Central Bedfordshire Pre-submission Local Plan (January 2018)

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Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy R1: Ensuring Town Centre Vitality

Representation ID: 9919

Received: 22/02/2018

Respondent: Quadrant SC Propco B.V

Agent: Miss Kelly McCann

Representation:

RETAIL - policy needs to reflect NPPF
RETAIL - evidence not up to date
RETAIL - definition of primary retail frontage required

06

Full text:

As drafted Policy R1 is open to misinterpretation as the 'town centre' boundary referred to is likely to cover a larger geographical area than that identified in the Framework as an 'edge of centre' locations. Policy R1 is should therefore be reworded to reflect the Framework's approach to the sequential test.

It would also appear that the PSLP fails to identify the extent of Dunstable town centre's Primary Shopping Area (PSA). Without this designation it is impossible to identify which locations would be in, edge or out of centre. Whilst Quadrant SC Propco B.V welcomes the inclusion of a locally set impact threshold, the failure to accurately describe the PSA has far reaching implications when considering the interpretation of Draft Policies R1 and R3, particularly when assessing the retail impact (which as currently drafted refers to proposals outside the 'designated town centre' boundary). This is not consistent with the Framework and would appear to be a serious shortcoming of the PSLP.

Attachments:

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy R2: Retail for minor service centres, villages and the rural economy

Representation ID: 9922

Received: 22/02/2018

Respondent: Quadrant SC Propco B.V

Agent: Miss Kelly McCann

Representation:

GENERAL - Policy needs to be NPPF compliant
POLICY - definition of primary shopping area required
GENERAL - evidence out of date

06

Full text:

Whilst not policy, Quadrant SC Propco B.V is concerned by reference in the PSLP (para 13.4.7) to the possibly that:

"...attention might need to shift beyond the town centre offer to nearby locations, such as the Grove Theatre".

It continues:

"Another location is the already well-established White Lion Retail Park which has both larger footprint stores accommodating big box retail."

The Council's retail evidence base was prepared in 2012 with a subsequent addendum, focusing upon convenience floorspace, produced in 2013. This is now 5 years old and may not reflect what is actually happening on the ground in terms of shopping patterns, market shares, turnover and leakage.

Where Councils are considering identifying sites outside of existing centres to accommodate retail growth they must ensure that their evidence base is up to date and that the identified need cannot be met in full within existing centres during the Plan period. The National Planning Policy Guidance (NPPG) also offers some helpful advice on how such strategies should be formulated.

* Any such strategy should be based on evidence of the current state of its town centres and opportunities to meet development needs and support their viability and vitality (003 Reference ID: 2b-003-20140306).; and
* Any proposed main town centre uses which are not in an existing town centre are in the best locations to support the vitality and vibrancy of town centres, and that no likely significant adverse impacts on existing town centres arise, as set out in the Framework (para 26) (006 Reference ID: 2b-006-20140306).

No such assessments have been undertaken as part of the PSLP consultation and it would therefore be premature to begin contemplating the sequential preference of edge or out of centre locations at this time. This strategy has not been positively prepared and is not justified.

Attachments:

Object

Central Bedfordshire Pre-submission Local Plan (January 2018)

Policy R3: Town Centre Development

Representation ID: 9925

Received: 22/02/2018

Respondent: Quadrant SC Propco B.V

Agent: Miss Kelly McCann

Representation:

GENERAL - policy needs to reflect NPPF
GENERAL - evidence not up to date
RETAIL - definition of primary retail frontage required

06

Full text:

Whilst not policy, Quadrant SC Propco B.V is concerned by reference in the PSLP (para 13.4.7) to the possibly that:

"...attention might need to shift beyond the town centre offer to nearby locations, such as the Grove Theatre".

It continues:

"Another location is the already well-established White Lion Retail Park which has both larger footprint stores accommodating big box retail."

The Council's retail evidence base was prepared in 2012 with a subsequent addendum, focusing upon convenience floorspace, produced in 2013. This is now 5 years old and may not reflect what is actually happening on the ground in terms of shopping patterns, market shares, turnover and leakage.

Where Councils are considering identifying sites outside of existing centres to accommodate retail growth they must ensure that their evidence base is up to date and that the identified need cannot be met in full within existing centres during the Plan period. The National Planning Policy Guidance (NPPG) also offers some helpful advice on how such strategies should be formulated.

* Any such strategy should be based on evidence of the current state of its town centres and opportunities to meet development needs and support their viability and vitality (003 Reference ID: 2b-003-20140306).; and
* Any proposed main town centre uses which are not in an existing town centre are in the best locations to support the vitality and vibrancy of town centres, and that no likely significant adverse impacts on existing town centres arise, as set out in the Framework (para 26) (006 Reference ID: 2b-006-20140306).

No such assessments have been undertaken as part of the PSLP consultation and it would therefore be premature to begin contemplating the sequential preference of edge or out of centre locations at this time. This strategy has not been positively prepared and is not justified.

Attachments:

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