Online Response Form


List of answers to the specified question
Duncan Crane Yes and No
If one develops major new sites (for example if the Wisley Airport site became available, then these should have retail provision within them. Otherwise I would agree with the question. One might also consider further development at existing retail parks such as Brooklands
21 Mar 2017 12:00
Duncan Crane Don't Know 21 Mar 2017 12:00
Deleted User • There should be a focus on mixed residential/retail/small business developments in these areas.
• Mixed residential/retail/small business developments have proven successful in many other countries in Europe.
• Mixed residential/retail/small business developments are likely to draw the required talent/labour resources to the strategic employment areas in the borough and do so in a more affordable manner.
21 Mar 2017 11:46
Deleted User Yes 21 Mar 2017 11:46
Save Cobham Green Belt (Keith… • There should be a focus on mixed residential/retail/small business developments in these areas.
• Mixed residential/retail/small business developments are the norm in many other countries in Europe and have proven successful.
• Mixed residential/retail/small business developments are likely to draw the required talent/labour resources to the strategic employment areas in the Borough and do so in a more affordable manner.
21 Mar 2017 11:14
Save Cobham Green Belt (Keith… Yes 21 Mar 2017 11:14
Birds Hill Oxshott Estate Co.… The provision of retail development with Town and Village Centres is proven to have substantial benefits over its provision in out of centre retail parks, notably in helping reduce car use and ensuring that facilities remain walkable whilst helping to maintain the viability and vibrancy of the Borough’s Town and Village Centres. 21 Mar 2017 11:06
Birds Hill Oxshott Estate Co.… Yes 21 Mar 2017 11:06
Deleted User Next have a long term requirement for a site to locate a new combined home and
fashion store of about 5,500-6,000 sqm gross (about 3,700 to 4,000 sqm net) in the
Brooklands area. This store is a distinct format that Next are opening around the
Country in solely out of centre locations, with only about 20 to 30 planned. The store
format is distinct and different from either Next’s existing fashion only ‘town centre’
type operations, or the current and more limited ‘Home’ only format normally found in
out of centre locations.
These new format stores provide a substantially expanded range of Home products,
encompassing not just the established Home furniture and soft furnishing ranges but
also fitted kitchens, bathrooms, carpets and floor coverings, DIY products to assist
home decoration such as paints, wallpapers and tools, and in addition a garden
centre area retailing plants and products for garden use including paving, outdoor
furniture, garden tools and so on. In addition, the stores include a significant fashion
element retailing Next’s men’s, women’s and children’s clothing ranges. The format
also includes a coffee shop. A similar format store recently opened near New
Malden and Raynes Park off the A3 (88 Bushey Road, SW20 0JW). Due to the existing retail function and employment profile of Brooklands, Next have
identified the area as one of the strategic locations for its network of these combined
dual format stores. Therefore, it is essential that policy recognises this substantial
retail requirement since it would demonstrate how the Council is considering market
signals, as advised in paragraph 004 of the Planning Practice Guidance (Reference
ID: 2b-004-20140306). Facilitating such a store through policy would meet a large
amount of Elmbridge’s retail needs in the comparison goods sector, as set out in the
Elmbridge Retail Assessment, April 2016 (ERA).
Indeed, the ERA finds that there is a need to 2035 of between 14,100 and 19,700
sqm net of comparison floorspace by 2035. The obligation for the Council under
paragraph 23 of the NPPF is for these needs to be ‘met in full’ and are ‘not
compromised by limited site availability’.
In general terms, the ERA uses a typical step by step analysis of quantitative need.
Generally speaking, the quantitative methodology adopted within the ERA is sound,
although it robustness is dependent on a number of key methodological assumptions
and inputs. As a general point, the omission of inflow expenditure in the quantitative
need calculations in the comparison sector has likely downplayed the need to some
degree, particularly in light of the significant employment floorspace at Brooklands.
However, we make the following fundamental points on the robustness of the
evidence: In Section 4, the ERA reviews the sub-regional context, highlighting the role
nearby centres such as Kingston, Woking, Staines, Guildford and Addlestone
play in influencing spending patterns Elmbridge. It is highlighted in the ERA
that some of these centres benefit from proposals that will inevitably influence
the shopping patterns in the Borough. In other words, other things being
equal, we consider that they are likely to attract more trade from Elmbridge
residents at the expense of destinations in Elmbridge. Travelling longer
distances to undertake shopping has inevitable sustainability draw backs.
 However, the ERA has not reviewed the evidence base or policy position of
these centres. This is surprising, since for two of the local authorities, the
evidence was produced by the same consultant. However, if this exercise
had been undertaken, it would be apparent that none of the centres are
actively promoting a policy position or using evidence that advocates an
increasing market share in the comparison goods sector for those areas.
 Therefore, it is with some surprise to note in Scenario 2 of the ERA (para 7.24
onwards), quantitative need has been tested with a reduction in market share
of 2.2 percentage points. Irrespective of the likely impact on shopping
patterns, the investments in the centres in question are not predicated on
increasing market share of comparison expenditure. Therefore, for Elmbridge
to consider a reducing market share leaves excess need that is not being met
through policy. This situation is contrary to the requirements of the NPPF. There is no evidence through the duty to co-operate that Elmbridge have
agreed to export this need to a neighbouring local authority. The use of a
declining market share scenario is wholly inappropriate due the sustainability
implications, particularly given that there is active market signal interest to
meet at least some of this need. Using the declining market share scenario
also serves to dampen the short-term needs and would appear to suggest to
the Council that there is no pressure to meet its needs locally. Therefore, we
consider that the lower figure of 14,100 sqm net of comparison floorspace
need to 2035 should be deleted from policy and only the higher constant
market share figures should be used; namely between 17,800 sqm net and
19,700 sqm net of comparison floorspace need.
