Point No 5
The need for an Impact Assessment
An Impact Assessment is broadly to do with the effect of the
new development on the viability and vitality of the existing Centre in terms
of diversion of trade from other businesses in the broader vicinity with the
consequential possibility of job losses.
In the case of the need for an Impact Assessment there is one further qualification other than
size.
The new National Planning Policy Framework (March 2012)
states the following at Paragraph 26.
“When assessing
applications for retail, leisure and office development outside of town centres
which are not in accordance with an up-to-date Local Plan, local planning authorities should
require an impact assessment if the development is over a proportionate,
locally set threshold ( If there is no locally set threshold, the default
threshold is 2,500 sq metres)”
(Please note the ‘Outside of Town Centres’ issue will be
dealt with separately. At this point in time and for the purposes of this
Application, the Site is outside the town centre)
This development at 2,810 sq metres meets the requirement of
needing an Impact Assessment on the basis of size.
Is the Application in accordance with an up-to-date Local Plan?
The developer insists that the development is in line with
the up-to-date Local Plan and therefore there is no need for an Impact
Assessment. Apparently the Planning Department agrees with this.
The Bolton Core Strategy/ Local Plan – whatever you call it
– supported by the Bolton Retail and Leisure Survey - does indeed mention
specifically Aldi’s search for a site in Little Lever for a 1,500 sq metre Gross (929 sq metre Net)
store.
The developer’s
argument is that this Net figure isn’t much different from the ‘uplift’ of 1,264 sq metres referred to above and therefore meets the Local
Plan.
However, if you accept that the ‘Uplift’ argument is invalid then :-
The proposal at 2,800
Gross (1,728 Net) is 1.83 times ( ie -nearly DOUBLE) the 1,500 Gross (929 Net) in the Local Plan
and thus the proposal is clearly NOT
in accordance with that plan.
Nowhere in the Bolton Core Strategy or base document BRLS is a store of the size applied for
(2,800 gross -1,728 net) – mentioned, justified or recommended.
(This is further
discussed, argued and clarified in Point No 13)
Conclusion:-
If the Committee are minded to agree that the Uplift argument is invalid then they must recognize that this development exceeds 2,500 sq metres (Gross) and conclude
that it is NOT in accordance with
the Local Plan and thus an Impact
Assessment is required.
Such an Impact Assessment has not been supplied with this
Application.
In the absence of such an Impact Assessment, I strongly suggest that the
Committee’s only options are Rejection
of the Application or Deferral until
such time as an Impact Assessment is provided.
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