retail and commercial leisure background paper (december 2012) · retail and commercial leisure...

Retail and Commercial Leisure Background Paper December 2012

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Retail and Commercial Leisure Background Paper

Contents

Section 1 – Introduction to the Background Paper ............................................................. 2

Section 2 – Policy Framework ........................................................................................... 2

Section 3 – Existing retail and commercial leisure provision in Gravesham ....................... 9

Section 4 – Identifying future needs to be met over plan period ....................................... 11

Section 5 – The policy approach set out in the Local Plan ............................................... 13

Section 6 – Comparing existing policy with proposed policy ............................................ 19

Appendix A: Derivation of adjusted retail headroom figures set out in Table 1. ............... 23

Appendix B: Derivation of guideline figures used for distribution of retail development in

Table 2. ........................................................................................................................... 35

Appendix C: Consideration of Responses to the Gravesham Retail Study Update and

Gravesend Town Centre and Retail Policy Approach Update Consultation ..................... 41

References - Links to main evidence base documents .................................................... 51


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Section 1 – Introduction to the Background Paper 1.1 The purpose of this Background Paper is to set out in summary form the basis upon

which the Council has developed its policies toward the main town centre uses of retail and commercial leisure1 and the evidence used to inform that approach. Information is also provided on existing retail and commercial leisure provision within the borough. The potential scale of future needs is also identified after taking into account the implications of existing planned provision and commitments. An appendix to the Background Paper also provides a consideration of responses to the July – September 2012 Gravesham Retail Study Update and Gravesend Town Centre and Retail Policy Approach Update consultation.

1.2 The above consultation documents are available on-line via the links at http://www.gravesham.gov.uk/services/environment-and-planning/planning/planning-

policy/local-development-framework/past-consultations

1.3 A table of references at the end of this Background Paper provides a list of

documents forming the main evidence base and links to where they are located on-

line. The content of this background paper should be understood in that context.

Section 2 – Policy Framework

National Policy

2.1 National policy on retail and commercial leisure (as main town centre uses) is set out

in the National Planning Policy Framework (March 2012) at paragraphs 23 – 27.

Planning policies should be positive, promote competitive town centre environments

and set out policies for the management and growth of centres.

2.2 Key to the policy framework is a pro-growth agenda whereby the planning system is

designed to facilitate (and not constrain) competition and consumer choice by

ensuring that sufficient sites are available over the plan period to fully meet identified

need.

2.3 Town centres are recognised as being at the heart of local communities set within a

network and hierarchy of centres that should be resilient to anticipated economic

changes. Local Planning Authorities are advised to define the extent of town centres

and Primary Shopping Areas and set policies that make clear which uses will be

permitted in such locations. Competitive town centres should be promoted that

provide customer choice and a diverse retail offer and that reflect the individuality of

towns centres whilst retaining and enhancing existing markets where appropriate.

1 Reference to commercial leisure in this context should also be taken to relate to entertainment facilities

and the more intensive sport and recreation uses unless otherwise specified as an associated main town centre use to which a similar policy approach applies.


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2.3 Applying a sequential approach, priority is given to town centre locations for new retail and commercial leisure development followed by well-connected and accessible edge-of-centre and then out-of-centre locations.

2.4 For retail uses, ‘in-centre’ is defined as being the Primary Shopping Area - an area

where retail uses are concentrated generally comprising the primary retail frontage and those secondary frontages that are closely related. ‘Edge-of-centre’ is defined as a location that is well connected and up to 300 metres of the Primary Shopping Area.

2.5 For leisure uses, ‘in-centre’ is defined as being the defined Town Centre boundary

and this may therefore include the Primary Shopping Area as an inset. ‘Edge-of-centre’ is defined as a location that is well connected and up to 300 metres of the Town Centre Boundary.

2.6 An Impact Assessment is required for retail and leisure (and office) developments

which are not ‘in-centre’, are not in accordance with an up-to-date Local Plan and are over 2,500 sq.m floorspace to determine the impact of the proposal on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal; and the impact of the proposal on town centre vitality and viability. Where an application fails to satisfy the sequential test or is likely to have significant adverse impact on one or more of the above factors, it should be refused.

Regional Policy

2.7 Regional Policy is contained in the adopted South East Plan (May 2009). Whilst it is

the stated intention of the Coalition Government to revoke its provisions, it currently

remains in force as part of the statutory development plan. It is also important as

setting out the position and role of Gravesend Town Centre within the regional and

sub-regional hierarchy of centres. A conformity statement of the Proposed

Submission Local Plan Core Strategy with the South East Plan has been prepared

and the following policies are of relevance:-

TC1 – Strategic Network of Town Centres

Establishes the main network and hierarchy of town centres with Gravesend and

Dartford identified as a Secondary Regional Centres below Chatham and Maidstone

as Primary Regional Centres and Chatham also as a Centre for Significant Change.

Main town centre uses to be directed to these centres under the sequential

approach.

TC2 – New Development and Re-Development in Town Centres

Centres of Significant Change identified as Regional Hubs where major retail

developments and other town centre uses of a large scale of a large scale should be

located. After these centres, the most significant growth is expected in the Primary

Regional Centres and then the Secondary Regional Centres. As Local Planning

Authorities draw up their DPDs, they are advised to consider whether there is a need

to re-balance the network of centres so it is not dominated by the largest centres.

Consideration should also be given to stimulate investment in areas where there are

deficiencies in town centres, deprived areas or areas that will undergo significant


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housing and employment growth. A range of criteria that should be taken in

developing strategies is also provided.

TC3 – Out-of-Centre Regional/Sub-Regional Shopping Centres

States that no need has been identified for further out-of-centre regional or sub-

regional shopping centres or large scale extensions to such centres over the plan

period (to 2026) and that the role and regeneration of town centres should not be

undermined by the intensification of such development.

KTG5 – The Role of the Retail Centres

States that a network of retail and service centres will be developed across Kent

Thames Gateway in which:-

• Bluewater will continue to maintain a specialist regional role as an out-of-centre

regional shopping centre for comparison goods with any proposals for additional

floorspace to be considered through a review of the SE Plan. Any such

proposals to provide for improved access by non-car modes.

• Town centres of Dartford, Gravesend, Sittingbourne and, on a larger scale,

Chatham to be developed as the major town centres at which new mixed retail,

leisure and service uses will be concentrated.

• New ancillary retail and service space to be provided at Ebbsfleet at a scale and

character to serve the resident and daytime population.

• Local development documents to make provision for local and district facilities in

conjunction with the development of major new neighbourhoods.

Local Policy

2.8 Relevant local policy comprises ‘saved’ policies from the adopted Gravesham Local

Plan First Review (1994) and, because of the overlapping catchment of their town

centre and proposals for new centres at Ebbsfleet and Eastern Quarry, the recently

adopted Dartford LDF Core Strategy (2011). A synopsis of relevant policies is set

out below.

‘Saved’ policies from Gravesham Local Plan First Review (1994)

S0 – General Policy for Shopping

Council will not normally permit new retail development outside established centres,

unless such proposals can be justified as an exception when considered against

criteria set out in the supporting text.

Replaced by: S08 - Retail, Leisure and the Hierarchy of Centres

S1 – Location of New Shopping Development (1)

Council will actively support, enhance and expand the primary shopping role of

Gravesend Town Centre, within the hierarchy of Kent shopping centres. In the case

of retail warehousing, preference to be given to development of retail warehouse

park at the Imperial Business Estate.


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Replaced by: CS08 - Retail, Leisure and the Hierarchy of Centres

S2 – Location of New Shopping Development (2)

Council will not normally permit the change of use of buildings to shopping or the

provision of new shopping outside the areas indicated on the Proposals map as

‘Town Centre Shopping Area’ and ‘Local Centres’ unless they relate to specific

proposals set out in the Plan, minor extensions to existing shops, or minor proposals

for change of use which would be accordance with area policies. Extract from Town

Centre Inset Plan (1994) included on the following page showing Town Centre

Shopping Area and retail frontages.


S3 – Policy for Maintenance of Shopping Frontages

Relates to Primary Shopping Frontages and states that the Council will generally

resist changes of use to alternatives other than shopping at ground floor level or the

principal trading level.

Continue to save. Review as part of the Site Allocations and Development

Management Polices DPD

S4 – Policy for Non-shopping Uses in the Shopping Areas

Relates to Secondary Shopping Frontages and states that the Council will allow

changes of use to uses which are appropriate to the Town Centre Shopping Area

and require a shop window frontage (including Use Class A2) provided that the total

number of buildings in such use in each particular length of street is not excessive.


Management Polices DPD.

S5 – Policy for Upper Floors in Shopping Streets

States that proposals for change of use of upper floors in the Town Centre Shopping

Area will be considered on their merits and that these will normally be permitted

where these would result in better utilisation and maintenance of the building.

Replaced by: CS05 - Gravesend Town Centre Opportunity Area

S6 – Policy for Local Centres and Villages

Council will generally resist applications which result in loss of shopping units in local

centres and villages and will support minor increases in shopping floorspace.

Provided shopping role of local centre is not undermined, some non-office services

and offices serving the needs of the locality will be acceptable, particularly where

they serve the needs of the locality.


S7 – Hot Food Shops and Restaurants and Other A3 Uses


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Sets out criteria against which change of use of existing retail shops to Class A3

uses will be considered including clustering to avoid dead frontage; effect on amenity

of nearby residential accommodation; parking; and design of ventilation extraction.


Management Polices DPD


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Fig 1: Adopted

Gravesham Local Plan First Review (1994) Town Centre Inset Map showing Town Centre Shopping Area (policy S2) and retail

frontages (policies S3 and S4)


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Dartford LDF Core Strategy (2011)

CS2 – Dartford Town Centre

Supporting text at 2.18 sets out strategy objectives for Dartford Town Centre,

including strengthening its role as a shopping centre, consolidating its role as a

service centre, and broadening the other attractions of the town in terms of leisure,

culture and recreation. Policy itself states that the Council will work with landowners,

developers and Government Agencies to increase the range and improve the quality

of food, comparison shopping and leisure offer. Identifies Lowfield Street, Hythe

Street and Kent Road sites as suitable for mixed-use development incorporating

retail and leisure at ground floor level and encourages proposals for refurbishment,

extension or re-development of Priory and Orchards Shopping Centres.

CS4 – Ebbsfleet to Stone Priority Area

States Council will work with partners to physically integrate Bluewater Regional

Shopping Centre with existing and new residential communities surrounding it and

consider options for the evolution of the centre to provide a wider range of uses

where this can provide synergies with Ebbsfleet and does not adversely impact on

neighbouring town centres.

CS12 – Network of Shopping Centres

States that a network of complementary shopping centres will be developed

comprising:-

• Dartford Town Centre

• Bluewater

• Ebbsfleet/Eastern Quarry

• Longfield

To act as the main foci for shopping and leisure activity according to the roles

established for each in a supporting table. States that planning permission will be

granted for development that supports these respective roles, taking into account

criteria set out in the policy and with guidance provided on the appropriate amount of

retail floorspace at each of the centres. The functions accorded Dartford Town

Centre, Bluewater and Ebbsfleet/Eastern Quarry are as per the SE Plan. Longfield is

identified as a District Centre.


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Section 3 – Existing retail and commercial leisure

provision in Gravesham

3.1 The main retail focus of the area is Gravesend Town Centre. The main shopping

streets are New Road, King Street, Queen Street, Windmill Street and the High

Street. A covered charter market lies between High Street and Queen Street, trading

weekdays and Saturday. A small open market also operates to the north on Market

Square on Saturday whilst there are occasional farmer’s markets and seasonal

markets held in New Road/Windmill Street. There are two shopping centres

positioned to the north and south of New Road, these being the St George’s

Shopping Centre and the Thamesgate Shopping Centre. The main department

stores are also clustered in this area, along with a number of food and drink outlets.

