Memorandum
CONSULTATION ON A PLANNING PROPOSAL

To:			Planning
From:			Economic Regeneration
Date:			12th August 2019
Ext:			3335
Ref:			19/00335/FUL
Town & Country Planning Act 1990 (as amended)
Town & Country Planning (General Development Procedure) Order 1995 Planning (Listed Buildings & Conservation Areas) Act 1990 (as amended)
Town & Country Planning (Control of Advertisements) Regulations 1992

Application No:	19/00335/FUL	
Applicant:	Mr Dylan Collins	
Site Location:	Land Rear Of 98 To 128  High Street Rayleigh SS6 7BY	
Proposal:	Proposed demolition of existing buildings. Redevelopment of the site to provide 2No commercial units and 35No residential apartments with associated landscaping.	

Dear Katie 

Regarding this application, we would like to make the following comments, referring to relevant policy documents: 
Retail & town centres 
•	The 2018 update of the National Planning Policy Framework (NPPF) covers town centres in Chapter 7, requiring local planning authorities to allocate a range of suitable sites in town centres to meet the scale and type of development likely to be needed, looking at least ten years ahead. Meeting anticipated needs for retail, leisure, office and other main town centre uses over this period should not be compromised by limited site availability, so town centre boundaries should be kept under review where necessary;
•	Rochford District Core Strategy 2011: The Core Strategy’s approach to centres and retail development is set out in policies RTC1 and RTC2. Respectively, these seek to strengthen and improve the retail offer of the District’s main centres and direct new retail development and other main town centre uses towards these locations through a sequential, town centres first approach. The Core Strategy also commits to the development of an Area Action Plan to deliver, among other things, a predominance of retail uses, including intensification of existing retail uses.
•	The Council’s Economic Growth Strategy 2017, part of the evidence base for the future Local Plan, commits the Economic Regeneration Team to support business growth and retention through being responsive to planning consultations to support business growth and investment, whilst resisting residential conversions of business spaces. It is noted that this planning application would lead to the creation of two new retail/commercial units. 
•	The 2018 South Essex Retail Study, which will inform the new Local Plan, identifies future retail and leisure space demand across Rochford District as the population grows. Up to 2034, it identifies there could be a requirement for up to 4,937 sq m comparison goods and 2,711 sq m convenience goods space. The analysis also identified a potential requirement for up to 3,000 sqm gross of floorspace for new food and beverage outlets across Rochford District. In terms of distribution, the priority for this was found to be for new A3 restaurant and café units within Rayleigh and Hockley.  This proposal has the potential to fulfil some of this demand through the provision of ground floor commercial space.
•	The proposals come at a time when high streets nationwide are under significant pressure, with 2018 representing a 5 year low in new shop openings, according to a May 2019 Local Data Company report. This analysis observed the GB vacancy rate rose by +0.3% in 2018 to 11.5% - the highest level since 2015. Much of this is attributed to £1 in every 5 now being spent online, although many leisure categories have also experienced significant decline. Traditional retail categories were amongst those experiencing the most significant declines (e.g. fashion and electrical retail), whereas the biggest growth categories were barbers, beauty/nail salons, cafes, restaurants and bars. It is important for prospective commercial units to be marketed in a way which will appeal to those sectors of the economy which are growing. 
•	The site falls within the boundaries of the 2015 Rayleigh Town Centre Area Action Plan (AAP), part of RDC’s Local Development Framework. Within this, it falls outside the primary/secondary shopping area. It also falls within Character Area C – High Street South and Eastwood Road. This states: Development in the High Street south and Eastwood Road area will support the retail function of the central High Street area, with an emphasis on the provision of secondary retailing and complementary uses, including service and office uses and community facilities.
•	A search of the Rightmove commercial property website on 12/08/19 revealed a total of 2 A1 (retail) units currently available to let in Rayleigh, and the vacancy rate on and around the High Street is generally low. Therefore, proposals that include additional retail space could fulfil a need. 

