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Schroder UK Property Fund objects to Policy TC1 on the basis that is unsound. Para 182 of the NPPF considers a plan to be sound only when it has been positively prepared, justified, effective, and consistent with national policy. In this instance, this policy is considered to unsound on the basis that the impact assessment threshold which has been applied to the District Centres, is unjustified.
The floorspace threshold for requiring an impact assessment is currently set at 2,500 m2 which is the default threshold set out in the National Planning Policy Framework (NPPF). The NPPF does allow for lower locally set thresholds where there is evidence to confirm that level would be appropriate having regard to the existing retail hierarchy. In setting a locally appropriate threshold, Planning Practice Guidance 'Ensuring the Vitality of Town Centres' advises that threshold it will be important to consider the following:
● scale of proposals relative to town centres;
● the existing viability and vitality of town centres;
● cumulative effects of recent developments;
● whether local town centres are vulnerable;
● likely effects of development on any town centre strategy;
● impact on any other planned investment.
Only limited evidence has been presented in the Councils 2013 Retail and Town Centre Uses Study to justify the use of a lower threshold other than a short section which confirms that "The 2,500 sq m gross threshold is considered to be appropriate for proposals in Colchester, however for the smaller rural district centres we consider that a lower threshold should be adopted as this scale of development would represent a significant proportion of the overall retail floorspace projections in the remainder of the Borough. Development smaller than 2,500 sq.m gross could have a significant adverse impact, particularly on the smaller town centres. Based on the retail floorspace projections and the network of centres, a threshold of 2,500 sq.m gross is recommended for retail development within Colchester town and a 500 sq.m gross threshold for other parts of the Borough".
Whilst these findings are not disputed, it is clear that this exercise needs to be based on some form of evidence as suggested by Planning Practice Guidance and it is clear that the proposed amendment is not supported by any evidence. Since Local Plans must be consistent with the principles and policies set out in the NPPF, it is clear that this particular part of the policy is unsound.
The Policy should also be amended to reflect our representations to Policy SG5 and ensure a consistent approach to that outlined in response to that policy either though a separate policy or within the text for Policy TC1.