect, though cannot
be sure, that a large number of these households are shopping at some of the
specialist stores in Ashtead” and that “the proportion of top-up shopping for more
local Ashtead residents is likely to be even higher than shown in the survey” (Page
21). Indeed, since these shops are currently trading successfully, it is inevitable this
is the case.

9.12 In order to estimate this higher amount, MVDC‟s consultants (RTP 09, Para
5.35) assumed 40% of the proposed store‟s top-up turnover would be captured from
the local stores. For the reasons explained at 8.21 to 8.24 above, this basis appears
fundamentally flawed, with the consequence that the impact on local stores is
significantly understated in RTP 09.

9.13 In RTP 09, MVDC‟s consultants also significantly changed (from the basis used
in RTP 08) the basis of apportionment of this turnover impact to the various local
stores without any reasons given. This change further significantly reduces the
estimated impact on the specialist stores shown in RPT 09, as clearly illustrated in
the tables at 8.26 and 8.27 above.

9.14 The position shown in the table at 8.29 above would seem to show the more
likely impact upon the turnover of the local convenience shops. It is clear the impact
(a loss of between 33% and 56% of turnover) is very significant indeed. Even using
 37

mid-point calculations (table at 8.35 above) the impact remains very significant (a
loss of between 20% and 29% of turnover).

9.15 In either case it would seem reasonable to conclude that the proposed food
store would “be likely to result in the closure of a number of food shops that would
detrimentally affect consumer choice and the character, vitality and viability of the
shopping centre”.

9.16 In regard to the impact on Ashtead‟s “vitality and viability”, it is acknowledged

that “some centres may be particularly vulnerable” and that in “centres which rely on
a particular diversity and special character, it may be appropriate to take a cautious
approach to potential adverse impacts” (Page 21). It is also acknowledged that this
“could be interpreted as meaning that adverse impacts may not just relate to the
commercial vitality and viability of a centre but whether its character is undermined
in some way by a development” (Page 23). This is an important point as it is clear
from the comments made by MVDC‟s Economic Development Unit Manager (Page
22) that the proposed supermarket would “attract alternative businesses to vacant
sites .....with a possible increase in comparison goods shops”.

9.17 Since there are currently virtually no vacant shops in Ashtead, what is really
being suggested by the MVDC‟s Economic Development Unit Manager is that
comparison goods shops will take the place of any existing specialist convenience
food shops which will close down as a result of the proposed store. Such an
outcome would clearly be a change in the existing “particular diversity and special
character” of Ashtead which was recognised by approximately 30% of people in the
RTP 07 survey.

9.18 Given the analysis above has clearly demonstrated the likelihood of some or
all of the local convenience shops closing, it would seem reasonable to conclude that
“a cautious approach to adverse impacts” should be taken.

9.19 The proposed store is projected to have a turnover of £9.82 million (RTP 09,
Para 3.3). After taking account of the turnover impact on local food stores shown in
 38

the mid-point table at 8.35 above (£6.95m-£2.0m=£4.95m) relative market shares

will become:

2011 Turnover
£m %
Alldays, The Street 0.65 4.4
Local Convenience Stores,
The Street 1.90 12.8
Local Convenience Stores, Craddocks 0.29 2.0
2.84 19.2
Tesco Express, Craddocks 2.11 14.3
4.95 33.5
Proposed Store 9.82 66.5
14.77 100.0

9.20 As the proposed store alone would have a 67% share of the local
convenience market, a turnover of 2 times all the other retailers combined and a
turnover of 3½ times the other retailers (excluding Tesco Express) combined, it
would seem reasonable to conclude that the proposed store “would dominate local
food shops”. Given the significant impact on the turnover of the other retailers, it is
likely to move to a much higher market share.

9.21 From the analysis above, it would seem reasonable to conclude that the
proposed development should be rejected on the same grounds as that of the
previously proposed development, namely:

“the proposed food store would be too large for Ashtead village centre and
would dominate local food shopping and be likely to result in the closure of a
number of food shops that would detrimentally affect consumer choice and
the character, vitality and viability of the shopping centre”.

Michael John Butler.

Fellow of The Institute of Chartered Accountants in England and Wales.

Fellow of The Institute of Chartered Accountants in Australia.