Q & A 18.1/10
A national sports retailer is seeking to roll out a number of health and fitness centres that will incorporate its normal shopping offer. Should these elements be disaggregated when carrying out the necessary sequential test?
PPS6, which applies to retail developments and health and fitness centres, advises that flexibility and realism are required when adopting a sequential approach to site selection, so that a range of sites can be identified for any identified need. The scope for disaggregation should be taken into account. This implies a general requirement to explore whether specific parts of a development could be operated from separate, sequentially preferable sites. But paragraph 3.18 explains: "A single retailer or leisure operator should not be expected to split their development into separate sites where flexibility in scale, format, car parking provision and the scope for disaggregation has been demonstrated". The statement adds that it is not the intention to seek arbitrary subdivision of proposals but "to ensure that consideration is given as to whether there are elements that could reasonably and successfully be located on a separate sequentially preferable site or sites". While it remains unclear exactly how this advice is intended to work, it suggests that consideration should be given to disaggregating the shopping and health and fitness centre elements you mention. However, where a proposal has a distinctive business model and operational characteristics, such as that demonstrated in a recent decision involving Costco (DCS No: 100041998), it may not be practicable to disaggregate individual elements. PPS6 indicates that the Government intends to publish guidance on applying the sequential approach. This may throw further light on the matter.