Post on 11-Dec-2021
transcript
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Local Plan Examination in Public
Council Hearing Statement
Matter 5: Retail, Leisure and other Main
Town Centre Uses
July 2018
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Contents Issue 5.1: Need for Main Town Centre Use Development ..................................................................... 3
Issue 5.2: Accommodating Main Town Centre Uses .............................................................................. 6
Issue 5.3: Development Management Policies relating to Retail and Town Centres ........................... 15
This appendix relates to Q81
Appendix 1: Local Centre Boundaries
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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Issue 5.1: Need for Main Town Centre Use Development Local plans should be based on assessments of the needs for land or floorspace for all foreseeable
types of economic activity over the plan period, including retail and leisure development33.
The Council’s Retail and Leisure Study 2015 [RT3] and Addendum [RT2] identify “capacity” or
potential demand during the plan period for:
• 6,000 to 7,600 sqm of additional net floorspace for convenience goods;
• 11,900 to 41,700 sqm of additional net floorspace for comparison goods; and
• new health and fitness clubs, a ten pin bowling alley, additional restaurants, and a small
multiplex cinema.
The Study advises that the long term assessment should be treated with caution due to the obvious
difficulties inherent in predicting the performance of the economy and shopping habits over time. In
any event, any identified capacity should not necessarily be viewed as justification of new retail
floorspace outside centres as this could prejudice the implementation of any emerging town centre
redevelopment strategies and the development of more central sites which may be currently
available or which could become available over time.
62. Does the Council’s evidence accurately identify the “capacity” for additional floorspace for
convenience and comparison goods shopping over the plan period? In particular, does the
evidence make realistic assumptions about (a) sales densities and (b) shopping patterns across the
catchment area?
Yes. The methodology adopted in identifying capacity (quantitative need) for additional convenience
and comparison goods shopping over the plan period is an industry standard / accepted one. The
methodology is frequently subjected to scrutiny by third parties and Inspectors and has been found
to be sound. The latest capacity findings are set out in the 2018 Broxbourne Retail and Leisure Study
2nd Addendum [RT3A].
In terms of the assumptions made in relation to sales densities and shopping patterns:
(a) Sales Densities - Having regard to the fact that the level of floorspace capacity will vary
dependent on the type of retailer proposed and, in the case of comparison goods, the type of
goods traded, minimum and maximum floorspace capacity figures are identified. The sales
density figures adopted for convenience goods floorspace capacity are derived from average
sales density figures for grocers identified by GlobalData.com (previously VerdictRetail.com)
which is an industry recognised source for grocers sales densities. The sales density figures
adopted for comparison goods floorspace capacity have regard to average sales density figures
published by Mintel Retail Rankings which again is an industry recognised source for sales
densities for comparison goods retailers. The minimum comparison goods sales density figure
is based on the identified capacity being met through the delivery of ‘high street’ floorspace and
the maximum figure relates to the identified capacity being met by bulky goods retailers or in
smaller town centre (which both generally accommodate operators which achieve lesser sales
densities). They represent both a higher and lower end of what is considered could be achieved
in the Borough of Broxbourne having regard to available sales density data of retailers.
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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(b) Shopping Patterns – Market Researchers NEMS were commissioned, as part of the market
research for the July 2015 Retail Study, to undertaken a comprehensive household telephone
survey to identify shopping patterns in the Borough and wider Study Area. The undertaking of a
household telephone survey is a standard and widely industry accepted approach in
establishing shopping patterns for both retail studies and planning applications for retail
development.
63. What are the most appropriate assumptions to make about sales densities for the type of
retail development proposed at Brookfield?
In the absence of named retailers for the planned Brookfield development professional judgements
have been made on sales densities for the convenience and comparison goods retail floorspace.
These judgements have been made having regard to average/benchmark sales density data
published by retailers and WYG’s retail planning experience. This is an orthodox, and NPPG
compliant, approach to estimating the turnover of planned/proposed retail developments.
In terms of the estimated sales density for the planned convenience goods floorspace for Brookfield
(£12,000/sq m at 2026), the figure is based on an average of the sales densities of the leading four
supermarkets (Tesco, Asda, Sainsburys and Morrison). The figure has been derived from sales
density data published by GlobalData.com.
Given the representations and discussions that took place at the previous Core Strategy examination
with regard to the sales density for the then larger amount of planned comparison goods floorspace
at Brookfield an assessment of three trading assessment scenarios is provided – each adopting
different sales densities [RT1A]. The precise comparison goods turnover of the planned Brookfield
will vary depending on the end retailers. It is considered that having regard to inter alia: the level of
planned retail floorspace, existing retail provision in Brookfield; the location of existing retail
provision (notably in Harlow and Enfield); and published average sales density, Scenario B, which
adopts a sales density of £5,750/sq m (at 2026), represents the most likely comparison goods
turnover figure. For reference purposes average sales density figures for a number of the main high
street comparison goods retailers are set out in the table below:
Retailer Sales Density (£/sq m)
Retailer Sales Density (£/sq m)
John Lewis Marks & Spences House of Fraser Next Primark
10,726 5,548 2,792 4,878 7,283
Arcadia Group H&M TK Maxx WH Smith Wilkinson
4,545 5,567 4,632 5,169 3,304
Average of above 10 Retailers = £5,444/sq m
Source: Mintel Retail Rankings 2017 Arcadia Group includes Top Shop/Top Man, Dorothy Perkins, Evans, Burton, miss Selfridge, Wallis, Oasis and Warehouse Sales Density figures are @ 2026. Allowance made for increased turnover efficiency as set out in Table 4b of Experian Retail Planner 15 2012 Prices
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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64. Does the Council’s evidence accurately identify the potential demand for additional leisure
developments in the Borough over the plan period?
