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Mytholm Works Retail Impact Assessment

From Paul Knights

Tuesday, 20 August 2013

On 4th December 2012 Calderdale Planning Committee deferred consideration of the application for a supermarket and hotel at Mytholm Works so that the applicant could submit a full retail impact assessment (which they had declined to do in advance). This very lengthy and in-depth report was finally submitted on 12th July. Darren Tweed, a Calderdale Planning Officer, issued his final verdict on the retail impact of the proposal on 6th August. A new period for public comments is now open and will close on Wednesday 28th August.

Mr Tweed, while disagreeing with some of the assumptions made in the retail impact assessment, concludes that 'the proposal would be unlikely to have a significant adverse impact on the vitality and viability of the centre as a whole', which is the National Planning Policy guidance against which it must be tested. However, in coming to this conclusion, he outlines some of the expected impacts on Hebden Bridge, including:

  • 'a combined impact of -28.9% on the town centre' shops' turnover
  • 'an impact of -36.5% of turnover' on the Co-op, leaving 'the store trading at 71% of its benchmark turnover figure by 2018', which would 'therefore bring the future viability of this town centre store into question and there would be a real risk that the store would close', undoubtedly leading to 'further cumulative impacts on turnover in the local shops, beyond those impacts predicted in this RIA, due to the loss of linked trips expenditure'
  • 'an impact of -20.5%' on town centre shops other than the Co-op (not taking into account the possible closure of the Co-op, which would presumably increase this figure)

Mr Tweed apparently comes to his conclusion that the vitality and viability of Hebden Bridge town centre would not be significantly adversely impacted despite these rather alarming estimates of the impacts for two reasons:

  • The relevant planning policy guidance states that 'likely future impacts should be assessed against trade in the town centre and local consumer choice... and clearly this proposal would offer increased consumer choice to the residents of Hebden Bridge and the wider catchment area'
  • 'Both the Co-op and Local Shops in Hebden Bridge are trading significantly above benchmark turnover values' and 'the centre is considered to be in good overall health' such that the 'resilience of the centre...to impacts on turnover in convenience floorspace is considered to be higher than more vulnerable centres in the district'

As I understand this, the reason that the proposal is judged not to be contrary to the relevant National Planning Policy guidance is that Hebden Bridge is flourishing to such an extent that it can afford to flourish a lot less and still not have its vitality and viability significantly adversely impacted. Mr Tweed's conclusions do, however, demonstrate that it will be impacted, and to my mind, if the impact is between a quarter and a third of the turnover of town centre shops and the closures that will inevitably result, this impact is certainly not insignificant.

I for one do not consider the increase in consumer choice that this proposal offers to be worth the loss in vitality and viability that Hebden Bridge will incur.

I urge everyone to read the relevant document (called 'Spatial planning comment') at the application website, because this is just my take on it, and to take this last opportunity to comment on the application in the light of this new information before 28th August.

From Anne Handley

Wednesday, 21 August 2013

I should have thought that if the Co-op were to close (which I hope it doesn't) it would have the opposite effect and actually increase the use of local town centre shops - on balance.

The Co-op itself describes the Hebden Bridge store as a convenience store, rather than a major supermarket, so it's competition is with the other small grocery outlets in Hebden as well as the butchers, bakers, greengrocers, organic shops, delicatessens etc. You see a lot of people coming out of there with one or two bags rather than a trolley full!

I suspect that those people who currently drive to the Co-op for a large shop would choose to drive to the new supermarket instead, whereas those who walk to the co-op (even if they are parked somewhere else in the centre) would try and get what they need from other town centre shops.

It seems that the Co-op will be most at threat - I think it suffers from being too big and yet not big enough!

From Anthony Rae

Wednesday, 21 August 2013

I'm not an expert on retail impact assessments (who is?) but my comments on the Calderdale officers' assessment and conclusions, in relation to the government guidance they must apply, would be:

PPS4 Practice Guidance: "7.32 … Where centres are vital and viable, and existing retailers/leisure operators are achieving high levels of turnover, they may be able to withstand high levels of trade diversion resulting from a proposal, although this does not mean in itself mean that such impacts are acceptable. In most cases, unless there is clear evidence of a significant impact on turnover likely to undermine the vitality and viability of the centre, the negative effect of trade diversion needs to be balanced against any positive town centre or wider impacts as part of reaching an overall judgement." AR – On the officer's calculated trade diversion impact of -28.9%, I think that 'there is clear evidence of a significant impact on turnover'. I don't see how it could be judged as anything else. This would need to be balanced with 'any positive town centre or wider impacts'.

