HAAP: Schedule of modifications
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HAAP: Schedule of modifications
MM14
Representation ID: 33165
Received: 13/01/2014
Respondent: The Co-operative Group
Agent: Barton Willmore LLP
MM14 - Policy 6
4. The Co-op maintains its objection to the revised Policy 6. In particular, the revised Policy 6 states that new A1 development within the Eldon Way Opportunity Site would be permitted where it would, amongst other things:
"b) Not exceed a maximum overall additional retail capacity for the centre of 3,000 sq m (gross)."
5. Whilst the detailed wording of criterion b) is not particularly clear, it has already been established that there is no capacity for convenience goods floorspace of 3,000 sq m gross in Hockley (either in or outside of the Centre). The only real difference to the revised criterion b) is that it no longer refers specifically to support for a foodstore. However, whilst the reference to a foodstore is removed, the use of the term 'retail' would clearly encompass both food (i.e. convenience) and non-food (i.e. comparison) retail. As such, the Policy would still support a foodstore of up to 3,000 sq m gross.
6. On the basis that there is no justification for a foodstore of up to 3,000 sq m gross, the Co-op maintains its position that the AAP is unsound.
7. In order for the AAP to be found sound, it is recommended that criterion b) is either deleted in its entirety or explicitly only permits comparison goods floorspace of up to 3,000 sq m gross, thus excluding any support for a foodstore.
8. The Co-op generally supports the inclusion of the additional requirements for a planning application after criterion d), however it should make it clear that all of the previous criteria need to be complied with and should be explicit that any planning application for retail development on the site will need to demonstrate compliance with the NPPF sequential and impact tests (paragraphs 24, 26 and 27 of the NPPF).
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':
* MM14 - amend Policy 6 to either delete criterion b) or amend it so that it clearly does not support a
foodstore / convenience goods floorspace.
* MM14 - amend the final paragraph of Policy 6 after criterion d) in order to be clear that all previous
criteria need to be complied with and that any planning application is required to demonstrate
compliance with the NPPF sequential and retail impact tests.
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.
Object
HAAP: Schedule of modifications
MM15
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.
Object
HAAP: Schedule of modifications
MM16
Representation ID: 33167
Received: 13/01/2014
Respondent: The Co-operative Group
Agent: Barton Willmore LLP
MM16 - New Paragraph Following the Fourth Paragraph
12. The Co-op objects to the additional text "alongside any foodstore" for the reasons set out above. This additional text should 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':
* MM16 - delete the reference to a foodstore.
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.
Support
HAAP: Schedule of modifications
MM17
Representation ID: 33168
Received: 13/01/2014
Respondent: The Co-operative Group
Agent: Barton Willmore LLP
MM17 - Fifth Paragraph
13. The Co-op supports the deletion of this paragraph.
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.
Object
HAAP: Schedule of modifications
MM18
Representation ID: 33169
Received: 13/01/2014
Respondent: The Co-operative Group
Agent: Barton Willmore LLP
MM18 - New Paragraph following the Fifth Paragraph
14. The Co-op is concerned that reference is made in this paragraph to concern that a large retail unit (of unspecified size) would have a negative impact on the vitality and viability of the centre and will not be favoured, but may be acceptable subject to various criteria, including assessing its impact on Hockley and other centres.
15. Subject to the amendments to Policy 6 recommended at paragraph 8 above, this modification is
unnecessary as it is ambiguous and would merely duplicate the revised wording of Policy 6. If it is
considered necessary to retain the paragraph, it should be amended to make it clear that any application for retail development will need to demonstrate compliance with the Policy 6 criteria as proposed to be amended at paragraph 6-8 above.
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':
* MM18 - either delete the paragraph in its entirety or amend it to make it clear that any application
for retail development will need to demonstrate compliance with Policy 6, as proposed to be
amended above.
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.
