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					                                                                                 February 2011

              Examination into Kettering Town Centre Area Action Plan
                Matter 3: The Economy (policies 1, 2 (part), 3 and 4):
                               Situation Update - Retail;
                              Situation Update - Offices;
                                 Evening Economy; &
                                 Shopping Frontages
Contents

3.1           Situation Update - Retail                                                    1-7
         i)        Evidence base for proposed retail increase                                1
        ii)        Location of retail development                                            2
       iii)        Is the expansion of comparison retail still justified                     2
       iv)         Is there scope for a „Plan B‟                                             3
        v)         Comparison floor space developed since 2005                               4
       vi)         How critical is the retail injection into the local economy               4
      vii)         Convenience shopping target for AAP                                       6
      viii)        What is meant by an „experiental offer‟                                   7

3.2           Situation update - Offices                                                  8-12
         i)        Increase in office floor space & delivery agencies                        8
        ii)        Implications of public sector office move                                10

3.3           Evening Economy                                                            13-15

3.4         Shopping Frontages                                                           16-20
         i)     3 consecutive non-retail frontages & property acquisition                   16
        ii)     Secondary Shopping Frontages criteria                                       16

This response, including two Situation Updates, has been prepared by Kettering
Borough Council to respond to matters raised by the Inspector relating to the Area
Action Plan‟s (AAP) approach to matters relating to the economy (policies 1, 2 (part),
3 and 4).

3.1           Situation Update – Retail

The significant expansion of comparison retail floorspace [at least 20,500 m² by
2021] would appear to be a significant catalyst in the Kettering town centre
regeneration programme. A situation update from the Council is required to provide
answers to the following questions:

(i)      What is the evidence base for the proposed retail increase, eg is it based largely
         on anticipated retail spend arising from population increase within the Borough,
         or from a mixture of this and other factors such as retail ‘capture’ from other
         areas/ increased prosperity over the plan period?




                                                   1
CSS Policy 12: Distribution of Retail Development indicates the minimum quantum of
additional comparison floor space that should be planned for in order to increase
trade retention in North Northamptonshire and improve the retail offer and vitality and
viability of all three growth town centres. The indicative minimum retail floor space
figures act as a guide for the more detailed plans prepared by the districts, which will
seek to accommodate the bulk of the required floor space within or adjoining the
town centres. Further significant growth in retail floor space will be required beyond
2021 and potential for this future development should be safeguarded in town centre
Area Action Plans. Policy 12 sets out that in the period to 2021 development plan
documents will make provision for, in addition to existing commitments, for a
minimum net increase in comparison shopping floor space of 20,500m 2 at Kettering.
Retail development is to be focussed at the growth towns with Kettering remaining
the main retail centre (CSS para 3.101). The CSS notes at para 3.103 that the retail
strategy will be reviewed in the light of market conditions and monitoring of delivery.

The level of retail increase seeks to increase the retention of comparison retail
expenditure and address „leakage‟ of expenditure to higher order centres outside the
North Northamptonshire study area. It is based on household surveys, population
forecasts and per capita expenditure projections.

A retail capacity update for North Northamptonshire is in preparation by Roger Tym
and Partners, in order to review the Town Centre Roles and Relationships Study
(2005) (Ref. 326) and Retail Capacity Update (2006) (Ref. 336) conclusions, to
assess whether the NNCSS proposals remain valid and achievable. The 2011 North
Northamptonshire Retail Capacity Update (Ref. 337) will be used to inform the CSS
review being undertaken at present that will consider the plan period to 2031.


(ii)   Is the aim of the AAP for the whole of the proposed retail increase to be located
       within the town centre, or is the figure a Borough-wide aim (see page 6, para
       1.2.2)? Does this imply a very restrictive policy for new retail development
       elsewhere, either within the rest of the town centre or elsewhere in Kettering?

The proposed retail development is to be focussed on the town centre covered by
this AAP as set out in CSS Policy 12: Distribution of Retail Development, with the
town centres of the growth towns of Kettering, Corby and Wellingborough being
strengthened and regenerated as the focus of sustainable communities in North
Northamptonshire. Retail policies for the remainder of Kettering town will be detailed
within the emerging Site Specific Proposals Local Development Document due for
adoption January 2013. Such policies will be consistent with the sequential approach
to retail development advocated by CSS policy 12 and PPS4, ensuring that
proposals do not have an adverse impact on the long term viability and viability of
Kettering town centre or the ability of North Northamptonshire to retain expenditure.


(iii) Is the figure still justified and how can it be delivered, bearing in mind the
      changed circumstances and trends since the work was carried out in the North
      Northamptonshire Town Centres Study (Roger Tym and Partners) dated August
      2005, especially relating to the effect of the economic downturn and the impact
      of internet shopping. When will it be delivered?


                                            2
See responses to matters 3 (i and iv) in relation to the update to the 2005 retail
capacity study.

The level of comparison retail is detailed within the CSS. Subsequent DPDs
including the Kettering Town Centre AAP must be in conformity with the CSS which
sets out in policy 12 the need to plan for a minimum net increase in comparison
shopping floor space of 20,500m2 at Kettering by 2021, of which the bulk will be
within or adjoining the town centre.

The Council has set out a clear vision to create a town centre that is characterful,
distinctive and fun, recognising that new development in itself will not be enough and
will soon be usurped by newer developments elsewhere. Paragraph 1.2.9 of the
AAP considers the impact of changing retail trends including the impact of internet
shopping and concludes that functional shopping will not be sufficient in itself to
deliver the vision. For a market town to compete it must offer something else; a
rounded experience with lots to offer.

