Sites and Policies Plan Consultation Draft
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Document Section | Sites and Policies Plan Consultation Draft Retailing, Town, District and Local Centres DM64-69 [View all comments on this section] |
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Comment ID | 8133281//1 |
Respondent | Sainsbury's Supermarkets Ltd. [View all comments by this respondent] |
Agent | Deleted User |
Response Date | 19 Apr 2013 |
Current Status | Accepted |
Comment | We have concerns about the requirement in Policies DM65 and WSM5 for Retail Impact Assessments (RIA) to accompany all applications for retail development in out-of-centre locations exceeding 200 sq m net. This figure is significantly below the default threshold of 2,500 sq m set out in the NPPF at para 26. Indeed, the proposed threshold is even below the typical size for a local convenience store (generally 250-280 sq m net). Paragraph 21 of the NPPF states that investment in business should not be “over-burdened by the combined requirements of planning policy expectations”. To require all retail development above 200 sq m to submit an RIA, in the absence of evidence to justify such a threshold, does place an unreasonable burden on smaller retail development which could unnecessarily act as a deterrent to sustainable economic growth.
Should the Council wish to set a local threshold for the requirement of a RIA, it is necessary to collect the evidence having regard to the size, scale and nature of centres in the area in order to set a realistic and proportionate local threshold. This evidence is currently not available. Accordingly, in the absence of such evidence, we recommend the default NPPF threshold of 2,500 sq m should be set. |
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