June 2010		

Earls Court
& West Kensington Opportunity Area
Retail & Leisure Assessment
Core Document Number: RD52 Particpant Number: 795

KEY POINT SUMMARY
i.	The Earls Court and West Kensington Opportunity Area (ECWKOA) has the potential to provide a retail, leisure and office centre, with significant residential, at the heart of a strategic area of regeneration and renewal. C&C proposes the allocation of the site as a new District Centre in the RLP.
ii.	The Earls Court Regeneration Area (ECRA) has been identified in the draft Replacement London Plan (RLP) as forming the majority of the ECWKOA (some 28 ha compared with the ECWKOA’s area of 31 ha), with its planned mixed use regeneration and growth. Annex 1 to the draft RLP identifies the ECWKOA as a significant high density regeneration opportunity with potential for various mixed uses, including town centre uses.
iii.	ECRA has the potential to provide a hub for the ECWKOA, focusing on key town centre uses such as retail, leisure, employment space and community uses, along with a significant element of residential.
iv.	The Opportunity Area will deliver many thousands of new homes and jobs. This will generate expenditure from within the Opportunity Area itself that would be sufficient to support the designation of a new centre in the ECWKOA.
v.	The ECRA site can deliver a vibrant place in line with the RLP aspirations for the ECWKOA and in accordance with what one would expect of an area designated as a District Centre. The designation of the ECWKOA as a District Centre would be consistent with policy advice in PPS4.
vi.	In producing this evidence base document, DP9 has undertaken a thorough review of all relevant retail studies.
vii.	It is clear from the existing studies that there is sufficient capacity to
accommodate a significant quantum of retail at the ECWKOA.
viii.	The figures from the 2009 GLA London Wide Retail Study report indicate that by 2026, there will be capacity in the London Borough of Hammersmith & Fulham (LBHF)/the Royal Borough of Kensington & Chelsea (RBKC) for an additional 97,315 –237,288 sqm (gross) of A1 retail floorspace.
ix.	The 2008 RBKC Retail and Leisure Needs Study concludes that by 2028 there will be additional capacity for 155,908 – 201,604 sqm (gross) of A1 retail floorspace within the borough.
x.	Finally, the 2006 LBHF West London Retail Needs Study highlights that there will be additional capacity for 81,362 sqm (gross) of A1 retail floorspace by 2021 within the borough.
xi.	None of these studies have taken the potential development at ECWKOA into account in terms of additional residential and worker spend and demand, so they are conservative in that respect.

xii.	We have considered three alternative development scenarios, each of which relates to a greater quantum of development than that currently suggested for the Opportunity Area within the draft RLP and which reflect the representations of C&C for an increase in the minimum amount of residential development and indicative employment capacity of the Opportunity Area. Our analysis of the additional retail expenditure generated and retained within the Opportunity Area as a result of these scenarios reveals that the residential element will generate between £23.24m and £49.78m of new convenience goods expenditure and £27.82 and £59.19m of new comparison goods expenditure.
xiii.	The new office worker population would generate between £2.1 1m and £6.06m of new convenience goods expenditure and between £3.25 and £9.24m of comparison goods expenditure.
xiv.	A3/A4/A5 and leisure floorspace is also required, having regard to the need to create a vibrant mix of uses and sense of place within a sustainable community in the Opportunity Area.
xv.	The analysis, based upon the level of available expenditure, demonstrates that there is capacity for 15,836 – 66,699 sqm of retail and leisure floorspace at ECWKOA, which translates as a new District Centre, rising to a new Major Centre if the higher development scenarios were progressed.
xvi.	We consider that the underlying objectives of the sequential approach would be met by the redevelopment of the ECWKOA. The likely comparison, convenience, food/drink and leisure floorspace, for which there is a need, promotes the creation of a new retail centre in the ECWKOA. This in itself would meet the aims of PPS4 and the sequential approach by delivering retail/leisure development to an underserved area in a sustainable location that is well served by public transport.
xvii.	Nonetheless, we have carried out an analysis of the main centres within RBKC and LBHF to assess whether there are sequentially preferable sites capable of accommodating as little as 2,500 sqm of retail and leisure development sales area, on a site of 0.3ha, to allow servicing, access and a small element of car parking. There are 10 sites which could fit 0.3ha criterion, however none can deliver the substantial land use change envisaged in the ECWKOA and deliver the required new urban quarter at ECWKOA.
xviii.	Levels of impact from a new centre at ECWKOA will be minimal as the majority of the demand for the floorspace is generated by indigenous (spend on site) residential and worker demand.
xix.	However, we have nonetheless carried out a sensitivity assessment of potential trade diversion (impact) if 50% of the comparison goods turnover for each of the three development scenarios were generated through trade diversion as opposed to indigenous ECWKOA demand. On this basis, the ECWKOA development scenarios would be likely to have less than 2.5% impact on any

individual centres within the two boroughs. This would be an acceptable level of trade diversion that is unlikely to have a detrimental effect on the vitality and viability of any individual centre.
xx. Accordingly, we request that Annex 2, table A2.2 be amended to incorporate a reference to ECWKOA having the potential to accommodate a new District Centre as a minimum.

1.0 INTRODUCTION AND METHODOLOGY
	1.1	This document is submitted in support of written representations and
statements made by Capital and Counties (C&C) on behalf of the Earls Court & Olympia Group (ECOG) in response to the Mayor’s draft Replacement London Plan (RLP). It relates particularly to the written statement on Matter 4F (Retailing), which explains the case for recognising within the RLP the suitability of the Earls Court West Kensington Opportunity Area (ECWKOA) for designation, at a minimum, as a new District Centre.
	1.2	To assist in the delivery of economic growth and the sustainable planning of
an ever-increasing population, the RLP (consistent with the current adopted London Plan) designates a series of Opportunity Areas. These are major reservoirs of brownfield land with significant capacity to accommodate new housing, commercial and other development.
	1.3	One of the defined Opportunity Areas is ECWKOA, which is referred to as
follows:-
“The area presents a significant opportunity for regeneration, estate renewal and housing and employment growth.”
	1.4	The text goes on to state that:-
“The potential for a strategic leisure, cultural and visitor attraction and strategically significant offices should be explored, together with retail, hotels and supporting social infrastructure.”
	1.5	In terms of retail related policies, suggested amendment 2.53 highlights the
need to review the London Plan hierarchy and bring forward new centres where appropriate. Furthermore, it highlights the potential and suitability of Opportunity Areas to accommodate new town centres as a result of high density mixed use development. Policy 4.7 states that retail, commercial and leisure development should be related to the size, role and function of a town centre and should be focussed on town centre sites, if none are available then the next preference should be for edge of centre sites.
	1.6	In preparing development plans, it is important to identify future levels of
retail and commercial floorspace in light of both strategic and local assessments and to take a proactive role in identifying capacity and bringing forward development.
	1.7	Paragraph 4.38 of the RLP identifies that there is capacity for an additional
1.3-2.2 million sqm of comparison floorspace by 2031, over and above ‘pipeline’ schemes. In order to meet this requirement the Mayor supports a proactive approach to growth within and on the edge of town centres.
	1.8	Annex 2 of the RLP categorises District and Major Centres as follows:-