A Market Commentary Report (submitted as library Ref. 338) has been prepared by
the Economic Development and Regeneration team at Kettering Borough Council
(the Council) with support from Joanna Embling Consultancy and the Council‟s
delivery partners – Roger Tym, Jones Lang LaSalle and others. The report provides
a review of, and the underlying business case for, the development proposals for the
specific sectors and quarters of Kettering town centre identified within the Kettering
Area Action Plan (AAP).

The findings of the Market Commentary Report are considered in the response to
matters 8 (i) and (iii). In summary it concludes that delivery will take place over one,
if not two, market cycles and it is likely that delivery will be deferred in the short term
until the market improves. It notes that in the current market Kettering‟s plans are
ambitious and could take up to 15-20 years to deliver the totality of the Kettering
vision. However, the Council is doing all it can to mitigate the risk to delivery
including using its land holdings for early win development projects such as the
Restaurant Quarter to provide the catalyst for further development within the town
centre and the preparation of detailed delivery strategies for key commercial site
including Wadcroft (SHQ1), Soans Yard (Y2) and the Station Quarter proposals,
demonstrating to investors that the Council understands the key issues and where it
can offer support. The AAP itself which will provide the planning policy basis for the
town centre proposals is also fundamental to securing delivery, ensuring
comprehensive development of key sites including site SHQ1 Wadcroft/ Newlands
Phase 1.


(iv) Is there scope for a ‘Plan B’ in case the economy, and in particular the
     ambitious retail growth envisaged in the AAP, fails to materialise? What form
     would Plan B take?

Flexibility / contingency within the AAP and the need for a plan B are considered
within the answer to matter 8 (iii). This is likely to take the form of a slower delivery
rate than anticipated and a prioritisation of sites as detailed within the AAP,


                                            3
particularly, SHQ1 Wadcroft/ Newlands Phase 1. Such developments will make
provision for modern comparison floor space over the plan period in order to maintain
and improve current market share and meet the comparison shopping needs of the
enlarged residential population.

In relation to retail proposals within the AAP numerous studies, including the Market
Commentary Report and Wadcroft Feasibility Study (Ref. 315) all demonstrate the
need for a more diversified and distinctive offer including a significantly higher
percentage of premium and national retailers. Such retailers will demand large
format retail units provided within Site SHQ1 Wadcroft / Newlands Phase 1, units that
are currently not provided within the primary shopping area.

The Roger Tyms Retail Capacity Update 2011 (Ref. 336) has revised the analysis
undertaken in 2005 and 2006 that underpinned the CSS, with the updated results
informing the review of the CSS. The report includes up-to-date forecasts in respect
of population, per capita expenditure, expenditure growth, special forms of trading
(for example, online shopping), and turnover efficiency of existing retailers.

The study has shown that the centres in North Northamptonshire continue to perform
reasonably in light of the economic downturn, with each of the growth towns showing
generally good signs of vitality and viability. The retail offer in Kettering town centre
has however stagnated somewhat, and the town centre has seen a reduced market
share compared to the previous study on account of increased patronage to the
town‟s retail parks, where there is improved provision compared to at the time of the
2005 study. The study proposes that the delivery of modern retail units as part of the
town centre redevelopment proposals should enable the town centre to more
effectively compete with the improved out-of-centre offer.

The comparison goods floorspace requirement within the study is reduced by
approximately one-third from the 2006 Update. The findings of the retail update will
inform the CSS review that will consider the period to 2031 and then cascade down
through the subsequent review of DPDs in North Northamptonshire including the
Kettering Town Centre AAP. The study is however clear that there is sufficient
capacity for planned town centre schemes including Wadcroft/ Newlands Phase 1 in
Kettering in the period to 2021.


(v)   How much of the proposed retail comparison floor space has been developed
      since 2005?

Monitoring information to April 2010 indicates that there has been a net increase of
186m2 in comparison retail floor space within the plan area. (1426m2 gains 1240m2
losses). This insubstantial increase demonstrates the underlying need to allocate
significant retail floor space within the AAP.


(vi) How critical is the retail ‘injection’ into the local economy, and in particular to
     achieve the Council’s vision for a thriving and distinctive town centre with a high
     quality public realm?



                                           4
Policy 1 in seeking to deliver Objective 2 sets out the regeneration priorities of the
AAP including retail led growth of at least 20,500m2 net comparison floor space to
2021, focused on the Shopping Quarter (Policy 15) and in particular site SHQ1
Wadcroft/ Newlands Phase 1 (Policy 16).

Site SHQ1 detailed through policy 16 is identified as the priority for delivering the first
phase of retail development in the town centre to deliver the requirements of the
CSS. The Wadcroft Feasibility Study (Ref. 315) illustrates that this location would be
able to provide for the critical mass of floor space to attract a new anchor store within
the town centre whilst also providing a number of modern large format retail units.
The injection of significant levels of comparison floor space is important in
diversifying the retail offer within the town centre and providing the large format retail
units that modern national retailers demand. The Shopping Quarter and Wadcroft
proposals will make an important contribution to delivering excellence and
distinctiveness in urban design, landscape design and architecture whilst respecting
Kettering‟s built heritage, in this part of the town centre. In line with Policy 11 Public
Realm and Art major development proposals as identified within table 3.3 of the AAP
will contribute positively towards high quality public realm through on site and
adjacents enhancements and through off site contributions. The emerging Kettering
Town Centre Public Realm Strategy SPD, (Ref. 334) will provide the framework for
all future public realm enhancements in the Plan Area.

The town centre is in a relatively strong position and is performing well in relation to
nearby centres as detailed within the latest North Northamptonshire Annual
Monitoring Report (Ref. 306). As detailed within the response to matter 3 (iv) above,
however, significant additional retail provision is required to maintain and reduce
comparison retail leakage to other surrounding areas and in part to address very
recent market share losses to out of town retail parks. Both the CSS and this AAP
therefore seek to provide balanced growth and make North Northamptonshire and
Kettering more self-sufficient in terms of access to jobs, shops, leisure, affordable
homes and services.

