Policy S9: Retail Hierarchy and Sequential Approach

Showing comments and forms 1 to 18 of 18

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 432

Received: 28/01/2019

Respondent: Mr Graeme Barrett

Representation Summary:

There has been a significant decline in facilities in East Wittering whilst we have seen a very significant growth in the Witterings housing stock, as mentioned earlier. A further point there is only one 24 hour free cash point in the area which regularly runs out of cash.

Full text:

Resident of West Wittering
There has been a significant decline in facilities in East Wittering whilst we have seen a very significant growth in the Witterings housing stock, as mentioned earlier. A further point there is only one 24 hour free cash point in the area which regularly runs out of cash.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 444

Received: 16/01/2019

Respondent: karen phillips

Representation Summary:

what is the council planning to do about the changing city centres?
There will be more opportunity in the city centre as retail changes. Maybe use some of the empty shops for housing or reduce the rates to encourage shops back in. Whatever is decided the council needs to be proactive in responding to the changes to ensure this is still a desirable place to live and visit.

Full text:

I write especially with regards to bosham as that is where I live but overall I am concerned about the sheer number of houses proposed mainly due to the impact of the increased cars. I already choose not to seek employment to the areas east of Chichester due to the sheer weight of traffic there is getting past the city. There is no clear road improvement strategy to manage the already heavily congested roads. Another 1000 plus houses and associated cars will only exacerbate the traffic issues and reduce the desirability of living and visiting the area.
I also do not see any clear funding plan for increasing health services for all the extra people. With an increasing elderly local population this needs addressing.

With regards to the Highgrove site in bosham my concerns include:

1) I understood that a water study noted how the rain water from the downs runs into Highgrove fields which would cause concerns around flooding if the area is built upon. How would this be managed?

2) when there is no funding or appetite from the council to build new schools. How would a two level entry school be built ?
Also where is the evidence that a two level entry school is required ?
Taking the school out of the heart of the village will increase car use and change the atmosphere of the village.
Also if the school is moved out of its current site no doubt the council would see the land for even more houses this increase the housing density in the village. This needs to be made a clear intention for people to be made aware of.

3) the housing you will be build is likely to overpriced for local young people who are generally already out priced by the low wages compared to house prices in the area. This does not solve the housing crisis.

On a slightly difderent note, what is the council planning to do about the changing city centres?
There will be more opportunity in the city centre as retail changes. Maybe use some of the empty shops for housing or reduce the rates to encourage shops back in. Whatever is decided the council needs to be proactive in responding to the changes to ensure this is still a desirable place to live and visit.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 455

Received: 28/01/2019

Respondent: Mr Robin Kidd

Representation Summary:

Whilst the objective, to ensure a lively retail scene in the city centre, is commendable, we should also support local citizens with larger more affordable shops, not just expensive independent boutiques. This especially applies to clothing. Currently I drive to adjacent districts (Bognor, Havant and beyond) to buy clothes, when I would much prefer to be able to buy clothes in Chichester. This could mean allowing a strictly limited number of large clothing shops in edge-of-town locations, to complement the expensive boutiques in the city centre.

Full text:

Whilst the objective, to ensure a lively retail scene in the city centre, is commendable, we should also support local citizens with larger more affordable shops, not just expensive independent boutiques. This especially applies to clothing. Currently I drive to adjacent districts (Bognor, Havant and beyond) to buy clothes, when I would much prefer to be able to buy clothes in Chichester. This could mean allowing a strictly limited number of large clothing shops in edge-of-town locations, to complement the expensive boutiques in the city centre.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 510

Received: 29/01/2019

Respondent: Mr Stephen Page

Representation Summary:

CDC seem to be way out of step regarding the diversity of the city centre. The number of restaurant and cafe outlets are already excessive with few other reason for visitors to come into the city centre.

Full text:

1 CDC seem to be way out of step regarding the diversity of the city centre. The number of restaurant and cafe outlets are already excessive with few other reason for visitors to come into the city centre.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 880

Received: 03/02/2019

Respondent: Ms Pamela Smith

Representation Summary:

I am concerned about the number of empty shops in Chichester. More needs to be done to support small businesses. With the number of residents in the City centre increasing, specialized food shops selling fresh local produce would be beneficial. The old butter market was a missed opportunity.

I welcome the proposal to restrict further out of town retail development.

Full text:

I am concerned about the number of empty shops in Chichester. More needs to be done to support small businesses. With the number of residents in the City centre increasing, specialized food shops selling fresh local produce would be beneficial. The old butter market was a missed opportunity.

I welcome the proposal to restrict further out of town retail development.