District centres – distributed more widely than the Metropolitan and Major centres, providing convenience goods and services for more local communities and accessible by public transport, walking and cycling. Typically they contain 10,000 –50,000 sqm of retail floorspace. Some District centres have developed specialist shoppingfunctions.
Major centres – typically found in inner and some parts of outer London with a borough-wide catchment. They generally contain over 50,000 sqm of retail floorspace with a relatively high proportion of comparison goods relative to convenience goods. They may also have significant employment, leisure, service and civic functions.
1.9 Annex 2 defines the hierarchy of centres and includes table A2.2 setting out potential changes to the town centre network. As justified in this evidence base document, the table should be amended to highlight the potential for new centres through redevelopment at Opportunity Areas such as ECWKOA. ECWKOA should be specifically highlighted in table A2.2 as a potential future new District Centre. As this document demonstrates, even under the lowest growth scenario at ECWKOA, the retail capacity generated on site by residents and workers equates to a new District Centre, rising to a new Major Centre using the medium and upper development scenarios.
1.10 This document sets out the specific case for designation in relation to the ECWKOA
1.11 The ECWKOA site has the potential to provide a retail, leisure and office centre at the heart of a strategic area of regeneration and renewal. C&C proposes the allocation of ECWKOA as a new District Centre as a minimum for the reasons set out below:-
•	National planning policy focuses on regeneration of brownfield sites for high density mixed use development. Significant emphasis is placed upon creating sustainable communities with easy access to places of work, shops and facilities.
•	Further, national guidance advises regional authorities to be, positive, proactive and flexible in setting policies for their network and hierarchy of centres. Identified deficiencies should be addressed by either promoting existing centres to function at a higher level or through the designation of new centres.
•	It is the very nature of Opportunity Areas that they are areas of planned substantial land use change and high density mixed use development, at a scale which can involve the development of new centres, as referred to in suggested amendment 2.53 of the draft RLP.
•	ECRA has been identified in the draft RLP as forming the majority of the ECWKOA, with its planned mixed use regeneration and growth. Annex 1 to the draft RLP identifies the ECWKOA as a significant high

density regeneration opportunity with potential for various mixed uses, including town centre uses.
•	ECRA has the potential to provide a hub for the ECWKOA, focusing on key town centre uses such as retail, leisure, employment space social and community uses, along with a significant element of residential. The site can incorporate hotels, leisure, restaurants/bars and various community facilities. When these town centre uses are factored in with the proposed residential, office and retail offer it creates a genuine mixed-use place with the potential for a large number of linked trips.
•	ECWKOA will deliver many thousands of new homes and jobs. This will generate expenditure that would support town centre uses within the Opportunity Area.
•	The ECRA site can deliver a vibrant place in line with the RLP aspirations for the ECWKOA and in accordance with what one would expect of an area designated as a District Centre as a minimum.
•	The designation of the site as a District Centre as a minimum would accord with the tests set out in PPS4, for the following reasons:
i.	There would be a need for the town centre uses of retail and leisure. The technical analysis carried out in this report demonstrates that redevelopment of the Opportunity Area is likely to be of a scale that will lead to sufficient indigenous generated expenditure to justify the provision of floorspace at a level which would be consistent with District Centre designation as a minimum as defined in the draft RLP.
ii.	The provision of these uses within the Opportunity Area, close to the new residential and office development that they would be intended primarily to serve, would allow that need to be satisfied in a highly sustainable and accessible location as part of a broader mix of uses, consistent with the underlying objective of the sequential approach.
iii.	A scheme with the characteristics of District Centre at ECWKOA would have no material adverse impact on the vitality and viability of neighbouring centres.
1.12 This document explains the above propositions in greater depth having regard to relevant guidance in PPS4 in respect of the proposed retail and leisure floorspace that will form part of the mix of uses within the Opportunity Area. A summary of the relevant national policies is at Appendix 2.
1.13 The methodology used begins with determining potential development scenarios to be tested. The C&C representations set out the case for increasing the minimum housing numbers and indicative employment figures applicable to the ECWKOA within the draft RLP (including an assessment of the office

floorspace that could appropriately be accommodated within the ECWKOA). In support of that work, and in line with the WSP Interim Transport Study, we have assessed 3 development scenarios which assume higher levels of development than the draft RLP anticipates within the ECWKOA. These scenarios are as follows:-
Table 1 – Development Scenarios
Scenario	Residential	Employment*	
low	5,560	10,470	
medium	8,286	20,812	
high	10,647	26,757	

*Employment figures exclude retail and leisure jobs
1.14 We review all relevant retail studies, along with Experian datasets, to assess the existing and future retail expenditure within RBKC and LBHF. This enables an assessment of likely levels of retail capacity within the boroughs in future years, in the absence of development within the ECWKOA.
1.15 We then analyse the potential expenditure generated under the above scenarios and calculate the likely demand for additional comparison and convenience goods (Use Class A1) as a result of the proposed development at ECRA. This assessment is used to calculate the level of floorspace that retained expenditure would generate.
1.16 In addition, an assessment is made of the need for other retail floorspace (Use Class A3-A5), calculated on the basis of national floorspace data and an analysis of other comparable mixed use schemes and locations.
1.17 We then assess whether it would be appropriate to allow for leisure floorspace in the ECWKOA and place this in the context of the potential designation of the ECWKOA as a District centre in the RLP.
1.18 Having examined the need for additional retail floorspace, we address the sequential approach before setting out the likely benchmark levels of trade diversion from existing town centres.

2.0 ECWKOA RETAIL CAPACITY ASSESSMENT
	2.1	This section analyses the capacity for new retail floorspace as a result of the
various development scenarios set out above.
Existing and Forecast Retail Context
	2.2	In producing this evidence base document, DP9 has undertaken a thorough
review of relevant retail studies, produced on behalf of the GLA, RBKC and LBHF to set out the future demand for retail floorspace in their locality. The studies analysed are as follows:-
•	Consumer Expenditure and Comparison Goods Retail Floorspace Need in London (March 2009) – Experian on Behalf of the GLA.
•	Royal Borough of Kensington and Chelsea (July 2008) – Nathanial Lichfield and Partners.
•	West London Retail Needs Study (December 2006) – GVA Grimley
	2.3	The above studies have indicated the following floorspace requirements:-
GLA

Table 2 Gross Comparison Goods Floorspace Requirements (2006– 2026) (m2)
	Productivity Growth	
	1.5%	2.2%	2.8%	
HammersmithandFulham	35,154	22,156	12,410	
Kensington and Chelsea	177,885	122,210	80,468	
Total	213,039	144,366	92,878	

Source: Experian (for the GLA) – March 2009
Table 3 Gross Convenience Goods Floorspace Requirements to 2016 (m2)
	Productivity Growth	
	0.15%	0.50%	1.00%	
Low Sales Density Scenario (£5,500/m2)	
Hammersmith and Fulham Kensington and Chelsea	9,800
14,449	6,620
10,493	2,374
5,210	
Total	24,249	17,113	7,584	
High Sales Density Scenario (£9,400/m2)	
Hammersmith and Fulham Kensington and Chelsea	5,734
8,454	3,873
6,139	1,389
3,048	
Total	14,188	10,012	4,437	

Source: Experian (for the GLA) – March 2009.

RBKC
Table 4 RBKC Comparison Expenditure/Floorspace Projections
	2008-
2012	2008-
2015	2008-
2020	2008-
2028	
High Growth Scenario	
Surplus Expenditure(fm)	164.11	295.31	582.48	1,180.99	
Projected Sales Floorspace - GROSS (m2)
Projected	Sales	Floorspace	-NET
(m 2)	32,053
24,040	55,164
41,373	100,993
75,744	181,668
136,251	
Low Growth Scenario		
Surplus Expenditure(fm)	31.19	146.95	403.95	943.67	
Projected Sales Floorspace - GROSS (m2)
Projected Sales Floorspace - NET (m2)	5,932
4,449	27,277
20,458	69,712
52,284	144,881
108,661	

Source: Nathaniel Lichfield and Partners (for RBKC) – July 2008
Table 5 RBKC Convenience Expenditure/Floorspace Projections
	2008-
2012	2008-
2015	2008-
2020	2008-
2028	
High Growth Scenario	
Surplus Expenditure (fm)	85.50	100.84	124.53	147.47	
Projected Sales Floorspace - GROSS (m2) Projected Sales Floorspace - NET (m2)	11,072
7,751	13,404
9,383	16,898
11,829	19,936
13,955	
Low Growth Scenario		
Surplus Expenditure (fm)	27.83	42.65	65.46	86.97	
Projected Sales Floorspace - GROSS (m2) Projected Sales Floorspace -NET (m2)	3,091
2,164	5,181
3,627	8,311
5,818	11,027
7,719	

Source: Nathaniel Lichfield and Partners (for RBKC) – July 2008 LBHF

Table 6 LBHF Future Comparison Goods Floorspace Capacity (2006 base) (m2)