3.2 Commercial leisure provision is very limited with the cinema and bingo hall that once

occupied town centre sites now closed. The Woodville Halls, a multi-purpose venue

built in the 1960s and forming part of the Civic Centre, lies immediately south of the

main shopping area on Windmill Street. New cinema projection facilities have

recently been installed. The Old Town Hall in Gravesend High Street, operated by

Kent County Council, is also available as a venue for smaller events.

3.3 Immediately west of the main Gravesend Town Centre, lying at a lower level in the

foot of a former chalk pit, is situated an Asda Superstore. Pedestrians may access

this by escalator and lifts from The Overcliffe on the edge of the Town Centre.

Vehicular access is from Thames Way to the north over which lies the Imperial Retail

Park, a 1980s retail warehouse development which includes a Bowling Alley.

3.4 Figure 2 shows the distribution of main uses within Gravesend Town Centre and

includes the site of the Asda Superstore and Imperial Retail Park. Aside from Asda,

there are two other superstores located out-of-centre in the Gravesham area. These

are a recently extended Sainsbury’s at Wingfield Bank, Northfleet and a Morrison’s at

Coldharbour Road, Northfleet.

3.6 Beneath Gravesend Town Centre within the retail hierarchy are a number of local

centres located in the urban and rural areas. These are shown on the adopted

Gravesham Local Plan First Review Proposals Map (1994). It is intended that the

local centres together with their boundaries will be reviewed when the Site

Allocations and Development Management Policies DPD is prepared in due course.

3.7 In addition to existing provision, there are a number of retail commitments within the

Gravesham area as a result of planning permissions granted or resolutions to permit.

These include allowances for retail floorspace within the Ebbsfleet development at

Springhead Quarter and Northfleet Rise Quarter, although the main retail component

is likely to be in the Dartford part of the development. This will be subject to Retail

Impact Assessment at the appropriate time. Allowances are also made for retail

floorspace to support local needs on some of the key regeneration sites – mainly at

Canal Basin and at Northfleet Embankment West, as an extension to The Hive local

centre. A limited amount of retail floorspace may also be needed to support mixed-

use development at Northfleet Embankment East.


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Fig 2: Plan showing distribution of main uses in Gravesend Town Centre together with location of Asda Superstore and

Imperial Retail Park.

Source: RTP Health Check Update of Gravesend Town Centre (December 2010)


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Section 4 – Identifying future needs to be met over plan

period 4.1 As stated above (at 2.2) the policy approach set out within the NPPF toward retail

and other main town centre uses is pro-growth and seeks to ensure that both this

and consumer choice is not constrained by a lack of suitable and available sites. The

purpose of identifying retail headroom over the plan period therefore is primarily to

ensure that the broad scale of retail (and other) need is understood and that this

informs the spatial strategy in terms of available site capacity. Any proposal for retail

floorspace that is not ‘in-centre’ would still be expected to meet the NPPF sequential

approach and impact test requirements at the time of application.

4.2 It should also be noted that whilst the Local Plan seeks to direct such development in

accordance with the NPPF sequential approach, delivery is a matter for the market.

The fact that sufficient sites may be available to meet identified needs in full does not

mean that the market will deliver all or any of them.

4.3 Conversely, because the planning system does not exist to constrain competition or

consumer choice, the levels of identified ‘need’ should not be seen as placing a

ceiling on the level of development that can be achieved provided the NPPF

sequential approach and impact test requirements are met.

4.4 To establish the broad quantitative scale of retail need over the plan period, the

Council has engaged consultants to undertake a series of assessments based on the

different development scenarios as work on the Local Plan has progressed. Links to

previous assessments are contained in the references section. The latest in this

series of assessments comprises the Gravesham Retail Study Update (March 2012).

This employs an industry standard approach that projects forward estimates of retail

spend per head of population, multiplies to take into account separate estimates of

population growth, and allocates the resulting spend to various centres or retail

outlets based on market share derived from survey data. An allowance for on-line

and other special forms of trading is also made. Dividing the resulting sum available

to each centre or retail outlet on the basis of the level of spending necessary to

support each additional square metre of retail floorspace in that location then

provides a broad estimate for the level of development that might be supported.

4.5 The estimates of quantitative retail need set out in table1 below are based on those

contained in the Gravesham Retail Study Update (2012) but are then further adjusted

to take into account a range of other permissions and commitments in the Dartford

and Medway areas that may also impact on the Gravesham catchment. These

estimates are based on the 100% population growth scenario with current market

shares as identified by the KCC household survey (2007). This approach is

considered robust as the 100% population growth scenario can reasonably be

considered the maximum identified level of need to be accommodated under the

spatial strategy. The KCC household survey also represents an appropriate datum

point for market share as it reflects ‘normal’ patterns of trade unaffected by the

current recession. Further detail on how the figures are derived and what has

been taken into account is set out in Appendix 1.


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Table 1: Estimate of quantitative retail need over Local Plan period

2028

Comparison goods – net sq.m 16,600

Comparison goods – gross sq.m 22,210

Convenience goods – net sq.m 1,620

Convenience goods – gross sq.m 2,180

Total – net sq.m 18,280

Total – gross sq.m 24,390

4.6 It should be noted that whilst the above section concentrates on quantitative

estimates of retail need, an additional qualitative justification for new retail floorspace

can also be made. The Council’s retail consultants have identified a qualitative need

for modern larger shop units (250 – 500 sq.m) to accommodate fashion multiples, to

broaden the offer of the Town Centre and to allow it to compete with rival centres

whilst combating the effects of retail polarisation. This is set within the context of a

proposed strategy whereby independent retailers are also supported as a means of

making the offer of Gravesend Town Centre more distinctive and the multi-functional

role of the Town Centre is also stressed, reflecting the recommendations of the

Portas Review2.

4.7 Identifying need for commercial leisure floorspace is more difficult in that there is no

standard approach in this area. With the closure of the cinema and bingo hall,

because of competition from outside the borough and changes to the commercial

leisure market, commercial leisure provision is now largely limited to the bowling alley

at Imperial Retail Park which lies to the west of the Town Centre. The Council’s

consultants have looked at this and suggest that there may be capacity for a small

multiplex or art cinema and a wider range of food and drink outlets. The recent

introduction of cinema projection facilities at the Woodville Halls allows the showing

of feature and other films. However, it should be noted that there is a considerable

quantum of D2 Use Class commercial leisure floorspace already committed in the

Dartford planning permissions for Ebbsfleet and Eastern Quarry (@40,000 sq.m

gross in total). This will have the potential to compete directly with new provision in

Gravesend Town Centre. The current lack of market interest in D2 Use Class

commercial leisure development in Gravesend Town Centre also makes it difficult to

be more positive in this area.

2 The Portas Review – An independent review into the future of our high streets (Dec 2011) available

at http://www.bis.gov.uk/assets/biscore/business-sectors/docs/p/11-1434-portas-review-future-of-high-streets.pdf


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Section 5 – The policy approach set out in the Local Plan

5.1 The wording of Policy CS08 on Retail, Leisure and the Hierarchy of Centres

contained in the proposed submission Core Strategy document (which should be

read in conjunction with the Town Centre Plan that follows3) says:-

Policy CS08: Retail, Leisure and the Hierarchy of Centres

The Council will seek to reinforce a sustainable network and hierarchy of centres by maintaining the sub-regional role of Gravesend Town Centre; protecting and enhancing existing local centres, as shown on the Policies Map, and creating additional local centres to meet local retail needs generated by new development on key sites. In support of this the Council will:

a) apply a sequential approach to the location of main town centre uses; b) require an impact assessment of larger retail and leisure development; c) support development of a scale and type appropriate to the position of the centres in the hierarchy and their character; d) safeguard the retail character and function of existing and new centres by resisting development that would adversely affect their vitality and viability, and protect lone village shops; and

e) encourage the provision of a mix of units including opportunities for small shops and independent traders in all centres. Gravesend Town Centre*

Gravesend Town Centre will be maintained as the highest order centre within the borough and retail, leisure, entertainment facilities and the more intensive sport and recreation uses will, unless otherwise allowed for under this policy, be directed as follows:

• The Primary Shopping Area as shown on the Policies Map will be the sequentially preferred location for new retail development followed by edge-of-centre sites and then out-of-centre sites.

• The area within the Town Centre (inclusive of the Primary Shopping Area) as shown on the Policies Map will be the sequentially preferred location for leisure, entertainment facilities and the more intensive sport and recreation uses, followed by edge-of-centre sites and then out-of-centre sites.

Proposals for retail development (around 7,340 sq m (NIA) retail floorspace (primarily A1 comparison floorspace) and up to 1,591 sq m food and drink floorspace (use classes A3, A4 and A5)), outside the primary shopping area will be supported at the Heritage Quarter key site where it can be demonstrated that the need cannot be met in the existing Primary Shopping area and there are good / clear pedestrian links to the existing primary shopping area to

3 In this document, the Town Centre Plan is figure 3 and this is the same as figure 17 in the Proposed

Submission Core Strategy


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facilitate circulation between New Road, the areas east and west of the High Street, and the riverfront.

Where a case has been made for large format retail/commercial leisure development and no suitable sites can be identified following the application of the sequential approach set out above, the Borough Council will support development in the West of Town Centre sub-area (3.2) as its preferred out-of-centre location for such development.

New and expansion of existing local centres

Proposals for new local centres and the expansion of existing centres listed will be supported where they are of a scale and form designed to meet local needs arising from associated planned new development.

• Springhead Quarter Key Site, Ebbsfleet • Northfleet Rise Quarter Key Site, Ebbsfleet • Old Northfleet Residential Extension Key Site (as extension to The Hive

Local Centre) • Northfleet Embankment East Regeneration Area Key Site

• Canal Basin Regeneration Area Key Site

Impact testing

Retail proposals outside the Primary Shopping Area, exceeding 2,500 sq.m floorspace, will be subject to an impact assessment in accordance with national policy.

Proposals for leisure, entertainment facilities and the more intensive sport and recreation uses outside the Town Centre, exceeding 2,500 sq.m floorspace, will be subject to an impact assessment in accordance with national policy.

* The Town Centre Plan (Figure 17 above) defines the Primary Shopping Area and the Town Centre boundary on the basis of the current uses and commercial activity. In applying this policy, the following definitions will apply:

• Edge-of-Centre: For retail purposes, a location that is well connected and up to 300 metres walking distance of the Primary Shopping Area and, for leisure, entertainment facilities and the more intensive sport and recreation uses, a location within 300 metres walking distance of the Town Centre boundary.

• Out-of-Centre: A location which is not in or on the edge of a centre but not outside the urban area.


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Fig 3: Town Centre Plan


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5.1 The policy approach set out above is intended to closely follow the NPPF by applying

a sequential approach to the location of new retail and commercial leisure

development and requiring impact testing of all new developments over 2,500 sq.m

floorspace that are not deemed to be ‘in centre’.

5.2 Smaller scale retail development is allowed for where it is commensurate with the

role of local centres in meeting day-to-day needs in a sustainable way. Other retail

development is allowed for where it is intended to create new or expand existing local

centres to serve Key Sites within the Opportunity Areas identified in the Local Plan.

5.3 In applying the sequential approach to new retail development, the Local Plan

identifies a Primary Shopping Area (PSA) within Gravesend Town Centre based on

the primary and those closely related secondary retail frontages where retail

development is concentrated.

5.4 This is more limited in some areas than the existing Gravesham Local Plan 1st

Review Policy S2 Shopping Area because it excludes the open air car parks at

Market Square, Horn Yard and Swan Yard where they are currently not in retail use

(see Figure 1 above). Conversely, some shopping areas that were formally excluded

or covered by area policies at Parrock Street, Manor Road and Windmill Street

(inside the one-way system, opposite Community Square) have now been included,

at least in part. In order to provide coherent boundaries, some non-retail uses have

also been included although this does not fundamentally affect the way in which the

sequential approach would operate.

5.5 Whilst a preliminary assessment was undertaken of the primary and secondary retail

frontages as part of the process of drafting the PSA area boundary, these will not be

formally revised until the Site Allocations and Development Management Policies

DPD is produced. This is because the issues involved relate more to detailed

development management issues and the balance of uses on various frontages

rather than the strategic issues dealt with through the Core Strategy.

