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On behalf of our client M&GRE, owners of the Culver Square Shopping Centre, we hereby submit the following representations to the Colchester Local Plan (Preferred Options). This submission follows our client's previous representations to the Issues and Options (February 2015).
Culver Square is the main shopping centre in Colchester, performing an important function within the town centre, contributing to the character and appearance of the town and to the quality of its shopping experience. However, like many town centre shopping locations across the UK Colchester has suffered in recent years as a result of the economic downturn and changes in consumer behaviour through the increased usage of online shopping, the prevalence of out-of-centre retail/leisure locations and out-of-centre proposals.
M&GRE are assessing their future investment proposals and other key stakeholders are considering their town centre representation. This is a critical period when Colchester needs a consistent and informed approach to development to ensure the creation of a vital and vibrant heart to its town centre. Preparation of the Local Plan is therefore welcomed
In this context M&GRE considers it extremely important to ensure that the prevailing conditions for existing retailers within the town centre are as strong as possible and that emerging planning policy is properly prepared.
Having reviewed the Draft Plan and the supporting evidence base M&GRE are supportive overall of the emerging policy in so far as it relates to retail planning policy and the approach to out-of-centre development.
M&GRE particularly welcome recognition:
of Colchester's pre-eminent position in the retail hierarchy and as the key focus for a wide range of development opportunities;
that significantly expanding the retail components of existing mixed use commercial areas within the Colchester urban area could undermine the vitality of the town centre and their reclassification as 'out of centre' locations;
of Stanway no longer being identified as an Urban District Centre and the restriction of further retail and leisure expansion due to the need to focus such town centre uses in Colchester Town Centre, in line with the Spatial Strategy;
of the need for greater diversity of town centre uses, including non-retail, in the Primary Shopping Area; and
that future development capacity within the town centre will largely be met by the redevelopment of existing areas including St Botolph's and Vineyard Gate, both of which are identified in the plan for development.
At this time we have focused our comments on Sections 4 and 6 of the Draft Plan, in particular: Policies SG5 (Existing Mixed Use Commercial Areas within Colchester); Policy WC1 (Stanway Strategic Economic Area); Policy TC1 (Town Centre Policy and Hierarchy); Policy TC2 (Retail Frontages); and TC3 (Town Centre Allocations). These are considered in turn below:
Policy SG5 confirms the approach to further development in existing commercial mixed use areas and in accordance with their classification as 'out of centre' locations in terms of the NPPF, the requirement for such development to satisfy the sequential and impact tests. Such an approach is welcomed.
Policy TC1 confirms Colchester Town Centre as being at the top of the Borough's retail hierarchy and reaffirms it as the focus for new town centre uses. This 'town centre first' approach and the identification of future development opportunities (by virtue of SG5 and TC3), is welcomed.
Recognition that proposals for town centre uses, not allocated in the plan and outside the town centre, will be required to satisfy the sequential and impact test is also supported. However whilst we welcome the setting of an impact threshold for proposals outside of district centres below the NPPF national threshold we would suggest that consideration should be had to reducing the 2500sqm impact proposed outside of the town centre.
Policy TC2 recognises that the town centre is more than just retail, which is welcomed as is the criteria based approach where planning applications are required. However, whilst not specifically referred to in TC2 the supporting text (para 6.6) notes that the Primary Shopping Area will no longer distinguish between primary and secondary frontage. The resultant flexible approach to the treatment of town centres uses within the PSA is welcomed but to ensure the plan is sound further work may be necessary to justify such an approach.
Policy TC3 reiterates the town centre as the preference for future development and identifies development opportunities to accommodate future capacity over the plan period. We welcome the recognition that if additional capacity exists later in the plan period, this too will be directed to the town centre. This approach to allocating future capacity is in accordance with the NPPF and is supported.
Policy WC1 recognises the function of Stanway as providing commercial services for the local area. In line with the Spatial Strategy and the role of Colchester town centre, the policy correctly restricts the expansion of retail and leisure uses. This approach is supported and further recognises that such former Urban District Centres do not reflect the commonly understood definition of what is a centre, in terms of the NPPF.
The policy also seeks to safeguard the Strategic Economic Area's primary function as an employment area. Whilst the policy allows for some enhancement and potential intensification of this (within the area defined as Zone 2), we are encouraged that this will be limited and subject to criteria (in this instance satisfy the sequential and impact tests) which serves to protect the employment area and the town centre.
Having reviewed the Local Plan Preferred Options, M&GRE is supportive of the emerging policies, which seek to protect the town centre and direct future development to the town centre in the first instance. However, to ensure the policies are justified we would suggest that further consideration is given to the impact threshold outside the town centre and the justification for abandoning primary and secondary shopping frontages.