	2011	2016	2021	
Future Capacity(m2 gross)	20,758	43,998	71,388	

Source: GVA Grimley (for LBs ofEaling, Hounslow and Hammersmith & Fulham) – December2006.
Table 7 LBHF Future Convenience Goods Floorsp ace Capacity (2006 base) (m2)
	2011	2016	2021	
Applied	Sales
Density	£4,000!
m2	£12,000!
m2	£4,000!
m2	£12,000!
m2	£4,000!
m2	£12,000!
m2	
Future Capacity (m2net)	10,966	3,655	15,754	5,251	20,945	6,982	

Source:GVA Grimley (for LBs of Ealing, Hounslow and Hammersmith & Fulham) – December 2006
	2.4	The three documents all utilise recognised and reliable figures, such as GOAD
and Experian expenditure data, resulting in broadly consistent results, albeit there are differing assumptions and timeframes in which requirements were forecast.
	2.5	It is clear from the existing studies that there is sufficient capacity to
accommodate a significant quantum of retail, including provision at the ECWKOA.
	2.6	The figures from the 2009 GLA report indicate that by 2026, there will be
capacity in LBHF/RBKC for an additional 97,315 – 237,288 sqm (gross) of A1 retail floorspace.
	2.7	The 2008 RBKC report concludes that by 2028 there will be additional
capacity for 155,908 – 201,604 sqm (gross) of A1 retail floorspace.
	2.8	Finally, the 2006 LBHF retail study highlights that there will be additional
capacity for 81,362 sqm (gross) of A1 retail floorspace by 2021.
	2.9	None of these existing studies have taken the potential development at
ECWKOA into account in terms of additional residential and worker spend and demand. As set out below, the level of expenditure from new residents and workers, the ‘indigenous’ demand, under all three development scenarios generates a need for additional retail/leisure floorspace in ECWKOA equivalent to a District Centre as a minimum.
Additional Expenditure as a Result of ECWKOA
2.10 This section of the Evidence Base document analyses the additional retail expenditure that will be generated as a result of the likely development at ECWKOA.

Residential
2.11 As set out in Section 2 three scenarios have been appraised in respect of the potential residential development at ECWKOA. According to the 2001 census, the average size of a household in London is 2.3 people. Table 8 below sets out the likely population increase as a result of the scenarios.
Table 8–2026 ECWKOA Population Increase
Scenario	Residential Units	Population Increase	
low	5,560	12,788	
medium	8,286	19,057	
high	10,647	24,488	

2.12 Utilising figures for expenditure per head in RBKC and LBHF, derived from the respective borough wide retail studies, we have projected forward to ascertain additional expenditure in 2026 for the three scenarios. It is considered that this approach provides a robust “upper” and “lower” assessment, as expenditure per head is higher in RBKC than in LBHF. According to Experian data, per capita comparison and convenience goods in RBKC in 2026 will be £6,907 and £2,245 respectively. The figures in LBHF are £6,216 and £2,020.
2.13 Table 9 below sets out our findings.
Table 9- New ECRA Residential Expenditure Forecasts
	Low
Scenario	Medium
Scenario	Upper
Scenario	
Residential Units	5,560	8,286	10,647	
New Population	12,788	19,058	24,488	
				
LBHF Expenditure				
				
Con Spend 2026	£2,020	£2,020	£2,020	
Com Spend 2026	£6,216	£6,216	£6,216	
				
Total Convenience	£25,831,760	£38,496,756	£49,465,962	
Total Comparison	£79,490,208	£118,463,285	£152,218,030	
				
RBKC Expenditure				
				
Con Spend 2026	£2,245	£2,245	£2,245	
Com Spend 2026	£6,907	£6,907	£6,907	
				
Total Convenience	£28,709,060	£42,784,761	£54,975,785	
Total Comparison	£88,326,716	£131,632,225	£169,139,307	

2.14 The above Table 9 sets out the total amount of expenditure generated by ECWKOA under the three scenarios. However, it should be recognised that
not all will be retained within the proposed development, other centres in the borough and further afield will also benefit.
2.15 In terms of ECWKOA we anticipate that the scheme will retain the majority of convenience expenditure, along with a significant proportion of the comparison expenditure. Shopping patterns for convenience goods tend to be localised, whereas consumers will travel further afield for comparison goods.
2.16 We have then assumed that 90% of resident’s convenience expenditure and 35% of comparison is retained within the ECWKOA. Table 10 below sets out the retained residential expenditure at ECWKOA under the three scenarios.
Table 10 Retained ECRA Residential Expenditure
	Low
Scenario	Medium
Scenario	High
Scenario	
Residential Units	5,560	8,286	10,647	
New Population	12,788	19,058	24,488	
				
LBHF Expenditure				
				
Total Convenience	£25,831,760	£38,496,756	£49,465,962	
Total Comparison	£79,490,208	£118,463,285	£152,218,030	
				
Retained	Convenience
Spend	£23,248,584	£34,647,080	£44,519,366	
Retained	Comparison
Spend	£27,821,573	£41,462,150	£53,276,310	
				
RBKC Expenditure				
				
Total Convenience	£28,709,060	£42,784,761	£54,975,785	
Total Comparison	£88,326,716	£131,632,225	£169,139,307	
				
Retained Convenience Spend	£25,838,154	£38,506,285	£49,478,206	
Retained	Comparison
Spend	£30,914,351	46,071,279	£59,198,757	

2.17 We therefore calculate that ECWKOA could provide between £23.24m and £49.78m of new residential generated convenience expenditure and £27.82 and £59.19m of comparison goods, based upon the lower and upper scenarios and whether LBHF or RBKC expenditure forecasts are utlised.
Office Workers
2.18 As set out in Section 1 the ECWKOA the three development scenarios also forecast the likely worker populations generated under each option. These range from 12,165 in Scenario 1, up to 31,895,000 sqm in Scenario 6.

2.19 In Table 11 below, we have calculated the potential expenditure from workers utlising the same expenditure per head figures for convenience/comparison goods as for the residential calculations, which is based upon LBHF and RBKC forecasts.
Table 11 New ECRA Office Worker Expenditure
	Low Scenario	Medium
Scenario	High
Scenario	
				
Worker Population	10,470	20,812	26,757	
				
LBHF Expenditure				
				
Convenience Spend 2026	£2,020	£2,020	£2,020	
Comparison Spend 2026	£6,216	£6,216	£6,216	
				
Total Convenience	£21,149,400	£42,040,240	£54,049,140	
Total Comparison	£65,081,520	£129,367,392	£166,321,512	
				
RBKC Expenditure				
				
Convenience Spend	£2,245	£2,245	£2,245	
Comparison Spend	£6,907	£6,907	£6,907	
				
Total Convenience	£23,505,150	£46,722,940	£60,069,465	
Total Comparison	£72,316,290	£143,748,484	£184,810,599	

2.20 Once again, we have anticipated that not all of this additional expenditure will be retained. Our calculations have assumed that just 10% of the convenience expenditure will be retained and 5% of comparison. The convenience figure is the opposite of the residential retention figure, whilst the comparison assumption is indicative of the fact that the majority of office shopping is lunchtime/after work ‘browsing’ as opposed to a main destination trip. The conclusions of this exercise are set out in table 12 below.
Table 12 Retained ECRA Office Expenditure
	Low
Scenario	Medium
Scenario	High
Scenario	
Worker Population	10,470	20,812	26,757	
				
LBHF Expenditure				
				
Total Convenience	£21,149,400	£42,040,240	£54,049,140	
Total Comparison	£65,081,520	£129,367,392	£166,321,512	
				
Retained Convenience Spend	£2,114,940	£4,204,024	£5,404,914	

Retained Comparison Spend	£3,254,076	£6,468,370	£8,316,076	
				
RBKC Expenditure				
				
Total Convenience	£23,505,150	£46,722,940	60,069,465	
Total Comparison	£72,316,290	£143,748,484	184,810,599	
				