5.6 A Town Centre boundary has also been defined in order to allow the application of

the sequential approach in relation to commercial leisure, entertainment facilities and

the more intensive sport and recreation uses, and arts, culture and tourism

development. This is drawn wider than the PSA to include those areas where other

main town centre uses are concentrated and it equates to sub-area 3.1 in the

Gravesend Town Centre Opportunity Area.

5.7 It should be noted that within the Gravesham Growth Scenarios and Core Strategy

(Oct 2011) and Gravesend Town Centre and Retail Policy Approach Update (July

2012) consultation documents this area was termed the Town Centre Commercial

Core (TCCC). In the Submission Version of the Local Plan the boundary of this area

has been amended to include the Gravesham Community Hospital on Bath Street as

a key community infrastructure use. The name of the policy area has also been

changed to ‘Town Centre’ to better reflect the terminology used in the NPPF.


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5.8 Fig 3 above identifies the areas covered by the PSA and the Town Centre. These

boundaries will also appear on the Policies Map.

5.9 The sequentially preferred location for new retail development will be the PSA,

followed by edge-of-centre sites then out-of-centre sites. Edge-of-centre is defined

as per the NPPF as being a location that is well connected and up to 300 metres

walking distance of the PSA. The term ‘walking distance’ is used here rather than a

direct line measurement of 300m as the policy is intended to evaluate sites on the

basis of accessibility.

5.10 The sequentially preferred location for new commercial leisure, entertainment

facilities and the more intensive sport and recreation uses will be the Town Centre

(inclusive of the PSA which forms part of it), followed by edge-of-centre sites then

out-of-centre sites. Edge-of-centre is defined in this instance as being a location that

is well connected and up to 300 metres walking distance of the Town Centre

boundary.

5.11 Following a consideration of available sites, it is unlikely that the scale and form of

retail development that might come forward over the plan period could be

accommodated within the PSA. Many of the main shopping streets lying to the east

of New Road also lie within conservation areas which constrain the form of

development that might be brought forward. As no market interest in redeveloping

more modern retail premises on New Road to create additional floorspace has been

identified this also implies that there is requirement to look toward edge-of-centre

sites to satisfy ‘need’ should the demand arise.

5.12 The Council has therefore identified the Heritage Quarter key site, to the east and

west of the High Street, as its preferred location for an appropriately designed high

quality mixed-use development that would replace existing open air car parking with

residential, retail, office, community, and hotel uses (see Fig 3 above) with decked

car parking.

5.13 Heritage Quarter West lies to the north of St George’s Shopping Centre and would

act as a logical extension to the PSA, accommodating larger retail units to meet the

needs of modern multiple fashion retailers as per the recommendations of the

Council’s retail consultant. Heritage Quarter East lies to the east of the High Street

and north of the Borough Market and could also accommodate a mix of retail uses

(including branded family restaurants etc) to improve the offer of the Town Centre.

5.14 The Council considers regeneration of the Heritage Quarter sites as being of crucial

importance in maintaining the position of Gravesend Town Centre within the sub-

regional hierarchy of centres and refreshing its offer in a way that is compatible with

its distinctive identity as a heritage riverside town. The development potential of a

number of the sites making up the Heritage Quarter had already been recognised

within the adopted Gravesham Local Plan First Review (1994). This was refined in

the Gravesham Local Plan Second Review Deposit Version (May 2000) that did not

proceed to adoption once work on the (then) Local Development Framework

commenced. The importance of Heritage Quarter as a key driver of regeneration

was also clearly recognised in the Gravesend Town Centre Strategy Review (2005).


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5.15 Whilst there are a number of other edge-of-centre locations that could accommodate

retail development, these would not bring the advantages of Heritage Quarter in

regenerating the area between New Road and King Street by reinstating important

parts of the town lost to slum clearance since the 1920s. Reintroducing high quality

mixed-use development into these areas will also serve to re-connect the town with

the River Thames and increase levels of activity in and around the historic High

Street, Queen Street and St Andrews Gardens close to where significant public

investment has recently been made in refurbishing the Grade II* Listed Town Pier

(oldest cast iron pleasure pier in the world) and the installation of a new passenger

pontoon facility.

5.16 However, even after making allowances for retail commitments elsewhere, Heritage

Quarter and the development of other available sites within the PSA would not be

sufficient to accommodate in full the identified retail need set out in Table 1 above.

Should demand for such development be forthcoming over the plan period, the

Council would then expect other edge-of-centre and then out-of-centre sites to come

into play employing the sequential approach and impact testing requirements set out

in policy CS08 of the Proposed Submission Core Strategy.

5.17 Such sites include the Lord Street/Parrock Street open air car park sites. The Council

considers that the Lord Street and Parrock Street sites (see sites 3 & 4 on Fig 3)

could be suitable to accommodate retail development as part of a wider mix of uses

(including offices, residential and public car parking) provided this is well integrated

with the PSA to the north and does not have a significant adverse impact on it. Lord

Street car park lies in the Town Centre and Parrock Street lies on the edge of centre,

in terms of the Council’s sequential approach. The remaining identified capacity for

retail development includes other sites with planning permission in opportunity areas

outside the town centre, where it is intended to create or expand existing local

centres.

5.18 The submission version of the Local Plan Core Strategy therefore seeks to be

compliant with the NPPF by ensuring as far as practicable that it would be able to

accommodate the full identified need for retail and other main town centre uses

covered by policy CS08 – should market interest emerge over the plan period.

5.19 Any requirement for convenience floorspace (other than to improve the qualitative

offer of the Town Centre or to meet needs in local centres/planned local centres) is

likely to be limited whilst the objective is to concentrate delivery of new comparison

floorspace in the PSA or on edge-of-centre sites at Gravesend Town Centre.

Heritage Quarter is identified as a priority for delivery of such floorspace, hence its

designation as a key site. The table below sets out guidelines for the distribution of

retail development over the Local Plan period by Opportunity Area. It should be

noted that these marginally exceed estimates of retail need set out in Table 1 above.

Further details on how these figures are derived are set out in Appendix 2.


19

Table 2: Guideline distribution of retail development to meet full quantitative need

over Local Plan period.

Convenience Goods

net.sq.m

Comparison Goods

Net sq.m

Gravesend Town Centre Opportunity

Area

- 15,900

Ebbsfleet Valley Opportunity Area 1,690 1,120

Northfleet Embankment and

Swanscombe Peninsula East

Opportunity Area

400 -

Gravesend Riverside East and North

East Gravesend Opportunity Area

300 -

Total 2,390 17,020

Combined Total 19,410

5.20 The phasing of delivery of new retail and commercial leisure floorspace will be dealt

with through the application of the sequential approach and impact testing as

required by the NPPF. Because the PSA boundary has been tightly drawn, retail

proposals that are ‘in-centre’ are likely to be relatively small scale. Proposals for new

retail and commercial leisure over 2,500 sq.m floorspace that are edge-of-centre or

out-of-centre would be subject to the sequential approach and impact testing and

would require robust justification before permission is granted.

5.21 This avoids the premature delivery of schemes that might otherwise have a

significant adverse impact contrary to national policy. It also overcomes the issue of

planning on the basis of accommodating full identified retail need over the plan

period, when that level of retail demand may not ultimately materialise. Schemes

that are not ‘in centre’ would still require justification at the point of delivery.

Section 6 – Comparing existing policy with proposed policy

6.1 It is useful to consider the practical application of existing ‘saved’ Local Plan retail

policy S2 with that proposed in new Local Plan policy CS08. The plan reproduced

below shows the policy S2 Town Centre Shopping Area together with the extent of

the proposed Primary Shopping Area under policy CS08. The Heritage Quarter (Key

Site) is also shown.


20

Fig 4: Gravesend Town Centre Shopping Areas Plan


21

6.2 It will be noted that the Town Centre Shopping Area (policy S2) has been amended

to reflect the definition of a Primary Shopping Area (PSA) as set out in the glossary to

the NPPF. Because the PSA is intended to represent a defined area where existing

retail development is concentrated within the town centre, the open air car parks to

the north of the Borough Market have been omitted. Conversely, a number of

shopping areas that were previously omitted from the Town Centre Shopping Area,

because they were covered by area policies or an employment policy that allowed

change of use to offices, have now been included within the PSA.

6.3 Existing ‘saved’ policy S2 directs new shopping development to the ‘Town Centre

Shopping Area’ and ‘Local Centres’ except where specific exceptions apply. This is

effectively the same approach as adopted within proposed policy CS08, where new

retail development is also directed in the first instance to the PSA.

6.4 The effect of policy as set out in the NPPF is that, where it is not possible to

accommodate new retail development within the existing ‘Town Centre Shopping

Area’ under ‘saved’ policy S2, the sequential approach would apply and ‘edge-of-

centre’ sites would be prioritised over ‘out-of-centre’ sites. ‘Edge-of-centre’ sites

would be defined under the NPPF as those lying within 300 metres distance of the

boundary of the ‘Town Centre Shopping Area’.

6.5 The result of this is that basically the same available sites would fall within the ‘edge-

of-centre’ zone irrespective of whether ‘saved’ policy S2 or proposed policy CS08

were to be deployed. The exception to this is the area of open air car parking to the

north of the Borough Market which is currently part of the ‘Town Centre Shopping

Area’ but would now be considered ‘edge-of-centre’. This is because it is not part of

the defined area where retail development is concentrated and therefore not part of

the PSA.

6.6 The main difference between existing retail policy and that set out in proposed policy

CS08 is the identification of Heritage Quarter as a key site suitable for mixed-use

regeneration including a retail component.

6.7 In the case of Heritage Quarter East, this effectively represents a continuation of

‘saved’ policy PM1 which states that the Council will promote the site for a mixed-use

development including offices, residential, shopping and public car parking. NPPF

impact testing requirements as set out in proposed policy CS08 would apply.

6.8 In the case of Heritage Quarter West, it will be noted that part of the Key Site

designation includes land that is currently within the policy S2 ‘ Town Centre

Shopping Area’, public highway, ‘white land’ not subject to policy designation, the

West Street Car Park site, and the former Ferry Motors (Blockbuster) site.

6.9 The policy relating to the West Street Car Park (‘saved’ policy PM2) simply says that

the Council will consider proposals for the site in the context of its prominent location

and adjacent re-developments and, if alternative car parking can be made available

elsewhere, may promote the site as a major landscaped public space. The principle

of redevelopment is therefore accepted, with no specific indication of end use. A

retail component is therefore not precluded, whilst the creation of a major landscape


22

public space is only an option – albeit the Council would expect any development to

include high quality public realm and open space as part of the urban design solution.

6.10 The policy relating to the former Ferry Motors site (‘saved’ policy PM13) states that

the Council will encourage the early development of the site for office purposes but

will require design of buildings to be of high standard, commensurate with the

townscape importance of the site.

6.11 The above policy position toward this area was modified within the Gravesham Local

Plan Second Review Deposit Version (May 2000). Whilst this did not proceed to

adoption, it is indicative of the travel of direction of policy at the time. Policy TC7

covers the West Street Car Park, Blockbuster, Church Hall and Rectory sites.

Subject to the site becoming surplus to car parking, it promotes the use of the site for

a well-designed mixed-use development including residential and employment uses

and replacement community facilities.

6.12 The case for treating Heritage Quarter as a priority for regeneration and designating

it a Key Site is set out at 5.12 – 5.15 above. In so doing, the Local Plan is

establishing the principle of development in this ‘edge-of-centre’ location and is not

prescriptive in terms of final design. Although any urban design solution should be

appropriate to context, it does not favour any particular approach as the acceptability

or otherwise of a submitted scheme is a matter to be determined at the detailed

application stage. However, designating Heritage Quarter as a Key Site involves an

acceptance that an appropriate design solution can be developed and that a suitable

mixed-use scheme incorporating retail is achievable.