The significant scale of additional comparison retail floor space is required to
maintain and enhance Kettering‟s market share and provide services for the borough
and the wider North Northamptonshire sub-region in the period to 2021. At present
the short supply of modern, large format shop units limits the potential to attract
quality retailers and this needs to be addressed, and Policy 15 (The Shopping
Quarter) allocates developments sites for this purpose.

The Council has set out through the AAP a clear vision to create a town centre that is
characterful, distinctive and fun, recognising that new development in itself will not be
enough and will soon be usurped by newer developments elsewhere. For a market
town to compete it must offer something else; a rounded experience with lots to offer.
Paragraphs 3.6.2 – 3.6.4 of the AAP and the response to matter 8 (iii) highlight the
delivery lead that the Council is taking within the town centre. Such schemes are
already acting as an important catalyst to regenerating the town centre and are
helping to build momentum.




                                            5
(vii) Is there a corresponding convenience shopping target for the AAP to plan for
      and to take into account in planning for the town centre?

The retail targets within the AAP are in conformity with those set out within the CSS
through policy 12: Distribution of Retail Development. The CSS does not set out
convenience shopping targets within its policies although it states at paragraph 3.104
that in the period to 2021, a further 12,201m 2 of convenience floor space is projected
to be required in North Northamptonshire, due to growth in population and
expenditure, based on 2006 North Northamptonshire retail capacity update.

The Roger Tyms 2006 Retail Update showed that the aggregate convenience sector
retention rate for the overall North Northamptonshire catchment area was 82 per
cent. The study identified quantitative capacity to support new convenience sector
provision in the North Northamptonshire Growth Area even under a „static retention‟
scenario, deriving from the substantial population increases that were anticipated in
North Northamptonshire. However both the 2005 Study and 2006 Update Study
identified that need for additional convenience foodstore provision in the short term
was relatively limited. As the significant population increases come forward, the
requirement for additional convenience goods floorspace increases accordingly.

It is considered that within the retail proposals detailed in the AAP there is sufficient
flexibility both within development allocations and policy guidance to cater for limited
scale convenience development that alleviates potential overtrading in the future and
supports the vitality and viability of the town centre as a whole.

The updated North Northamptonshire Retail Capacity Update 2011 (Ref. 337)
contains updated convenience retailing information. Paragraph 4.21 notes that at the
time of the Goad survey, June 2009, 21 of town centre units had convenience uses,
equivalent to 6.2 per cent of the total. Figure 8 in Appendix 1 sets out the diversity of
uses by floor space, and it can be seen that the retail mix in Kettering is largely in line
with current UK averages, with marginal overrepresentation in convenience goods
floor space and under-representation in services floor space. Figure 8 shows that
48.4 per cent of floor space in Kettering is given over to comparison goods uses,
whilst the convenience and service sectors each account for circa 19 per cent of floor
space.

Convenience shopping is a much more localised activity than comparison shopping –
that is to say, people are generally less willing to travel as far to undertake food
shopping as they are for non-food, specialist shopping. This is reflected in the
convenience goods retention rate for North Northamptonshire which has risen to 87.4
per cent overall. This study concludes can be considered a reasonably strong
performance and represents a 5 percentage point increase from the retention rate
identified by the 2005 household survey. Retention is Kettering town is even higher
at 89.7%

Based on a detailed   analysis of existing foodstores the study identifies that there are
no significant gaps   in provision, (paragraph 9.41). The major four convenience
retailers of Tesco,   Asda, Sainsbury and Morrisons are all represented within
Kettering, with the   recent acquisition of the Co-op Extra superstore by Asda
completing the set.    In many cases, the principal foodstores have been subject to


                                            6
modernisation and extension in order to better meet the needs of consumers and the
retailers themselves. It is noteworthy that there is relatively little provision of
„Express‟ format supermarkets in any of the town centres and the provision of these
might benefit the retail mix and vitality and viability of the centre as a whole.

It is important to consider the suitability of the existing network of large foodstores to
meeting the planned extension of Corby, Kettering and Wellingborough. The
consultants do not consider there to be any significant deficiencies in the quality of
main existing convenience stores. Findings from the North Northamptonshire Retail
Capacity Update 2011 including findings of the household survey, supported by the
consultants own observations, show that a qualitative need will exist over the course
of the CSS review plan period to 2031 for additional foodstore provision on the
eastern side of Kettering, in order to meet the needs of the extended urban area
resulting from the Sustainable Urban Extension. It proposes that new foodstore
provision should be of a scale to meet the needs of the new urban extension, and not
of sufficient scale that trade will be diverted from existing foodstores in the town
centre, thus undermining the vitality and viability of these stores.


(viii) What is meant by an ‘experiential offer’ (page 8, paras 1.2.7 and 1.2.19)?

An experiential offer refers to the desire to make Kettering Town Centre more than
just a place to shop. Visitors to the town will be able to experience a high street
shopping offer, but more than that they will also be able to enjoy dining,
entertainment, cultural activities or just come into town to catch up with friends.




                                            7
3.2      Situation Update – Offices

A significant office expansion is also proposed in the AAP [38,500m² additional
floorspace by 2021]. A situation update from the Council is required to provide
answers to the following questions:

(i) What is the justification for such a significant increase in office floorspace in the
AAP and how/when will it be delivered? Have any delivery agencies been identified?