Retained Convenience Spend	£2,350,515	£4,672,294	£6,006,947	
Retained Comparison Spend	£3,615,815	£7,187,424	£9,240,530	

2.21 We therefore calculate that ECWKOA could provide between £2.14m and £6.06m of new worker population generated convenience expenditure and £3.25 and £9.24m of comparison goods, based upon the lower and upper scenarios and whether LBHF or RBKC expenditure forecasts are utlised.
Additional Retail Floorspace Capacity as a Result of ECWKOA 2.22 This section translates the above findings into retail floorspace capacity.
2.23 We have aggregated retained new residential and office worker expenditure generated under the three development scenarios for ECWKOA. These have been analysed against the average expenditure per head estimates for both LBHF and RBKC. The results of the various scenarios are set out in Table 13 below.
Table 13 Total ECRA Retained Expenditure
	Low
Scenario	Medium
Scenario	High
Scenario	
Residential Units	5,560	8,286	10,647	
Worker Population	10,470	20,812	26,757	
				
LBHF Expenditure				
				
Retained Resi Convenience Spend	£23,248,584	£34,647,080	£44,519,366	
Retained Worker Convenience Spend	£2,114,940	£4,204,024	£5,404,914	
Total Retained Convenience Spend	£25,363,524	£38,851,104	£49,924,280	
				
Retained Resi Comparison Spend	£27,821,573	£41,462,150	£53,276,310	
Retained Worker Comparison Spend	£3,254,076	£6,468,370	£8,316,076	
Total Retained Comparison Spend	£31,075,649	£47,930,519	£61,592,386	

				
RBKC Expenditure				
				
Retained Resi Convenience Spend	£25,838,154	£38,506,285	£49,478,206	
Retained Worker Convenience Spend	£2,350,515	£4,672,294	£6,006,947	
Total Retained Convenience Spend	£28,188,669	£43,178,579	£55,485,153	
				
Retained Resi Comparison Spend	£30,914,351	£46,071,279	£59,198,757	
Retained Worker Comparison Spend	£3,615,815	£7,187,424	£9,240,530	
Total Retained Comparison Spend	£34,530,165	£53,258,703	£68,439,287	

2.24 The next stage is to convert the surplus expenditure figures into floorspace.
This exercise depends upon the anticipated level of floorspace turnover.
2.25 It is necessary to have a range to reflect the potential mix of uses, which in convenience terms will range from individual butchers/grocers to large format foodstores.
2.26 For comparison goods we have therefore used as an upper or ‘high’ scenario, the forecast average high street sales density in 2026 of £6,029 per sqm, derived from Experian Retail Planner Brief 7.1. However, it needs to be recognised that there potentially could be a wide range of comparison goods uses, which at the more specialist and independent end of the market will inevitably have a lower turnover. Therefore, we have adopted a ‘low’ scenario of £3,014 per sqm.
2.27 The results are set out in Table 14 below, which applies the LBHF and RBKC expenditure figures under each scenario against the “high” and “low” comparison expenditure figures.
Table 14 Total ECRA Comparison Floorspace
Capacity Sqm (gross)	
			
Low Scenario	High Turnover	Low turnover	
LBHF Expenditure	14,727	7,363	
RBKC Expenditure	16,364	8,182	
			
Medium Scenario	High Turnover	Low turnover	
LBHF Expenditure	22,714	11,357	
RBKC Expenditure	25,239	12,620	
			
High Scenario	High Turnover	Low turnover	
RBKC Expenditure	29,189	14,594	

LBHF Expenditure	32,433	16,217	

2.28 The same exercise has been carried out for convenience goods. Experian Retail Planner Brief 7.1 highlights that the average turnover of convenience goods floorspace in 2026 will be £7,528 per sqm. However, we have used this as our ‘low’ scenario as the figure covers grocery specialists such as bakers, butchers, greengrocers, delicatessens etc. Our high ‘figure’ represents the turnover of a major supermarket operator such as a Sainsbury’s or Waitrose. We have taken a 2010 turnover of £12,000 per sqm and projected it forward to 2026, providing a turnover of £12,365 per sqm.
2.29 Table 15 below sets out our findings, which applies the LBHF and RBKC expenditure figures under each scenario against the “high” and “low” convenience expenditure figures.
.
Table 15 Total ECRA Convenience Floorspace
Capacity Sqm (gross)		
			
Low Scenario	High Turnover	Low turnover	
LBHF Expenditure	4,992	2,930	
RBKC Expenditure	5,548	3,257	

Medium Scenario	High Turnover	Low turnover	
LBHF Expenditure	7,647	4,489	
RBKC Expenditure	8,499	4,989	
			
High Scenario	High Turnover	Low turnover	
RBKC Expenditure	9,826	5,768	
LBHF Expenditure	10,921	6,410	

2.30 We have then amalgamated the comparison and convenience figures from Tables 14 and 15 to set out the levels of floorspace that can be supported by ‘indigenous spend’ under the three development scenarios. These are set out in Table 16 below.
Table 16- Total ECRA Convenience and Comparison
Goods Capacity - Sqm (gross)	
LBHF	RBKC	LBHF	RBKC	
Expenditure High
Turnover	Expenditure
High Turnover	Expenditure Low
Turnover	Expenditure
Low Turnover	
				
Low Scenario		Low Scenario		
10,294	11,439	19,719	21,912	
				
Medium
Scenario		Medium
Scenario		
15,846	17,608	30,361	33,738	

Upper Scenario

Upper Scenario

20,362

22,627

39,015

43,354

2.31 The above figures demonstrate that even with the lowest development scenario (scenario 1) there will be sufficient indigenous generated capacity to support 10,294 – 21,912 sqm of A1 floorspace, rising to 20,362 – 43,354 sqm under the highest development forecasts in the upper scenario. This is equivalent to a District Centre. Furthermore, this amount of floorspace would form a relatively small part of the projected borough wide capacities identified in the respective LBHF and RBKC retail studies, which have been calculated without taking into account the significant additional expenditure that would arrive as a result of the development of the Opportunity Area.
A3/A4/A5 Floorspace Need
2.32 As set out previously, the ECRA site can deliver a vibrant place in line with the RLP aspirations for the ECWKOA. A critical element of this is the creation of a place or new urban quarter to serve the level of development proposed. In addition to the A1 retail element outlined above, it is imperative in place creation that the ECWKOA incorporates an appropriate quantum of restaurants/bars/pubs etc as part of the overall retail offer envisaged by policy.
2.33 Although A3/A4/A5 uses fall under the broad umbrella of retail, there is no standardised, expenditure-based appraisal process of floorspace need for restaurants, cafés and bars. Our assessment of potential provision at ECKOA is therefore based upon a comparison with London-wide averages for A3/A4/A5 floorspace in existing centres.
2.34 As with the A1 uses, the A3/A4/A5 provision would be pitched primarily at servicing the needs of the indigenous worker and residential population. Furthermore, the A3/A4/A5 provision is an important factor in cementing the site’s mixed-use credentials and creating ‘out-of-hours’ entertainment and footfall.
2.35 For the purposes of this analysis, A3/A4/A5 uses cover five GOAD definitions – Restaurants, Cafés, Fast Food & Takeaways, Public Houses and Bars & Wine Bars.
2.36 Taking GOAD data for all London centres identified in the 2009 Experian GLA study, A3/A4/A5 uses account for an average of around 23% of all combined retail floorspace across all London centres. This figure is an average, including both ‘Major’ and ‘Neighbourhood’ centres.
2.37 Most relevant to ECWKOA are other London areas with high levels of office and/or residential. Key examples with higher than average A3/A4/A5 provision includes major workplace areas such as Bank, Kings Cross, London Bridge and Victoria; see Table 17 below.