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 969

Received: 30/01/2019

Respondent: Chichester Conservation Area Advisory Committee

Representation Summary:

We support this policy and commend the six bullet points in para 4.60. We strongly support in 4.66 the promotion of the city centre's retail offer and the restriction of further retail development in out-of-centre locations.

Full text:

Retail Hierarchy and Sequential Approach.

We support this policy and commend the six bullet points in para 4.60. We strongly support in 4.66 the promotion of the city centre's retail offer and the restriction of further retail development in out-of-centre locations.

Chichester City Development Proposals.
Whilst this acknowledges need for new development to have special regard for the city's historic character by the use of Supplementary Planning Documents or Development Plan Documents, what faith can we have that they will be adhered to? The previous Southern Gateway Development Framework specified that buildings should be two storey with occasional three. Despite this the recent canal-side development, known as John Rennie Road, was permitted to be three storey with a lot of four, and is of such poor quality design it damages the approach to the city and the Conservation Area. Chichester Gate, as permitted, is an architectural disaster displaying as it does poor design and cheap materials. Furthermore the policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan

The Council must undertake to enforce the provisions of their SPDs etc otherwise they are worthless. The policy should make the point that the whole of the city centre is a conservation area and should be respected as such. A map shewing the Conservation Area boundary should be appended to the Local Plan.

Design
This acknowledges the historic environment, the need to create high quality buildings and the need for policies to drive this. All well and good - but policies need to be adhered to by CDC when determining applications and there is little evidence of this happening at present.
Policy S20 introduces the concept of 'Sense of Place' and the importance of getting scale, height density right. This is a laudable aspiration which has been ignored in the past.

Ensure the policy is enforced when determining all planning applications

Historic Environment.
This acknowledges the importance of Heritage Assets, the need for further Conservation Area Character Appraisals (CACA) and the importance of protecting Heritage Assets. Fine - but with no Conservation Officers on the staff preparation of CACAs is falling woefully behind. The revision to the Chichester CACA is still not completed over two years on.

Commit to filling the Conservation Officer posts and completing all the CACAs as a matter of urgency

Southern Gateway
This policy fails to acknowledge that a large part of the designated Southern Gateway area lies within the Conservation Area and includes several Designated and Non-Designated Heritage Assets, GII-listed buildings in Southgate and Basin Road, buildings on the Local List and others identified as positive in the latest Conservation Area Character Appraisal. The statements regarding the majority of the buildings in the SG area not making a positive contribution are misleading. The railway station, county court, Boys' High School and bus garage all do make a positive contribution. The bus garage is an important example of the early use of thin-shell pre-stressed concrete to give a clear span. It is an attractive building whose open space should be put to new uses (an open market for e.g.). Once again the need for high quality design is included in the policy but will it be enforced? The Southern Gateway has recently been defiled by two appalling permitted developments - John Rennie Road and Chichester Gate.
The ideas for traffic management and diverting all but buses along Basin Road are dubious.

Correct the policy by stating that the SG area is in the Conservation Area and include from the above about the heritage assets, listed buildings etc. Also commit to enforcing the design policy.

Chichester Centre Retail
We support paragraphs 1 to 4 of this policy and revision to the shopping frontages, especially with regard to Crane Street. The policy rightly acknowledges the constraints of the historic character of the city centre and the need to improve the visitor experience. Out-of-town retail developments such as Barnfield suck the life out of the city centre and should be resisted. 7.69 mentions the importance of considering the Council's Shopfront and Advertisement Design Guidance Note within the Conservation Area. This is a laudable aim but, sadly, shopfronts which patently do not conform are usually permitted. The Guide requires hand painted lettering on a painted timber fascia, yet metal or plastic fascias with raised lettering are invariably permitted without question. Case officers do not seem to know of the existence of the guide and one has to wonder whether applicants are made aware of it. It is not easy to find on the CDC website.

Ensure case officers are aware of the ship front guide and that it is enforced in their decisions. Strengthen enforcement to rule on unauthorised shopfronts

Historic Environment
7.154-7.166 acknowledges conservation areas, the existence of local lists and character appraisals and emphasises the need for further conservation area character appraisals (CACA) and the need to protect Heritage Assets. Fine words, but with no Conservation Officers on the staff all this is getting woefully behind. The revision to the Chichester CACA is still not completed over two years on. CCAAC have put forward in the past four years several proposals for additions to the local list whose scoring was agreed by the then Historic Buildings Advisor but which have still not been signed off, leaving those buildings with no protection Once again, with no conservation officers these aspirations cannot be met .
Policy DM27 itself includes conserving and enhancing the special interest and settings of designated and Non-Designated Heritage Assets but not about the need to protect these assets themselves. This omission should be corrected

