Black Country Core Strategy Issue and Option Report

Search representations

Results for Aldi Stores Ltd C/o Turley search

New search New search

Object

Black Country Core Strategy Issue and Option Report

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there

Representation ID: 945

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

Table 1 indicates that a 'Retail Capacity Study' and 'Town Centre Uses Study' will form part of the updated evidence base supporting the Core Strategy Review. Our client strongly agrees that the Core Strategy Review must be informed by new retail evidence.
The retail policies of the current Core Strategy are based on evidence dating from 2009. Given that so much has changed in terms of retail provision since this date, the household shopping surveys on which the policies are based are of limited use. New and up to date retail evidence, based on a new household shopping survey to identify existing patterns of retail expenditure, is therefore essential.
The new Retail Capacity Study must consider both quantitative and qualitative factors regarding need. Without doing so, there is a danger that the study will fail to pick up issues relating to the geographical distribution of facilities and areas of under provision. The evidence base should also include a full health check assessment for higher order centres.

The consultation document states that the retail evidence will inform the Draft Plan stage, which is currently due to be consulted on in September 2019. On this basis, the Preferred Spatial Options stage would be prepared without the benefit of an updated retail and town centre evidence base.
Reference to Table 1 indicates that the evidence base relating to all other major topic areas, excluding waste, is programmed to be completed at either Issues and Options or Preferred Spatial Options stage. Given that the existing retail evidence base dates back to November 2009, our client would like to see the new evidence prepared at an earlier stage to inform the Preferred Spatial Options stage.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain w

Representation ID: 946

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

We do not wish to comment directly on whether the employment land requirement identified in the Economic Development Needs Assessment (EDNA) is appropriate. We would, however, emphasise the importance of the Core Strategy Review being sufficiently flexible when it comes to the future use of existing employment areas.
Paragraph 3.29 of the Issues and Options document does recognise that "there may be a limited number of existing employment areas which are unlikely to be 'fit for purpose' and could be considered for redevelopment to alternative uses, especially housing". In order to promote economic growth, the Core Strategy Review must not protect employment land that has no realistic prospect of coming forward for such uses. Equally, flexibility is required in relation to the reuse of existing premises/land that is no longer suitable for employment use.
Any assessment of employment land should not focus entirely on the need for, and protection of, solely B-class uses. It should also recognise the importance of other forms of economic development, including retail. The Core Strategy Review should therefore allow sufficient flexibility for the reuse of employment sites, where appropriate, for retail purposes, in order to support the sub-regional economy, through local and inward investment.

Attachments:

Comment

Black Country Core Strategy Issue and Option Report

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be

Representation ID: 947

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

The key issues set out in Part 3 reflect the main strategic challenges that need to be addressed in the Core Strategy Review. Key Issue 1, updating the evidence base, will be fundamental to ensuring that the other matters identified are addressed.
Taking Key Issue 4 for example, Paragraph 3.31 notes that the primary evidence base informing the Core Strategy's retail and centres policy framework dates back to November 2009. Given the dynamic nature of retail and centres, this evidence is now significantly out of date. As set out above, it is important that this work is undertaken at an early stage to ensure that it can effectively feed into the review of the Core Strategy.
It is also noted that a number of the 'Key Issues' identified are interlinked. Referring to Key Issue 4, it is clear that policies to support strong and competitive centres will be influenced by other areas of the Core Strategy Review. This includes the commitment to delivering significant levels of housing and employment growth. The location of new housing and employment growth will directly affect the demand for retail provision over the plan period.

Paragraph 23 of the NPPF makes it clear that planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period. In doing so, the NPPF makes it clear that needs for retail (and other main town centre uses) must be met in full. The retail need for the Black Country area must therefore be met, even if there is a requirement for new centres (potentially as part of new settlements) or provision in out of centre locations (where the necessary tests are met).

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate

Representation ID: 948

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

Paragraph 4.7 of the Issues and Options document recognises that, following the completion of the evidence base summarised in Table 1, some of these objectives may need to be amended. The changing role of centres is provided as one such example. We would support the need for the spatial objectives to be revisited when the necessary evidence base is in place.
It is, however, noted that the first objective refers to focussed investment and development in comparison shopping and other specific town centre uses within the four Strategic Centres. No reference is made to convenience retail. There remains a need to support the provision of convenience food retailing within and adjoining Strategic Centres (and potentially outside those centres, in out of centre locations) in order to meet demand from the existing and future population.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think

Representation ID: 1043

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

We agree that both Policy CSP1 and CSP2 should be updated and amended to reflect new evidence and the required level of growth over the plan period. As it stands the figures provided in each policy are based on out of date evidence, for example, retail evidence dating to 2009.

Greater emphasis should be placed on the provision of new convenience floorspace to serve the Strategic Centres and Regeneration Corridors. An updated Policy CSP2 should also reflect the need for sufficient convenience floorspace to be provided in order to serve the new growth proposals outside of the Growth Network.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.

Representation ID: 1056

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

On the basis of the opportunities and challenges set out in the Issues and Options document, Strategic Option 1A is, in principle, the most realistic and deliverable approach to meet the required need over the plan period.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 25 - Will there be any new social infrastructure requirements necessary to serve large new housing developments? Yes/No; If yes, please explain the type and scale of any new social infrastruc

Representation ID: 1057

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

Paragraph 5.7 of the Issues and Options document notes that new housing may in some locations create a need to expand health, education and other community services. It continues by stating that as options for the location of major new housing allocations develop through the review process, so will decisions about the need for any such facilities and their locations.

Whilst not strictly 'social infrastructure', it is important that the Core Strategy Review provides flexibility for the market to deliver sufficient convenience retailing, in the right locations, to support the significant planned housing growth.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

6. Review of Existing Core Strategy Policies and Proposals

Representation ID: 1059

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

Table 3 of the Issues and Options document provides an overview of the extent to which the Core Strategy policies may change as part of the review process. The table recognises that Policy CEN1 to CEN7 will most likely be subject to major change in most cases, with criteria and thresholds likely to be reviewed based on new and emerging evidence.

Our client supports the commitment to review the relevant retail policies, and the recognition that they will require major change. This must be based on a new retail evidence base, which is prepared at an early stage of the review process.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 49a - Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.

Representation ID: 1060

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

There remains a need for a policy to provide appropriate criteria to assess the release of employment land to other uses.

Attachments:

Support

Black Country Core Strategy Issue and Option Report

Question 49b - If yes, should this policy be used to assess the release of employment land to alternative uses, other than housing? Yes/No; If yes, please explain why.

Representation ID: 1061

Received: 08/09/2017

Respondent: Aldi Stores Ltd C/o Turley

Agent: Turley Assocs

Representation Summary:

Policy DEL2 currently relates specifically to the balance between employment land and housing. The Core Strategy Review, and Policy DEL2 specifically, should recognise that schemes for uses other than housing could also be appropriate. This could include other employment generating activities, such as retail.

Attachments:

Need help completing this? Click here for our simple user guide.