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Newark & Sherwood Local Development Framework Plan Review - Preferred Approach Town Centre & Retail

Preferred Approach Town Centre and Retail Questionnaire

Responses

List of answers to the specified question
ResponseOptionTextDate
#550343

Ref: 15/6/1

We agree with the proposed expansion of Policy DM11 to cover all main town centre uses and the encouragement of Class A3 uses around Newark Market Place. However, in terms of proposed Section 4 of the policy:
- we would reiterate that the sequential approach to out-of-centre sites should give
preference to the most accessible locations that are best connected to defined centres, in accordance with the NPPF;
- the wording of the policy should be clear that impacts on investment only relate to incentre investment;
- in terms of the criteria to be addressed by impact assessments, the references to 'current and forecast expenditure capacity' should be removed. We would refer to appeal decision APP/B3030/W/16/3146578 of September 2016 in which the Inspector states at paragraph 19 that 'the Framework does not require that the need for new retail floorspace is justified, and this is a discrepancy between Policy DM11 and the Framework'. The proposed policy wording is not consistent with Section 2 or paragraph 212 of the NPPF;
- whilst it is reasonable for impact assessments to take account of impacts on allocated
sites, this would only be the case where site allocations have been made in accordance with the sequential approach set out at paragraph 23 of the NPPF. For the reasons set out in response to Question 4, the Council's proposed approach is not in accordance with paragraph 23.

25 Jul 2017 16:38
#550336

Ref: 14/6/1

We agree with the preferred approach in amending Policy the 11 “Retail Main Town Centre Uses” as this broadly complies with the NPPF town centre first approach.

However, we object to the proposed wording for edge and out of centre locations and that for proposals which exceed the thresholds in Core Strategy Policy 18 we do not consider it reasonable or necessary for such applications to be accompanied by robust assessment of impact i.e. a retail impact assessment. Such demand for retail proposals will be market led following the result of consumer demand, as opposed to an academic capacity assessment. Capacity and expenditure is not only based on population growth but on the state of the economy and purchasing power from consumers. The approach advocated by this policy allows no flexibility for that investment and takes a rigid approach, inflexible to potential retail demand. Furthermore, undertaking such a level of assessment for a small convenience retail store is wholly disproportionate to the level of impact one small local needs convenience retail store would bring.

The correct approach would be to rely solely on the use the sequential assessment route for small scale convenience store retailing i.e. 500 square metres or less which more accurately portrays the state of the market at the particular time an application is made i.e. are there more suitable and available units within a centre that would fulfil the particular retailer‟s needs. This way if there are no other suitable units available, which considering that the study concludes that most district centres are vibrant and healthy, then there would be no threat to a district centre for permitting an out-of-centre retail proposal and the district would still benefit from the investment, jobs and retail provision that this would bring.

Effectively by taking a hard-line impact approach that relies on capacity assessments at a district level, the likelihood is that up to 2026, the assessment would result in there being no further capacity for more retail provision. Clearly however if a retailer is wanting to open a retail unit within the district they would consider that there is a level of market demand for their goods and the district would miss out on that benefit and investment by taking such a rigid and negative approach by solely focusing on capacity as opposed to the sequential approach which rightly considers defined centres first and still allows for out of town retail if no such suitable or available units are available. This reinforces the need for two levels of locally set thresholds between convenience retailing and comparison retailing as smaller convenience retail stores that meet day-to-day needs are less likely to threaten the viability of existing centres as opposed to larger format comparison retailers that may well impact upon existing centres.

25 Jul 2017 16:18
#550298

Ref: 12/6/1

We consider the preferred approach to amending Policy DM11 'Retail and Main Town Centre Uses' is unsound. In particular the reference to capacity in relation to assessing proposals for edge / out of centre development is not consistent with the NPPF (whereby only the sequential and impact tests need to be passed). There is also no NPPF requirement to assess the impact of such development on allocations (where these are not in-centre). The policy should therefore be amended on this basis to ensure consitency with the NPPF and for it to be found sound.

*Additional information provided in the supporting information attached to these comments.

25 Jul 2017 15:08
#550285

Ref: 11/6/1

As with the response to Question 5 - we support the preferred approach to amending DM11 in respect of the local centres and specifically the new local centre at Fenwood as indicated at Figure 7 of the Core Strategy, where new and enhanced retail development and other non-retail main Town Centre uses, consistent with the size and role of the centre, will be supported. As previously stated Fernwood is identified to accommodate in the region of 3200 dwellings and currently has capacity in terms of land availability to accommodate a wide range of retail and main town centre
uses beyond the very modest scale proposed in the resolution to grant planning permission for the Persimmon scheme.This will require some consideration from a masterplanning perpsective having regard to land ownerships around the broad location of the local centre identified by Policy NAP2C

25 Jul 2017 14:50
#539859

Ref: 8/6/1

No, in view of the above, the requirement for Retail Impact Assessment should exclude allocated sites.

 

12 May 2017 10:03
#533977

Ref: 9/6/1

Historic England has no objection to the revised wording of DM11

 

18 Apr 2017 09:54
#533974

Ref: 5/6/1

As with the response to Question 5 - we support the preferred approach to amending DM11 in respect of the local centres and specifically the new local centre at Fenwood as indicated at Figure 7 of the Core Strategy, where new and enhanced retail development and other non-retail main Town Centre uses, consistent with the size and role of the centre, will be supported. As previously stated Fernwood is identified to accommodate in the region of 3200 dwellings and currently has capacity in terms of land availability to accommodate a wide range of retail and main town centre uses beyond the very modest scale proposed in the resolution to grant planning permission for the Persimmon scheme.This will require some consideration from a masterplanning perpsective having regard to land ownerships around the broad location of the local centre identified by Policy NAP2C

 

18 Apr 2017 09:45
#524677

No comment.

24 Feb 2017 20:34
#524237

Ref: 4/6/1

No - As far as Southwell is concerned there is sufficient retail capacity already. There has recently been an increase (albeit small) in the number of empty outlets.

24 Feb 2017 09:05
#523553

Ref: 3/6/1

Policy DM11: Broadened policy to address non-retail main town centre use more comprehensively. And align policy approach with NPPF. Retail and non-retail development within 'Local Centres' must be consistent with the size and role of the centre. This preferred approach is considered to have no cross-boundary implications for Gedling Borough Council.

22 Feb 2017 15:20
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