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Letter: The ‘Sequential Test’ Needs To be Properly Applied to Supermarket Proposals

Published on: 10 May, 2013
Updated on: 10 May, 2013

Aldi SignFrom Gerald Bland

Following on from my letter: Aldi Should Only Go To Burpham If There Is No Town Centre Site I would like to add –

A supermarket is a main town centre use which paragraph 24 of the NPPF (National Planning Policy Framework) stipulates should ‘be located in the town centre, then in edge of centre locations and only if suitable sites are not available should out of centre sites be considered’.

Just as ‘main town centre use’ is defined so the framework defines ‘edge of centre’ as a location within 300 metres of High Street and North Street.

The planning officer’s report on the Aldi application reads ‘Officers agree that edge of centre is the correct designation for the application site when considering retail development, as the site is within 300m of Kingspost Parade local centre, which we consider to be the whole local centre’.

Although I was unable to attend the planning committee meeting it seems plain the planning officer’s report led councillors to believe the Green Man site should be accorded the same sequential status as every available site within 300 metres of High Street and North Street.

In fact, sites should have been considered in sequence, those closest to the centre first.

I doubt councillor voting would have been so close if the underlying purpose of the sequential test, with its emphasis on the primacy of the town centre, had been clearly explained and the Green Man site accorded ‘out of centre’ status.

To clarify, I am not advocating any supermarket use for the Bellerby as there exist sequentially preferable sites in the core town centre.

Gerald Bland is a director of the Guildford Vision Group.

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Responses to Letter: The ‘Sequential Test’ Needs To be Properly Applied to Supermarket Proposals

  1. Jim Allen Reply

    May 12, 2013 at 2:56 pm

    I quite agree with Mr Bland. Words like ‘primary’ and ‘main’ were misused in the officers’ report. Guildford Local Plan 2003 clearly identifies the ‘primary shopping centre’ as ‘Guildford Town Centre’. We simply don’t have 15 undesignated primary centres as implied in the report. The NPPF clearly refers to the ‘main’ town centre.

  2. Graham Hibbert Reply

    May 13, 2013 at 11:42 am

    “I doubt councillor voting would have been so close if the underlying purpose of the sequential test, with its emphasis on the primacy of the town centre, had been clearly explained and the Green Man site accorded ‘out of centre’ status”

    I would support Mr Bland on this. During the planning meeting it was pointed out that the old Comet site was available. However, the officers pointed out that this site was designated “out of centre” and so was of a lower priority than the Burpham site. Had the Burpham site been also designated as “out of centre” then there would have been no reason not to consider the Ladymead site.

    My impression was that the majority of councillors were unaware of the way officers were implementing the NPPF. If so, this is deeply worrying about the quality of governance in GBC.

  3. Keith Reeves Reply

    May 31, 2013 at 1:14 pm

    Following on from my reply to Mr Bland’s previous letter there is a danger that those opposed to Aldi in Burpham are being a little selective in their interpretation of ‘centres’. The planning officers are quite correct in according Burpham local centre status. Otherwise, in theory, they would reject many proposed developments outside Guildford town centre, possibly to the detriment of local centres. That wasn’t the intention behind the NPPF.

  4. Jim Allen Reply

    June 2, 2013 at 12:31 am

    Apart from the sequential testing, the application of which I am awaiting a definitive explanation of from central government, because its apparent logic seems illogical), I think one should remove the name “Aldi” from this application and replace it with “developer”.

    It could then be accepted that the developer wants to place an “out of character” building, compared with its surroundings, positioned too close to the road. This will encourage too many people to visit the site, using roads already running at 105% of designated capacity, into a car park too small for its intended use.

    Suggesting putting a football stadium on the site would also come under the heading “Site not fit for intended purpose.”

  5. Bibhas Neogi Reply

    June 2, 2013 at 5:38 pm

    Can’t help thinking that if all those in Burpham, apparently the majority of locals who objected to Aldi application, do not shop at the store the feared additional traffic problem and undersized car park issue would be automatically solved.

    So, if Aldi manages to open their shop I don’t think Mr Reeves needs to worry. I don’t expect he would bump into any locals, when shopping there, with whom he could discuss the nuances of NPPF.

  6. Jim Allen Reply

    June 2, 2013 at 11:15 pm

    Sadly, once the building is constructed it will be too late.

    Simply placing ones head in the sand and saying any developer can do anything they want is neither democracy nor common sense.

    Locals “simply not using the facilities forced upon them against their wishes”, will not stop “out-lander shoppers” inundating the ‘local’ shopping centre by car from Aldershot, Cranleigh, Chobham, Woking etc, i.e. the true catchment area for this shop.

    The people of Burpham have been order by decree [of the NPPF and the developers documents] to walk and cycle to and fro to form the 25% of shoppers who are not allowed to use their cars to go shopping at this development! It will only be ‘outlanders’ who will drive to this site and clog the streets of Burpham.

