We posted yesterday about the importance of remembering, and ensuring, that Claygate is a Village, not a Town.
You can read more below about the importance of ensuring that this development, indeed any future development proposals, complete a Retail Impact Assessment to show the impact to our Village, and how implying Claygate is a Town is a tactic to avoid such scrutiny.
Summary
A retail development is easier to get through planning in a town than a village environment.
Size matters! National guidelines require larger developments to go through a formal “retail impact assessment” (RIA) in a village site but not in a town. An adverse assessment (“it will hurt local shops”) is likely to kill a retail application.
Kilo (and M & S) are therefore, for their own ends, doing their best to portray Claygate as a town (or part of Esher town) rather than a village in all their public statements and publicity material.
We should not have to be forced to defend our village’s status. It has never been known or seen as anything other than a village.
This plan is therefore about much more than a large food store being imposed on Claygate: it is about our future status as a village. What could follow?
What is a Retail Impact Assessment and what is the National Planning Policy Framework?
A Retail Impact Assessment (“RIA”) is a report by a qualified consultant, paid by the applicant and aims to evaluate the impact of the proposed development on the vitality and viability of existing centres within the local area.
A RIA is not mandatory under the National Planning Policy Framework (NPPF) (2021) for proposals in 'town centres' for developments less than 2500m2 floor space 'unless a different locally appropriate threshold is set by the local planning authority' such as Guildford town centre where the LA has set the trigger point at 500m2.
Claygate is a Village!
The NPPF is the official Government Guideline and sets out framework for the Government’s Planning Policies. All Local Authorities have to comply in regards to their Local Plans and planning matters for housing and other developments. All planning applications must also comply with the recommendations as set out in the NPPF as well as those issued by the Local Authority such as Elmbridge Borough Council (EBC), in their own Local Plan. As stated in the NPPF, a RIA is required as part of an application for retail development above 2500m2 in areas which are outside a defined retail centre.
So what?
It is generally accepted that where a proposed development, though smaller than the 2500m2 limit ‘is likely to have a marked impact on the viability of smaller centres within the catchment area’ (such as a Village like Claygate), then a RIA should be provided by the applicant.
WHY have the EBC NOT insisted upon a RIA when clearly a large M&S at the end of the Parade of Independent shops & behind the Co-Op is highly likely to have a marked impact on the viability of [our] smaller centre?
They are likely to look at Arboricultural, Environmental or Ecological issues which can be easily mitigated by the applicant but not a Retail Impact Assessment ...which if it's conclusions are negative, cannot be so easily dismissed.
We find this shocking & appears to be a deliberate attempt by EBC and Kilo to avoid a RIA. Given the Claygate Can Do Better survey results, we are however not surprised!
For the sake of clarity, fairness and transparency we strongly recommend that EBC ensure that prior to any Planning Application by Kilo, that a fully independent Retail Impact Assessment is carried out which can be viewed and commented upon.
How does this affect the proposals for Torrington Lodge Car Park and Claygate?
According to EBC’s own Statement of Community Involvement (2021 & 2023) section 4.2.7 states that a 'Small scale major development' is defined as where the floor space to be built exceeds 1000m2 or where the site is between 1ha and 2ha.
TLCP has a total open area of 2985m2/0.3ha (excluding access road off Hare Lane) so is not in excess of 1ha but the proposals currently published by Kilo indicate a building with a footprint in excess of 1100m2, so it meets EBC's own definition of a 'small scale major (retail) development'.
When EBC originally determined application 2021/3857 on the Aldi scheme in Thames Ditton, one of their reasons for the refusal stated: 'The development would have an adverse impact on the vitality and viability of Thames Ditton/Hinchley Wood local centres'. Aldi, in their appeal against this decision argued that as the proposals fell below the minimum 2500m2 floor space requirement (as set in the NPPF) to trigger a RIA therefore, they did not have to carry one out and were thus able to blithely assert that any impact of the proposals on existing shops in Thames Ditton or Hinchley Wood ‘would be minimal and far short of any prospect of an impact being demonstrably 'significant'.
WHY does EBC take this line for Thames Ditton BUT NOT for Claygate?