Yes. In order to ascertain whether that are any shortfalls in respect of existing commercial leisure
uses the 2015 Retail and Leisure Study [RT3] identifies commercial leisure needs for the Borough by
assessing its existing provision against accepted sector ‘benchmarks’. The adopted methodology is
set out in Section 8.2 of RT3. Again, the methodology has adopted is an industry standard /
accepted one and is frequently subjected to scrutiny by third parties and Inspectors and has been
found to be sound.
As noted in RT3, the assessment of quantitative need in the leisure market necessarily departs from
the quantitative retail need methodology for a number of reasons, including the fragmentation of
leisure markets and the limited availability of accurate data. The household telephone survey
undertaken to support the 2015 Retail and Leisure Study however allows an assessment of the
market share secured by commercial leisure facilities with the Borough and the wider Study Area for
a variety of leisure sectors. This qualitative assessment of the attractiveness of the Borough’s leisure
facilities is supplemented through the use of national data in respect of the typical level of provision
of specific types of facilities across the UK. By referencing to estimated increases in the Retail Study
area population, the ‘benchmarking’ exercise informs our judgement in respect of the likely future
need for additional commercial leisure facilities in the Borough.
65. Does the potential “capacity” or potential demand for additional main town centre uses
identified in the Council evidence represent a “need” for such forms of development during the
plan period?
Yes. RT3, RT2 and RT3A identify both quantitative (capacity) and qualitative needs for retail and
commercial leisure uses for the Borough. They represent the retail and commercial leisure needs for
the Borough. The NPPF (paragraph 23) places emphasis on the requirement for all identified needs
to be met (met in full) and that such needs are not compromised by limited site availability.
Accordingly, in planning for Brookfield, the Council has had regard to both quantitative (capacity)
and qualitative needs identified in RT3, RT2 and RT3A.
If the Council does not plan to meet the identified retail and commercial leisure needs identified in
RT3, RT2, RT3A, residents in Broxbourne will continue to be disadvantaged and have to travel
distances to other centres outside the Borough.
66. Given that the Retail and Leisure Study and Addendum set out ranges for the potential
capacity for additional retailing, and the caution that it recommends in the use of the long term
assessments, is the proposal in the Plan for around 40,000 sqm of new retail development
justified?
Yes. Notwithstanding the acknowledged difficulties inherent in predicting the performance of the
economy and shopping habits over a long period, the planned retail floorspace at Brookfield has
been allocated having regard to the requirements of paragraph 23 of the NPPF. Paragraph 23
requires LPA’s, in drawing up Local Plans, to set out policies for the growth of centres over the plan
period. Bullet point 6 of paragraph 23 specifically identifies that it is important that needs for retail,
leisure, office and other main town centre uses are met in full. In accordance with bullet point 7 of
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paragraph 23, in the absence of appropriate town or edge of centre sites the Council has proposed
policies to seek to meet the identified plan period needs (in full) in a new town centre at Brookfield
which will be a highly accessible location.
67. Given that the Retail and Leisure Study does not quantify the amount of floorspace that may
be needed for the leisure uses that it suggests that the Borough could support, is the proposal in
the Plan for 10,000 sqm of new leisure development justified?
Yes. As noted in our response to Q65, the NPPF (paragraph 23) places emphasis on the requirement
for all identified needs (both quantitative and qualitative) to be met. Accordingly, in planning for
Brookfield, the Council has had regard to both quantitative (capacity) and qualitative commercial
leisure needs identified in the 2015 Retail and Leisure Study [RT3].
The methodology for assessing commercial leisure needs in the Borough is summarised in
our response to Q64.
The potential mix of leisure uses was derived from 2015 Borough of Broxbourne Retail and
Leisure Study and early master planning discussions with Bayfordbury Estates, the original
promoter of the Brookfield commercial development. It was consequently envisaged that
there would be a mix of leisure uses as follows:
- 4,000 sq m food and drink
- 2,500 sq m health and fitness
- 3,500 sq m cinema
The 10,000 square metre figure within the Policy was drawn from this mix. The potential
impact of the leisure uses was assessed within the Brookfield Retail and Leisure Impact
Study 2017. This concluded that the impacts of the proposed mix of leisure uses on town
centres inside and outside the borough would be acceptable. It is therefore considered that
this policy provision is justified.
Issue 5.2: Accommodating Main Town Centre Uses Local plans should positively seek opportunities to meet the development needs of their area.
Objectively assessed needs should be met in full with sufficient flexibility to adapt to rapid change
unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits
when assessed against the policies in the NPPF taken as a whole or specific policies in the NPPF
indicate development should be restricted.