23

Appendix A: Derivation of adjusted retail headroom figures set out

in Table 1.

A.1 This section sets out how the Council has arrived at the retail headroom figures set

out within the Proposed Submission Gravesham Local Plan Core Strategy. The

original retail headroom figures are derived from the Gravesham Retail Study Update

(July 2012) document. These were based on population projections commissioned

from Kent County Council to support the Gravesham Growth Scenarios and Core

Strategy Consultation (Oct 2011) which looked at a range of options for housing

growth through to 2031. These assumed a housing target of 5,200 dwellings to

2031, equivalent to 4,600 dwellings by 2028 – the total now being put forward in the

Proposed Submission Gravesham Local Plan Core Strategy.

A.2 As the population projections assumed a constant rate of delivery of housing over the

plan period, it is possible to adjust the original figures on a pro-rata basis to provide

retail headroom figures for 2028. The figures below also assume 100% delivery over

the period as being representative of full retail need as required by paragraph 23 of

the National Planning Policy Framework (NPPF).

A.3 Although the Gravesham Retail Study Update (July 2012) document includes

sensitivity testing on the basis of both 75% and 50% housing delivery and population

growth, such scenarios would represent a shortfall against the spatial strategy and

cannot be considered to represent full retail need. It would therefore be

inappropriate to plan on that basis as it would be to assume either a failure of the

spatial strategy or a different spatial strategy based on lower growth scenarios. The

table below therefore sets out the original retail headroom figures for convenience

and comparison floorspace based on the 100% growth scenario amended to show

an end date of 2028, based on a 4,600 dwelling housing target.

Table A1: Retail headroom from Gravesham Retail Study Update (July 2012)

with extrapolated figures for 2028

Summary of quantitative retail need 2016 2021 2026 2028

Comparison goods4 – net sqm 4,400 12,600 18,100 20,540

Comparison goods – gross sqm 5,900 16,800 24,200 27,400

Convenience goods5 – net sqm -600 500 1,300 1,620

Convenience goods – gross sqm -700 700 1,700 2,180

Total – net sqm - 13,100 19,400 22,160

4 Comparison retailing is the provision of items not obtained on a frequent basis. These include

clothing, footwear, household and recreational goods. 5 Convenience retailing is the provision of everyday essential items, including food, drinks,

newspapers/magazines and confectionary.


24

Total – gross sq.m - 17,500 25,900 29,580

A.4 Taking into account retail commitments that affect headroom

A.5 The Gravesend Town Centre and Retail Policy: Assessment of Consultation

Responses Paper (July 2012) set out in Section 4 how existing retail commitments

both in Gravesham and the Borough of Dartford had been taken into consideration in

adjusting the above retail headroom figures. This paper is available on line and may

be consulted at

http://www.gravesham.gov.uk/__data/assets/pdf_file/0010/78733/Retail_PolicyAppro

achUpdateJuly2012.pdf#Town%20Centre%20Retail%20Policy

A.6 In considering the issue, it was evident that existing convenience retail commitments

greatly outweigh identified headroom as a result of the creation of planned new

centres – particularly at Ebbsfleet and Eastern Quarry in Dartford but also to a lesser

degree in Gravesham. On this basis, it was decided to leave the convenience figures

unadjusted because quantitative need was effectively being met in full by existing

commitments – albeit this would not prevent new floorspace being justified elsewhere

on a qualitative basis.

A.7 The issue of comparison floorspace was considered to be more critical as it was

necessary to determine the potential impact of new development on the ability of

Gravesend Town Centre to refresh its offer without adversely impacting on planned

development coming forward elsewhere.

A.8 The basis of the figures used in the calculations in determining the impact of

commitments in Dartford was the Dartford Retail and Commercial Leisure Study

(2010) which formed the evidence base in relation to the recently adopted Dartford

Local Development Framework Core Strategy (2011).

A.9 The Council has therefore attempted to ensure that its own Core Strategy is

compatible with that of neighbouring Dartford Borough Council by using their

evidence base to inform its own approach. The full content of the Dartford study may

be consulted on line under document reference EB37 at

http://www.dartford.gov.uk/by-category/environment-and-

planning2/planning/planning-policy/evidence-base

A.10 Because the Dartford Retail and Commercial Leisure Study (2010) only covers the

period of the Dartford Core Strategy to 2026, it was not possible to go beyond this

date in making adjustments to Gravesham’s own figures. However, this approach is

considered to be robust because the Dartford study fully takes into account planned

expansion of retail at Dartford Town Centre; the limited expansion of Bluewater

Regional Shopping Centre based on maintaining market share within the immediate

catchment; and the phased delivery of new centres at Ebbsfleet/Eastern Quarry.

A.11 The estimated impact of the trade diversion from new centres at Ebbsfleet/Eastern

Quarry in Dartford was set out at 4.22 of the Gravesend Town Centre and Retail


25

Policy: Assessment of Consultation Responses Paper (July 2012) and this is

reproduced in table form below.

Table A2: Impact of new centres at Ebbsfleet/Eastern Quarry (taking into account

other commitments in Dartford) on comparison floorspace in Gravesham.

A.12 Issues raised as a result of consultation on the Gravesend Town Centre Retail

Policy: Assessment of Consultation Responses Paper (July 2012) in relation to

retail headroom.

A.13 Dartford Borough Council has queried whether consideration has been given to the

effect of new comparison floorspace at ASDA, Greenhithe (DA/08/00343/FUL) which

has been implemented, or the 5,000 sq. m. net comparison floorspace provided for at

Bluewater in the Core Strategy.

A.14 Gravesham has responded to Dartford Borough Council on both of these issues and

has sought its agreement under the Duty to Co-Operate. In terms of Bluewater, this

is fully taken into account by using the outputs from the Dartford Retail and

Commercial Leisure Study (2010) to inform the above calculations.

A.15 The Asda, Greenhithe development was permitted and implemented post 2007 and

would not therefore have been identified as a comparison retail destination within the

KCC household survey. However, it is noted that the additional comparison

floorspace permitted under DA/08/00343/FUL was only 1,830 sq.m gross and was

justified within the report to DBC Development Control Board (2nd October 2008)

because it would only function ancillary to the main convenience role of the store and

Year Comparison

retail need

for year

derived from

Gravesham

retail update

(2012)

Trade diverted

from Gravesend

Town centre as a

result of new

centres in

Ebbsfleet/Eastern

Quarry

Sales

density

comparison

floorspace –

High Street

format from

Gravesham

retail

update.

Reduction in

comparison

retail

floorspace

in needed to

avoid

adverse

impact on

new centres

at Ebbsfleet

& Eastern

Quarry

Comparison

retail need

fully

avoiding

adverse

impact on

new centres

at Ebbsfleet

& Eastern

Quarry

Net. sqm

(A)

£ million

(B)

£/Net sqm

(C)

Net. sqm

(D)

Net. sqm

(A – D)

2016 4,333 1.9 4,947 384 3,949

2021 12,590 6.94 5,395 1,286 11,304

2026 18,142 8.73 5,884 1,484 16,658


26

would not perform as a comparison destination in its own right. It was contended by

the applicant (and accepted by DBC) that this would not have an adverse impact on

Dartford Town Centre. No consideration was given to impact on Gravesend Town

Centre so it is assumed that the trade draw of the Asda development has a minimal

impact.

A.16 The Dartford Retail and Commercial Leisure Study (2010) does not appear to take

this additional comparison floorspace into account either. The household survey

upon which it relies (Nems Market Research – Dartford Tesco Shopping Survey. July

2007) predates the Asda, Greenhithe planning application whilst comparison

Scenario 2 does not list it as a commitment. It should also be noted that the retail

policies in the adopted Dartford LDF Core Strategy (2011) rely on significant ‘claw

back’ from this out-of-centre store to support the creation of new convenience retail

floorspace in Dartford Town Centre (-29.6% in 2016 and – 50.2% in 2026 as set out

in Table 22, Appendix 6B under Convenience Scenario 3). As the comparison

floorspace at Asda is ancilliary to the convenience, it would be reasonable to assume

that this trade would also be ‘clawed back’. The ability of retail outlets in Gravesend

Town Centre to also ‘claw back’ trade from this out-of-centre store (or any other in

the Gravesham catchment) should not therefore be precluded under NPPF

principles.

A.17 A number of responses also raised the issue of the need to take into account retail

commitments in the Medway Council area. Once again, the primary concern in

relation to the Proposed Submission Gravesham Local Plan Core Strategy is

comparison expenditure and whether the two retail strategies are compatible.

A.18 In making its evaluation on this aspect, the Council has relied on published evidence

contained in the Medway Retail Study (2009) and an examination of the impact of

major commitments. The Medway Retail Study can be viewed on line as reference

ED68 at:-

http://www.medway.gov.uk/environmentandplanning/developmentplan/localdevelopm

entframework/ldfevidencebase.aspx

A.19 Appendix C, Table 9c of the study shows on the basis of baseline population growth

and constant market shares that there is sufficient comparison headroom to balance

with commitments in Strood between 2016 and 2021. Further, Appendix C, Table 9c

also shows that for the Medway catchment as a whole there is £100.52m surplus

comparison expenditure after commitments in 2016. As the Gravesham retail

strategy is also only based on maintaining market share, it is unlikely therefore that

delivery of comparison retail floorspace in Gravesham post 2016 would have a

significant adverse impact on centres in Medway given available headroom.

A.20 However, it should be noted that the Medway Retail Study does not take into account

comparison retail permissions granted post 2008. The main concern in terms of

impact on the Gravesham catchment is expansion of comparison retail at Strood. It

should be noted that the original permission for the Sainsbury’s, St Anthony’s Way,

Strood site was for a larger comparison retail development than that included in the

superstore itself. This combined with other commitments exceeds the other Strood


27

comparison retail commitments that have come forward since. This is shown in the

table below.

Table A3 – Comparison of comparison retail commitments taken into account in Medway Retail Study with post 2008 changes

Comparison Retail Commitments at Strood taken into account in Medway Retail Study. (Appendix A, Table 3A)

Net sqm

Main Outstanding Comparison Commitments at Strood subsequent to the Medway Retail Study / post 2008.

Net sqm

Netto, High Street, Strood (completed after 2008 survey)

137 Netto, High Street, Strood 137

Wilkinson’s, High Street, Strood

1,132 Wilkinson’s, High Street, Strood 1,132

Matalan, Strood Retail Park (completed after 2008 survey)

2,680 Matalan, Strood Retail Park (MC/06/2275 with other units below – 5,167 sq.m gross)

2,680

Other Units, Strood Retail Park

1,346 Other Units, Strood Retail Park 1,346

Aldi, Priory Park, Strood 225 Aldi, Priory Park, Strood 225 Non-Food Unit, Priory Park 309 Non-Food Unit, Priory Park 309 Non-Food Warehouse, St Anthony’s Way, Strood (originally permitted as B & Q unit under MC/03/1301 but later allowed to convert to 10 wider comparison units MC/07/0238 + 239 and MC/09/0671 apply)

12,265 Sainsbury’s, St Anthony’s Way, Strood (MC/10/2125)

2,584

Tesco’s, Cuxton Road, Strood (MC/10/3579) [increase over existing comparison]

1,781

Total 18,094 10,194 A.21 It is noted that in addition to the above, a new Asda store has been permitted as part

of the Chatham Waters scheme (MC/11/2756) and that this should also be taken into

account as another commitment. Whilst this is most likely to compete with adjoining

superstores within the immediate catchment, it does have the potential to further

consume available comparison retail headroom so it is still relevant.

A.22 Based on the conditions set out in the report to Medway Council Planning Committee

held on the 31/10/2011, it is understood that the comparison component only

amounts to 1,666 sq.m net (40% of 4,165 sq.m net total). This would still give a

combined comparison retail floorspace figure well below that originally taken into

consideration for the Strood area under the Medway Retail Study.

