Sequential approach or the sequential test in retail

The difference between the sequential approach and the sequential test in retail policy is the difference between a way of thinking and a formal hurdle. The sequential approach is the general idea that development should go to the most suitable location first and less suitable locations only if the better ones cannot take it. The sequential test is the specific, named requirement in national planning policy that applicants for main town centre uses outside an existing centre must pass before their application can be supported.

Officers use the phrases interchangeably in reports and committee minutes. A refusal based on the formal test, where the applicant has only addressed the loose idea, is a bad afternoon for everyone.

What each term means in retail policy

The sequential test applies where a proposal involves main town centre uses, is not in an existing centre, and is not in accordance with an up-to-date development plan. The applicant has to show that there is no suitable, available and viable site in a preferable location. The order of preference runs from sites in the centre, to edge of centre sites, then to out of centre sites with a preference for accessible locations well connected to the centre.

The sequential approach, by contrast, describes the same logic applied in other policy areas. It appears in flood risk, where the aim is to steer development away from areas at the highest risk and, within a site, to place the most vulnerable uses on the highest ground. It appears in minerals, in waste and in design decisions on parking. The approach has no fixed hierarchy of named location types and no defined evidence requirement.

So the question to ask about any document is which one is being discussed. If the answer is retail, leisure or office development outside a centre, the formal test is engaged and the evidence has to be structured accordingly. For the parallel steer applied to flood risk, the mechanics are set out separately in the flood risk Sequential Test and work very differently.

Site selection and the area of search

The area of search is agreed, or argued about, at the start. It should reflect the catchment the proposal would serve rather than the applicant's land interests. For a convenience store serving a neighbourhood, the search area is the neighbourhood and the nearest centres. For a larger food store serving a town, the search area is the town.

Define the area in a sentence and justify it by reference to the catchment, drive times or the hierarchy of centres in the adopted local plan. The authority will have its own view, and the gap between the two is usually where the argument happens.

Then search properly. List sites in the centre and on its edge, whether or not they are on the market, and deal with each one on suitability, availability and viability. A table listing three sites and rejecting them all in a line each will not survive scrutiny.

Edge of centre and how distance is judged

National policy treats an edge of centre location, for retail purposes, as one that is well connected to and within easy walking distance of the primary shopping area. In practice 300 metres is the figure most often cited as the working measure of easy walking distance for retail, with office uses judged more generously by reference to the centre boundary.

Measure the walking route, not the straight line. A site 250 metres away as the crow flies, separated from the centre by a dual carriageway with no crossing, is not well connected. A site 320 metres away along a lit footway with a signalised crossing probably is. Walk it, photograph it and say what you found.

Disaggregation and flexibility of format

Applicants must be flexible about scale and format. That means considering whether the proposal could be delivered in a smaller unit, on a smaller site, with less parking or over two floors, and showing the result of that consideration honestly.

It does not mean splitting the proposal into pieces and scattering them across several town centre sites. The courts have been clear that there is a limit to how far an authority can require a scheme to be broken up, and the test does not require an applicant to abandon the scheme that is actually proposed. Where a council presses for disaggregation, the question is whether the resulting operation would still be a realistic proposition for the operator rather than whether the floorspace could theoretically be divided.

Flexibility is also where applicants damage their own case. An application stating that the operator requires exactly 1,850 m² on a single level with 120 spaces, and that nothing else is possible, invites the response that the requirement was written to fit the site already owned.

Evidence that satisfies the test

A sequential test that works reads as a search report and contains, for each site considered:

1. The site address, area and ownership position as far as it is known.
2. Its location relative to the defined centre, with the walking route measured.
3. Availability, with the evidence: marketing material, agents' confirmation, or an owner's stated intentions.
4. Suitability for the development proposed, dealing with site constraints, access and configuration rather than preference.
5. Viability where it is argued, with figures.
6. A reasoned conclusion, written so a reader who disagrees can see the basis.

Suitability means suitable for the development proposed, as the Supreme Court held in the Tesco and Dundee case in 2012, rather than suitable for some notional alternative the decision maker might prefer. That holding does a lot of work for applicants, and it is frequently misquoted in both directions.

Add a plan showing the centre boundary, the primary shopping area, the application site and every site considered. Officers need to see the geography in one view.

Where impact assessment follows

Passing the sequential test does not end the exercise. A separate impact assessment is required for retail and leisure development outside centres above a floorspace threshold, which is set locally where the plan does so and otherwise defaults to the figure in national policy. The assessment addresses the impact on existing, committed and planned investment in centres, and on town centre vitality and viability.

The two documents are related but distinct. The Retail Impact Assessment deals with trade diversion, turnover and health of the centre. The retail Sequential Test deals only with whether a better located site exists. Mixing them produces a document that answers neither question. And where the proposal generates material trips, the transport evidence sits alongside both, which is a separate decision about whether a travel plan or a transport statement is the right instrument.

Presenting the conclusion

Write the conclusion as a finding with its reasoning visible. State the area of search and why. State how many sites were identified and from what sources. State which were rejected and on which of the three grounds. Then state the conclusion in one sentence.

Avoid two habits. The first is burying the weak site, the one in the centre that nearly works, in an appendix; officers find it, and it then looks concealed rather than considered. The second is claiming that no sites exist without saying where you looked, which invites the authority to produce one from its own land availability assessment.

Where a site in the centre very nearly works, address it head on with figures. A reasoned explanation of why a constrained in-centre site cannot accommodate the operation carries far more weight than silence.

This is general guidance, not legal advice, and local plan thresholds and centre boundaries vary, so check the adopted plan and any local impact threshold with your local planning authority or a qualified professional before relying on it.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.