Local plans should aim to ensure the vitality of town centres and set out policies for their
management and growth over the plan period. Local plans should allocate a range of suitable sites to
meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and
residential development needed in town centres such that those needs are met in full and not
compromised by limited site availability. Local planning authorities should undertake an assessment
of the need to expand town centres to ensure a sufficient supply of suitable sites. Appropriate edge of
centre sites for main town centre uses that are well connected to the town centre should be allocated
where suitable and viable town centre sites are not available. If sufficient edge of centre sites cannot
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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be identified, identified needs should be met in other accessible locations that are well connected to
the town centre.
This issue is concerned with establishing whether the strategy for accommodating main town centre
use development is consistent with the available evidence, justified in other respects, and consistent
with national policy.
Policy DS1 states that provision will be made for around 40,000 sqm of new retail development and
around 10,000 sqm of new leisure development.
The Council’s Retail and Leisure Study 2015 [RT3] includes a study area that includes Broxbourne
Borough and surrounding areas in Enfield, Welwyn Hatfield, East Hertfordshire, Epping Forest and
Harlow and identifies 7 “higher order” town centres in that area including “regional centres” in
Welwyn Garden City and Stevenage and “sub regional centres” in Enfield and Harlow.
The Council’s Brookfield Retail Impact Study 2017 [RT1] indicates that, even if the proposed retail and
leisure development at Brookfield takes place, all town centres would experience significant growth
in expenditure 2016-2024 eg Hoddesdon 6%, Waltham Cross 16%, Enfield 30% and Harlow 40%.
Based on high sales density assumptions, the impacts on turnover at other town centres are
predicted to be:
• Cheshunt -2.5%
• Hoddesdon -3.3%
• Welwyn -4.6%
• Waltham Cross -5.2%
• Harlow -5.7%
• Enfield -6.1%
• Others <-3%
The Study does not identify any significant adverse impacts on existing, committed or planned
investments in town centres in the catchment area, and concludes that their viability and vitality is
unlikely to be affected by the retail or leisure developments proposed in the Plan.
The Council’s response to the main issues raised in representations [EXAM5] refers to an update to
the Retail Impact Study being prepared.
The Council responded to Preliminary Question 23 related to this issue [EXAM3A], and to Further
Preliminary Questions 3 and 4 [EXAM4A].
68. Could all, or a greater proportion than proposed in the Plan, of identified needs for main town
use development be accommodated in or through the expansion of existing town centres in the
Borough or elsewhere?
No. In terms of the potential expansion of existing town centres in the Borough, the 2015 Retail and
Leisure Study [RT1] sought to assess, in accordance with the sequential approach to site selection,
where the identified forecast additional retail and leisure capacity/need and growth could be
located. The assessment identified that (1) with the exception of the site at Northern High Street
(Waltham Cross), there were no new opportunities for retail or commercial leisure developments
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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within or on the edge of the town centres; and (2) there was very little physical capacity to
accommodate all of the assessed convenience and comparison goods floorspace need/capacity over
the plan period within the existing town centres. As explained in our response to Q69 the Council’s
endeavours to redevelop the site at the northern High Street (Waltham Cross) for a retail led
development have not attracted investors and therefore the Council is now promoting it for a mixed
use residential led development with limited commercial/A1/community ground floor uses. The
evidence available, and the assessment undertaken, identifies that the retail and commercial leisure
needs for the Borough cannot be accommodated in or through the expansion of existing town
centres in the Borough.
It is relevant to note that the Council has not been approached by any party with an interest in
land/buildings within or on the edge of the existing town centres in the Borough. Furthermore, no
parties have identified any alternative sequentially preferable sites elsewhere in the Borough to
accommodate the identified main town centre use development needs.
In terms of meeting the Borough’s retail and commercial leisure needs in existing town centres
outside the Borough, whilst no assessment of sites has been undertaken by the Council, the
expansion of town centres outside the Borough would result in residents of the Borough being
disadvantaged and an increase in unsustainable patterns of movement.
69. Is the proposed mix of uses on the town centre site at Waltham Cross Northern High Street
(policy WC2) justified, or should there be a greater focus on redevelopment for retail uses?
The original proposal for the redevelopment of Waltham Cross Northern High Street was a retail-
based development of two major floor plate stores of c. 3,500 square metres and smaller retail
units. The two stores were targeted at a food retailer and a comparison outlet and alternative
configurations were possible. However, despite this proposal being pursued for c. three years there
was little market interest. The finalised Waltham Cross Town Centre Strategy therefore encapsulated
the current Local Plan proposal for a mixed use redevelopment of main town centre use ground
floors along the alignment of Waltham Cross High Street and residential above and on the remainder
of the site (the current site of the Homebase store). Of the two proposals, the current policy is
considered to be far more viable, commensurate with the commercial scale of Waltham Cross town
centre and will introduce more residents into the town centre, adding to its vitality.
70. Paragraph 3.12 of the Plan states that “in the event that there are difficulties in
implementation of the development strategy, contingency planning will focus on bringing forward
… the Waltham Cross Area Action Plan (policy WC3)”. Is it likely that additional main town centre
uses could be developed during the plan period in that part of Waltham Cross either in advance, or
following the preparation, of an AAP?