A.23 However, it is important to recognise that different comparison outlets trade in

different ways and therefore it is necessary to take into account not just floorspace

but estimates of turnover in assessing retail impact. This is difficult because turnover

figures for schemes permitted post 2008 are derived from different retail


28

assessments using different price and design years. The table below sets this aside

to give a broad indication of sales volume to compare against available headroom.

Table A4 – Comparison of turnover of Medway commitments

Comparison Retail Commitments at Strood taken into account in Medway Retail Study. (Appendix A, Table 3A)

Turnover

£m

Main Outstanding Comparison Commitments at Strood subsequent to the Medway Retail Study.

Turnover

£m Netto, High Street, Strood (completed after 2008 survey)

£1.46 Netto, High Street, Strood

£1.46

Wilkinson’s, High Street, Strood

£3.96 Wilkinson’s, High Street, Strood

£3.96

Matalan, Strood Retail Park (completed after 2008 survey)

£5.97 Matalan, Strood Retail Park (MC/06/2275 with other units below – 5,167 sq.m gross)

£5.97

Other Units, Strood Retail Park

£3.70 Other Units, Strood Retail Park

£3.70

Aldi, Priory Park, Strood £0.95 Aldi, Priory Park, Strood £0.95 Non-Food Unit, Priory Park £1.55 Non-Food Unit, Priory

Park £1.55

Non-Food Warehouse, St Anthony’s Way, Strood (originally permitted as B & Q unit under MC/03/1301 but later allowed to convert to 10 wider comparison units MC/07/0238 + 239 and MC/09/0671 apply)

£33.73 Sainsbury’s, St Anthony’s Way, Strood (MC/10/2125)

£18.85

Tesco’s, Cuxton Road, Strood (MC/10/3579) [increase over existing comparison]

£14.68

Asda, Chatham Waters, Rochester (MC/11/2765) [2016 design year; 2009 price base]

£12.46

Total £51.32m £63.32m A.24 It will be noted that even with an increased notional turnover of say £12m per annum

from the smaller comparison floorspace commitment, there is still adequate surplus

expenditure (£100.52m) across the Medway catchment at 2016 to support this level

of development.

A.25 It is also noted that the Chatham Waters Retail Study (2011) suggests that the level

of comparison retail headroom at 2016 within the immediate catchment could be

even higher. This study was based on a fresh household survey undertaken in

August 2011 using a different form of questions from the Medway Retail Study –

most significant of these was that people were asked where they normally shop

rather than the last place they shopped.


29

A.26 The study was accepted as sufficiently robust in terms of convenience outputs by

Medway Council (see report to Planning Committee on MC/11/2765 dated

31/10/2011) so it is assumed that the same holds true for comparison outputs. This

found that even after taking into account commitments (including Sainsbury’s and

Tesco’s in Strood) and Special Forms of Trading that there would be something in

the region of £249.89m surplus comparison expenditure in 2016 (2009 price base) to

support additional development.

A.27 This appears to confirm that there is sufficient retail headroom within the Medway

catchment to support comparison retail commitments based on maintaining existing

market shares and that these commitments would not prejudice Gravesham bringing

forward its own schemes based on Gravesend Town Centre also maintaining its own

market share.

A.28 As the Medway CS includes a policy intent (at para. 6.46) to increase retail market

share, it is also important that we understand the implications of this for Gravesham

should it be achieved. This is difficult to do using the Medway Retail Study because

the appendices do not tabulate the impact on locations outside Medway, rather the

implications of increased market share on the ability to support increased levels of

retail floorspace in Medway itself under the baseline and high population growth

scenarios.

A.29 It is necessary therefore to extrapolate on the basis that an increased market share

for Medway will result in a proportionate decrease for all competing centres. Around

94% of the Gravesham spend derives from Medway Zone 8, with smaller proportions

of spending coming from Zones 1, 2, 3 and 5. The extent of Zone 8 is shown on the

plan below, with a plan of the Gravesham retail zones provided for comparison.

Fig A1: Medway Retail Zones


30

Fig A2: Gravesham Retail Zones A.30 Appendix C, Table 7c of the Medway Retail Study sets out market share based on

the 2008 household survey under baseline population growth in 2026.

Table A5: Baseline market share from Medway Retail Study

Zone 1 Zone 2 Zone 3 Zone 5 Zone 8 Total Spend

Expenditure 2026

£184.40 million

£322.93 million

£289.75 million

£319.91 million

£1,183.61 million

-

Medway Market Share

62% 69% 82% 72% 16% -

Other Areas Market Share

38% 31% 18% 28% 84% -

Gravesham Market Share (as part of Other Areas)

7% 1% 1% 1% 30% -

Gravesham Turnover £m

£12.91m £3.23m £2.90m £3.20m £355.08m £377.32m

:


31

A.31 Appendix C, Table 12c of the Medway Retail Study provides improved market shares

for Medway in 2026 and these are extrapolated below to estimate the impact on

Gravesham turnover under the baseline scenario. This should be seen as a worst

case scenario, as any growth rate above baseline would result in increased

population growth and retail spend leading to a recovery in levels of turnover.

Table A6: Improved market share for Medway from Medway Retail Study

A.32 Evaluated on the basis of the Medway Retail Study’s assumption of an average 3.7%

increase in comparison spending over the plan period, a 5.5% reduction in turnover

would be made up in about two years and hence would not have a significant

adverse impact on overall trade levels in Gravesham. A similar conclusion would be

reached using the more conservative comparison growth rates used in the

Gravesham Retail Study Update (3.6% per annum 2011 -16/ 3.0% per annum 2021 –

26).

A.33 In the context of the above, it should be noted that the Medway and Gravesham retail

studies are comparable in terms of projected overall levels of trade (despite the

methodological differences and use of 2006 and 2007 price year bases) assigned to

Gravesham in 2026.

A.34 The Medway Retail Study (with household survey undertaken in 2008 during the

recession) estimates the comparison goods turnover of Gravesham (effectively

Gravesend Town Centre in household survey) under a constant market share with

baseline population growth in 2026 to be £377.32m (Medway Retail Study Appendix

C, Table 7c).

A.35 The Gravesham Retail Study Update (with household survey undertaken in 2007

prior to the recession) estimates the comparison goods turnover of Gravesend under

Zone 1 Zone 2 Zone 3 Zone 5 Zone 8 Total Spend Expenditure 2026

£184.40 million

£322.93 million

£289.75 million

£319.91 million

£1,183.61 million

-

Medway Market Share

70% 75% 85% 75% 20% -

Other Areas Market Share

30% 25% 15% 25% 80% -

Pro-rata Reduced Gravesham Market Share (as part of Other Areas)

5.5% 0.8% 0.8% 0.9% 28.6% -

Reduced Gravesham Turnover £m

£10.14m

£2.58m £2.30m £2.88m £338.5m £356.40m

Reduction £m/%

£20.92/5.5%


32

constant market share with 100% population growth to be £375.4m (Gravesham

Retail Study Update. Appendix 1, Table 5b).

A.36 The conclusion reached therefore is that the approaches adopted in the Medway

submission Core Strategy and the Proposed Submission Gravesham Local Plan

Core Strategy are consistent and compatible.

A.37 However, to ensure that comparison retail headroom projection for Gravesham is

robust should Medway increase its market share in line with Table 6 above, it would

be prudent to use the 2026 figure – i.e. to take into account a potential impact

equivalent to two year’s growth as set out in paragraph A.32 above.

A.38 In addition to the above, comments on the Gravesend Town Centre Retail Policy:

Assessment of Consultation Responses Paper (July 2012) raised the issue of

potential completion from the new Westfield Shopping Centre (Stratford) and the

planned expansion of Lakeside Regional Shopping Centre (Thurrock).

A.39 The expansion of Lakeside was dealt with initially through a single issue review of the

East of England Plan concluding in January 2010. This resulted in new policy ETG2

allowing for up to 50,000 sqm net of new comparison floorspace at the Regional

Shopping Centre by 2019. This provision has now also been incorporated into the

Thurrock Core Strategy and Policies for the Management of Development DPD (Dec

2011) under policy CSTP7 .

A.40 The evidence base that accompanied the single issue review of the East of England

Plan included a retail impact assessment undertaken by the consultants GVA

Grimley in March 2009. This is available on-line at

http://webarchive.nationalarchives.gov.uk/20100528142817/http://www.eera.gov.uk/What-we-do/developing-regional-strategies/east-of-england-plan/planning-for-lakeside-basin-single-issue-review-/study-documents/

A.41 The GVA study considered the combined impact of Westfield and an expanded

Lakeside Regional Shopping Centre (50,000 sqm net additional comparison

floorspace) on a number of centres within the East and South East of England,

including Dartford and Gravesend Town Centres and the Bluewater Regional

Shopping Centre. Whilst the zones considered do not extend as far east as

Gravesham, Zone 13 covers the Borough of Dartford and extensive areas to the

south and west. The conclusion reached was that there would be a -4.0% impact on

Bluewater; a -0.4% impact on Dartford Town Centre; and no impact on Gravesend

Town Centre (see GVA study above – Appendix 11, Table 17).

A.42 The impact of an extension to the Lakeside Shopping Centre has been considered

again through the current planning application for a major extension, including an

additional 37,651 sqm Gross Internal Area (GIA)/30,121 sq.m net sales area

comparison floorspace. Details of the application can be found on-line at the

Thurrock Council website planning application pages under 11/50433/TTGOUT.

A.42 Although it is once again based on a catchment that only includes the Dartford Zone

13, the Retail Impact Assessment submitted with the above application suggests that


33

the effect on Gravesend Town Centre would have no significant impact on

comparison trade. At 2021, the reduction in trade going to Gravesend Town Centre

from the Dartford Zone 13 would only be £30,000 (from £21.90m to £21.87m). It

should be noted that Appendix 4, Table 14 of the Retail Impact Assessment suggests

that the overall reduction of comparison trade of Dartford Town Centre would be -

0.1% and Bluewater – 0.08% in 2021 as a result of the proposed extension at

Lakeside. On this basis, it is reasonable to assume that the impact can be set aside

for Local Plan purposes.

A.43 For the sake of completeness, the following plan shows the catchment of the

Westfield Shopping Centre at Stratford as set out on the operator’s website. This

clearly indicates that Gravesham and its catchment lies outside the main catchment

of this facility. This would appear to confirm the conclusion of the GVA study that any

impact of the new centre on Gravesend Town Centre would be marginal.

Fig: A3: Westfield Shopping Centre catchment plan from operators website (Link: http://uk.westfield.com/stratfordcityleasing/leasing/location catchment/)

A.44 It is noted that more recently proposals have emerged for the expansion of the

Bluewater Regional Shopping Centre in Dartford Borough beyond those floorspace

limits set in the adopted Dartford LDF Core Strategy (2011). In the absence of a

formal planning application and retail impact assessment it is not possible to take this

into account in this analysis. However, it is noted that Policy CS12 of the adopted

Dartford Core Strategy include impact on neighbouring town centres and regional

considerations (undefined) as being material in the determination of any application.

Employing NPPF principles it would be expected therefore that any permission

granted in respect of Bluewater should not have a significant adverse impact on

Gravesend Town Centre.


34

A.44 Conclusion A45 On the basis of the above analysis it is concluded that for Local Plan purposes it is

reasonable to plan on the basis of retail headroom figures that take into account

commitments in the Dartford Borough Council area as per section 4 of the

Gravesend Town Centre and Retail Policy: Assessment of Consultation Responses

Paper (July 2012). A review of commitments in the Medway Council area suggests

that the comparison retail headroom figure should be held to the 2026 figure to take

into account their strategic position – this results in a comparison floorspace figure of

16,600 net sqm (22,210 gross sqm) as per table 2 above.. As the Westfield,

Stratford and Lakeside, Thurrock developments are only likely to have a marginal

impact, it is possible to set these aside for planning purposes. Any emerging

proposals for the Bluewater Regional Shopping Centre in Dartford should not

adversely impact on the Gravesham spatial strategy in terms of the retail component

and at this stage should also be set aside.