Table 17 - Breakdown of Floorspace (gross m2) in Selected London Centres
Goad Centre	Retail
Floorspace
(m2)	A3/A4/A5
Floorspace
(m2)	Total Retail &
A3/A4/A5
Floorspace
(m2)	A3/A4/A5
as % of
Total	
Shoreditch	12,827	19,703	32,530	61%	
Kings Cross	5,930	6,765	12,696	53%	
Bank	13,601	14,382	27,983	51%	
Paddington	10,095	10,047	20,142	50%	
Greenwich	12,543	10,299	22,843	45%	
London City	165,838	127,357	293,195	43%	
London Bridge	30,098	17,539	47,638	37%	
Victoria Street	54,695	25,951	80,645	32%	
Canary Wharf	59,087	26,846	85,933	31%	

Source: Experian GOAD
2.38 Many of the centres identified as having a higher than average proportion of A3/A4/A5 floorspace are either established or emerging new ‘urban quarters’, such as Canary Wharf, Greenwich, Paddington and Kings Cross. There is a clear pattern in which urban quarters tend to allocate larger proportions of floorspace to A3/A4/A5 use, in line with the creation of sustainable and attractive residential and office locations.
2.39 On the basis of the above, in order to create a sense of place and provide a genuine mixed-use development, it would be appropriate for ECWKOA to accommodate circa 35% of A3/A4/A5 floorspace as a proportion of overall retail space.
2.40 In Table 18 below we add the percentage of A3/A4/A5 floorspace to the A1 floorspace projections set out in Table 17.
Table 18 Total ECRA Capaci
(A1/A3/A4/A5) Sqm Gross	
				
LBHF	RBKC	LBHF	RBKC	
Expenditure
Low Turnover	Expenditure	Expenditure	Expenditure	
	High Turnover	Low Turnover	Low Turnover	
				
Low Scenario		Low Scenario		
15,836	17,598	30,337	33,711	
				
Medium
Scenario		Medium
Scenario		
24,378	27,090	46,710	51,905	
				
Upper Scenario		Upper
Scenario		
31,326	34,811	60,023	66,699	

2.41 Even in the low development scenario, 15,836 – 33,711 sqm of A1 – A5 retail floorspace would be appropriate. This is well above the threshold of 10,000 sqm of retail floorspace that is used to define a District Centre in Annex 2 of the London Plan. The capacity for retail floorspace increases through the various scenarios up to 31,326 – 66,699 sqm under the upper scenario. This upper quantum falls within the definition of a Major Centre from Annex 2 of the London Plan, which provides a threshold of 50,000 sqm of retail floorspace.
2.42 It is therefore considered that ECWKOA should be identified at a minimum as a future District Centre in Annex 2, table 2.2 of the Replacement London Plan.
2.43 It should be noted from the outset that the ECWKOA already incorporates a significant quantum of D1, D2 and associated ancillary uses, principally within the Earls Court Exhibition Centre.
2.44 In terms of destination, the Earls Court Exhibition Centre already offers an established brand, which is a major asset. It is a well known location, with positive attributes and associations, existing activity and strong connectivity. It is a natural fit with the existing brand, reputation and Exhibition Centre and related uses to have a significant amount of leisure and cultural and destination venue floorspace in the ECWKOA. In terms of brand, competing destinations spend millions of pounds to achieve lesser levels of recognition, so the advanced starting point of the ECWKOA provides a real benefit and attraction.
2.45 A mix of cultural, destination and leisure uses helps create a place and reinforces the importance of creating a new urban quarter in the Opportunity Area, to make it an attractive and successful location for residents and office workers. For example, restaurants, bars, gyms, cinemas etc have a positive effect on a development through creating a place where people wish to live and work in. Furthermore, major leisure facilities benefit from locating together to create sufficient scale to make an area a destination. Furthermore, new leisure facilities will also benefit the existing population within the two boroughs.
2.46 Alongside cultural and destination venue uses, there is a strong general leisure use consumer demand, as evidenced by GVA Grimley’s West London Retail Needs Study (for LBHF) and Nathaniel Litchfield and Partners Retail and Leisure Needs study (for RBKC). They indicate a number of existing commercial facilities including cinemas, bingo clubs, ten-pin bowling destinations, bars, clubs and restaurants, and health and fitness clubs within RBKC and LBHF. However, the quantum of development in the Earls Court Regeneration Area itself will lead to a significant increase in terms of the immediate catchment.
2.47 In addition to the above, DP9 has utilised information from the 2009 GLA London Wide Town Centre Town Centre Health Check (extracts contained within appendix 3) to ascertain the average quantum of leisure floorspace (use class D2) in London Town Centres.

2.48 This demonstrates that the average leisure component of a defined London town centre is 10% of the total floorspace. However, certain centres such as Fulham, Queensway, Hammersmith, Greenwich and Paddington have 15 – 25% of their total floorspace made up of leisure floorspace. Therefore, in the case of ECWKOA, with its existing strong leisure component, we would anticipate it accommodating approximately 15% of leisure floorspace to support any significant increase in housing and office space in the area. Table 19 below demonstrates the level of leisure floorspace capacity generated under each scenario. Table 20 adds this quantum of leisure floorspace to the total quantum of A1-A5 floorspace for the 3 scenarios to provide an indication of the overall level of retail and leisure floorspace capacity generated.
Table 19 Total ECRA Capaci
Retail and Leisure Sqm Gross	
				
LBHF Expenditure	RBKC	LBHF	RBKC	
	Expenditure	Expenditure	Expenditure	
Low Turnover	High Turnover	Low Turnover	Low Turnover	
				
Low Scenario		Low Scenario		
3,288	3,654	6,298	6,999	
				
Medium Scenario		Medium
Scenario		
5,061	5,624	9,697	10,776	
				
Upper Scenario		Upper
Scenario		
6,504	6,143	10,592	11,770	

Table 20 Total ECRA Capaci
Retail and Leisure Sqm Gross	
				
LBHF Expenditure	RBKC	LBHF	RBKC	
	Expenditure	Expenditure	Expenditure	
Low Turnover	High Turnover	Low Turnover	Low Turnover	
				
Low Scenario		Low Scenario		
18,631	20,703	35,690	39,660	
				
Medium Scenario		Medium
Scenario		
28,680	31,870	54,952	61,064	
				
Upper Scenario		Upper
Scenario		
36,855	34,811	60,023	66,699	

2.49 The above demonstrates that it would be appropriate to plan for 3,288 – 6,999 sqm of leisure under the lowest development levels (low scenario), rising to 6,054 – 11,770 sqm under the upper scenario.
2.50 Table 20 sets out the combined retail (A1-A5) and leisure need generated under the three development scenarios. This further justifies the identification of ECWKOA as a future District centre under the low development scenario, rising to a new Major Centre using the medium and upper development scenarios.

3.0 SEQUENTIAL APPROACH ANALYSIS
	3.1	PPS 4 requires retail development to adopt a sequential approach to the
selection of sites, requiring an examination of the potential for developing
town centre sites, in preference to edge of centre then out of centre sites.
	3.2	ECWKOA is one of the most significant development sites in London. It is
important to recognise that with the delivery of 5,560– 10,647 new residential units and 12,165 – 31,895 new jobs, there is a requirement to create a “place” or “new urban quarter” to support the retail and leisure demand such development generates.
	3.3	ECWKOA has the potential to provide a retail, leisure and office centre at the
heart of a strategic area of regeneration and renewal.
	3.4	The Opportunity Area is classified as edge of centre as it adjoins Fulham
Town Centre.
	3.5	The retail and leisure development likely to be delivered at ECWKOA will
fulfil various functions:
•	Serving the day to day needs of those living, working and visiting the site, along with providing facilities for existing people in the local area.
•	Providing a focal point in the Opportunity Area by delivering a
commercial hub and new urban quarter serving the new community.
•	Providing a mix of retailers/leisure operators in a variety of unit sizes.
	3.6	The first two functions would not be catered for by development in any of the
existing centres in RBKC and LBHF.
	3.7	In light of the need to identify new centres in Opportunity Area set out in
suggested change 2.53 of the RLP and the likely retail function at ECWKOA, we consider that the underlying objectives of the sequential approach would be met by the redevelopment of the site. The likely comparison, convenience, food/drink and leisure floorspace, for which there is a defined quantitive/ qualitative need, promotes the creation of a new retail centre in the ECWKOA. This in itself would meet the aims of PPS4 and the sequential approach by delivering retail/leisure development to an underserved area in a sustainable location that is well served by public transport.
	3.8	Nonetheless, we have carried out an analysis of the main centres within RBKC
and LBHF to assess whether there are sequentially preferable sites capable of accommodating as little as 2,500 sqm of retail and leisure development sales area, on a site of 0.3ha, to allow servicing, access and a small element of car parking.
	3.9	This figure represents ultimate flexibility as none of the centres could
accommodate the full level of floorspace likely to be delivered at the
ECWKOA or achieve its planning objectives. The centres assessed, by