Yes. The Local Plan policy enables the redevelopment of Waltham Cross Northern High Street in
advance of the preparation of the AAP and other significant developments that would contain town
centre uses are proposed that could come forward in advance of the AAP – notably at the Pavilions,
the Gala Bingo site and Fishpools. These developments would need to be generally in accordance
with the approved Waltham Cross Town Centre Strategy as well as the draft/adopted Local Plan.
Whilst the AAP would include the town centre within its boundaries, the focus will be on the lands
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around the station in support of Crossrail 2. Decision making within the town centre will of course be
cognisant of the intention to produce the AAP and of its probable content.
71. If identified needs for main town centre use development cannot be accommodated within
existing or expanded town centres, are there other accessible locations well connected to town
centres in the Borough or elsewhere that could meet help meet those needs?
No, as noted in our response to Q68, Brookfield has been identified to meet the identified retail and
commercial leisure needs following a sequential site assessment. Furthermore, no parties have
identified any alternative sites in sequentially preferable locations well connect to the town centre in
the Borough to accommodate the identified main town centre use development needs.
In terms of meeting the Borough’s retail and commercial leisure needs on potential sites in
accessible locations well connected to town centres outside the Borough, as previously explained in
our response to Q68, this would result in residents of the Borough being disadvantaged and an
increase in unsustainable patterns of movement.
72. Would accommodating identified needs for additional main town centre uses within
Broxbourne Borough contribute to achieving sustainable patterns of development and ensuring
the viability and vitality of town centres in the Borough and wider sub area including in Enfield,
Harlow and Welwyn Hatfield?
From the initial concept of a mixed-use town centre linked with a new residential community,
through subsequent masterplanning stages, Brookfield has been carefully planned to maximise
opportunities to foster sustainable patterns of development. Relocation of the Council offices and
co-location with a range of services and facilities is proposed to enable linked trips. Further details
are set out in the draft transport strategy (evidence library document T2).
It is the Council’s position that there is no other more sustainable strategy available to meet the
identified needs for the Borough. If the identified needs are not met in Brookfield, given that there
are no alternative sequentially preferable sites in the Boroughs town centres, it is likely that planning
applications for unsustainable out-of-centre retail and commercial leisure development will come
forward in the plan period. Such development will not be able to provide the substantial social,
economic and environmental benefits that Brookfield would deliver.
Furthermore, a quantum and critical mass of retail and commercial leisure floorspace at Brookfield is
required which is able to clawback a proportion of the shopping and leisure trips lost from the
Borough and in turn encourage more sustainable shopping and leisure patterns. In the absence of
any sequentially preferable sites, the allocation of a number of separate out-of-centre sites in the
Borough would not meet the objective of providing an accessible sustainable town centre capable of
clawing back the lost expenditure from the Borough. A strategy to identify a number of a separate
out-of-centre sites in the Borough to meet the identified needs is also likely to result in the centres
of Harlow, Enfield and Welwyn Garden City maintaining their attractiveness to residents in the
Borough and in turn encourage an increase in unsustainable travel patterns.
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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73. Is the proposal to make provision for around 40,000 sqm of new retail development in the
Borough (policy DS1), including around 30,000 sqm of net retail comparison floorspace and 3,500
sqm of retail convenience floorspace at Brookfield Riverside, consistent with the available
evidence about the need for such development, justified, and consistent with national policy
relating to the location of main town centre uses?
Yes, we respond on each matter in turn below.
Consistency with available evidence and justified – The available evidence, which identifies the
relevant retail and commercial leisure uses needs for the Borough in the plan period, is provided in
the 2015 Retail & Leisure [RT3], 1st addendum [RT2] and 2nd addendum [RT3A]. The level of
convenience and comparison goods floorspace planned for Brookfield accords with the findings of
the evidence base documents. For convenience goods, RT3A identifies £63.4m (before
commitments) / £57.7m (after commitments) of quantitative need by the end of the plan period
(after commitments). The planned convenience goods floorspace at Brookfield is estimated to have
a turnover which falls within the identified quantitative need (estimated at up to circa £36.0m @
2026).
In terms of comparison goods floorspace, RT3A identifies, under a constant market share approach,
quantitative need of £137.0m (before commitments) / £124.4m (after commitments) by the end of
the plan period. The evidence identifies that a significant proportion of residents in the Borough are
travelling distances to other centres/facilities outside the Borough for comparison goods (circa 45%
of comparison goods expenditure ‘leakage’) and that there is potential to recapture some of this
expenditure to help stem some of this leakage, reduce travel distances, encourage more sustainable
travel patterns, and make sure the needs of the residents of the Borough are met locally and are
accessible. RT3A identifies, assuming a hypothetical uplift in Broxbourne’s comparison goods
market share (15% increase in study area market share (25.2% to 28.9%)), comparison goods
quantitative need could increase to £234.1m (before commitments) / £221.5m (after commitments).
The planned comparison goods floorspace at Brookfield is estimated to derive a turnover of up to
£131.7m-£175.6m depending on the sales density scenario. The planned comparison goods
floorspace is intended to meet the identified needs however it should be noted that in doing so it
will only claw back a small proportion (between circa 5-10% from Zones 1-4 (Broxbourne Borough))
of the comparison goods expenditure leakage. The assessed impacts on the town centres of Harlow,
Enfield and Welwyn Garden City, albeit not at a significant adverse impact level, needs to be
considered/balanced against the benefits of recapturing expenditure leakage and the provision of a
sustainable and accessible new town centre to meet the needs of Broxbourne residents. If the
identified needs for the Borough are not met locally at Brookfield, and centres outside the Borough
continue to improve their retail and leisure facilities, unsustainable travel patterns will increase and
residents in the Borough will continue to be disadvantaged.
