LewishamTown Centre Plan (LTCP) – examination of soundness

Agenda for 9 July 2013

Introduction

During the spring the Council advertised some Main Modifications (MMs) of the plan. Following the receipt of representations in response to the MMs I consider it necessary to convene this additional hearing session to discuss the matters summarised below concerning LTCP’s treatment of the edge-of centre sites at Loampit Vale and Conington Road.

1Conington Road as an edge-of-centre site

1.1There has been past discussion about whether or not Conington Road should be classified as ‘edge of centre’ or ‘out of centre’. The case for defining Conington Road as edge-of-centre is not as clear-cut as in the case of the sites at Loampit Vale, Lee High Road and Lewisham High Street South as the retail frontages at those locations directly address main routes entering and exiting the Primary Shopping Area as it is now proposed to be defined. In contrast, the Conington Road site is less prominently visiblefrom such a route and is most directly reached on foot by a loop via Silk Mills Path.

1.2However, although it is on the opposite side of the river and railway line from the Lewisham Gateway site and the rest of the Primary Shopping Area, policy LAAP5 and the River Ravensbourne Corridor Improvement Planrequire that future development at both Conington Road and Lewisham Gateway will contribute towards the delivery of more accessible and inviting footpath/cycle links across these two current barriers as shown indicatively on Figure 4.3 of the LTCP. Overall, I consider that the Council’s decision to define Conington Road as edge-of-centre is likely to be broadly ‘sound’ (ie not unjustified or unreasonable).

2LTCP’s specification of future retail proposals at Loampit Vale (policy LAAP4) Conington Rd (LAAP5)

2.1In the case of Conington Road LTCP currently proposes (in the key objectives set out below LTCP para 4.17) that the site should accommodate ‘retail services for the Borough’s residents in the form of an extension to the existing foodstore, suitable for an edge-of-centre location that supplements those contained in the town centre’. Policy LAAP5 (2), relating to site S6, quantifies this extension as ‘up to 3,000sq.m additional floorspace’.

2.2Turning to Loampit Vale, the tracked change version of the plan (January 2013) currently proposes (para 4.8) that ‘New retail provision should complement and not compete with the existing Primary Shopping Frontage’. Policy LAAP4 states that ‘This area is considered appropriate for non-food retail for bulky goods but will not be considered acceptable for convenience retail’.

2.3Iceni Projects o/b Chesterfield Properties consider that LTCP inappropriately restricts the edge-of-centre Loampit Vale site to non-food forms of retailing. In their view there is no clear evidence to support this market restriction, eg in the form of a rigorous site capacity assessment of sites in the town centre boundary, followed by those on edge-of-centre sites. The Council’s approach therefore amounts to cherry-picking a specific retailer (Tesco) and placing it in a specific reserved location, protecting it from legitimate competition elsewhere.

2.4In Iceni’s view removal of the restriction placed on the form of retailing at Loampit Vale site would:

(a) create a deliverable option for increased convenience floorspace at that site, thus widening consumer choice and encouraging existing convenience operators to improve their offers, and

(b) assist the wider regeneration of the Loampit Vale area by permitting scope for a convenience outlet providing a walk-in facility serving the 1000+ new homes on its doorstep, anchoring smaller operators drawn to this location, and intercepting some of the car-borne trade before it enters areas in the town centre with the greatest footfall.

2.4Iceni further suggests that if the above restrictions were to be removed, the sequential and impact tests in the NPPF provide the Council with the means of resisting any proposal at Loampit Vale site S4 shown to be of a type or scale likely to have a negative impact upon existing and planned investment within the wider town centre. It is therefore unnecessary to include a pre-emptive policy of the type represented by policy LAAP4 and paragraph 4.13.

3To discuss:

3.1Is there a clear and convincing policy base for directing this quantity of convenience retail development to the edge-of-centre site at Conington Road and ruling out any such development at Loampit Vale, bearing in mind the NPPF requirement (para 23) to promote competitive town centres providing customer choice and a diverse retail offer?

3.2If there is not, would it be a sound approach to delete the references to convenience floorspace at Conington Road and the restriction of convenience floorspace at Loampit Vale and adopt more flexible wording towards retail development at these locations backed up by the need for NPPF sequential and impact tests to assess the consequences of developments at such times as they may be submitted? If this approach were to be adopted would it be necessary to set any particular local threshold for applying such a test? (see NPPF para 26)

Roy Foster

Inspector

25 June 2013