    Interesting psychology of planning.

  7. Bibhas Neogi Reply

    June 3, 2013 at 7:24 am

    Democratic process is being followed here. If Aldi appeals then whether they win or lose democracy would have been observed. Developers do not have the freedom to do what they like. There is a long process they have to go through to get to the application stage. The Green Man site at Burpham is an excellent example of this.

    As for catchment area extending to Aldershot and Chobham, I think some shoppers in those locations would find Camberley [Blackwater] Aldi their nearest store. Woking shoppers would have the choice of Camberley, Walton on Thames and the Burpham store if it is built, as these would be more or less the same distance from Woking.

    That leaves Cranleigh. Well, if you live in Cranleigh you have already decided on a semi-rural retreat and would hardly want to venture into an Aldi in Burpham too often, if at all.

  8. Jim Allen Reply

    June 3, 2013 at 11:20 pm

    One of the small number of letters ‘for’ was actually from Cranleigh….

  9. C Stevens Reply

    June 4, 2013 at 9:16 am

    In his letter Mr Bland, of the Guildford Vision Group, suggests Aldi should only be sited in Burpham if there is no suitable town centre site and that the ‘sequential test’ has not been correctly applied in this case.

    If that’s right, then the democratic process isn’t being followed, it’s being derailed.

    And I think Mr Neogi is being a little naive in seeing the delay on the Green Man site as evidence of democracy in action and of the way developers are constrained by the system. When the planning application goes in is up to the applicant, that’s when the clock starts running.

    Further, with the current government’s presumption in favour of sustainable development (though what that means I don’t know), the Planning Inspectorate does tend to find for the developer and I’m not convinced that’s a guarantee of the democratic process being observed.

    The key issue is whether or not GBC Planning correctly applied the sequential test and that should become clear if there’s an appeal.

  10. David Smith Reply

    June 4, 2013 at 4:55 pm

    Can I ask if anyone has actually seen the reasons for the Aldi refusal on GBC’s decision notice?

    There are only two: inadequate parking and; out of character with the area.

    There is no mention of any sequential test not being applied

    Aldi will have an easy job overturning this one!

  11. Bibhas Neogi Reply

    June 5, 2013 at 6:09 am

    Mr Bland and others are free to express their views about whether the correct procedure had been applied. If they disagree with the recommendations of the Planning and Transport Officers of the GBC and SCC, they can ask their elected councillors to raise the issues.

    Councillors are advised by council officers but the councillors have the right to decide against the advice given and that is what they have done. The applicant, if not granted planning permission, has the right to appeal. This is the democratic process.

    I’ve found the following information on the local media about the history of the Green Man site concerning Aldi:

    Aldi bought the site in 2006, and the pub was demolished in 2009. But it has remained a derelict  site without planning consent, raising concerns among residents.

    Aldi said in a statement: “The scheme follows a number of years of discussions with officers at both Guildford Borough Council and Surrey County Council and it is agreed that the principle of an Aldi foodstore is acceptable in planning terms.”

    In 2007 Aldi prepared a planning application for a store with 12 homes above it but decided not to proceed after residents raised concerns about over-development, the store’s design and traffic problems.

    So the process of Aldi’s planning application didn’t start last December, it started back in 2007.

  12. C Stevens Reply

    June 6, 2013 at 4:33 pm

    If the sequential test hasn’t been properly applied, won’t the objectors to the original plan be able to raise the matter in a comment, which I believe they will be entitled to make, on the appeal?

    And while it’s true to say that the Green Man site has been derelict for some years, it’s not uncommon for this to happen and it does give developers the opportunity to present themselves as the saviours of the locality. But one mustn’t forget that it’s often the developers who were responsible for the demolition of the building and the creation of the derelict site in the first place.

  13. Bibhas Neogi Reply

    June 7, 2013 at 12:56 pm

    Is Burpham part of Guildford town centre? Clearly not, according to the definition applied to it by the Guildford Borough Council and illustrated in the link:

    Okay, the site could have been designated as an out of centre site, as is the vacant Comet site in Ladymead. Are there any other out of centre vacant sites? I’m not aware of them.

    In my view, the Comet site is unsuitable as a food store. The Business Park design mainly caters for adult shoppers and the car park and the stores are separated by the very busy access road. A food store would be often frequented by mothers and young children and the layout is totally unsafe. Access to Ladymead Business centre requires crossing the very busy dual carriageway of the A25. So very risky for shoppers on foot with young children from the wrong side of the Business Park.

    Let’s not play semantics with the terms in NPPF and look for the true reasons for refusal that Mr David Smith has cited.

    I think Aldi is going to get a favourable outcome if they appeal as Burpham is more than a mile away from the edge of town centre and has its own small shopping parade. To invoke the criteria for testing other sites for suitability in Guildford town centre in my view is not relevant.

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