CSS Policy 8: Delivering Economic Development states that a net increase of 47,400
jobs across North Northamptonshire will be sought in the plan period 2001 – 2021.
CSS Policy 11: Distribution of Jobs supported by table 6 details net job creation
targets with Kettering Borough providing 16,200 jobs of which 3260 are planned to be
office employment. Policy 11 states that the town centres and other areas with good
public transport connections will be the preferred locations for new office
development. The quantum of floor space proposed is therefore consistent with the
CSS strategy of diversifying the economy into higher value activities, and town centre
regeneration. The review of the CSS, being undertaken at present, will consider
employment targets over the period to 2031 and once adopted its policies will inform
subsequent reviews of this AAP.

The Preferred Options Baseline Report (Ref. 320) and Kettering Town Centre Topic
Papers - Retail, Commercial & Housing (Ref. 307) detail work undertaken in
developing a strategy to provide suitable sites to meet the strategic objectives.
Urban Capacity Analysis (Ref. 330) identified capacity for approximately 38,000m 2 of
B1 office floor space, predominantly within the Station Quarter, in the period to 2021.

The Station Quarter will deliver 32,000m2 of office floor space across seven sites as
set out in table 5.5 of the AAP and detailed within Policy 20.        Using the CSS
technical note on converting employment land into jobs, the AAP will deliver circa
2100 office jobs with 1777 deriving from Station Quarter allocations1.             The
employment potential for sites within the Station Quarter have been identified within a
number of employment land reviews including the Kettering Employment Land Study
2005, Northamptonshire Commercial Property and Employment Land Assessment –
December 2006 and Northamptonshire Strategic Employment Land Assessment
(SELA) November 2009 (Ref. 329). The 2005 Kettering Employment Land Study in
particular examined the employment land opportunities that exist through
comprehensive development to the south east of the station and identified this area
as being the most deliverable employment land in the town centre. The SELA also
identifies and supports the site as a preferred employment site. The Commercial
Topic Paper (in Kettering Town Centre Topic Papers - Retail, Commercial &
Housing) (Ref. 307) details the origin and evolution of commercial sites within the
AAP.

The proposed office land allocations within the Station Quarter area of the town


     Technical Note for partner Local Planning Authorities on translation of job numbers into employment land requirements
January   2008     details    that    one     B1    job     will   be     provided    per     18m2    of    floor    space.




                                                            8
centre will provide a plan-led commercial focus for the town. Through a sequential
approach business growth will be directed to the town centre, within an area greatly
enhanced by a mix of land use and public realm strategies, as well as through rail
links to London, enhanced public realm and links with the Primary Shopping Area.

The most recent monitoring information demonstrates that whilst Kettering is the best
performing authority in North Northamptonshire in terms of net jobs growth, having
achieved 24% of its NNCSS target (3937 in the period 2001 - 2009), significant
employment generation is still needed with over 1000 net jobs annually required to
meet current CSS targets.

Deliverability

The Station Quarter Study (Ref. 317) was commissioned to develop the Preferred
Options proposals further and identify engineering and other issues which would
affect their implementation, including an identification of next steps. Figure 3.2 of the
study illustrates land ownership within this Quarter. It notes that a significant number
of elements of the Station Quarter proposed development are in the control of
Network Rail and Kettering Borough Council rather than the private sector. Thus
there is an opportunity to bring forward a range of public realm and transport
improvements in the short to medium term (2008-2016), including a reconfiguration
of the station forecourt layout to accommodate a bus interchange. Redevelopment of
larger plots, in particular those on the western side of the railway line and to the
south along the Crescent (STQ 7, 8, 9) require more complex land negotiations.

The phasing programme identifies that the Station Quarter proposals will be
delivered in the short to medium term (2010 – 2016) as detailed in policy 25. The
monitoring framework at table 6.1 establishes targets, indicators and triggers through
which the plan will be monitored. Trigger COI BD1 Commercial states that if
development in the Station Quarter has not been secured/ delivered by 2016 then the
likely reasons for delay will be identified and if necessary a review of the plan
undertaken to identify alternative sites for such uses.

The Borough Council has through the Station Quarter Study and other reports
undertaken work to understand the physical constraints to bringing forward a office
hub and transport interchange at the station, and is working with partners to identify
funding and bring forward the vision for the quarter. This will maximise strong
transportation links to London, Leicester and Nottingham and help to meet the job
targets in the Core Spatial Strategy. Transport improvements are already being
delivered with the Station Quarter with the Northampton Road/ Northfield avenue
junction improvements due for completion spring 2011 (see response to matter 5i).

Deliverability of the Station Quarter proposals is considered within the Market
Commentary Report (Ref. 338) and summarised within the remainder of the matter 3
(i) response. Section 5.2 of the report provides sector analysis of commercial and
business space within the AAP. It concludes that Kettering has the potential in terms
of location and pricing to sustain significant growth over the medium to long term and
to create an office market within the town centre, provided that the town can attract
and retain a more highly educated workforce.



                                           9
The report highlights that Kettering has a plentiful supply of employment land and a
supportive environment in which to bring forward development but needs a quality
town centre offer to compliment its out of town offer. The Council understands the
financial challenges involved and the need for a viable in-town alternative, and has
identified the Station Quarter, which it is promoting through the AAP. The Council
also has an ongoing dialogue with Network Rail, a significant land owner, to bring
forward development proposals at the Station.

In the face of strong competition from other regional centres, the Council will need to
work hard and concentrate its efforts to attract small and medium sized companies to
Kettering and in particular local companies, companies looking to consolidate and
companies seeking to relocate from London and more expensive locations. A town
centre scheme offering a range of accommodation, and with the benefit of planning
consent, would be of considerable help in this regard.