A46 The broad estimates of retail headroom set out in Proposed Submission Gravesham

Local Plan Core Strategy at Table 5 are therefore considered a sufficiently robust

estimate of full retail need. These figures are reproduced below, with further

discussion on how this need might be met if market demand emerges is included in

Appendix B.

Table 7 – Summary of quantitative retail need

2028

Comparison goods6 – net sqm 16,660

Comparison goods – gross sqm 22,210

Convenience goods7 – net sqm 1,620

Convenience goods – gross sqm 2,180

Total – net sqm 18,280

Total – gross sq.m 24,390

Above table forms Table 5 in Proposed Submission Gravesham Local Plan Core Strategy.

6 Comparison retailing is the provision of items not obtained on a frequent basis. These include

clothing, footwear, household and recreational goods. 7 Convenience retailing is the provision of everyday essential items, including food, drinks,

newspapers/magazines and confectionary.


35

Appendix B: Derivation of guideline figures used for distribution of

retail development in Table 2.

B.1 In order to demonstrate the ability to accommodate full need for retail development is

not compromised by limited site availability (NPPF, paragraph 23), the Council has

produced the following tables to show what in theory is capable of being delivered on

a site-by-site basis. It should be noted that these tables are not intended to be

prescriptive and assumptions made are clearly set out.

B.2 The retail headroom figures set out in Table 1 inform the figures used in the

Proposed Submission Gravesham Local Plan Core Strategy at Table 5 – Summary

of Quantitative Retail Need. These are used here as a notional target for new retail

floorspace over the plan period that take into account commitments elsewhere in

Dartford and Medway.

B.3 It should be noted that the purpose of producing these figures in the context of the

Local Plan differs from that at the planning application stage. In terms of the Local

Plan, the aim is to define the broad level of demand for new retail floorspace that

may need to be accommodated and to demonstrate that this has been taken into

account in developing the spatial strategy. In the case of a planning application,

there is no requirement to demonstrate need rather compliance with the NPPF

sequential approach and (where necessary) the impact test. At that stage, existence

of demonstrable need may be a factor in evaluating no significant adverse impact on

existing centres or planned investment etc.

B.4 The retail headroom figures should also be used with caution because they are only

intended to show the amount of new retail floorspace that could be accommodated in

both the convenience and comparison goods categories based on predictions of

available spend directed to each location or centre. The projections used in this

Local Plan assume that Gravesend Town Centre retains a constant market share

based on the 2007 KCC household survey. This is not an unreasonable assumption

as there is an expectation that it will maintain its position as a Secondary Town

Centre within the regional hierarchy of centres. This also aligns with the sub-regional

approach as set out in South East Plan policy KTG5.

B.5 However, there are other ways in which projected increased spend available to a

centre could also be absorbed in part over the Plan period. This includes the coming

back into use of vacant properties that have become empty during the recession –

although it is always likely that there will be some vacant premises due to turnover of

businesses and the end of leases. For this reason, an allowance has been made in

the calculations for re-occupation of some vacant floorspace. A separate table is

also provided indicating the extent of current levels of vacancy.

B.6 In addition, it is possible that higher sales densities than used to calculate retail

floorspace projections could be achieved. However, the effect of this is likely to be

marginal as even a 10% increase in comparison sales density at 2026 would only

result in a reduction of around 1,650 net sqm on the figure set out in Appendix A.


36

B.7 It is noted that a qualitative case could be made for additional convenience

floorspace in the Town Centre to improve and diversify its retail offer. As this may

take up some of the identified space in the table assumed to be available for

comparison retail, it is appropriate that the Council set out how this would be

handled.

B.8 Any additional capacity to develop larger scale convenience retail within the Primary

Shopping Area is limited by the availability of suitable sites and edge-of-centre

proposals exceeding 2,500 sq.m would be subject to impact testing under proposed

policy CS08 using the NPPF approach.

B.9 The effect of any proposal for new convenience goods floorspace displacing potential

for comparison goods floorspace is therefore likely to only impact in policy terms

towards the end of the plan period and could be dealt with by subsequent reviews of

those sections of the Local Plan, having regard to the level of market demand at that

time.

B.10 The following sites (Table B2) have been identified as potential locations where the

scale and type of retail development identified in the Proposed Submission

Gravesham Local Plan Core Strategy could be met over the plan period. It should be

noted that no allowance has been made for ‘out of centre’ development that is

justified in line with the NPPF policy tests as the presumption remains that

development should be directed to the most central locations in the first instance.

B.11 These figures have been used to inform Table 6 in the Proposed Submission

Gravesham Local Plan Core Strategy. This table is reproduced below as Table B1.

Table B1– Guideline distribution of retail development to meet full quantitative need

over Local Plan period

Convenience

Goods net sq.m

Comparison

Goods net sq.m

Gravesend Town Centre

Opportunity Area

- 15,900

Ebbsfleet Valley Opportunity Area 1,690 1,120

Northfleet Embankment and

Swanscombe Peninsula East

Opportunity Area

400 -

Gravesend Riverside East and

North East Gravesend Opportunity

Area

300 -

Total 2,390 17,020

Combined Total 19,410


37

Table B2: Detailed breakdown informing guideline distribution of retail development

to meet full quantitative need over Local Plan period

Gravesend Town Centre Opportunity Area Potential Retail Floorspace

sq.m net

Site Description Convenience Comparison

Heritage Quarter GR/08/0696 was refused planning permission due

largely to scale, form and massing of proposed

development in the Western Quarter. Schedule 1 +

2 to the original application show a maximum gain in

net tradable A1 retail floorspace of 7,340 sq.m and

this is used here as broadly indicative of possible

capacity of a new scheme. Eastern Quarter includes

a separate provision for 1,591 sq.m GIA area of A2 –

5 floorspace but this is ignored for the purposes of

this exercise as any scheme is likely to be mixed

whether this floorspace is included in either western

or eastern quarter.

- 7,340

Transport Quarter GR/11/0246 details pursuant of interchange building

includes 205 sq.m A1 retail. Include full figure as

possible small comparison unit.

- 205

Gala Bingo, New Road GR/10/0773 includes 554 sq.m A1/A2/A3 retail in

small units. Assume around one third comparison

retail.

- 190

Former Police Station,

Windmill Street

GR/08/0095 allows for mixed-use development of

site with 923 sq.m commercial floorspace

(A1/A2/B1/D1) on the ground floor. Assume figure is

net as based on plan + that @ 25% is A1

comparison retail.

- 230

Former ABC Cinema,

King Street

GR/08/305 was refused planning permission due to

height and massing of the residential component (7

storeys) at the rear. However, the ground floor plan

does give an indication of maximum capacity ‘at

grade’ with 815sq.m shown for retail/community

space and four kiosks on Brewhouse Yard with a

combined floorspace of 102 sq.m. This gives a

combined floorspace of around 900 sq.m gross

used here as indicative of what might be

accommodated, although this could be reduced if

final design solution is of an arcade type, providing

better connections and through route between King

Street, Brewhouse Yard and Queen Street. Figure

converted to net at 75% to provide more robust

estimate.

- 675

M Block, Bath Street Potential for limited amount of retail on edge-of-

centre site to create part of active frontage on Clifton

Road linking Town Centre with Wickes Site and

Imperial Retail Park beyond.

Say 260

Lord Street/Parrock

Street

In combination, the Lord Street/Parrock Street sites

represent a major opportunity for mixed-use

regeneration in the town centre over the plan period

- 5,000


38

containing a mix of retail, office, residential and car

parking uses. Whilst the Heritage Quarter is a

logical choice for an extension to the Primary

Shopping Area should the case be made and no

more central sites are shown to be available, Lord

Street/Parrock Street is also edge-of-centre and

would be the next sequentially preferable large

regeneration site following Heritage Quarter over the

plan period.

Allowance for vacant

units in and around town

centre

Whilst there will always be a number of vacant units

within the town centre due to turnover of premises,

an objective of the strategy is not just to focus on

larger ‘multiples’ but to also support the development

of independent retailers. An allowance for smaller

units coming back into use is therefore made.

- 2,000

Sub-Total - 15,900

Ebbsfleet Valley Opportunity Area

Springhead Quarter GR/96/0035 allows for 1,000 sq.m gross (in

total) A1 floorspace. This equals 750 sq.m

net (based on ratio of 75%). Assume 60%

convenience/40% comparison.

450 300

Northfleet Rise Quarter GR/96/0035 allows for 2,750 sq.m gross (in

total) A1 floorspace. This equals 2,060 sq.m

net (based on ratio of 75%). Assume 60%

convenience/40% comparison.

1,240 820

Sub-Total 1,690 1,120

Northfleet Embankment and Swanscombe Peninsula East Opportunity Area

Lafarge Mixed-Use

Development (Hive

Extension)

GR/09/0238 (resolution to permit) includes up

to 850 sq.m (Gross Internal Area)

retail/café/takeway. Assume 640 sq.m net

(based on ratio of 75%) with 60% A1

convenience retail + remainder

café/takeaway.

400 -

Sub-Total 400 -

Gravesend Riverside East and North East Gravesend Opportunity Area

Canal Basin GR/11/0713 (resolution to permit major

mixed-use scheme) includes up to 3,800 sq.m

gross A1 -5, B1a, D1 and D2. Assume equal

split at 400 gross sq.m each, with A1

convenience unit converted to net at 75% of

gross as a conservative estimate.

300 -

Sub-Total 300 -

Total 2390 17,020

Combined 19,410


39

Table B3 - Vacant Retail Units in Gravesend Town Centre as defined in Proposed

Submission Gravesham Local Plan Core Strategy policy CS08 as at 1 October 2012

The purpose of the table below is to provide a broad understanding of the level of vacant

retail floorspace within the Gravesend Town Centre policy area. It has not been derived

through detailed survey and, unless otherwise stated, net floor area is assumed to be 75% of

footprint of building as measured off OS Plan. Buildings being fitted out for re-use at time of

survey have not been counted.

Site Description Approx Floor

Area sq.m net

2 Brewhouse Yard Small shop unit 35



12 – 14 High Street 3 small shop units formed as part of redevelopment under

GR/01/564. Shells not fitted out but assume shop units 10m

deep and net floor area to be 75% of gross.

200

(3 units)

15 High Street Small shop unit on corner of Bank Street. Floor area taken

from GR/2006/0626 as 640 sq ft/60 sq.m

60

31 High Street Small shop unit 75


49/50 High Street Shop shop unit 120



8 King Street Small shop unit, being western ground floor of PH. Unable to

measure floor area from OS – estimate only

30

12 King Street Small shop unit to eastern side of former cinema entrance -

Unable to measure floor area from OS – estimate only

20

22b King Street Small shop unit - Unable to measure floor area from OS –

estimate only

30

4 Manor Road Small shop unit 30


10 Manor Road Small double fronted shop unit previously used as Thai

restaurant

65

15 Manor Road Small shop previous used as gallery 25


18 Manor Road (part) Small shop unit 15

11 New Road Former hairdresser 50


40

Site Description Approx Floor

Area sq.m net

72 – 73 New Road Former JJB Sports (First floor above Tesco – assume similar

scale). As at first floor level with no display, would lend itself

to alternative town centre type use.

@1,000

74 New Road Former Early Learning Centre 250

Unit 2 St George’s

Centre, New Road

Small shop unit. 70


Centre, New Road

Small shop unit. 100


Centre, New Road

Small shop unit – sales area from www.commercialroute.com 81


Centre, New Road

Small shop unit – similar size to unit 6 81

Unit 16 – 17 St

George’s Centre, New

Road

Larger shop unit – was Loose Linens. Sales area from

www.commercialroute.com

239

Unit 19 – 20 St


Road

Larger shop unit. Sales area from www.commercialroute.com 207

Unit 26 – 27 (?) St


Road

Larger shop unit – was used temporarily as library. Net

tradable area taken from GR/2008/0055 (60% of gross 468

sq.m)

283


Centre, New Road

Shop unit – sub-divided from previous larger unit occupied by

Dixons. Sales area from www.commercialroute.com

212

Unit 1 Thamesgate

Centre, New Road

Small shop unit 115

57 Overcliffe Small shop unit 35

59 Overcliffe Small shop unit 50

1 Queen Street Small shop unit 20

2 Queen Street Small shop unit – last used by Salvation Army 70

9 Queen Street Small shop unit 30

19 – 21 Queen Street Two old shop units (c18th/19th) in derelict condition with yard

to rear. No 21 last used as greengrocer with open frontage.