Complete processing of outstanding Local List applications, appoint Conservation Officers, and reword the policy to provide for protecting the assets

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 988

Received: 04/02/2019

Respondent: The Hon Susan Barnes

Representation Summary:

Retail purchasing is changing very rapidly towards an online focused experience. There was only one department store in Chichester City centre which closed earlier this year. Overall footfall has decreased. High costs (rent/rates/maintenance) in the city centre lead to repeated store vacancies. To view the city centre as being able to cope with retail expansion would require an increase in vehicle parking facilities as there is currently insufficient frequent local alternative transport across the south coast. Proposals for expansion outside the city centre must again take into account increased traffic load.

Full text:

Retail purchasing is changing very rapidly towards an online focused experience. There was only one department store in Chichester City centre which closed earlier this year. Overall footfall has decreased. High costs (rent/rates/maintenance) in the city centre lead to repeated store vacancies. To view the city centre as being able to cope with retail expansion would require an increase in vehicle parking facilities as there is currently insufficient frequent local alternative transport across the south coast. Proposals for expansion outside the city centre must again take into account increased traffic load.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1153

Received: 05/02/2019

Respondent: Mr Iain Dodson

Representation Summary:

Chichester centre. Online shopping is destroying secondary/tertiary retail areas. Grasp the nettle and use these areas for apartments. Stop the influx of Charity shops the usual death knell of shopping areas. Incentivise change of use to residential. Get the Housing Associations involved with Government support.

Full text:

I am a retired FRICS and have some knowledge of Housing Matters. The need for more affordable/social housing is accepted by most people who want to see a settled and fair society. How this is achieved is the issue. The current proposals achieve nothing, mainly due to how the big builders manage to manipulate Government policy to suit themselves at the expense of local needs and in this locality create problems listed as follows.

1.Flooding. Increase in surface water drainage ends up in the water meadows and harbour AONB.
2.Pollution. Most surface water drainage is polluted and I draw attention to a recent hydrocarbon spillage in Fishbourne which gravitated as always into the Millpond Water Meadows and Harbour all of which are protected areas and home to endangered species including water vole.
3.Capacity issues at Appledram Sewage Works and others. A recent Freedom of Information Act enquiry confirmed the system cannot cope with the current volume of waste and now admitted by Southern Water. On site treatments are unreliable and failure in this locality could be catastrophic.
4.Traffic. More development of the type proposed will just exacerbate current well documented problems around the A27 and local roads.

There needs to be new thinking by both Central and Local Government on where to put extra housing and stop the obsession of building on green belt and creating urban sprawl.

1.Chichester centre. Online shopping is destroying secondary/tertiary retail areas. Grasp the nettle and use these areas for apartments. Stop the influx of Charity shops the usual death knell of shopping areas. Incentivise change of use to residential. Get the Housing Associations involved with Government support.
2.Put in required infrastructure especially sewage disposal before development. This is just plain common sense.
3.Remove the rules that favour developments of more than 100 units
4.Rein in the South Downs National Park Authority. Many communities in the South Downs would welcome small pockets of affordable housing so that younger people with families can remain and ensure the survival of local primary schools, village shop, real communities. Again get the Housing Associations involved with Government support and make it less of an attraction for 2nd home owners.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1172

Received: 31/01/2019

Respondent: Rawleigh Property Management Ltd

Agent: Genesis Town Planning

Representation Summary:

Policy S9 and S10 both refer to local and village parades and village centres interchangeably which is confusing.

Full text:

The 'tests of soundness' for Local Plan preparation are set out in paragraph 35 of the NPPF2. They require the 2016-35 Local Plan to have been:
* Positively prepared - providing a strategy which, as a minimum, seeks to meet the
area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
* Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
* Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
* Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in this Framework.

We will deal with these matters more thoroughly at Submission stage but our headline comments to the Preferred Approach deal with the retail policies S9 and S10 in connection with the Broadbridge Business Centre Bosham.

The policies have been informed by the Chichester Retail and Main Town Centre Uses Study 2018 Final Report this being part of the evidence base for the Plan. Paragraph 9.12 states that Bosham has some retail uses and services, consistent with the role of a local centre, serving the immediate local catchment area. Table 11.4 identifies Bosham as a Local/Village Parade in the retail hierarchy. Table 10B at Appendix 2 has not identified the centre but refers to the 2 principal convenience goods destinations, 1) Co-op at Delling Lane (the Broadbridge Business Centre)
and 2) the Co-op at Station Road Broadbridge.