The availability of appropriate property is a key criterion for occupiers seeking new
locations; to compete most effectively towns and cities need a full portfolio of choice
to meet the needs of as wide a range of occupiers as possible. In Kettering the
quality offer is dominated by existing and planned out of town parks, providing for
occupiers attracted by the mobility offered by the road network. There is an
opportunity to provide a complimentary offer with access to town centre services, rail
borne labour and business links. Companies are seeking demonstrably sustainable
locations which we expect to become more important as a location factor in the
future. This provides an obvious niche for the Station Quarter provided this can be
correctly oriented and positioned. With the East of Kettering Sustainable Urban
Extension bringing in 5,500 new homes and wider sub-regional growth, there will be
an increase in the local labour market that will choose to live in Kettering and it is
realistic therefore to assume further town centre office space will need to be created
to meet this demand.


(ii) What are the implications of relocating large public sector office employment
(police, local government) from the town centre to an out-of-centre business park?
(Para 1.2.18); how many jobs would be lost to the town centre through this action?

Kettering Borough Council is not looking to relocate all of its functions to an out-of-
centre business park. It is instead looking to enhance its existing multi-agency
customer service offer over the plan period, within the Southern Quarter. The
consequence of such enhancements would be that existing back office functions of
the Council and/or the Police may have to move out of their existing sites thereby
potentially creating regeneration potential in this part of the town centre.

The vision for the Southern Quarter is to realise its potential to contribute to
regeneration, in a way that is responsive to its position as the southern gateway to
the town centre. The potential relocation of back office functions away from a key
town centre regeneration site would create an opportunity to bring significant new
investment into the town centre and would also enable the Borough Council to act as
a catalyst for a new business park to help meet the job targets set out in the Core
Spatial Strategy.



                                          10
The Southern Quarter element of the AAP (section 5.7) examines the potential for
regeneration that exists within the quarter. Paragraph 5.7.3 emphasises the potential
competitive advantage of the site as one of the few areas within the town centre
where comprehensive land ownership exists, a significant factor under present
market conditions. It also considers the ambition of the Council and Police to move
back office functions away from their respective sites, whilst at the same time
enhancing customer service delivery through an improved One Stop Shop,
incorporating service delivery partnerships with other public and voluntary sector
organisations. It is anticipated that this will lead to increased footfall and vitality within
the area.

Kettering Borough Council is already working to expand its excellent customer
service offer with more front-line voluntary sector services, health services and
greater partnership working with existing public sector partners such as the Police,
Fire Service, HMRC and Kettering General Hospital who are establishing themselves
within the Customer Service Centre. This is increasing activity and footfall in this
area of the town, thereby supporting the delivery of the vision as a southern gateway
to the town centre and enhancing services to the public. HM Revenue and Customs
has been located within the customer service centre since April 2009 and currently
attracts approximately 60 customers per day. In January 2011 an innovative new
NHS blood test facility, believed to be the first of its kind in the Country, opened in the
customer service centre in a joint venture between KBC and Kettering General
Hospital. The aim is to make blood testing more convenient and reduce pressure on
the blood testing service at Kettering General Hospital, with the new unit providing
blood tests for up to 170 patients per day. Such uses, that have previously been
located outside the town centre, are now making a positive contribution to town
centre regeneration by drawing significant numbers of people who previously had no
reason to visit the town centre, into this southern gateway site.

The AAP recognises the importance of key town centre uses and therefore the threat
of major employers potentially relocating from the town centre, within the plan period.
It is therefore important that any redevelopment must result in a positive impact on
the vitality and viability of the town centre (para 5.7.5). The Cultural Quarter Scoping
Study (2010) (Ref. 314) explores the issues related to the potential relocation of the
Council‟s and Police‟s back office functions.

The report considers a range of potential development options as detailed at table
2.1 of the study (page 8). The study assumes for modelling purposes that the
Council will relocate all “back office” staff currently located at the offices and front
office staff will remain in the town centre. Table 24 at page 28 considers the potential
employment impact of Proposed Cultural Quarter Development. This concludes that
none of the options maintain the same levels of employment as existing within this
part of the town centre. Under all options there is a positive increase in employment
within both the plan area through sites allocated for employment uses and Kettering
Borough as a whole resulting from significant numbers of jobs being relocated from
other surrounding areas outside of the borough. More crucial than the employment
numbers are the impacts on overall town centre spend resulting from the relocation
of staff. This is considered in detail within section 3.8 of the study and summarised
within the table on pg 23. The results indicate that under both development
scenarios the mixed use and supermarket options modelled result in an overall


                                             11
increase in annual town centre spend, with only the residential led options unable to
produce a positive change in annual town centre spend.

Increasing demand for co-located customer service facilities from partner
organisations may therefore necessitate the relocation of those back office staff that
at present do not deal directly with customers. Such employees do little to either
attract a diversity of visitors to the Southern Quarter or improve the vitality of the town
centre. The breadth of services delivered from the Customer Service Centre is
expanding over time, with the Council at present working with Kettering General
Hospital to explore further opportunities to deliver services together. Such
improvements are already placing increased demands on the existing office
accommodation, a process that is likely to be exacerbated over the plan period. Sites
SOQ1 and SOQ2 are therefore identified within policy 23 of the AAP as opportunity
sites for future development that will support the vitality and viability of the town
centre, if the Council decides to relocate its back office functions during the plan
period. The Scoping Study and therefore policy 23 make clear that under such a
scenario the Southern Quarter opportunity sites can be brought forward for
regeneration with a form of development which does not have a detrimental effect on
the economic viability of the town centre itself, and which contributes positively to the
vitality and viability of the town centre as a whole. Such a development would have
to be comprehensively masterplanned and adhere to policies 5, 8 and 12 of the plan.




                                            12
3.3: Evening Economy

Should the evening economy be specifically addressed in the AAP? Is it the
intention of policy 3 not to permit any additional night clubs or similar uses in the town
centre, or just in the primary shopping area? If so, are there alternative locations for
these uses?