NPPF 27. "Where an application fails to satisfy the sequential test or is likely to have significant adverse impact on one or more of the above factors, it should be refused." AR – notice this is in two parts. and also the clear instruction. Firstly, satisfying the sequential test. What NPPF 24 states is "only if suitable sites are not available should out of centre sites be considered" i.e it says considered, not approved. Secondly – 'likely to have significant adverse impacts": again I think -28.9% is significant. So putting the two together doesn't support approval.

The officer says: 'However, in the case of Hebden Bridge, due to the strength and diversity of the centre, I would conclude that the proposal would be unlikely to have a significant adverse impact on the vitality and viability of the centre as a whole.' But the 28.9% adverse impact IS the impact on the centre as a whole, with significant negative impacts on both of the Co-op (-36.5%) and Local Shops (-20.5%). The fact that the latter would still be trading at 152% of the benchmark doesn't appear to the/a critical test in policy, and in any case both the Co-op (71%) and the town as a whole (98.6%) are down against the benchmark. Maybe this 152% is being taken as passing the 'vital and viable/ achieving high levels of turnover' test of the first sentence of para. 7.32 I quoted above but the level of turnover reduction associated with it is still -20.5%.

So I'm not clear that the officers' conclusion that "I can therefore conclude that the proposal satisfies both impact tests set out in paragraph 26 of the NPPF" is strongly founded. You could conclude instead that it fails the 2nd impact test of NPPF paragraph 26 and the separate test of paragraph 27.

Despite having examined the highway impacts in detail with the benefit of further information provided by the applicant, which appeared to demonstrate that the traffic generation at the site junction itself could be met without problems, I wasn't content that the Calderdale position is not to consider the impact on congestion away from the immediate site i.e on the town centre, so I think this remains a concern although not one where the impact can be quantified.

From Graham Barker

Thursday, 22 August 2013

I haven't read the impact assessment but I'm dismayed by Darren Tweed's apparent mindset.

If Hebden Bridge's reputation rests on its small independent shops, and those shops are doing tolerably well in difficult conditions, the logical response should be to help them do even better. Strengthen the Hebden Bridge brand, if you like. Instead, the Calderdale view seems to be: 'They're surviving hard times, so they can survive a kick in the teeth from us'.

Let's be under no illusion that 'a combined impact of -28.9% on the town centre shops' turnover' is anything other than an enormous blow. I agree with Anthony that there is absolutely no justification for Mr Tweed's naive conclusion that 'the proposal would be unlikely to have a significant adverse impact on the vitality and viability of the centre as a whole'. Perhaps Mr Tweed would like to tell us how he'd feel if his salary were to be cut by 28.9 per cent. If he understood anything about business, he'd realise that sanctioning a drop in turnover of that size would condemn many otherwise robust small businesses to death.

A final point: why use such precise percentages when they're only predictions? For example, 28.9 per cent is better expressed as 'around 30 per cent'. Mr Tweed's use of precise figures where no precision is possible suggests a slavish acceptance of a report that might well prove wide of the mark in its impact assumptions.

From Susan Quick

Monday, 30 September 2013

I have to ask whether Calderdale have got their hands in their pockets: "We work out your annual Business Rates bill by multiplying the rateable value of the property by the rate in the pound set annually by the Secretary of State. For 2013/14 the non-domestic rating multiplier is 47.1p in the pound." This would provide a revenue of £? in these straightened times. Can we expect a truly unbiased decision from our planners?

Previously, on the HebWeb

HebWeb News: Brown's site: Questions raised over new Retail Assessment which backs proposed supermarket 15 July 2013

HebWeb News: Brown's site: Planners recommend refusal of Supermarket and Hotel plans

HebWeb Forum - discussion from July 2012

HebWeb Forum - discussion from March to May2012