Sequential Test - Retail
The Sequential Test is a fundamental principle of UK retail planning policy that requires proposals for main town centre uses to be located in existing town centres first. Only if no suitable town centre sites are available should edge-of-centre and then out-of-centre locations be considered. The test is set out in paragraphs 87 to 89 of the National Planning Policy Framework and applies to all retail, leisure, office, and other main town centre uses proposed outside an existing centre. Failing the Sequential Test is sufficient grounds for refusal regardless of the merits of the scheme.
Typical Cost
£300 – £5,000+
Turnaround
1 – 6 weeks
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What is a Sequential Test - Retail?
The Sequential Test is a site selection exercise that assesses whether there are any suitable and available sites for the proposed development in locations that are sequentially preferable to the application site. The sequence of preference runs from town centre sites as the first choice, to edge-of-centre sites, and finally to out-of-centre sites. The applicant must demonstrate that they have thoroughly assessed all reasonably available alternative sites in sequentially preferable locations and that none can accommodate the proposed development, applying an appropriate degree of flexibility in terms of format, scale, and car parking arrangements.
When is a Sequential Test - Retail required?
The Sequential Test is required for all planning applications for main town centre uses that are not in an existing centre and not in accordance with an up-to-date development plan. Main town centre uses as defined by the NPPF include retail development, leisure and entertainment facilities, offices, and arts, culture, and tourism uses. The test applies regardless of the size of the development, though some local authorities waive the requirement for very small proposals below a locally defined threshold. Applications for extensions to existing out-of-centre uses may also be required to pass the Sequential Test where the extension is significant.
What does a Sequential Test - Retail include?
A Sequential Test assessment includes a clear definition of the proposed development and its operational requirements, identification of the catchment area that the development is intended to serve, an explanation of the approach to flexibility in terms of format, scale, and car parking provision, a systematic search of all town centre and edge-of-centre sites within the catchment area that could potentially accommodate the development, an assessment of each alternative site against criteria of suitability, viability, and availability, an explanation of why each alternative site is not considered sequentially preferable, supporting evidence such as marketing particulars, correspondence with landowners, and site photographs, and a conclusion demonstrating that no sequentially preferable sites can accommodate the proposed development.
How much does a Sequential Test - Retail cost?
A Sequential Test assessment for a straightforward out-of-centre retail proposal typically costs between £2,000 and £5,000. More complex assessments involving extensive site searches across multiple centres, detailed analysis of site suitability, and engagement with landowners generally range from £5,000 to £12,000. Where the Sequential Test is submitted alongside a Retail Impact Assessment, the two documents are often prepared as a combined commission, with costs ranging from £8,000 to £30,000 for the package. The cost depends largely on the number of alternative sites that need to be assessed and the complexity of the arguments regarding flexibility and suitability.
Who can prepare a Sequential Test - Retail?
Sequential Test assessments should be prepared by specialist retail planning consultants, typically chartered town planners who are members of the Royal Town Planning Institute (RTPI) with expertise in town centre and retail planning. The assessment requires detailed knowledge of the NPPF sequential approach, familiarity with relevant case law including the Dundee and Mansfield decisions, and competence in presenting a robust site selection methodology. The same consultant who prepares the Retail Impact Assessment will usually also prepare the Sequential Test.
How long does a Sequential Test - Retail take?
A Sequential Test assessment typically takes 4 to 8 weeks to prepare, depending on the number of centres and alternative sites that need to be considered. The programme should allow for site visits to assess alternative locations, enquiries to landowners and agents about site availability, review of relevant planning history for alternative sites, and detailed analysis of suitability. Where the local authority has strong views on which alternative sites should be considered, early engagement through pre-application discussions can save considerable time and avoid abortive work.
Frequently Asked Questions
What does 'sequentially preferable' mean?
A sequentially preferable site is one that is in a more central location in the retail hierarchy. Town centre sites are sequentially preferable to edge-of-centre sites, and edge-of-centre sites are sequentially preferable to out-of-centre sites. The applicant must demonstrate that they have considered all sites in more central locations before concluding that only the out-of-centre application site can accommodate the proposed development.
How is flexibility applied in the Sequential Test?
The NPPF requires applicants to demonstrate flexibility on issues such as format and scale when assessing whether alternative sites can accommodate their proposal. This means that an applicant cannot simply argue that no town centre site can accommodate their exact proposal in its preferred format. Case law from the Dundee and Mansfield Supreme Court decisions established that applicants must consider whether their development could reasonably be adapted to fit available town centre sites, for example by reducing the floor area, reconfiguring the layout, or adopting a multi-level format.
What is the definition of edge-of-centre?
For retail purposes, edge-of-centre is defined in the NPPF glossary as a location within 300 metres of the primary shopping area boundary. For all other main town centre uses, it means a location within 300 metres of the town centre boundary. Edge-of-centre sites are sequentially preferable to out-of-centre locations, so they must be considered and discounted before an out-of-centre site can pass the Sequential Test.
Does the Sequential Test apply to all retail applications?
The Sequential Test applies to all applications for main town centre uses outside an existing centre that are not in accordance with the development plan. Very small retail proposals below locally set thresholds may be exempted by some authorities. Applications within existing town centres do not need to pass the Sequential Test, as the town centre is already the sequentially preferable location.
What are main town centre uses?
The NPPF defines main town centre uses as retail development including warehouse clubs and factory outlet centres, leisure and entertainment facilities and more intensive sport and recreation uses, offices, and arts, culture, and tourism development including theatres, museums, galleries, cinemas, concert halls, and hotels. All of these uses are subject to the Sequential Test when proposed outside existing centres.
How do I assess whether an alternative site is available?
An alternative site is considered available if it could be developed within a reasonable period, taking account of the timescale for the proposed development. Sites that are currently occupied but marketed for sale or lease may be available. Sites with no prospect of becoming available within the relevant timescale can be discounted. Evidence of availability should include correspondence with landowners or agents, marketing particulars, and an assessment of any constraints on delivery.
What is the Dundee case and why is it important?
The Tesco Stores Ltd v Dundee City Council case decided by the Supreme Court in 2012 is a landmark judgment on the Sequential Test. The Court held that the question of suitability must be assessed by reference to the type of development proposed rather than the particular operator. This means an applicant cannot argue that a town centre site is unsuitable simply because it cannot accommodate a specific retailer's preferred store format. The decision significantly strengthened the Sequential Test and continues to be cited in appeals.
Can disaggregation be required in the Sequential Test?
Disaggregation means splitting a proposed development into smaller components that could be located on separate town centre sites. The NPPF does not explicitly require disaggregation, and the extent to which it can be expected is a matter of debate. However, the requirement for flexibility means that applicants should consider whether elements of their proposal could reasonably be accommodated on sequentially preferable sites separately. The approach to disaggregation should be proportionate and realistic.
What happens if I fail the Sequential Test?
If the local planning authority concludes that the Sequential Test has not been passed, the application should be refused. There is no balancing exercise that allows other benefits to override the failure. The applicant would need to either identify and address the sequentially preferable sites, demonstrate that the authority's assessment of alternative sites is incorrect, or appeal the decision and present their case to a planning inspector. Sequential Test failures are frequently contested at appeal.
Does the Sequential Test apply to online retail fulfilment centres?
Online retail fulfilment centres and distribution warehouses are generally classified as storage and distribution use rather than retail use, so they do not fall within the definition of main town centre uses and are not subject to the Sequential Test. However, if a facility includes a significant element of direct retail sales to visiting customers, the retail component may trigger the Sequential Test requirement. Each case is assessed on its specific facts and the nature of the use proposed.