Policy S9 refers to Bosham as a 'village centre in the hierarchy to be defined in the
Neighbourhood Plan or Development Plan Document DPD' and applies the impact threshold of 250m2. It also states 'local centres including shopping parades and standalone shops form an important resource for businesses, visitors and residents. The expansion and additional provision of such facilities to a scale appropriate to the existing settlement or the planned expansion of that settlement will be welcomed by the Council provided it adds to the range and accessibility of
goods and services'.

Policy S10 is titled Local Centres: Local and Village Parades. Like policy S9 it encourages development at local centres but also includes local and village parades. It also refers to village centres.

Policy S9 and S10 both refer to local and village parades and village centres interchangeably which is confusing.

Policy S9 - Retail Hierarchy and Sequential Approach
The policy wording needs amending to make clear that additional retail will be supported at local centres and village centres including shopping parades and standalone shops. For consistency the policy should either refer to village centres in the hierarchy instead of local village parades.

Consideration should be given to elevating Bosham to a local centre especially given the significant planned additional growth of 250 dwellings proposed at Highgrove Farm in policy SA7. If this is accepted the impact threshold should also be raised to over 500m2. Importantly, the village centre (or local centre if Bosham is elevated to this in the hierarchy) must be defined in the next Submission version Local Plan and not left to a future Neighbourhood Plan or Site Allocations DPD. According to the local Development Scheme (2018-2021) the next DPD is not due to
be adopted until July 2022. We understand the Bosham Neighbourhood Plan is not being reviewed. Without this amendment allowing the definition of the Bosham village or local centre there would be no retail policy in place for Bosham until 2022 and potential retail development which would otherwise be welcomed by policy would be prevented from coming forward.

The Co-op at Broadbridge Business centre is larger than the store at Station Road. The business centre has other facilities including a doctor's surgery and some of the business units there already have an ancillary retail offer. It has ample ground level parking and is better suited as a retail destination than the Station Road parade.

We therefore recommend the Broadbridge Business Centre is defined in the Submission Plan as the retail centre of Bosham as shown on the attached plan edged blue. The centre should be at least a village centre although, with the potential 250 dwellings at Highcroft Farm, the centre would better be suited as local centre in the retail hierarchy.

Policy S10 - Local Centres, Local and Village Parades
As a corollary to our comments on S9, Policy S10 should be renamed Local Centres and Village Centres. The policy wording should confirm that within the defined centre loss of employment would not be a reason for allowing a change of use of an existing B1 use to A1 retail. The proposed amendments would benefit the Plan in meeting the tests of soundness, namely the positively prepared, effective and consistent with national planning policy tests.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1417

Received: 07/02/2019

Respondent: Ms Paula Chatfield

Representation Summary:

See Objection to para.s 4.60-4.71.
Shopping parades and stand alone shops should be distinguished from Local Centres.
And policy is needed for Trade Parks.

N.B. As a Committee member of Parklands' Residents' Association (PRA), please note that PRA may wish to pursue the subject of local parades/shops with CDC and with the Inspector at Examination in Public, if it is not adequately addressed.

Full text:

See Objection to para.s 4.60-4.71. The policy wording:
"Local Centres, including shopping parades and stand-alone shops form an important resource for businesses, visitors and residents. The expansion and additional provision of such facilities to a scale appropriate to the existing settlement or the planned expansion of that settlement will be welcomed by the Council provided that it adds to the range and accessibility of goods and services."
is not grounded in these paragraphs but turns out of nowhere. Please distinguish "shopping parades and stand-alone shops" from Local Centres. And address the role of, and policy for, Trade Park premises.


N.B. As a Committee member of Parklands' Residents' Association (PRA), please note that PRA may wish to pursue the subject of local parades with CDC and with the Inspector at Examination in Public, if it is not adequately addressed.

CHANGE TO PLAN

Identify and add local parades to the Centre Hierarchy - they are important to Strategic Objectives, including Health and Well-Being. (Consider also the function of individual shops like the One-Stop at St Paul's Road and the Summersdale shop.) Review the function of Trade Parks and how they fit into the retail strategy of the Plan.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1445

Received: 07/02/2019

Respondent: Ms Paula Chatfield

Representation Summary:

This Policy introduces the concept of "comparison floorspace". It is not clear to me whether the subsequent references to retail provision/use refer to all Class A uses (i.e. https://www.planningportal.co.uk/info/200130/common_projects/9/change_of_use ) or simply to A1 shops.
It would benefit from clarification.
Dependent on how it is clarified, I may have further comments.