looking for sites within the defined town centre and 300 metres from the primary shopping frontage, are listed below:-
•	Shepherds Bush (Metropolitan)
•	Knightsbridge (International)
•	Fulham (Major)
•	Hammersmith (Major)
•	Kensington High Street (Major)
•	Kings Road (Major)
•	Earls Court Road (District)
•	Fulham Road (District)
•	Notting Hill Gate (District)
•	Portobello Road (District)
•	South Kensington (District)
3.10 Accordingly, identified sites as small as 0.3 hectares, have been assessed against the following tests:
•	sites are assessed for their availability, suitability and viability
•	ensure that all in-centre options have been thoroughly assessed before less central sites are considered
•	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
•	ensure that in considering sites in or on the edge of existing centres, developers and operators have demonstrated flexibility in terms of: - scale
- format
- car parking provision
- the scope for disaggregation.
3.11 Our search of the centres, which incorporated all land within and on the edge of the centre boundaries as defined in the relevant adopted UDP’s, has revealed that there are 10 sites which could fit 0. 3ha criterion. These are assessed in detail in Appendix 1 of this report.
3.12 In summary, none of the identified sites can deliver the substantial land use change envisaged in the OA and deliver the required new urban quarter at ECWKOA.

4.0 POTENTIAL IMPACT FROM ECWKOA
	4.1	We consider that levels of impact from a new District/Major Centre will be
minimal as the vast majority of the demand for the floorspace is generated by indigenous residential and worker demand. In so far as expenditure generated by development of the ECWKOA produces demand outside the OA, this would be likely to have a positive effect on other town centres.
	4.2	However, in order to be robust we have carried out a sensitivity assessment of
potential trade diversion (impact) if 50% of the comparison goods turnover for each of the three development scenarios was generated through trade diversion as opposed to indigenous ECWKOA demand. The figure of 50% is considered appropriate as clearly it would be perverse to analyse the scenarios against 100% trade diversion, bearing in mind the quantum of residential and employment floorspace. We have not carried out an assessment of impact for convenience and A3-A5 as these are more localised would be more appropriately assessed at the planning application stage.
	4.3	In order to be robust, we have assessed the potential impact of the RBKC
expenditure generated ‘high’ turnover comparison floorspace figures from each scenario. Detailed impact figures and calculations for all three development scenarios are contained in Appendix 2. Below we set out impact figures for the low and upper scenarios to set out the minimum and maximum potential levels of impact.
	4.4	The main steps in calculating comparison goods trade diversion are as
follows:-
•	Calculate the 2026 comparison goods turnover of the identified main centres in RBKC and LBHF
•	Estimate the turnover of the retail at ECWKOA
•	Estimate the expected trading patterns and trade draw of the proposed floorspace at ECWKOA and calculate the expected turnover of existing centres following its development
	4.5	The expected trade diversion is the numerical difference between the pre-
proposal turnover and the post-proposal turnover of the affected centres, the impact is the percentage difference between the two. We incorporate two scenarios, the first is the situation in 2026 assuming no development at ECWKOA, and the second is the situation in 2026 following development of ECWKOA.
	4.6	We have used survey data derived from a DP9 commissioned household
telephone survey covering 3,500 households across London Travel Zones 1-3, which incorporated the entirety of RBKC and LBHF. In addition, the surveys used to inform the LBHF and RBKC retail studies have also been utilised.

Existing Town Centre Turnovers
	4.7	We have utilised turnover figures, for the relevant centres, derived from the
DP9 telephone survey and relevant borough wide retail studies. These figures have been projected forward to 2026, factoring in increases for floorspace efficiency.
	4.8	The figures reflect all known commitments in Central London, including
Stratford City, Brent Cross, One New Change and Kings Cross.
Potential Turnover of the ECWKOA Floorsp ace
	4.9	In calculating the potential for additional comparison goods retail as a result of
development at ECWKOA, we utilised a higher turnover of £6,029 per sqm in 2026, derived from the long term forecasts in the 2009 Experian Retail Planner Brief 7.1. This turnover has also been used to assess the potential impact of the floor area that cannot be justified through ECWKOA development alone in the higher growth scenarios.
4.10 The floor area assessed for the low scenario is 8,182 sqm gross, with a discount of 30% for storage, staff accommodation etc, the turnover will be £34.53m in 2026. Of this, 50% or £17.26m is assumed to be derived from trade diversion from existing centres.
4.11 The floor area assessed for the upper scenario is 16,637 sqm gross, with a discount of 30% for storage, staff accommodation etc, the turnover will be £70.21m in 2026. Of this, 50% or £35.11m is assumed to be derived from trade diversion from existing centres.
Potential Impact of the ECWKOA Proposals
4.12 To model the likely impact of the ECWKOA low and upper scenarios development on individual centres, we have estimated the turnover of the new development, and where this turnover is likely to come from. These assumptions are informed by analysis of the trading pattern of established higher order centres, and ECWKOA’s accessibility to different parts of the survey area. These assumptions have been applied to calculate ECWKOA trade diversion under scenarios 1 and 3 from existing centres following opening of the new development in 2026.
4.13 The findings are set out in Tables 21 and 22 below. Table 21 Low Scenario – Benchmark Impact
Centre	2026
Turnover	£ impact as
result of
proposal	Turnover
following
development
of ECRA	% Impact of
ECRA on
turnover	
					
White City	£726.28m	£5.69m	£720.58m	0.8	
Kensington	£289.12m	£2.58m	£286.52m	0.9	

Hammersmit					
h	£104.89m	£1,03m	£103,85m	1.0	
Fulham	£41.62m	£0.51m	£41.10m	1.2	
Kings Road	£329.84m	£1.72m	£328.12m	0.5	
West End	£5,309.42m	£4.48m	£5,304.93m	0.1	

Table 20 Upper Scenario – Benchmark Impact
Centre	2026
Turnover	£ impact as
result of
proposal	Turnover
following
development
of ECRA	% Impact of
ECRA on
turnover	
					
White City	£726.28m	£11.58m	£714.69m	1.6	
Kensington	£289.12m	£5.26m	£283.84m	1.8	
Hammersmit h	£104.89m	£2.10m	£102.78m	2.0	
Fulham	£41.62m	£1.05m	£40.57m	2.5	
Kings Road	£329.84m	£3.51m	£326.33m	1.1	
West End	£5,309.42m	£9.12	£5,300.30m	0.2	