PPS4: Planning for Sustainable Economic Growth, states that „Local Planning
Authorities should proactively plan to promote competitive town centre environments
and provide consumer choice by:

       supporting a diverse range of uses which appeal to a wide range of age and
        social groups, ensuring that these uses are distributed throughout the centre
        planning for a strong retail mix.

PPS4 goes on to say that „Local Planning Authorities should manage the evening
and night-time economy in centres, taking account of and complementing the local
authority‟s Statement of Licensing Policy and the promotion of licensing objectives
under the Licensing Act 2003. Policies should:

       encourage a diverse range of complementary evening and night-time uses,
        which appeal to a wide range of age and social groups, making provision,
        where appropriate, for leisure, cultural and tourism activities such as cinemas,
        theatres, restaurants, public houses, bars, nightclubs and cafes, and
       set out the number and scale of leisure developments they wish to encourage
        taking account of their potential impact, including the cumulative impact, on
        the character and function of the centre, anti-social behaviour and crime,
        including considering security issues raised by crowded places and the
        amenities of nearby residents‟.

Disregarding the evening economy or exclusion of policy 3 would fail to create a
pleasant environment for people to enjoy in a cohesive community which is safe. It is
considered that policy 3 provides enough flexibility with regards to the location of
uses throughout the town centre and ensures that the town centre is not overly
dominated by evening related uses.

The current nightclub provision in Kettering is outlined in the table below (please note
the figures given for floor space are approximate figures largely based on information
contained within earlier planning permissions for these premises):

Nightclub Premise       Approx.     floor No. floors        Location       Occupancy
                        space (sqm)
Cocoon                        360               1               SSF        Occupied
64/70 Gold St
Rehab                           869                2            SSF        Occupied
21 Montagu St
Abacus                          919                3            SSF        Occupied
19 Dalkeith Place
Level 3                         183                1            PSF        Vacant
57/59 High St


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There is currently a high concentration of nightclubs in the secondary shopping
frontage, and one nightclub (although currently vacant) in the primary shopping
frontage. Most nightclubs within the plan area are located at first floor level and are
therefore not regulated by the criteria (points I – XI) contained in policy 3. In addition
to the number of nightclubs outlined above there is a high level of provision of A4
uses within the plan area as identified in the Kettering Town Centre Health Check
Update 2011 (Ref. 339). Many of these A4 uses are large „super‟ pubs containing a
nightclub function i.e. providing drinking into the early hours and dance floors.

Pubs within the Primary Shopping Area with a nightclub function as outlined above
are listed in the table below (this information has been provided by the Northants
Licensing Partnership):


Public House                  Location                     Opening hours
Cavan Nightclub               Restaurant Quarter           Mon - Wed 10:00 - 01:30,
Market Place                                               Thursday 10:00 - 02:30, Fri
                                                           - Sat 10:00 - 04:00, Sunday
                                                           12:00 - 01:30
Sessions                      Restaurant Quarter           Mon - Sun 07:00 - 01:30
7 Market Place
Watercress Harrys             Secondary         Shopping Mon - Sat 08:00 - 04:30,
7 Market Street               Frontage                   Sunday 10:00 - 04:30
Peacock Inn                   Primary           Shopping Sun - Wed 10:00 - 01:00,
7 Lower Street                Frontage                   Thurs - Sat 10:00 - 02:00
Henry‟s                       Secondary         Shopping Mon - Sun 10:00 - 03:00
4 Horsemarket                 Frontage
Xtra                          Secondary         Shopping Mon - Thur 10:00 - 00:30, Fri
Dalkeith House, Dalkeith      Frontage                   - Sat 10:00 - 02:30, Sunday
Place                                                    11:00 - 00:30
Sun                           Secondary         Shopping Sun - Wed 12:00 - 02:30,
3 Silver Street               Frontage                   Thur - Sat 12:00 - 05:30
Bar Q Bano                    Secondary         Shopping Sun - Wed 10:00 - 01:30,
Ebenzer Place                 Frontage                   Thurs - Sat 10:00 - 03:00

A comparison can be made to the number of nightclubs in Kettering Borough‟s two
neighbouring authorities, Wellingborough and Corby. These towns are both North
Northamptonshire Core Strategy growth towns and are of comparable size to
Kettering. Wellingborough has only one nightclub within its town centre boundary
and there are no occupied nightclubs within Corby‟s town centre boundary.
However, one site in Corby has planning permission to operate at a nightclub and
contains 2241sqm of floorspace (as specified in the planning permission).
Wellingborough Borough Council has no record of the floorspace contained within
the nightclub that currently operates in their town centre but their recorded site area
for the site is 830sqm (obviously the floor area of the nightclub would be less than the
site area, however there appears to be limited outside space). Based upon the
current offer of this type of facility in both Wellingborough and Corby it appears that
nightclub provision in Kettering is substantial.



                                           14
Consultation responses to the Preferred Options policy KTC 7 (evening economy)
highlighted concerns regarding an over-concentration of A4, A5 and nightclubs uses
within the Town Centre. Northamptonshire Police in particular stated that „the current
concentration of uses within the Montagu Street, Silver Street, Horsemarket, Dalkeith
Place and Market Place means the town centre is at or near saturation point with
regards the evening uses‟. This is supported by statistics showing incidents of crime
as collated by the Kettering Community Safety Partnership demonstrating that the
highest concentration of offences occur within the wards in town centre, especially in
the evenings and at weekends.