Full text:

This Policy introduces the concept of "comparison floorspace". It is not clear to me whether the subsequent references to retail provision/use refer to all Class A uses (i.e. https://www.planningportal.co.uk/info/200130/common_projects/9/change_of_use ) or simply to A1 shops.
It would benefit from clarification.
Dependent on how it is clarified, I may have further comments.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1669

Received: 07/02/2019

Respondent: Chichester BID

Representation Summary:

Cultural anchors could replace retail earlier than we think. There is over-stock of brick and mortar shopping.

Full text:

It may well be that bricks and mortar retail loses its attraction as a reason prior to 2026 for visiting the City. Consideration should be given to building/licensing a cultural, leisure and/or entertainment hotspots at the extremity of each shopping zone such particularly at the at Southern Gateway site. The policy may have to view cultural plant as fulfilling the role the old anchor store concept did before, with the Chichester Cinema at the Eastgate, the Cathedral/Novium complex at the East, and the CFT at the North. The obvious missing art form would be for a multipurpose space which should include provision for music and dance to complete the city's offer.

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1673

Received: 07/02/2019

Respondent: Mrs Claire Stratton

Representation Summary:

No mention of Lavant as a village centre and as there is space for residential development outside of the SDNP this needs to feature in the local plan as a village centre to support the new settlement boundary that should be in the local plan as a strategic site outside of the SDNP.

Full text:

No mention of Lavant as a village centre and as there is space for residential development outside of the SDNP this needs to feature in the local plan as a village centre to support the new settlement boundary that should be in the local plan as a strategic site outside of the SDNP.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1856

Received: 07/02/2019

Respondent: Mr Christopher Tod

Representation Summary:

The issue is the proposal to release areas within the Primary category, where no more that 25% of shop frontages can be in non-A1 retail uses, to the Secondary category whereby up to 75% of the shop frontages can be in non-A1 retail use - particularly South Street (less concerned about Southgate/Eastgate/Crane Street).

Full text:

I am writing in response to your proposal within the Local Plan Review to change the designation of retail areas of the City Centre.

The issue is the proposal to release areas within the Primary category, where no more that 25% of shop frontages can be in non-A1 retail uses, to the Secondary category whereby up to 75% of the shop frontages can be in non-A1 retail use.

The retailing area in the City Centre is compact and relatively small scale. It provides a good range of retailing offer in an attractive environment and shoppers come from a fair distance to Chichester and numbers are helped by the influx of tourists to the area.

I fully appreciate the difficulties that retailers are facing at this moment with online competition, increase in out of town retailing, massive Rates liabilities, current economic uncertainty and high parking costs.

We all recognise how important a vibrant shopping centre is to the fabric of the City. However if you considerably reduce the Primary trading area, to allow up to 75% in non retail use, you are drastically shrinking the range of retail offer that is urgently required to attract shoppers. The net effect would be to render the City Centre less attractive, fewer shoppers come and we are on the slippery slide destruction.

I recognise that there are some areas where your policy could be effective such as Southgate and Eastgate and Crane Street but never in South Street, which makes a significant contribution to the retail offer. It is the main route from the transport hub and major car park to the Cross and to permit a further 50% of shops in South Street to be in non retailing use would be savage and counterproductive.

There will be plenty of opportunity to provide for the non A1 uses in the proposals for the Southern Gateway and the fringe areas but if you loose the main retail area now you will never get it back ! It is far too important to the future of Chichester to risk it's destruction.

The success of our City Centre retail area is absolutely vital to Chichester. South Street plays an important part of the Primary retail area. Please retain it as such.

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2590

Received: 07/02/2019

Respondent: Countryside Properties

Agent: Turley

Representation Summary:

Policy unhelpful in application to Tangmere where there is a close proposal for transition of Tangmere village centre to local centre

Full text:

See attachment

Comment

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2634

Received: 05/02/2019

Respondent: Barton Willmore

Representation Summary:

Supportive of policy to protect existing retail but concerned that does not make provision for scale of retail which could be supported by new strategic development

Full text:

See attachment

Attachments:

Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 2856

Received: 07/02/2019

Respondent: MR William Sharp

Representation Summary:

Object on grounds that: nightime economy creates problems; health of city centre retail has not been resilient through recent recession; widening area of retail centre would make centre less easily walkable and impact upon car parks; edge-of-centre shops would encourage hollowed out city centre.

Full text:

See attachment

Attachments:

Support

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 3281

Received: 29/01/2019

Respondent: Westbourne Parish Council

Representation Summary:

Support retail hierarchy to safeguard Westbourne as village centre.

Full text:

See attachment