Consistency with National Policy – As noted in our response to Q62 and Q64, the methodologies and
approach adopted in the Broxbourne Retail & Leisure Study [RT3, RT2, RT3A] and Brookfield Retail &
Leisure Impact Assessment [RT1, RT1A] are fully in accordance with the NPPF and NPPG and adopt
industry accepted standards for such evidence base documents.
Furthermore, as noted in our response to Q68, Brookfield has been identified in accordance with the
sequential approach to site selection. There are no other sequentially preferable or more
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sustainable and accessible sites able to accommodate the identified retail and commercial leisure
needs for the Borough.
74. Is the proposal for up to 10,000 sqm of leisure floorspace, a hotel, and a civic centre at
Brookfield Riverside justified and consistent with national policy relating to the location of main
town centre uses?
The justification for the leisure floorspace is set out within the Council’s response to Question 67. In
seeking to create a sustainable, mixed used town centre at Brookfield, the Council has also sought to
introduce other main town centre uses, including a civic centre and an hotel. Historically, the main
civic functions were undertaken within the three main Broxbourne centres of Hoddesdon, Cheshunt
and Waltham Cross. However, that is no longer the case with the Council’s own offices located
within an out of town centre location that is not easy to access for many members of the
community. None of those centres has the primacy or centrality to provide more centralised and
accessible civic functions for the borough. Brookfield, however, would contain those characteristics
if delivered in the manner set out within the Local Plan. The main user within a civic centre would be
the Borough Council and that is likely to be accompanied by a primary health centre and a police
presence. Other civic uses will also be considered to create a true civic hub within Brookfield and
that would be a key component of the new town centre. The Local Plan promotes various sites for
hotels within the borough and an hotel would be a natural accompaniment to the range of retail,
leisure, civic, business and residential uses being planned for Brookfield Riverside.
75. Are the proposals in policy INF14 for hotel developments at Park Plaza and High Leigh Garden
Village justified and consistent with national policy relating to the location of main town centre
uses?
The proposal for a hotel at Park Plaza is reflects the anticipated need for a hotel primary to service
the business traveller market arising from the development of the proposed business campus as
described in Policy PP1. The proposal for a hotel at High Leigh Garden Village reflects an existing
planning permission which forms part of the extant planning permission.
76. (a) Are the proposals for a total of around 150,000 sqm of B1 floorspace at Brookfield and Park
Plaza West (policies BR1 and PP1), and further B1 uses at Park Plaza North and South (policies PP2
and PP3) and other employment areas (policy ED2) consistent with national policy relating to the
location of main town centre uses, and (b) what effect would they have on the vitality and viability
of town centres in the Borough or elsewhere?
a) The proposed B1 floorspace is a qualitatively different ‘product’ to the local town centre office
market both in Broxbourne and the surrounding area. It should not be thought of as a town centre
use, but aims requires a highly visible location on the strategic road network suitable to attract
inwards investment from larger businesses which would not otherwise look to invest in town centres
in either the borough or the wider area. This is a distinct and complementary proposition to the local
office market provision. As stated in the Employment Land Study, at a local office market level,
office-based employment will continue to play a role in supporting small and medium sized
businesses in Broxbourne: “the (low) forecast change in floorspace demand is therefore more
reflective of a supply position which is relatively constrained with few sites able to attract or cater for
businesses seeking sites to build out large, high quality office space.” (ELS, page 97, paragraph 6.5.7).
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The overall approach is consistent with the requirement in Paragraph 21 of the NPPF that Local Plans
should “set out a clear economic vision and strategy for their area which positively and proactively
encourages sustainable economic growth.”
b) The effects on town centres would be neutral at worst for the reasons set out above relating to
the difference between the strategic and local office markets, but there is significant potential for a
positive effect on the vitality and viability of surrounding town centres. As has been shown in recent
years, significant development of office floorspace by existing occupiers (such as VolkerVessels or
MSD) could lead to improved perceptions of the area including its town centres as a place for
business growth. The town centre office market in the wider area beyond the borough is also largely
comprised of SMEs, and it is not anticipated that such businesses would be attracted from their
existing locations by the strategic business parks.
77. Would the main town centre use development proposed at Brookfield Riverside, along with
existing retail uses, be likely to lead to the creation of a new “town centre” in that location as
proposed in RTC1 and described in paragraphs 5.4-5.11 of the Plan?