Taking into consideration the number of actual nightclubs within the town centre and
the pubs which include a nightclub function, it is intended that the no additional
nightclubs will be permitted within the plan area. The intention of this policy is to
prevent an over-concentration of non-retail uses within the town centre, to encourage
diversity within the current evening economy and prevent the „cumulative impacts‟
from this type of use such as crime, anti-social behaviour, disturbance, litter etc. As
previously stated, there is a vacant unit within the town centre that was previously a
nightclub. This unit is obviously available if another nightclub operator was interested
in establishing such a use within the town.

For the reasons outlined above, it is the intention of the Plan to prevent further
planning permissions being granted for additional nightclubs anywhere within the
Plan Area.




                                          15
3.4: Shopping Frontages

In relation to shopping frontages:

(i) Is the policy 3 requirement for not more than 3 consecutive non-retail frontages
open to abuse through property acquisition?

The intention of „Policy 3 – Primary Shopping Frontages‟ is to avoid an over-
concentration of non-retail uses in the PSF, as this is the most appropriate location
for A1 (retail) in accordance with the guidance outlined in PPS4: Planning for
Sustainable Economic Growth.

Property acquisition resulting in the loss of an A1 retail unit, leading to more than
three consecutive non A1 retail frontages, in most instances would require planning
permission i.e. a material change of use would have occurred. Any material change
of use would require planning permission, subject to a planning application assessed
on its merits and in accordance with all points contained within policy 3 (and any
other relevant policies contained within the Plan). Policy 3 introduces criteria (points
I – V) in which material changes of use should be assessed against, in summary the
criteria is: the necessity for no less than 75% of A1 frontages retained within the PSF;
no more than three consecutive non-retail uses in a row; no additional A4 or A5;
protection of the vitality and viability of the town centre; and protection of an active
and well designed frontage.

In the event property acquisition resulted in the ownership of a building containing
more than one ground floor unit including an A1 unit and a non-retail unit(s), planning
permission would be required to change the use of the A1 unit unless an element of
A1 remained in the resulting unit i.e. no material change of use. Precedent for
changes of use and constitution of a planning unit has been established in the case
for Church Commissioners for England v SoSE [1996] JPL 669.


(ii) What is the basis for the requirement in policy 3 for no more than 17% and 8% of
the Secondary Shopping frontages being in A4 and A5 uses respectively?

Policy 3 seeks to outline a positive approach to new development and regeneration
within the town centre. Through restricting the amount of A4 and A5 uses within the
town centre although allowing a small increase in the total number of these uses will
have a generally positive effect in the form of both direct and indirect economic
benefits. The attractiveness of the area for visitors will increase as well as for
investors as outlined below.

The Kettering Town Centre Framework (Ref. 311) highlights the current poor image
of the night time economy within Kettering created by poor quality pubs and clubs
and limited food and drink offer. It also states the need to manage the night
economy and balance evening and day time uses and offer an alternative to drinking.
The Town Centre Area Action Plan Preferred Options Baseline Report (Ref. 320)
outlines the need to limit the current over-concentration of A4 and A5 uses and
promote policies which encourage further A3 and A4 uses dispersed across the area,
which enhance the public realm.


                                          16
The Preferred Policy Direction KTC7 (evening economy) and accompanying SA
stated that „diversifying the evening economy offer by restricting further bars and
clubs whilst allowing more restaurants is the most sustainable option and would
contribute positively to sustainability appraisal objectives relating to accessibility,
crime, community, liveability, reducing the need to travel, economy and the vitality of
the Town Centre‟. Consultation responses to the Preferred Options policy KTC 7
(evening economy) highlighted concerns regarding an over-concentration of A4 and
A5 uses within the Town Centre. Northamptonshire Police in particular stated that
„the current concentration of uses within the Montagu Street, Silver Street,
Horsemarket, Dalkeith Place and Market Place means the town centre is at or near
saturation point with regards the evening uses‟. Other consultation responses
highlighted an overconcentration of this type of use especially along Montagu Street,
Silver Street and Dalkeith Place.

Taking into account the background studies undertaken and the consultation
responses regarding A4 and A5 provision a Town Centre Health Check was
undertaken in 2009 (Ref. 305). This health check has been subsequently updated
(February 2011, Ref. 339). As the background studies and consultation responses
highlight a current overconcentration of particular uses within the town centre, the
AAP seeks to limit the increase of A4 and A5 uses within the town centre particularly
in areas where increases in retail provision are preferential. However, it is
considered that a small increase in the number of A4 and A5 uses within the SSF
would not have a detrimental impact on the vitality and viability of the town centre
and would promote economic benefits and competition provided retail remains the
primary function of the Primary Shopping Area and the size of pubs is limited to
diversify the current offer within the town centre.

Policy 3 of the Proposed Submission AAP seeks to provide a vibrant Kettering
Evening Economy characterised by a mix of leisure and A3-A5 uses with a diverse
offer and reasonable control over amenity taking into consideration the planned town
centre residential growth. The Area Action Plan therefore proposes controls over the
number, location and size of A4 and A5 uses. This is supported by PPS4, which
states „Local Planning Authorities should manage the evening and night-time
economy in centres, taking account of and complementing the local authority‟s
Statement of Licensing Policy and the promotion of licensing objectives under the
Licensing Act 2003. Policies should:

      set out the number and scale of leisure developments they wish to encourage
       taking account of their potential impact, including the cumulative impact, on
       the character and function of the centre, anti-social behaviour and crime,
       including considering security issues raised by crowded places and the
       amenities of nearby residents‟.

The current level of provision of A4 and A5 uses is outlined in the tables below. This
provision comprises of a high concentration of A5 uses, a lack of leisure facilities and
an evening economy of limited quality and choice based largely around a high
number of large/super-pubs and nightclubs, which cause high levels of anti-social
behaviour, disturbance and litter. Many of the existing drinking establishments are
either traditional public houses or super-pubs rather than modern café-style


                                          17
(Chameleon) bars. The latter offer a diversity of choice and extended opening hours,
acting as quality cafes in the day and early evenings and operating as bars in the
evenings. The provision of chameleon bars would in turn diversify the existing limited
drinking offer and avoid areas of the town centre becoming dormant at certain times
of the day due to the evening based open hours of such establishments.