 Therefore, the suggestion that 14,100 sqm net of comparison floorspace need
is a minimum is misleading (final bullet in summary to Section 7 of the ERA).
The minimum ought to be the 17,800 sqm net figure. Furthermore, a strict
maximum should not be set, since this would put an artificial cap on
Elmbridge’s ability to maintain its market share and ensure shopping patterns
are sustainable. Rather, the higher figure should be seen as a guide. In the treatment of Brooklands, the ERA is inconsistent in its advice to the
Council and therefore encourage the Council to award its findings limited
weight when formulating policy. Firstly, it advises in paragraph 10.35 (in the
context of recommendations on Weybridge) that ‘future expansion of
Brooklands which would diversify the retail offer or broaden the range of uses,
should be resisted in order to protect the vitality and viability of Weybridge District Centre…’. This conclusion would prejudice any ability to put forward an application under the necessary development management tests expected to be included in policy (namely sequential test and retail impact). Notwithstanding this point, diversifying the retail offer or broaden the range of uses does not automatically mean there will be increased competition with Weybridge and other centres. The level of competition will depend on the nature of any proposals put forward. Finally, this statement appears to be contradictory with paragraph 10.57, where the ERA simply says ‘further development at Brooklands should be tested against the requirements of the NPPF and local planning policies’ which is somewhat more neutral than the comment in paragraph 10.35.
 Finally, there is limited explanation in the ERA as to what the qualitative needs are in the Borough and how it is expected that these would be met. There are factual analysis of existing centres. However, nowhere does the study address the fundamental point on whether the retail floorspace in the Borough is currently providing, or will provide in the future, adequate consumer choice taking into account the market trends evidence at Section 3. If it had done so, it would have identified the clear opportunity to improve retail choice at Brooklands that complements the existing network of town and village centres. Therefore, we consider that the ERA has under-represented the need for additional comparison retail floorspace by testing a reducing market share scenario and has not provided sufficiently robust evidence on qualitative need. However, irrespective of the approach taken in the ERA, there are clearly substantial retail needs in the comparison sector and the NPPF requires these needs to be met in full. The policy approach, as drafted, provides little reference to the ERA nor the NPPF obligations to meeting needs in full. Indeed, we have significant concerns over the suggested approach in policy for retail as summarised in paragraphs 4.36 and 4.37.
Firstly, paragraph 4.36 states that there are ‘limited development opportunities’ to deliver new retail floorspace within town centres, since they are ‘tightly bound by residential areas of physical barriers such as the Thames’. This might be so, but the NPPF makes it clear that the requirement to meet needs in full should not be compromised by limited site availability. The statement that it will be ‘a challenge to meet the levels of development required to retain market share when faced with competition from centres such as Kingston and Guildford’ adds little to policy formulation and appears to invite defeat where market share decrease, expenditure leakage increases and therefore the sustainability of consumer behaviour in the retail sector reduces. This is the antithesis of positive forward planning as required by the NPPF. At this stage, policy does little to address the conundrum presented by the ERA. There is a substantial need in the comparison sector, yet paragraph 4.37 simply states ‘our policy, in line with the NPPF, seeks to focus all new retail development in our town centres…’. This is not what the NPPF says and there is no preclusion of out of centre retail floorspace within the NPPF. Indeed, it is supported, subject to satisfying the sequential test and demonstrating that there will be no likelihood of a significant adverse impact on the town centre (paragraphs 23-26). In a situation where there are no sites to meet the substantial comparison goods needs that exist, and there are clear market signals for additional retail floorspace within the Borough, policy should proactively facilitate the planned retail investment for the area. Whilst at this stage, no final site has been identified by Next, the specific characteristics of this type of retail unit, combined with the Council’s acknowledgement that it will be a ‘challenge to meet the levels of development required’ mean that it can be safely concluded that a site in the Brooklands area would meet the sequential test, as being the next most accessible after town centre and edge of centre.
In terms of retail impact, the levels of need mean that the impact of a store of the size Next are seeking will not have a significant adverse impact. Paragraph 14 of the Planning Practice Guidance (reference ID: 2b-014-20140306) explains that ‘[i]f the Local Plan is based on meeting the assessed need for town centre uses in accordance with the sequential approach, issues of adverse impact should not arise’. Even under the minimum need outputs according to the ERA (14,100 sqm net by 2035), a Next store of approximately 4,500 sqm net would fall well within these need requirements and for reasons explained above, it can be safely assumed that a store in the Brooklands area would meet the sequential approach. Therefore, issues of adverse retail impact should not arise. In light of the above, we would encourage the Council to provide explicit support within the Local Plan to meet Next’s retail requirements within the Brooklands area. Since the site has not yet been agreed upon, other land uses policies on employment and Green Belt should be aligned that allows for the case to be made for retail uses in the Brooklands area, subject to satisfying other policies in the Plan (as explained elsewhere in these representations).
21 Mar 2017 10:53
Deleted User No 21 Mar 2017 10:53
First pagePrevious page Next pageLast page