Brookfield Riverside is planned to include a mix of town centre uses within a planned “town centre”
environment and it will function as a town centre. It is therefore the Council’s intention to create a
new town centre at Brookfield. There has been a long dialogue within the Council and between the
Council, the promoters of Brookfield Riverside and the Council’s retail advisors as to how Brookfield
should be defined. The original proposal promoted through the Broxbourne Core Strategy was for
Brookfield to be described as a borough centre which remains an accurate description of its planned
role in relation to the borough of Broxbourne. However, that term has no recognition within national
policy and retail hierarchies. In terms of the scale and proposed mix of uses within Brookfield and
the environment that will be created, it would fall most precisely within the town centre definition
and Policy RTC1 therefore proposes that eventuality. The Council has always been mindful that such
a definition could lead to unrestricted growth of main town centre uses to the detriment of other
town centres within and outside the borough. It is for that reason that Policy BR1 caps the allowable
floorspace on certain main town centre uses within Brookfield. The Policy requires a comprehensive
master plan that will ensure those floorspace limitations are respected and any planning permissions
will ensure that Brookfield is comprehensively delivered in accordance with that master plan.
78. Does the Brookfield Retail Impact Study 2017 [RT1] made realistic assumptions about (a)
existing and future turnover in town centres in the catchment area; (b) sales densities at
Brookfield; and (c) shopping patterns / trade draw across the catchment area and beyond?
(a) Existing & Future Turnovers – The existing and future turnovers of centres/facilities in the 2018
Brookfield Retail and Leisure Impact Study [RT1A] (which supersedes (in part) the 2017 Brookfield
Retail and Leisure Impact Study [RT1]) are derived from the 2018 Broxbourne Retail & Leisure Study
2nd Retail Addendum [RT3A]. The methodology adopted in deriving turnovers of centres/facilities is
an industry standard/NPPG compliant one. It applies the estimated relevant retail expenditure
derived from residents in each zone to the market share shopping patterns identified for each zone
by the household telephone survey. The 2018 Broxbourne Retail and Leisure Study 2nd Retail
Addendum [RT3A] updates the retail capacity/quantitative need previously updated in RT2 in RT3. It
takes in account the most recently published retail data/documents and Experian’s retail
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
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expenditure data and projections. It also updates the population and population projections data
and accords with the Council’s household projections. Whilst the household telephone survey which
informed the 2015 Retail & Leisure Study [RT3] has not been updated there is not considered to be
any material changes in circumstances which would warrant a new household survey to be
undertaken.
The turnovers of town centres outside the Borough have been estimated based on the neighbouring
Council’s latest Local Plan retail study evidence base documents.
(b) Sales Densities for Brookfield - we refer you to our response to Q63.
(ci) Shopping Patterns - we refer you to our response to Q62
(cii) Trade Draw – The pattern of retail trade to the planned retail floorspace for Brookfield has been
assessed having regard to the trade draw patterns of existing retail facilities in Brookfield. Existing
comparison goods retailers, complemented by a number of food and drink operators, include M&S,
Next, Outfit (including TopShop/Top Man/Dorothy Perkins, Evans, Burton, Miss Selfridge, Wallis,
Oasis, Warehouse), River Island, New Look, Boots, JD Sports, Argos, Tesco Extra, and Clarks. The
pattern of trade draw to the planned floorspace has been assessed on the basis that Brookfield will
provide similar ‘high street’ retailers to that already provided in Brookfield and to that currently
contained in the larger town centres outside Broxbourne (Harlow, Enfield and Welwyn Garden City).
To put the assessed trade draw patterns into context, the retail impact assessment robustly assumes
that 51% of the planned Brookfield comparison goods retail floorspace is derived from residents
outside the Borough of Broxbourne (Zones 1-4). Given that the planned comparison goods
floorspace at Brookfield is seeking to meet the identified comparison goods retail capacity needs for
residents within the Borough in addition to seeking to clawback a small proportion of the
comparison goods expenditure currently ‘leaking’ from the Borough to other centres (circa 45%
(£157.6m @2018) of comparison goods expenditure from the Borough) the trade draw patterns are
considered to be reasonable.
Notwithstanding this, given the representations received in relation to the assessed comparison
goods trade draw patterns, an additional quantitative retail impact sensitivity scenario is provided in
the 2018 Brookfield Retail & Leisure Impact Study Retail Addendum [RT1A] testing a higher level of
comparison goods trade diversion from the surrounding town centres of Harlow, Enfield, and
Welwyn Garden City (New Sensitivity Testing 3). The sensitivity testing identifies that even assuming
a higher unrealistic level of trade diversion from these centres all are anticipated to still benefit from
an increase in retail turnover in the impact assessment period.
79. Does the Brookfield Retail Impact Study 2017 [RT1] accurately predict the impacts on (a)
turnover and (b) investments in town centres in the catchment area?
Yes, responding to each in turn:
(a) Impacts on Retail Turnover - The methodological approach that has been adopted in the
2017 Retail & leisure Impact Study [RT1] and 2018 Retail Impact Study Addendum [RT1A]
accords guidance in the NPPG. The steps undertaken in predicting impact on centre
turnover are set out in Section 4.3 of RT1. Our response to Q63 provides further details in
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
14
relation to the sales density/turnover estimated for the planned Brookfield whilst Q78
provides further explanation in relation to trade draw and shopping patterns that have been
adopted. A number of trade draw scenarios are provided to sensitivity test the impact on
centre turnover. In all scenarios the assessed level of quantitative impact the turnover of
relevant centres assessed is not considered to be at a level that would, constitute ‘significant
adverse’ and would be refused if Brookfield came forward as a planning application
proposal.