4.14 The above demonstrates that even under the highest development projection (upper scenario) the ECWKOA proposals will have less than 2.5% impact on any individual centre, a more than acceptable level of trade diversion that is unlikely to have a detrimental effect on the individual centres vitality and viability. Furthermore, it should be recognised our calculations demonstrate that 65% of the residential expenditure generated by ECWKOA will be spent in others centres, meaning that a number, such as Fulham and White City, could actually benefit from an increased turnover.
4.15 The main impact in percentage terms (2.5%) is Fulham town centre, due to its proximity to ECWKOA. However, the LBHF retail study indicates that the centre is healthy, with a below average vacancy level and a good range of comparison shops, including a number of independent and specialist retailers. Accordingly, a 2.5% impact will have a negligible effect on the centre. Furthermore, as ECWKOA adjoins Fulham, it will actually benefit from the increased number of residents and workers who will visit and use its facilities.
4.16 Hammersmith, Kensington High Street and White City could see trade diversions of 2.0%, 1.8% and 1.6%. These are large centres with low vacancy levels, high footfall and excellent environments. It is therefore considered that such levels of trade diversion will have no detrimental impact on these centres.
4.17 The remaining centres have minor levels of impact ranging from 0.2 – 1.1%, an imperceptible level of diversion.
4.18 We deal with other aspects of impact below.
4.19 We are not aware of any major unimplemented town centre planning permission commitments in either of the two boroughs. Similarly we are unaware of any out-of-centre allocations. However, as set out in the sequential

approach analysis, there are a number of small sites in the various centres that have been allocated for redevelopment.
4.20 We do not consider that the redevelopment of ECWKOA will impact adversely on the redevelopment of any of these sites. As we have identified, the floorspace envisaged in the Opportunity Area will in the main be supported by indigenous growth, as opposed to trade diversion. Furthermore, even in the worse case scenario, involving small levels of impact on existing centres, the figures are insignificant and would in no way detrimentally impact on a centre so as to deter investment.
4.21 Furthermore, it is anticipated that the ECWKOA will only retain a proportion of the resident and worker expenditure that it generates, meaning that nearby existing centres will actually benefit from increased footfall from ECWKOA residents.
4.22 Scale considerations are primarily related to development in or on the edge of an existing centre (see PPS4 policy EC16 (e)); and whilst the edge of the Opportunity Area adjoins Fulham town centre, the development of the area would instead create a new District/Major Centre, as opposed to an extension of Fulham. In any event, the technical analysis carried out by DP9 demonstrates that redevelopment of the Opportunity Area is likely to be of a scale that will lead to sufficient indigenous generated expenditure to justify the provision of retail and leisure floorspace at a level which would be consistent with a minimum District Centre designation as defined in the draft RLP.
4.23 The provision of these uses within the Opportunity Area, close to the new residential and office development that they would be intended primarily to serve, would allow that need to be satisfied in a highly sustainable and accessible location as part of a broader mix of uses, consistent with the role of a District Centre in the London hierarchy of centres.

5.0 CONCLUSIONS
	5.1	Retail and leisure development will be a key element of the redevelopment of
the ECWKOA and is essential to create a new mixed use quarter in line with the objectives of the RLP. This evidence base document demonstrates that there will be more than sufficient retail/leisure capacity generated by all three development scenarios to justify the allocation of a new centre within the ECWKOA. Under the low development scenario, there is sufficient capacity for a District Centre, rising to a Major Centre under the medium and upper scenarios. An allocation as a future District Centre as a minimum allocation is therefore appropriate.
	5.2	The ECWKOA has the potential to provide a retail, leisure and office centre.
The retail element will in the main serve both local residents/workers. Accordingly C&C proposes the allocation of the site as a new District Centre as a minimum for the reasons set out below:-
•	National planning policy focuses on regeneration of brownfield sites for high density mixed use development. Furthermore, significant emphasis is placed upon creating sustainable communities with easy access to places of work, shops and facilities.
•	ECRA has been identified in the RLP as forming the majority of the ECWKOA, with its planned mixed use regeneration and growth. Suggested change 2.53 highlights the potential and suitability of Opportunity Areas to accommodate new town centres as a result of high density mixed use development
•	ECRA has the potential to provide a hub for the ECWKOA, focusing on key town centre uses such as retail, leisure, employment space and community uses, along with a significant element of residential. The number of new residents and workers in the ECWKOA as a result of all of the likely growth scenarios identified by C&C would generate expenditure that would support the designation of a new centre in the ECWKOA.
•	ECRA site can deliver a vibrant place in line with the RLP aspirations for the ECWKOA and in accordance with what one would expect of an area designated as a District Centre. The site can incorporate hotels, leisure, restaurants/bars and various community facilities. When these town centre uses are factored in with the proposed residential, office and retail offer it creates a genuine mixed-use place with the potential for a large number of linked trips.
	5.3	The main purpose of both the retail and leisure and uses will be to serve the
significant number of new residents and office workers that will be generated by the proposals. Analysis by DP9 indicates the three development scenarios generate a floorspace capacity for retail (use classes A1-A5) ranging from 15,836 – 66,699 sqm (gross). In addition, there is a clear and defined need for

the likely quantum of leisure proposed, particularly bearing in mind the existing use of the site.
	5.4	Therefore, we conclude that the potential designation as a District Centre as a
minimum will have a limited effect on existing nearby centres. Indeed, it is likely that the other centres will benefit from the significant additional expenditure generated by ECWKOA, as it is not realistic to assert that all of the money generated will be spent at the site.
	5.5	Nonetheless, DP9 have calculated the worse case scenario, where only
approximately 50% of the comparison goods floorspace proposed in the highest development scenario is met by ECWKOA generated expenditure. A benchmark impact assessment has been carried out to analyse the likely levels of trade diversion from nearby Major and International shopping centres.
	5.6	The ECWKOA proposals are likely to have less than 2.5% impact on any
individual centre, a more than acceptable level of trade diversion that is unlikely to have a detrimental effect on the individual centres vitality and viability.
	5.7	The main impact in percentage terms (2.5%) is Fulham town centre, due to its
proximity to ECWKOA. However, the LBHF retail study indicates that the centre is healthy, with a below average vacancy level and a good range of comparison shops, including a number of independent and specialist retailers. Accordingly, a 2.5% will have a negligible effect on the centre.
	5.8	Hammersmith, Kensington High Street and White City could see trade
diversions of 2.0%, 1.8% and 1.6%. These are large centres with low vacancy
levels, high footfall and excellent environments. It is therefore considered that
such levels of trade diversion will have no detrimental impact on these centres.
	5.9	The remaining centres have minor levels of impact ranging from 0.2 – 1.1%,
an imperceptible level of diversion.
5.10 The analysis set out in this evidence base document is reinforced by borough wide retail and leisure studies undertaken on behalf of LBHF and RBKC, both of which demonstrate that there is capacity to support substantial retail and leisure development in RBKC/LBHF in the period between now and 2026.
5.11 Accordingly, we request that Annex 2, table A2.2 to the draft RLP be amended to incorporate a reference to ECWKOA having the potential to accommodate a new District Centre as a minimum.

APPENDIX 1
Royal Borough of Kensington and Chelsea Kings Road
DP9 have carried out a thorough assessment of Kings Road Major Centre in accordance with the methodology set out in paragraph 7.8 above. Our research has found that there are four potential redevelopment sites within or on the edge of the defined centre.
Of these four sites, all are too small to accommodate 2,500sqm of retail/leisure on a site of 0.3ha and are dismissed as unsuitable.
The first, Sloane Square Station is just 0.09 ha and only capable of accommodating a small amount of floorspace.
The next site is 250 Kings Road, which comprises a retail unit of noticeably worse quality than others in the centre. However this is only 0.07ha and could only deliver a small amount of retail/leisure space.
The third and fourth sites are 125-155 Sydney Street and 102 Sydney Street, both of which have been identified by RBKC as suitable for redevelopment, are just 0.2ha and 0.02ha respectively and are only capable of accommodating a small amount of retail/leisure floorspace.
Furthermore, there is a need to create a sense of place and a sustainable community within the OA, requiring parts of the development envisaged to be located within even a number of smaller sites would run contrary to policy aspirations.
Knightsbridge
DP9 have carried out a thorough assessment of Knightsbridge International Centre in accordance with the methodology set out in paragraph 7.8 above. Our research has found that there is just a single potential redevelopment/new retail/leisure site within or on the edge of the defined centre. Knightsbridge is characterised by high quality retail along Brompton Road, tightly surrounded by exclusive residential properties on the surrounding streets. As a result redevelopment opportunities are extremely limited.
The single opportunity for significant new retail/leisure in the centre is identified by RBKC in their Core Strategy is the ground floor area of the Park Lane Hotel, which could provide up to 0.1 9ha of floor area. This falls below the figure of 0.3ha adopted in the methodology and the site is dismissed as unsuitable.
Kensington High Street
DP9 have carried out a thorough assessment of Kensington Major Centre in
accordance with the methodology set out in paragraph 7.8 above. Our research has

