Proposed Submission Core Strategy

The Strategy for Bexhill Town Centre is to:

(iii) 'Provide for some 2,500 sqm additional convenience goods and 4,000 sqm comparison goods floorspace, primarily through 'edge of centre' retail expansion on the north side of the railway, as well as effective use of town centre accommodation.'

Paragraph 8.38

Supporting text of Policy BX2 sets out that "north side of the railway" will include the area from Sea Road through to Terminus Road, including the southern end of Beeching Road.

Comments:

Policy EC3 of PPS4 states local planning authorities should set out a strategy for the management and growth of centres over the plan period by (a) setting flexible policies for their centres which are able to respond to changing economic circumstances and encourage, where appropriate, high-density development accessible by public transport, walking and cycling.

We consider that policies in the Core Strategy should be flexible and feasible to meet the short, medium and long term demand.

There is currently no scheme coming forward to develop the identified land at north side of the railway for retail development. The certainty and timescale of delivery for this edge of centre site remains unknown and this site is unlikely to be available in the short or medium term. In order to be consistent with the objectives of national policy PPS4, Policy BX2 should allow retail provision to meet the short and medium term demand, subject to the sequential assessment as set out in PPS4 Policy EC15.

In addition, local planning authorities should also consider setting floorspace thresholds for the scale of edge of centre and out of centre developments which should be subject to an impact assessment under (EC16.1 of PPS4) and specify the geographic areas these thresholds will apply to as set out in EC3d of PPS4.

Supporting text of Policy BX2 states 'if a viable proposal within the town centre were not possible, then alternative locations would be considered in accordance with Policy EMP7 (retail sequential test). This would include Ravenside Retail Park, particularly for the sale of bulky goods, and also subject to sufficient and sustainable transport capacity.'

Comments:

Ravenside Retail Park is the most popular out of centre shopping destination in the District. It is an established shopping location with good accessibility. It clearly represents the best location for accommodating new retail floorspace apart from the town centres. Land Securities supports the identification of Ravenside Retail Park as an alternative location for retail development subject to PPS4 sequential site assessment. Ravenside would strengthen the commercial role of Bexhill and limit further leakage of expenditure to neighbouring centres.

Paragraph 16.38 states that the "district-wide Shopping Assessment undertaken in 2008 identified some potential growth in Bexhill, Battle and Rye. In each case, a scale of growth is identified that would retain the town centres' roles and 'clawback' some trade lost to Hastings and Eastbourne and other centres over recent years."

Paragraph 16.39 states that the forecast growth in spending has been reviewed downwards particularly discretionary spending on comparison goods, this approach is still regarded as valid for longer time horizon retail planning forecasts.

However, the qualitative need for additional retail floorspace has been reinstated in paragraph 16.40 it states "given the overall level of retail provision in the town centre centres has remain unchanged since 2008, hence the quantitative needs are still supported in terms of qualitative needs."

Comments:

Despite the economic recession, the latest retail forecast shows that there is still a steady expenditure growth on both comparison and convenience expenditure in the short to medium term. Experian's latest forecast (Retail Planner Briefing Note 9) indicated that convenience expenditure growth at 0.5% p.a. in the period of 2012 - 2021. Comparison expenditure growth is at 2.8% p.a. in the period of 2012-2021. As a result, it is clear that there is an immediate need to meet the short and medium term demand.

As stated in paragraph 16.40, the town centre has not had any additional retail provision since 2008. CgMs reviewed the retail capacity identified by the district wide Shopping Assessment and considered that taking into consideration of the recent change of growth rates, there would still be approximately £9m convenience expenditure growth and £45m of comparison expenditure growth between 2011 to 2016. In light of the major retail investments in Eastbourne (Arndale Centre extension scheme) and Hastings town centres (Priory Quarter), this would further increase the attractiveness of those two centres. This would inevitably increase the leakage from Bexhill.

Land Security therefore recommends the Core Strategy recognises the need to enhance retail provision within the short to medium term period, in order to retain Bexhill's roles and 'clawback' loss trade to other centres.

Paragraph 16.43 states "in the case of Bexhill, consideration will be given to locations in or adjoining Sidley and Little Common district centres ahead of out-of-centre locations. The only significant out of centre shopping are is the Ravenside Retail Park. This attracts trade from across Bexhill and St Leonards, for both convenience and comparison goods. Its established role and potential for linked trip with the Retail Park would place it ahead of other out of centre locations in Bexhill. However, the priority is to focus on town and district centres (both in Bexhill and Hastings), and related edge of centre sites."

Comments:

We agree with the Council's comments that Ravenside has an important role in Bexhill and its position ahead of other out of centre locations in Bexhill. For larger retail proposals, it may not be appropriate to be placed in lower order centres and therefore should be considered carefully.

PPS4's Practice Guidance on Need, Impact and the Sequential Approach sets out guidance in determining the appropriate area of search for an application. Paragraph 6.21 of the Guidance states that 'the scale and form of development likely to be appropriate in each centre should have been considered carefully.'

In particular, Paragraph 6.24 states that 'in determining the appropriate area of search for an application, including whether it is appropriate to consider sites within or on the edge of established centres, it will be relevant to consider the scale and form of development proposed.'

We consider that Bexhill, as the highest order of centre, is suitable for large scale retail development. The function of Sidley and Little Common district centres in Bexhill are local shopping centres servicing local community needs, each comprising up to 60 small to medium retail units. Developments which are likely to serve a wider catchment area would be inappropriate for these two district centres.

Paragraph 16.43 states "in the case of Bexhill, consideration will be given to locations in or adjoining Sidley and Little Common district centres ahead of out-of-centre locations. The only significant out of centre shopping are is the Ravenside Retail Park. This attracts trade from across Bexhill and St Leonards, for both convenience and comparison goods. Its established role and potential for linked trip with the Retail Park would place it ahead of other out of centre locations in Bexhill. However, the priority is to focus on town and district centres (both in Bexhill and Hastings), and related edge of centre sites."

Comments:

We agree with the Council's comments that Ravenside has an important role in Bexhill and its position ahead of other out of centre locations in Bexhill. For larger retail proposals, it may not be appropriate to be placed in lower order centres and therefore should be considered carefully.

PPS4's Practice Guidance on Need, Impact and the Sequential Approach sets out guidance in determining the appropriate area of search for an application. Paragraph 6.21 of the Guidance states that 'the scale and form of development likely to be appropriate in each centre should have been considered carefully.'

In particular, Paragraph 6.24 states that 'in determining the appropriate area of search for an application, including whether it is appropriate to consider sites within or on the edge of established centres, it will be relevant to consider the scale and form of development proposed.'

We consider that Bexhill, as the highest order of centre, is suitable for large scale retail development. The function of Sidley and Little Common district centres in Bexhill are local shopping centres servicing local community needs, each comprising up to 60 small to medium retail units. Developments which are likely to serve a wider catchment area would be inappropriate for these two district centres.