(b) Impact on In-Centre Investment – information regarding in-centre investment was sought
from the relevant local planning authorities. A site was identified by Harlow Council in their
representations to the Pre-submission Local Plan (Regulation 19 Stage). This site (Harlow
Town Centre North Site) was assessed in Section 3 of the 2018 Retail & leisure Impact Study
Addendum [RT1A]. No other sites have been identified by neighbouring Councils and, more
importantly, no representations from neighbouring Councils have been made specifically
stating that the planned retail and leisure floorspace at Brookfield would result in significant
adverse impact on in-centre investment in their administrative areas. The assessments of in-
centre investment in the 2017 Retail & Leisure Impact Study [RT1] and 2018 Addendum
[RT1A] are fully compliant with both the NPPF and NPPG (paragraph 17) and relevant
Secretary of State appeal decisions. Of particular relevance to the assessment of impact on
in-centre investment is how advanced a project/scheme needs to be able to be classified as
‘planned investment’. The Inspector in the Scotch Corner, North Yorkshire appeal decision
(endorsed by the Secretary of State) confirms:
“This part of the impact test [impact on existing committed and planned in-centre
investment] is, in my view, clear and straightforward. As the first bullet point of the
Framework paragraph 26 sets out and as confirmed by PPG, it is only existing public
and/or private investment that has been made, committed or is planned that requires to
be tested. Existing and committed investment are straightforward terms. Whilst what
constitutes planned investment is not specifically defined by either the Framework or PPF,
paragraph 16 of PPG identifies that the key considerations will include, (i) the policy status
of the investment i.e whether it is outlined in the development plan; (ii) the progress made
towards securing investment, e.g. if contracts are established and; (iii) operator
demand/investor confidence. These indicate to me that to be considered as planned
investment a project has to be at a very advanced stage”
Appeal Reference APP/S1530/W/16/3147039, IR Paragraph 11.16, Scotch Corner, North
Yorkshire
Notwithstanding that the impact assessments contained in RT1 and RT1A are consistent with
the above approach and identify no significant adverse impacts arising as a result of the
planned Brookfield development, as noted at paragraph 1.2.6 of the 2018 Brookfield Retail
& Leisure Impact Study (RT1A), the NPPG (paragraph 14) identifies that in plan-making the
impact test may be “useful” in determining whether proposals in certain locations would
impact on existing, committed and planned public and private investment, or on the role of
centres. Firstly, it should be noted that the NPPG identifies that if the Local Plan is based on
meeting the assessed need for town centre uses in accordance with the sequential approach
(which in our opinion the Broxbourne Local Plan is) issues of adverse impact should not
arise. Secondly, it should be noted that the NPPG identifies that the impact test may be
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
15
useful and does not specifically identify that an assessment of impact is a requirement.
Thirdly, and finally, it does not make any mention, or set out any requirement, for Councils
to undertake a quantitative and qualitative impact assessment on town centre vitality and
viability. The Council consider these are important matters that the Inspector should take
into account when considering the submitted retail and leisure impact assessments
contained in RT1 and RT1A.
80. Overall, what would be the cumulative effects on the vitality and viability of existing town
centres in the Borough and elsewhere of the proposals in the Plan for main town centre use
developments?
The Council’s conclusions on the cumulative effects of Brookfield and relevant commitments on the
vitality and viability of existing town centres in the Borough and elsewhere are set out in Section 7 of
the 2017 Brookfield Retail & Leisure Impact Study [RT1] and in Section 4 of the 2018 Brookfield
Retail & Leisure Study Addendum [RT1A]. The assessment identifies that the cumulative effects on
the vitality and viability existing town centres within and outside the Borough would not be
“significant adverse”.
Issue 5.3: Development Management Policies relating to Retail and Town
Centres 81. Is the sequential test described in policy RTC1(II)(b) consistent with that set out in NPPF
paragraph 24 and, if not, is it justified?
Policy RTC1(II)(b) is inconsistent with paragraph 24 of the NPPF in that it does not reflect the
sequential test, instead indicating equal weight is given to ‘existing centres or on edge of centre
sites’. The paragraph also includes references to the historic environment which do not form part of
paragraph 24 and also refers to retail rather than the full range of ‘main town centre uses’ defined in
the Glossary to the NPPF.
The Council therefore considers that a number of main modifications to policy RTC1 are required,
including those necessary to address the above but also to amend inconsistencies in relation to the
approach to local parades, which are excluded from the national definition of defined centres. For
the avoidance of doubt, maps showing the defined Local Centres to which Policy RTC1 applies are
provided as an appendix to this hearing statement.
Furthermore, given that Brookfield Riverside is not yet a town centre a modification is proposed to
remove it from the existing retail hierarchy set out in RTC1. It is instead identified as an emerging
town centre. A town centre boundary for Brookfield Riverside will be defined, and the centre will be
included in the retail hierarchy, as part of a review of the Local Plan, once the likely extent of the
town centre is known.
82. Is the approach to directing retail uses to “main retail centres” and “local centres” as set out in
policy RTC2 consistent with national policy and, if not, is it justified?