found that there are just three potential redevelopment sites within or on the edge of the defined centre. As with Knightsbridge, Kensington High Street due to its high quality frontages and tightly penned streets of exclusive housing surrounding the centre has limited redevelopment opportunities.
However, two of the three potential redevelopment sites are both below the methodology threshold of 0.3ha.
The first is the Odeon Cinema site, which obtained planning permission for residential development and smaller cinema in 2008. However, it is just 0.1 8ha in size and unsuitable for the application proposal.
The second site is Lancer Square, which has been identified for potential redevelopment by RBKC in their Core Strategy as the square is under utilised by pedestrians. The site is just 0.25ha in size and unsuitable for the application proposal.
The third site is the Commonwealth Institute, which at 1.37 hectares is capable of accommodating a significant amount of retail floorspace. However, the site is dismissed as it is both unavailable and unsuitable for retail led development. The Commonwealth Institute was granted planning permission for a new Design Museum, along with ancillary retail, restaurants, cafés, offices, residential and leisure.
Even if the above scheme is not implemented, the site is identified in the Core Strategy to deliver:-
“a high trip generating public institutional arts or cultural use, preferably an exhibition use.”
In light of the above the site is considered unavailable and unsuitable for the retail/leisure element of the ECWKOA proposals.
Furthermore, there is a need to create a sense of place and a sustainable community within the OA, requiring parts of the development envisaged to be located within even a number of smaller sites in Kensington High Street would run contrary to policy aspirations.
London Borough of Hammersmith and Fulham Fulham
Only one site has been identified for examination in Fulham town centre. This is 84- 88 Fulham High Street, which at 0.37ha is capable of accommodating a small amount of retail/leisure floorspace.
The likely form of development would be unit shops at ground floor level with residential above. Indeed, there is an unimplemented planning permission for 46 residential units and 295 sqm of retail and 403 sqm of restaurants.

In light of the above, the site is dismissed as it would not provide the facilities required to support the level of residential and office development envisaged at the ECWKOA.
Hammersmith
DP9 have carried out a thorough assessment of Hammersmith Major Centre in accordance with the methodology set out in paragraph 7.8 above. Our research has found that there are four potential redevelopment sites within or on the edge of the defined centre. However, one of these, the Hammersmith Palais site, is dismissed as at 0.24ha, it falls below the size criteria of 0.3ha.
The first site to be appraised is the Hammersmith and City Station Car Park site, which at 0.61 ha is capable of accommodating some retail and leisure development. However, the site is identified for predominately mixed use office and residential development. Whilst it is capable of accommodating some ground floor retail/leisure development, this is only likely to be small/medium unit shops.
However, even if a scheme incorporating 2,500 sqm of retail/leisure could be progressed, it would not deliver the benefits envisaged in the ECWKOA proposals. The site is therefore dismissed.
The next site is Hammersmith Island Phase 4. This is located adjacent to the existing transport interchange in the town centre and at 0.37ha, is capable of accommodating some leisure and retail development.
However, it is dismissed as unsuitable as the site has been identified in the LBHF Site Specific Allocations Preferred Options document for offices, residential and as an extension to the existing bus station.
The final site is the Hammersmith Town Hall Extension site. This is 1 .33ha in size and capable of accommodating a reasonable amount of retail and leisure development. The preferred use in the Site Specifics Allocation document is new civic accommodation, along with other town centre uses, including retail and potentially a replacement cinema.
Whilst the site is suitable for retail/leisure development, equating to a proportion of the likely ECWKOA proposal floorspace, it would not provide the facilities required to support the level of residential and office development envisaged at ECWKOA. It is therefore considered that the site is not suitable for the retail/leisure proposed at ECWKOA.
In conclusion, there is a need to create a sense of place and a sustainable community within the OA, requiring parts of the development envisaged to be located within even a number of smaller sites would run contrary to policy aspirations.

Shepherds Bush
Only one site has been identified for examination in Shepherds Bush town centre. This is the former Odeon Cinema site, which at 0.3ha is capable of accommodating a small amount of retail/leisure floorspace.
The likely form of development envisaged by the Council in their Site Specific Allocations document is to retain the existing building and convert it into a mix of uses, potentially including a hotel with retail/leisure at the ground floor.
In light of the above, the site is dismissed as it would not provide the facilities required to support the level of residential and office development envisaged at the ECWKOA.

APPENDIX 2
POLICY
PPS1 - Delivering Sustainable Development, February 2005
PPS1 sets out the overarching planning policies in respect of the delivery of sustainable development through the planning system. The Government makes it clear that planning should facilitate and promote sustainable and inclusive patterns of urban development through a number of initiatives, including the need to ensure that new developments provide good access to jobs and key services for all members of the community.
In promoting sustainable development, the Government reaffirms through the guidance that the planning system needs to provide improved access for all to jobs, health, education, shops, leisure, community facilities, open space, sport and recreation by encouraging new development in locations where everyone can access services and facilities on foot, bicycle or public transport, as opposed to relying on the private car.
The Government promotes the more efficient use of land through higher density, mixed use development and the use of suitably located previously developed land and buildings.
PPS4
PPS 4 states that the Government’s overarching objective is to achieve sustainable economic growth.
In terms of specific plan making policies, the following are relevant to this evidence base document:-
Policy EC 1: Using evidence to plan positively At the regional level, the evidence base should:
•	be based on an understanding of the economic markets operating in and across the area;
•	assess, in broad terms, the overall need for land or floorspace for economic development including main town centre uses over the plan period.
When assessing quantitative need, have regard to relevant market information and economic data, including a realistic assessment of:
•	existing and forecast population levels.
•	forecast expenditure for specific classes of goods to be sold, within the broad categories of comparison and convenience goods and for main leisure sectors and forecast improvements in retail sales density.
Policy EC2: Planning for Sustainable economic Growth

EC2.1 Regional planning bodies and local planning authorities should ensure, amongst other considerations, that their development plan:
a.	sets out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth
b.	seeks to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use
c.	locates or co-locates developments which generate substantial transport movements in locations that are accessible
EC3 – Planning for Centres
Regional planning bodies and local planning authorities should, as part of their economic vision for their area, set out a strategy for the management and growth of centres over the plan period and should:
•	set flexible policies for their centres which are able to respond to changing economic circumstances and encourage, where appropriate, high-density development accessible by public transport, walking and cycling.
•	define a network (the pattern of provision of centres) and hierarchy (the role and relationship of centres in the network) of centres that is resilient to anticipated future economic changes.
Policy EC5: Site selection and land assembly for main town centre uses
Local planning authorities should identify an appropriate range of sites to accommodate the identified need, the should:-
a.	base their approach on the identified need for development identify the appropriate scale of development, ensuring that the scale of the sites identified and the level of travel they generate, are in keeping with the role and function of the centre within the hierarchy of centres.
b.	apply the sequential approach to site selection.
c.	assess the impact of sites on existing.
d.	consider the degree to which other considerations such as any physical regeneration benefits, employment opportunities, increased investment in an area or social inclusion, may be material to the choice of appropriate locations for development.
Under the sequential approach, local planning authorities should identify sites that are suitable, available and viable in the following order:
•	locations in appropriate existing centres where sites or buildings for conversion are, or are likely to become, available within the plan period.
•	edge-of-centre locations, with preference given to sites that are or will be well connected to the centre.
•	out-of-centre sites, with preference given to sites which are or will be well served by a choice of means of transport and which are closest to the centre and have a higher likelihood of forming links with the centre.

In assessing the impact of proposed locations for development, local planning authorities should:
•	take into account the impact considerations set out in Policy EC16, particularly for developments over 2,500 sqm ensuring that any proposed edge of centre or out of centre sites would not have an unacceptable impact on centres within the catchment of the potential development; and
•	ensure that the level of detail of any assessment of impacts is proportionate to the scale, nature and detail of the proposed development
EC16: The impact assessment for planning applications for main town centre uses that are not in a centre and not in accordance with an up to date development plan 
PPS 4 states that these sites should be assessed against the following:
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.