120

(two units)

34 Queen Street Small shop unit – floor area taken from GR/2006/0721 38

16A Stone Street Small shop unit 37

169 Windmill Street

Total Approx 4,083


41

Appendix C: Consideration of Responses to the Gravesham Retail

Study Update and Gravesend Town Centre and Retail Policy

Approach Update Consultation

C.1 Introduction

C.2 The Gravesham Retail Study Update (March 2012) and Gravesend Town Centre and

Retail Policy Approach Update (July 2012) were issued for the purposes of public

consultation for a six week period between 26th July and 6th September 2012. This

section sets out the key issues raised as a result of this consultation and the

Council’s response.

C.3 The Council received 6 responses to the consultation from:

• Urban Gravesham

• Theatres Trust

• Kent Police

• Paul Hancock (Local Resident, Northfleet)

• Roger Steer (Local Resident, Gravesend)

• Dartford Borough Council (Received After Deadline)

C.4 Issues raised

C.5 The main issues raised concern:

• The validity of the evidence base and whether the KCC household survey is sufficiently up-to-date (2007) and robust to provide an accurate picture of future retail needs;

• Whether the impact of retail commitments elsewhere in Dartford, Medway and elsewhere have been fully taken into account in estimating retail headroom;

• The effects of the recession and whether future projections of retail spending based on the full growth assumptions should be used or a lesser figure;

• Whether we should be seeking to maintain Gravesend’s market share of comparison retail spending;

• Where is the best location to accommodate future retail growth, its scale and form;

• The need to have a more rounded vision and strategy for the town centre that is not so retail focused and sensitive to location;

• The need to be more ambitious in terms of commercial leisure and cultural facilities; and

• The need to better articulate the ability of the town centre to become a future office location as identified within the Economy and Employment Space Study and to allocate sites/set a floorspace target.

C.6 These issues are dealt with below following a reprise of national planning policy and

the requirements of the National Planning Policy Framework (NPPF) in this area.


42

C.7 National planning policy and the requirements of the NPPF.

C.8 National planning policy includes a presumption in favour of sustainable development

and explicitly supports sustainable economic growth. The planning system is not

intended to constrain competition but stands to direct town centre type uses to the

most central locations whilst avoiding significant adverse impacts on existing and

planned centres.

C.9 The NPPF states (at paragraph 18)

The Government is committed to ensuring that the planning system does

everything it can to support sustainable economic growth. Planning should

operate to encourage and not act as an impediment to sustainable growth.

Therefore significant weight should be placed on the need to support

economic growth through the planning system.

C.10 To ensure that competition is not constrained, the NPPF requires that Local Plans

identify sufficient sites to accommodate the full range and scale of main town centre

uses over the plan period.

C.11 The NPPF states (at paragraph 23) 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. The local planning authority is directed to

recognise the town centre as the heart of its community and pursue policies to

support its viability and vitality. A competitive town centre should be promoted that

provides customer choice and a diverse retail offer, reflecting the town centre’s

individuality, with existing markets retained and enhanced where appropriate.

C.12 A range of suitable sites should be allocated to meet the scale and type of retail,

leisure, commercial, office, tourism, cultural, community and residential development

needed in the town centre, with the needs for town centre type uses being met in full

and not compromised by limited site availability.

C.13 Where it is not possible to allocate sufficient sites within the town centre to meet

these needs, appropriate edge-of-centre sites well connected to the town centre

should be identified. Where this cannot be done, policies should be set for meeting

identified needs in other accessible locations that are well connected to the town

centre.

C.14 Where town centres are in decline, local planning authorities are directed to plan

positively for their future to encourage economic activity.

C.15 The Borough Council does not consider Gravesend Town Centre to be in an

inevitable state of decline and believes it to perform an important role as a Secondary

Regional Centre - as per the recent South East Plan designation. It is of the opinion

therefore that we should plan to meet identified needs for town centre type uses in

full where practicable to do so.

C.16 This does not mean that all identified sites will be taken up by the market (or others)

over the plan period, rather that we should plan to ensure that sustainable options for

growth are not artificially curtailed by the lack of availability of suitable sites.


43

C.17 Unless otherwise stated, the policies set out in the emerging Local Plan are therefore

intended to direct development to the most central town centre sites in the first

instance in accordance with national policy. It is for those proposing development in

edge-of-centre or out-of-centre locations to demonstrate that they are compliant with

Local Plan policy on the application of the sequential approach and that there are no

significant adverse impacts.

C.18 The Borough Council would also argue that it is for those promoting an alternative

spatial strategy to demonstrate that this is compliant with the NPPF and that the

needs for town centre type uses are also being met in full. Where these needs are

not being met within the town centre or in the most central locations, the reasons why

should be fully explained and the potential for significant adverse impacts properly

assessed.

Appraisal of Issues Raised

C.19 The validity of the evidence base and whether the KCC household survey is

sufficiently up-to-date (2007) and robust to provide an accurate picture of

future retail needs

C.20 A number of respondents raise the issue of whether a household survey undertaken

in 2007 is sufficiently up to date and robust to provide a sufficiently accurate picture

of retail needs over the plan period. The impact of the recession is cited as a factor

to take into account and the fact that schemes have been permitted since 2007 that

may have affected the pattern of retail trade.

C.21 In particular, a number of respondents cite a comment made by the Borough

Council’s expert retail consultant at 4.26 of the Gravesham Retail Study Update

(March 2012):-

As highlighted in earlier sections, the key shopping patterns in this study are

based on Kent CC household survey data collected in 2007 and these data

are therefore almost five years old. When reviewing local policy documents

and retail needs for the Borough, we recommend that the Council invest in

fresh survey of shopping patterns in the Borough and surrounding area within

five years. This survey should use the latest questioning techniques in order

to mitigate any bias towards larger centres and foodstores.

C.22 It will be noted that the above does not state that the 2007 survey is unfit for purpose

and that a new study should be commissioned now – rather that when it comes to

reviewing local policy documents in the future, a new survey should be undertaken

that will be able to take into account changes that might have occurred at that stage.

C.23 The KCC household survey used as part of the retail study was undertaken in

April/May 2007. The purpose of the survey was to establish the broad pattern of

retail trade draw throughout Kent and neighbouring parts of London and Surrey to

update work previously undertaken in 1998 and 2000. Whilst the national economy

entered a double-dip recession in late 2008, there is no evidence to suggest that this

will have significantly altered the broad pattern of trade (as opposed to short term

volume of trade) within the Gravesend Town Centre catchment.


44

C.24 However, there are very good reasons why it would not be appropriate to undertake

a new household survey now:-

• The Local Plan is intended to provide a long-term basis for the planning of the area through to 2028. We are currently emerging from a double-dip recession and this may have the effect of changing patterns of trade between centres so the results may not reflect ‘normal’ conditions. The effect of the recession may be to reduce personal expenditure on transport and higher value goods, making local ‘value’ centres such as Gravesend appear more attractive as retail destinations; and

• A number of the permitted schemes outside Gravesham have yet to be built and a new household survey undertaken now would not detect any effect on the pattern of trade of the various centres anyway – these include a new Sainsbury’s out-of-centre superstore at St Anthony’s Way, Strood; the rebuilding and extension of the Tesco superstore in Strood; the building of a new Tesco superstore in Dartford Town Centre; and the expansion of the Lakeside Regional Shopping Centre at Thurrock.

C.25 The potential impact of retail commitments is considered further below. However, it

is notable that the Medway Council Retail Needs Study (March 2009) confirms the

relative strength of Gravesend Town Centre as a comparison goods destination.

C.26 Whilst this was undertaken on a different basis to the Kent survey and is based on

different retail zones, the survey was carried out during the worst part of the

recession in November 2008 so it is useful in understanding relative performance

under such conditions. The following tables show the strength of Gravesend Town

Centre as a comparison retail destination for a range of different goods within its

immediate catchment (Medway Retail Zone 8).

Fig C1: Plan of Non-Food Shopping Destinations in Medway Outer Retail Zones


45

Table C1: Medway Retail Study Household Survey Results for key comparison goods in

Medway Zone 8: Gravesham (light green in Fig C1 above)

Question 5: In which location do you buy

most of your household’s non-food

shopping?

Question 7: At what location did your

household last buy shoes and clothes?

Gravesend Town Centre 30.8% Bluewater 30.4%

Bluewater 28.1% Gravesend Town Centre 26.5%

Maidstone Town Centre 5.8% Maidstone Town Centre 7.3%

Dartford Town Centre 5.4% Dartford Town Centre 6.5%

Chatham City Centre 3.1% Chatham Town Centre 4.2%

Internet/delivered 1.9% Internet/delivered 3.8%

Question 8: At which location did your

household last buy domestic electrical

appliances?


household last buy other kinds of electric

goods such as TV/Hi-Fi and computers?

Gravesend Town Centre 20.8% Gravesend Town Centre 16.2%

Bluewater 10.0% Bluewater 15.4%

South Aylesford Retail Park 5.4% Dartford Town Centre 4.2%

Maidstone Town Centre 4.2% Chatham City Centre 3.5%

Dartford Town Centre 3.8% South Aylesford Retail Park 3.5%

Internet/delivered 14.6% Horstead Retail Park 3.5%

Internet/delivered 16.2%


household last buy furniture, soft

furnishings and floor coverings?

Question 11: At which location did you

buy your last DIY/hardware items?


Bluewater 12.3% B & Q Strood 11.2%

Dartford Town Centre 6.5% B & Q Gravesend 10.8%

Lakeside 4.6% Dartford Town Centre 8.8%

Chatham City Centre 3.1% B & Q Gillingham 3.8%



46


household last buy garden items?


household last buy chemist, health and

beauty items?


B & Q Gravesend 7.7% Bluewater 13.8%

B & Q Strood 7.7% Dartford Town Centre 3.5%

Dartford Town Centre 5.4% Chatham Town Centre 3.5%


At which location did your household

last buy other non-food items such as

books, CD’s, toys and gifts?

Bluewater 23.5%

Gravesend Town Centre 18.5%

Chatham City Centre 5.8%

Maidstone Town Centre 5.0%

Dartford Town Centre 1.9%

Internet/delivered 15.8%

Source: Medway Council Retail Needs Study 2009. Appendices, Medway Household Survey for

Nathaniel Lichfield and Partners by NEMS Market Research (carried out November 2008).

C.27 It is clear from the above that Gravesend Town Centre remains the main centre

within Medway Retail Zone 8 (Gravesham) for a variety of comparison goods and

only comes marginally second to Bluewater on shoes and clothes, books, CDs, toys

and gifts. This confirms it is still performing an important role as a Secondary

Regional Centre (as per the South East Plan designation) and reinforces the

Borough Council’s contention that it should plan on the basis of accommodating the

full requirement for town centre type uses so as not to stifle economic growth.

C.28 It is also interesting to note that the Medway & Gravesham retail studies suggest

similar levels of projected comparison retail spend for Gravesend Town Centre at

2026.

C.29 The Medway Retail Study (with household survey undertaken in 2008 during the

recession) estimates the comparison goods turnover of Gravesham (effectively

Gravesend Town Centre in household survey) under a constant market share with

baseline population growth in 2026 to be £377.32m (Medway Retail Study Appendix

C, Table 7c).


47

C.30 The Gravesham Retail Study Update (with household survey undertaken in 2007

prior to the recession) estimates the comparison goods turnover of Gravesend under

constant market share with 100% population growth to be £375.4m (Gravesham

Retail Study Update. Appendix 1, Table 5b).

