Paragraph 26 of the NPPF is clear that we can only ask for a retail impact assessment where proposals exceed 2500sqm or where we have set a local floorpsace threshold. In the absence of a locally set threshold, our interpretation has been that the consideration of retail impact is still a valid consideration in relation to proposals falling below 2,500sqm, we just can't require a full impact assessment to aid our consideration of the issue.
The NPPG now seems to have muddied the water in terms of our interpretation as it clealry says that the impact test (not the requirement for an assessment) only applies to proposals exceeding 2500sqm, or a locally set threshold.
I guess my question is, in the absence of a locally set threshold, are we able to consider the retail impact of proposals falling below 2500sqm? Like many areas, we are receiving a number of applications for discount supermarkets (circa 1300sqm) and in light of the NPPG are now not entirely clear whether impact is a valid consideration.
Proposals falling below 2,500sqm clealry have the potential to start undermining the vitality and viability of identified centres through trade diversion, certainly from a cummulative perspective. I can understand that is reasonable to set a threshold for when a full assessment is required but find it quite worrying that the NPPG basically seems to indicate that impact cannot be considered for proposals under 2500sqm.
Any thoughts on the interpretation of this issue are much appreciated.