Boundary                   % of that type of use in the boundary
                           A4                                   A5
             Frontage   % of     No.    % of Frontage        % of   No.          % of
                in    frontage Units units          in     frontage Units        units
              metres                             metres
Primary
frontage        75.0      3.5%       5     2.6%        5.3       0.3%       1    0.5%

Secondary
frontage       221.8      15.4%      7     4.9%      103.1       7.2%      13    9.0%

Restaurant
Quarter         30.4      11.0%      3     14.3%       8.8       3.2%       1    4.8%

**Kettering Town Centre Health Check 2009** (Ref. 305)



Boundary                   % of that type of use in the boundary
                           A4                                   A5
             Frontage   % of     No.    % of Frontage        % of   No.          % of
                in    frontage Units units          in     frontage Units        units
              metres                             metres
Primary
frontage        75.0      3.5%       5     2.6%        5.3       0.3%       1    0.5%

Secondary
frontage       221.8      16.2%      7     4.9%       92.1       6.7%      11    7.7%

Restaurant
Quarter         30.4      11.0%      3     14.3%       8.8       3.2%       1    4.8%

**Kettering Town Centre Health Check 2011**

The only change to the provision of A4 and A5 uses within the past 19 months has
been a decrease in the number of A5 uses within the Secondary Shopping Frontage.
This increase in frontage for A5 uses allows greater flexibility in the plan for the
provision of this type of use.

An over-concentration of A4 and A5 uses in one area can result in unacceptable
„cumulative impacts‟ where for example, concentrations of drinkers queue at fast food
outlets and for public transport. Queuing in turn often leads to conflict, disorder and
anti-social behaviour. Policy 3 restricts the amount of A4 and A5 frontage within the


                                          18
Primary Shopping Area whilst allowing some flexibility within the policy to
accommodate growth. The percentages for A4 and A5 uses have been set as
follows:

       Existing A4 in Secondary Frontages – 16.2%
        The Submission policy proposes that the amount of A4 frontages should
        not exceed 17%. This equates to approximately 11 metres available for
        further units, subject to the proposal being in conformity with the remaining
        criteria of policy 3.

       Existing A5 in Secondary Frontages – 6.7%
        The Submission policy proposes that the amount of A5 frontages should
        not exceed 8%. This equates to approximately 18 metres available for
        further units, subject to the proposal being in conformity with the remaining
        criteria of policy 3.

       Existing A4 in the Primary Frontages – 3.5 %
          The Submission policy proposes no further allowance for A4 uses in the
          Primary Frontages.

       Existing A5 in the Primary Frontages – 0.3%
          The Submission policy proposes no further allowance for A4 uses in the
          Primary Frontages.


Policy 3 also contains criteria that will help to diversify the current evening economy
offer and avoid an over-concentration of uses on those streets highlighted as specific
areas of concern. As there is already a large number of super pubs in the town
centre and a limited number of chameleon or family establishments, A4 uses should
not exceed 500 metres net total floor space to encourage diversity of offer.

The key is to provide a mix of A4 uses, Kettering town centre has a number of similar
size A4 uses offering a culture of late night drinking and entertainment which does
not appeal to a range of users particularly families. Policy 3 (X) seeks to discourage
further similar A4 uses to that which currently exist. Therefore, the 500sqm criteria
has been arrived at based upon the current estimated floorspace of existing A4
premises and has been set slightly lower to encourage a diversity of A4 type uses
within the town centre.

The Primary Shopping Area acts to protect the main core of the centre from non-
retail developments which can destroy its vitality and viability. Therefore, no further
allowance has been made for A4 or A5 uses in the Primary Frontages.

Kettering Borough Council in partnership with Police, local business and residents
manage some of the negative impacts resulting directly from the poorly diversified
evening economy which currently exists in Kettering Town Centre. In 2009/2010
615 alcohol related crimes occurred in the Borough, 60% of town centre violence
across Northamptonshire was alcohol related and Alcohol related harm costs
Northamptonshire Public Sector (Health, police, fire, unemployment and community
cohesion) costs £271 million annually. Existing working groups have been set up to


                                          19
mitigate any negative effects from the evening economy and include Council/Police
lead schemes:

      Kettering Borough Alcohol Harm Reduction Group (In November 2009,
       Northamptonshire was red-flagged by the Comprehensive Area Assessment
       (CAA) for alcohol harm. The Kettering Local Strategic Partnership Conference
       2010 setup an alcohol workshop group to deliver actions locally to combat the
       above stats).
      The Town Centre Task Force (sharing best practice and reducing the
       incidence of crime and anti-social behaviour as well as monitoring the
       cumulative impacts of a concentration of licensed premises)
      Night Time Enforcement Officer (reducing incidence of crime and enforcing
       licensing laws etc)

And one locally led scheme:

      Pub watch (run and attended by local pubs and clubs, Local Authority, Council
       Members and Police to address issues and impose responsible drinking
       procedures).

These groups, as well as street cleaners (litter collecting seven days a week), work
together to reduce the negative effects from the existing over-concentration of pubs
and clubs along Silver Street, Dalkeith Place and Montagu Street and throughout the
rest of the town centre. The Kettering Borough Three Year Partnership Plan sets
targets to reduce crime within the town centre and provide a cleaner environment
across Kettering Borough. Any significant increase in the number of large pubs,
bars, nightclubs and hot-food takeaways would put unnecessary pressure on these
working groups to their detriment.




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