C.31 Whether the impact of retail commitments elsewhere in Dartford, Medway and

elsewhere have been fully taken into account in estimating retail headroom

C.32 Developments in Gravesham

C.33 Sainsbury’s, Wingfield Bank, Northfleet – Extension to out-of-centre superstore

permitted under planning application reference GR/2010/0898 allows for expansion

to 6,968 sq.m net floorspace, with comparison floorspace not to exceed 2,090 sq.m

net. This represents an increase in comparison floorspace of 1,559 sq.m net.

Planning permission was taken into account as an existing ‘hard’ commitment within

Gravesham Retail Study Update (March 2012) in calculating retail headroom.

Sequential approach and impact test reviewed within RTP Sainsbury’s, Pepperhill,

Northfleet: PPS4 audit of revised store extension proposals (Nov 2010).

C.34 Morrison’s, Coldharbour Road, Northfleet – Extension permitted under application

reference GR/2007/0648 to increase sales area by 773 sq.m. Not more than 15% of

additional floorspace to be used for sale of goods other than food, tobacco and other

convenience goods. Scheme therefore only increased comparison floorspace by 116

sq.m. so effect would be marginal.

C.35 Asda, Gravesend – Extension permitted under GR/2003/0293 and GR/2003/0297

allow for a maximum of 2,244 sq.m net comparison/durable floorspace. Works were

completed prior to the household survey in 2007 so any trading effect would have

been taken into account via the household survey.

C.36 Developments in Dartford

C.37 Issues in relation to developments in Dartford are fully dealt with in the Gravesend

Town Centre and Retail Policy: Assessment of Consultation Responses Paper (July

2012) in Appendix A, paragraphs A12 – A16. This text is not reproduced here.

C.38 Developments in Medway

C.39 Issues in relation to developments in Medway are fully dealt with in Appendix A,

paragraphs A17 – A37. This text is not reproduced here.

C.40 Developments elsewhere – Westfield, Stratford; Lakeside, Thurrock; and

Bluewater, Dartford

C.41 Issues in relation to these locations are fully dealt with in Appendix A, paragraphs

A38 – 44. This text is not reproduced here.


48

C.42 The effects of the recession and whether future projections of retail spending

based on the full growth assumptions should be used or a lesser figure.

C.43 The NPPF (at paragraph 23) requires that any need for town centre type uses should

be met in full and not be compromised by limited site availability. The Council would

argue that to establish retail needs ‘in full’ is to plan on the basis of the remainder of

the spatial strategy also being achieved in full as the component parts are

complementary.

C.44 This means working on the basis of the Gravesham housing target being met (4,600

dwellings) over the Plan period, resulting in population projections and potential

increases in retail spend also coming forward in parallel.

C.45 This approach seems reasonable given the 4,600 dwelling target (2011- 2028) is not

significantly different from the historic build rate figure of 4700 dwellings (2011 –

2031) set out in the Gravesham Growth Scenarios and Core Strategy Consultation

(Oct 2011) document.

C.46 Rates of housing development within neighbouring Dartford Borough are taken from

the recently examined and adopted Dartford LDF Core Strategy (2011) following

discussions with their Planning Department. This approach is therefore also

considered to be robust.

C.47 In any event, it should be recognised that the purpose of identifying retail headroom

within the Local Plan at this stage is not to justify individual schemes – it is to ensure

that sufficient sites are identified so it is clear on independent examination that the

market is not constrained by lack of development opportunity and consumer choice

thereby impaired.

C.48 In this sense, much of the debate over short-term reductions in retail spending or the

effects of e-commerce etc. are largely academic – it is recognised that retail

projections are likely to change over the Plan period and that we are only basing our

assessment on a snap-shot in time. The projections are therefore considered

sufficiently robust for these purposes.

C.49 It is not considered to be a significant issue if the Local Plan is based on a marginal

over-estimate of retail need. All this results in is a need to demonstrate the market

has a greater choice of sites to develop than may eventually be needed. Justification

for development of those sites which are not ‘in-centre’ would still have to be made at

the application stage, following the NPPF sequential approach and impact testing

where required.

C.50 Whether we should be seeking to maintain Gravesend’s market share of

comparison retail spending

C.51 Paragraphs C.26 – C.30 and Table C1 above show that Gravesend Town Centre

continues to function as an important Secondary Regional Centre even in a time of

recession. The Gravesham Retail Update (2012) also makes clear the opinion of the

Council’s expert retail consultant that it is important to update and diversify the offer


49

of the Town Centre (including its retail component) to maintain its position and to

avoid long-term decline.

C.52 The Council’s position is therefore that the Local Plan strategy should be founded on

seeking to maintain Gravesend’s market share of comparison retail spending and not

to discourage investment in new schemes where acceptable urban design solutions

are achievable.

C.53 However, the Council would contend that where it is suggested an alternative

strategy be adopted, with the capacity for retail development being more constrained,

the implications should be fully set out by those opposing the Local Plan position.

C.54 Firstly, the reasons for this alternative approach need to be properly justified given

that diverting otherwise acceptable retail investment away from a central location

such as Gravesend Town Centre would be contrary to the policy principles set out in

the NPPF.

C.55 Secondly, those promoting an alternative vision for Gravesend Town Centre that

effectively diverts retail investment elsewhere should clearly set out how the

requirements of paragraph 23 of the NPPF would be met. This would include where

retail investment would be directed as an alternative to the Town Centre in order to

meet needs in full and the impact of this alternative strategy on the Town Centre.

C.56 Where is the best location to accommodate future retail growth, its scale and

form.

C.57 Policy CS08 set out in the Proposed Submission Gravesham Local Plan Core

Strategy closely follows the NPPF by prioritising the Primary Shopping Area (PSA) as

the preferred location for new major retail development, followed by edge-of-centre

and then out-of-centre sites. Policy CS08 also allows for new retail development of

an appropriate scale in local centres and in conjunction with Key Sites to support

residential and other development.

C.58 However, the Council also recognises that the scale of new comparison retail

floorspace required to meet needs in full and the form and scale it may have to take

to meet market demand for modern premises implies that it is unlikely to be feasible

to accommodate this in the PSA. For this reason, the Heritage Quarter has been

identified as its sequentially preferred edge-of-centre location for such development.

In this context, Heritage Quarter West is considered the preferred location for larger

modern retail units where it can be better integrated with the St George’s Centre and

the concentration of existing larger retail premises in and around New Road. No

objection is raised to A1 retail uses as part of the mix of uses in Heritage Quarter

East given this is also another edge-of-centre site. However, it is less well located in

terms of connectivity with the concentration of existing modern retail stores on and

around New Road.

C.59 The few responses to consultation received appear to indicate that there is some

agreement that new comparison retail should not be directed to the Imperial Retail

Park to the west of the Town Centre unless it requires a warehouse format and no


50

PSA/Town Centre location is available. This is because such development would

effectively pull the Town Centre further to the west away from its traditional core.

C.60 Similarly, there appears to be a degree of agreement that A1 retail should not be

directed towards the Lord Street/Parrock Street sites in advance other sites in and

around the PSA/Town Centre because this could have the potential to draw the Town

Centre further to the south away from its traditional core. The Council agrees with

this and it is one of the reasons why it has prioritised Heritage Quarter as an edge-of-

centre site.

C.61 The fundamental difference between those responding to the consultation and the

Council revolves around Heritage Quarter and in particularly the development of the

Heritage Quarter West sites.

C.62 For example, Urban Gravesham argues that priority should be given to the former

Majestic Cinema site (King Street), sites around Queen Street, and Horn Yard to

accommodate new A1 retail. However, it is extremely unclear what urban design

solution is being proposed; the implications of this in terms of site capacity; how the

sites would be serviced; and how public car parking issues would be handled. It is

also unclear whether there is any interest from the site owners in this form of

development or whether the alternative strategy is deliverable.

C.63 If the sites promoted by Urban Gravesham are incapable of accommodating full

identified retail need over the Plan period, the question raised at C.55 above arises –

where would any unmet need by satisfied and how would this impact on the Town

Centre? In the view of the Council, the suggestions being put forward by Urban

Gravesham represent an incomplete alternative spatial strategy.

C.64 The need to have a more rounded vision and strategy for the Town Centre that is not

so retail focused and sensitive to location.

C.65 The Council does not agree that its strategy for the Town Centre is only about retail,

although it must be recognised that retail does and will continue to be a major land-

use within this area. Retail, in all its various forms, is one of the reasons for the very

existence of Gravesend Town Centre and an essential part of its character.

C.66 This does not mean that the Council does not recognise the multi-functional nature of

Gravesend Town Centre and the different roles it plays – including a place to live,

work, visit and participate in a range of cultural and other activities. The need to

develop this multi-functional role is clearly articulated in the Gravesham Retail

Update (March 2012) document and this has been incorporated into policy as far as

is practicable. The reader is therefore directed to Proposed Submission Gravesham

Local Plan Core Strategy policy CS05 on the Gravesend Town Centre Opportunity

Area and the reasoned justification that precedes it.

C.67 The need to be more ambitious in terms of commercial leisure and cultural

facilities.

C.68 This aspect is considered in detail at paragraph 4.7 of the background paper where it

is stated that Identifying need for commercial leisure floorspace is more difficult in


51

that there is no standard approach in this area. With the closure of the cinema and

bingo hall, commercial leisure provision is now largely limited to the bowling alley at

Imperial Retail Park which lies to the west of the Town Centre.

C.69 The Council’s consultants have looked at this and suggest that there may be capacity

for a small multiplex or art cinema and a wider range of food and drink outlets. The

recent introduction of cinema projection facilities at the Woodville Halls allows the

showing of feature and other films.

C.70 However, it should be noted that there is a considerable quantum of D2 Use Class

commercial leisure floorspace already committed in the Dartford planning

permissions for Ebbsfleet and Eastern Quarry (@40,000 sq.m gross in total). This

will have the potential to compete directly with new provision in Gravesend Town

Centre. The current lack of market interest in D2 Use Class commercial leisure

development in Gravesend Town Centre also makes it difficult to be more positive in

this area.

C.71 Whilst the Council commissioned a museum feasibility study, the absence of any

definitive plans for such a facility or evidence as to its deliverability make it difficult to

me positive within the Local Plan Core Strategy.

C.72 It should be noted however that the area of commercial leisure and cultural provision

could be revisited under the Site Allocations and Development Management Policies

DPD should any projects be brought forward in advance of its preparation.

C.73 The need to better articulate the ability of the town centre to become a future

office location as identified within the Economy and Employment Space Study

and to allocate sites/set a floorspace target

C.74 This aspect does not relate to retail and commercial leisure provision but is

addressed through Proposed Submission Gravesham Local Plan Core Strategy

policy CS07 on Economy, Employment and Skills and Opportunity Area policies

CS03 – 06. The Economy and Employment Background Paper (2012) also applies.

References - Links to main evidence base documents

Document Link

Gravesham Retail Study Update (March

2012)

http://www.gravesham.gov.uk/__data/asset

s/pdf_file/0009/78732/Retail_Study_Update

_March_2012.pdf

Gravesend Town Centre and Retail Policy

Approach Update (July 2012)

http://www.gravesham.gov.uk/__data/asset

s/pdf_file/0010/78733/Retail_PolicyApproac

hUpdateJuly2012.pdf

Retail and Commercial Leisure Study (Dec

2009)

http://docs.gravesham.gov.uk/WebDocs/En

vironment%20and%20Planning/LDF/Retail_

Leisure_Study1.pdf


52

Retail and Commercial Leisure Study

Addendum (July 2010)



Leisure_Study2.pdf

Health Check Update of Gravesend Town

Centre (May 2011)



Leisure_Study3.pdf

Town Centre Health Indicators – Gravesend

(2009)


vironment%20and%20Planning/LDF/Town_

Centre_Health_Indicators_2009.pdf

Gravesend Wider Town Centre Baseline

Report (Oct 2011)


vironment%20and%20Planning/LDF/Wider_

Town_Centre_Baseline_Report_October_2

011.pdf

retail and commercial leisure background paper (december 2012) · retail and commercial leisure...

Documents