As set out above, the Glossary to the NPPF includes local centres within the overarching definition of
town centres. The NPPF refers to ‘main town centres’ rather than ‘main retail centres’. A further
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
16
inconsistency in this policy has been identified in part II b), which refers to ‘shopping centre’. This
word implies a limited focus on retail which is not present in the NPPF emphasis on a range of ‘main
town centre uses’. Potential modifications to policy RTC2 are proposed below to remedy these
inconsistencies.
83. To be effective and consistent with national policy, should RTC1, RTC2 or other policies in the
Plan set out a sequential test for main town centre uses in addition to retail?
The Council suggests that it would be appropriate to incorporate the sequential test within Policy
RTC1 which sets the context for subsequent policies. Potential modifications are set out in the table
below.
84. Is the Council’s proposed main modification to add a clause to policy RTC2 requiring
development to have regard to relevant town centre strategies necessary and adequate to ensure
that the Plan is effective?
For reference the proposed new clause within RTC2 is shown in the table of potential modifications
below. The Council considers that the modification is necessary to provide a framework for the
consideration of the context for planning applications within the designated centres.
Document EXAM6 includes modifications to policies WC1, HOD1, and CH3 for each of the designated
centres and the accompanying reason states: “Change required to ensure that the intended outcome
of the policy is clear and to make clear how a decision maker should react, in accordance with NPPF
paragraph 154. In order to make the policy effective a modification will be made to the Policies Map
to delineate the policy area and the status of the town centre strategy will be secured by insertion of
additional wording into Policy RTC2: Development within Designated Centres.”
Taken together, the modifications to the above policies and the status given to the relevant
strategies is considered adequate to provide a clear basis for decision-making.
Potential Main Modifications
Policy Proposed modification Q. no
Paragraph 23.4 Development within Retail Defined Centres
The Policies Map shows the boundaries of the Borough’s main shopping centres: Hoddesdon Town Centre; Waltham Cross Town Centre; Cheshunt Old Pond District Centre; and Brookfield Retail Centre., as well as seven local centres.
181
New paragraph 23.5
National policy sets out ‘main town centre uses’ which are considered appropriate within these defined centres as follows:
retail development (including warehouse clubs and factory outlet centres);
leisure/entertainment facilities/the more intensive sport and recreation uses (including cinemas, restaurants, drive-through restaurants, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres, and bingo halls);
offices;
arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).
181
5.10 This new development will bear all the hallmarks of a town centre and Brookfield will therefore ultimately assume town centre status within the retail hierarchy, alongside Hoddesdon and Waltham Cross.
181
Policy RTC1: Retail Hierarchy
Policy RTC1: Retail Hierarchy and Main Town Centre Uses I. The Council will permit new retail town centre use development within town
181, 183
Council Hearing Statement Matter 5: Retail, Leisure, and Other Main Town Centre Uses
17
Policy Proposed modification Q. no and district the defined centres, as shown on the Policies Map, that is compatible with their function and position within the retail hierarchy below: • Town Centres: Brookfield Riverside, Hoddesdon Town Centre and Waltham Cross Town Centre; • District Centre: Cheshunt Old Pond District Centre; and • Neighbourhood Centres, Local Centres and Parades.: High Street, Cheshunt; High Road, Broxbourne; High Street, Waltham Cross (Nos 228-286 and 229-267); Crossbrook Street ( Nos 99-137); Goffs Oak; Wormley; and Rye Road. The NPPF sets out a sequential test for retail uses, which applies the hierarchy, set out above. II. Brookfield Riverside is identified as a broad location for a proposed new town centre where main town centre uses will be acceptable if delivered in accordance with an integrated masterplan as set out in Policy BR1. A town centre boundary will be defined as part of a review of the Local Plan, once the extent of the town centre is known. III. Retail Main town centre use development will not be permitted elsewhere in the Borough unless otherwise provided for in this plan or where: (a) need can be demonstrated which is not adequately met within the Borough at present: and (b) following a sequential test, it is demonstrated that the requirements of development cannot be physically accommodated within existing centres; or on edge of centre sites or the existing centres cannot accommodate the development without damage to their historic or architectural character or overall environment: (a) it satisfies, where applicable, national policy requirements relating to a sequential approach and impact assessment; and (c)(b) the proposals would not have a material significant adverse impact upon existing, committed and planned investment in a centre or centres or on the vitality and viability of town, district and local centres.
Policy RTC2: Development within Designated Centres
Policy RTC2: Development within Designated Centres I. Retail uses, excluding small convenience shops must be directed in the first instance to the Borough’s main retail centres as shown on the Policies Map, i.e. Hoddesdon Town Centre, Waltham Cross Town Centre, Cheshunt Old Pond District Centre and Brookfield Centre. If these locations are unavailable or unsuitable, retail uses will be directed to the Borough’s local centres. II. I. The following criteria will be used to consider the acceptability of new development proposals, including extensions, alterations, and changes of use within the Borough’s centres at Hoddesdon, Waltham Cross, Cheshunt Old Pond, and Brookfield Riverside, as defined on the Policies Map: (a) whether the development enhances the historic character of the centre (where relevant) and the public realm; (b) the role of the shopping centre and services it provides; …… III. Planning applications for new development, including changes of use, within the designated centres should have regard to the relevant Council strategy, namely the town centre strategies for Hoddesdon or Waltham Cross, or the district centre strategy for Cheshunt Old Pond.
182, 184 EXAM6
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