Offices & workspace
•	The South Essex Economic Development Needs Assessment 2017 (EDNA), part of the Evidence Base for the new Local Plan, includes data on business survival rates as follows: Year 1, 95%; Year 2, 81.7%; Year 3, 65%; Year 4, 55%.  These are the highest rates in South-Essex, suggesting an entrepreneurial culture, and further emphasising the need for grow-on space for existing start-up businesses, to prevent them being forced to either relocate or remain in unsuitable premises or at home. As a result, it is considered a positive that the proposal will provide further space that could be used by small businesses.   
•	The EDNA also identified severe under-supply of employment space in Rochford District relative to demand, whilst more widely supply has dropped sharply across South Essex. The analysis also considered scenarios such as the Greater London Authority Industrial Land Study 2016-2036 and a model to reflect growth as a result of London Southend Airport. This anticipated potential workspace demand for Rochford District 2016-2036 to be for an additional 30,000m2 of employment space, over 7ha land, creating an additional 1,200+ jobs. This is clearly dependent upon provision of suitable employment space, and whilst the Council’s Allocations Plan 2014 identifies new sites with potential to accommodate new offices and industrial units with large floorplates, it is important to consider provision of small business workspace in tandem with this.
•	Rochford District Council’s Employment Land Study (ELS) 2014 forms part of the evidence base for the emerging Local Plan, and notes that Rochford District currently experiences low job density, and consequently high flows of out-commuting as residents travel elsewhere for work.

•	The Essex Grow-On Space Feasibility Study, conducted by SQW and commissioned by Essex County Council in October 2016 includes data which demonstrates that in regards to grow-on space there is a mismatch between the supply of, and demand for, grow-on space across the county and that both industrial and office space in this category are in short supply. This is most pronounced in Rochford District. Rochford is the second highest in the area and above the County, Eastern region and National for proportion of ‘micro businesses’ (0 to 9 employees) so there is a good supply of local businesses that would either require start-up space or eventually grow-on space. This indicates there is a lack of available grow-on space for our businesses, and the site in question represents an opportunity to address this and prevent such businesses being forced to move out of the district as they grow, or otherwise remain in unsuitable premises or at home. 

•	A search of the Rightmove commercial property website on 12/08/19 revealed a total of 5 units available to rent across Rayleigh, which were both under 2,000 sq ft and suitable for B1/A2 use, with this number being 9 across the whole Rochford District. 5 of these were in Rayleigh itself, although 4 of these were the ground and first floors of the same properties, indicating there is not a considerable variety of office properties available. It should be noted that Rayleigh has already lost office space to residential through ‘permitted development’ in the town centre, whilst a small industrial estate on Castle Close, to the rear of Eastwood Road has received consent for redevelopment to residential, further reducing the amount of employment space in the town centre. Therefore, proposals for new employment space would help to redress this loss. 

•	A recent Centre for Cities report has further highlighted the importance of supporting and encouraging high-quality employment opportunities in urban centres, indicating that the most successful towns and cities had a strong base of knowledge-intensive employment opportunities, which in turn supported further retail and leisure vitality in the town centre.
Residential 
•	The proposals for 35 flats as part of this proposal accord with ongoing dialogue from central government regarding the place for residential in town centres, with a House of Commons Housing, Communities and Local Government Committee report entitled ‘High streets and town centres in 2030’ discussing this in detail. It acknowledged the role of residential in generating additional footfall and spend in town centres, supporting the existing retail and commercial businesses. However, it warned against the ongoing loss of commercial space through permitted development rights, which can reduce the overall vitality of town centres. That the proposal is for new space on a derelict site, rather than a conversion of existing commercial space, is a positive in this respect. 
Based on the above, there is potential for the proposals to support the current high street functions and provide new business accommodation. However, it cannot be ignored that the scheme could potentially impact upon existing high street businesses in a negative way, and we note the letters submitted by businesses such as the Co-operative Funeral Parlour and Eden Independent Financial Advisers regarding privacy and site access/parking issues. In addition, Rayleigh Town Centre is a known congestion hotspot and the increased use of this access road by vehicles driving to/from the development has the potential to exacerbate this and affect the local economy. We would request that these concerns are considered and mitigated against before such a scheme is passed. 
Yours sincerely, 

Dan Kudla
Regeneration Officer – Economic Regeneration Team