Policy RET 3: Sequential and impact tests

  1. In accordance with LPS Policy EG 5 'Promoting a town centre first approach to retail and commerce', a sequential test will be applied to planning applications for main town centre uses that are neither in a defined centre footnote 21 nor in accordance with an up-to-date plan. Main town centre uses should be located in designated centres, and then in edge-of-centre locations, and only if suitable sites are not available or expected to become available within a reasonable period, should out of centre sites be considered. In terms of edge and out of centre proposals, preference will be given to accessible sites that are well connected to the town centre.
  2. Development proposals for retail and leisure uses that are located on the edge or outside of a defined centre footnote 21, are not in accordance with an up-to-date plan and that exceed the floorspace thresholds set out in the table below, will have to demonstrate that they would not have a significant adverse impact on:
    1. the delivery of existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and
    2. the vitality and viability of any defined centre footnote 21, including local consumer choice and trade in the town centre and relevant wider retail catchment, up to five years from the time the application is made. For major schemes where the full impact will not be realised in five years, the impact should also be assessed up to ten years from the time the application is made.
      Impact test thresholds for retail centres
      CentreImpact test threshold (gross floorspace)
      Principal town centres 500 sq.m
      Town centres 300 sq.m
      Local centres 200 sq.m
      Local urban centres See thresholds in Table 9.3 'Impact test thresholds for local urban centres'
  3. All proposals to extend existing class E(a) stores in 'edge-of-centre' or 'out-of-centre' locations should also be accompanied by an impact assessment, where the additional floorspace proposed exceeds the relevant impact test threshold. Proposals to vary the range of goods permitted to be sold should also be accompanied by an impact assessment where the necessary impact test threshold has been exceeded.
  4. Where any proposal fails to satisfy the sequential test and/or is likely to have a significant adverse impact on one or more of the considerations set out in Criterion 2 on a defined centre, it should be refused.

Supporting information

9.12 National planning policy promotes the role of town centres as the heart of communities and requires that their vitality and viability are protected and enhanced. In doing so, it requires applications for edge and out-of-centre development for retail and leisure uses that are not in accordance with an up-to-date development plan, to be supported by impact assessments, where their size exceeds the relevant threshold. The NPPF sets a national threshold of 2,500 sq.m; however, local planning authorities are able to set their own thresholds in the light of local evidence.

9.13 In accordance with guidance set out in Planning Practice Guidance, the Threshold Policy for Main Town Centres Uses Impact Test: Evidence and Justification Report (2018) and the Retail Study Partial Update (2020) have analysed data from a number of sources in forming a view on the appropriateness of setting alternative threshold levels. Overall, the reports concluded that it is appropriate to set local thresholds for the borough to reflect the differing scale of defined retail centres. These are shown in the table within the policy. For local urban centres, the threshold for the town where the local urban centre is located will apply.

Table 9.3 Impact test thresholds for local urban centres
 Local urban centreImpact test threshold (gross floorspace)
  • Nantwich Road (Crewe)
  • West Street (Crewe)
500 sq.m
  • West Heath Shopping Centre (Congleton)
  • Welsh Row (Nantwich)
  • Chapel Lane (Wilmslow)
  • Dean Row Road (Wilmslow)
300 sq.m

9.14 Where a catchment area extends across a number of centres, the need or otherwise for an impact assessment must have regard to the thresholds for each centre. Applicants are encouraged to engage with the council at an early stage to discuss the implementation of the sequential and impact assessment.

9.15 The Town and Country Planning (use classes) (Amendment) (England) regulations 2020 (SI 2020 No.757) have established Class E (commercial, business and services), Class F1 (learning and non-residential institutions) and Class F2 (local community) use classes. Policy RET 3 ‘Sequential and impact tests’ applies to new floorspace, but also to change of use (where appropriate) and variations of conditions to remove or amend restrictions on how units operate in practice. In considering proposals for variations of conditions, the threshold should apply to the whole of the unit in question, rather than just the quantity of floorspace subject to the condition.

9.16 In undertaking the sequential test, flexibility should be demonstrated on matters such as format and scale. In line with LPS Policy EG 5 'Promoting a town centre first approach to retail and commerce', the sequential test will not be applied to applications for small scale rural offices or other small scale rural development.

Related documents

(Footnote 21) Principal town centres, town centres, local centres or local urban centres

Policy information


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