MM15
Object
HAAP: Schedule of modifications
Representation ID: 32804
Received: 08/12/2013
Respondent: Rochford District Residents
I support the Modification you require but I am concerned that the actual wording put forward might unintentionally to give the Council an option to only give lip service to other retail mix options which would run contrary to your intentions and be against the principles of natural justice. Some form of publicly exhibited due diligence, independently audited and verified, with formal public consultation needs to be added by you to this Modification. In other words if a single supermarket is proposed because there is no other viable commercial option then that must be proven independently and in public.
Mr. Smith. I attended Day 1 of the HAAP PE. Whilst I support the principles of the Modification you require I am concerned that the actual wording put forward might unintentionally to give the Council an option to only give lip service to other retail mix options which would run contrary to your intentions and be against the principles of natural justice. Some form of publicly exhibited due diligence, independently audited and verified, with formal public consultation needs to be added by you to this Modification.
I understand you to be stating that a 3000 square metres food store is unsound and should be replaced with "overall additional retail capacity of 3000 square metres".
I recall Ward Members for Rayleigh speaking in Development Committee regarding the Asda Supermarket in Rawreth Lane saying that in Rawreth residents expected lots of small retail outlets selling food, comparison goods, electricals, butchers, bakers etc,. But in Rawreth residents ended up with a single ASDA store selling the usual comprehensive range of goods with competition only on other brands and pricing determined by ASDA. In other words a single supermarket.
The Modification you put forward for Hockley could be interpreted by a developer and the Council to still mean a supermarket with a gross floor area not exceeding 3000 square metres. This is what the Council originally put forward of course.
I think that the Council still believes that "an anchor store" is a proven necessity for any shopping centre to thrive but it would seem that Residents and you do not agree.
I believe that you need to add the requirement for the Council to conduct a professional Due Diligence with Evidence, independently audited and verified, presented to public scrutiny in a further public consultation to ensure that the previous policy is not delivered without proper and exhaustive investigation and promotion of the Modification. In other words if a single supermarket is proposed because there is no other viable commercial option then that must be proven independently and in public.
Object
HAAP: Schedule of modifications
Representation ID: 33166
Received: 13/01/2014
Respondent: The Co-operative Group
Agent: Barton Willmore LLP
MM15 - Page 48, Fourth Paragraph
9. For the reasons set out under MM14, the Co-op also objects to the modification to this paragraph, which sets a 3,000 sq m maximum floorspace level.
10. It should also be noted that the final sentence of this paragraph, which is not proposed to be changed, still refers to "the overall level of convenience capacity". As there is no justification for additional convenience goods floorspace in Hockley, it is unclear why this sentence has not been deleted.
11. We therefore recommend that the paragraph is either deleted in its entirety or is amended so that it explicitly permits only comparison goods floorspace of up to 3,000 sq m gross and clearly excludes a foodstore. Reference to convenience goods capacity should also be deleted.
Recommended Changes To The Hockley Area Action Plan - Main Modifications Consultation
16. For the reasons set out above, the Co-op maintains its objection to the AAP, as proposed to be
modified. The following changes are proposed in order to make the Plan 'sound':
* MM15 - either delete the paragraph in its entirety or amend it so that it explicitly does not support a
foodstore, in which case any references to convenience goods capacity should also be deleted.
1. We act on behalf of the Co-operative Group ("the Co-op") and have been instructed to submit
representations and objections to the Main Modifications consultation on the Hockley Area Action Plan
("the AAP"). This follows the submission of previous representations in January 2013, a Hearing
Statement dated August 2013 and appearance at the Hearing Sessions held in September 2014. This
representation should be read in the context of our previous comments.
2. The Co-op's previous comments focused primarily on the allocation of a circa 3,000 sq m gross foodstore on the Eldon Way Site, under Policy 6 of the emerging AAP. During the Hearing Sessions and in its Hearing Statement, no evidence was provided by the Council to demonstrate that the proposed allocation of a foodstore of up to 3,000 sq m gross was justified against the evidence base, or was consistent with the NPPF. It could not therefore be considered sound. This view was supported by the Inspector in his letter to Rochford District Council dated 17th October 2013 which found that the proposed Policy 6 was unsound as there was no justification for a foodstore of 3,000 sq m gross.
3. Against this background, we set out below our comments to the Main Modifications to the AAP, and the AAP's performance against the soundness tests contained within the National Planning Policy Framework (NPPF) at paragraph 182.