Objection Letter sent by LOCALSHOPSLOCAL FIRST CAMPAIGN
Preferably you should use this letter for background information. You may also send it, in whole or in part, as it is but 'form letters' are only considered as one objection. However - as with a petition - the sheer number of local residents writing in still has influence with members of the committee.
EDITABLE WORD VERSION OF THIS DOCUMENT
Mrs Jackie Batchelor
Head of Development& Technical Services
Havant Borough Council
Civic Offices
HAVANT
PO9 2AX
12 October 2007
Your Ref 06/58840/014
Tesco Stores Ltd. Solent Road Havant PO9 1TR
Dear Mrs Batchelor,
We are an independent, voluntary group of residents, local small businesses and environmentalists working to support our local shops and services.
We write to lodge strong objections to Tesco's proposed redevelopment of their site in Solent Road as set out in the planning application reference above. We received your notification on the 28th September, leaving 18 days to prepare our case compared with the 14 months Tesco had to prepare theirs. We understand Havant Council normally allows a minimum of 28 days for comment on planning applications.
Planning policy provides that a statement of public involvement from the applicants is required. Tesco's response was a presentation to just the Havant & Bedhampton Community Board and a store poll of Tesco customers. Evidently the Community Boards in Emsworth, Hayling and Leigh Park were not thought relevant. In our view the applicants should have called a public meeting (as Lidl did in Leigh Park), commissioned an independent poll and launched a website to encourage a full and open debate. Havant Council could have used its Citizens Panel to encourage feedback. In Fareham Tesco mounted an exhibition in the shopping centre with company representatives present. A Havant councillor and leading member of DMC is quoted in the News saying there had not been many letters but most were in favour and this only 48 hours after the re-advertisment. In fact of the 59 letters on file at that time, most were overwhelmingly opposed.
The application has taken 15 months to come before the council. True, there are important matters of detail regarding Section 106 Heads etc but the application is much the same now as it was in July 2006. Our assumption is that the application has not been hastened largely to allow time for the Hargreaves development, opposite the store, to open. Tesco could be hoping that the new retail sheds, once open for business, would diminish potential objections to their store being a separate destination, a crucial determinant in the case.
We next turn to Tesco's business case for replacing its present store. They claim it will improve their offer and enable them to compete on a more equal footing with Bedhampton based ASDA, among others, and more curiously, their own Portsmouth Tesco Extra. Their primary catchment area lies within a 10-15 minute drive of Solent Road, thus bringing Leigh Park, Havant Town, Emsworth and Hayling Island within range.
Planning issues relating to need, likely impact and the consequences of permitting Tesco's expansion are very fully dealt with in the DTZ Report, commissioned by Havant Council. There's little point in repeating the detail shown in this report. But it is worth emphasising what it says about the impact of the new store, particularly on Havant Town Centre and on Leigh Park. The report predicts that a while a significant proportion of the new business (claw back to Tesco) will come from ASDA in Bedhampton with smaller contributions from other large format units (not all in the catchment area) some locally significant business (9.4%) could be diverted out of Havant Town centre and Leigh Park. This could also include, Waitrose, the town centre's anchor store. 'Tesco's Finest' which would become an offer in the new store, directly targets Waitrose customer base. We would go further and suggest that among other potential casualties are Curry's, Wilkinsons, Iceland, Mackays the town's pharmacies and Smiths plus various clothes shops and perhaps the opticians. Tesco's response to DTZ consists of obfuscation over study areas and speculation about Havant's place in the retail hierarchy. Havant already has 10 empty shops (out of 73) with reports of others struggling to remain open. Allowing this application could finish off the town as a shopping destination and produce a doughnut effect. The removal of Halfords from a key corner site suggests the process has started. Nor would the impact be confined to Havant and Leigh Park centres. Emsworth has so far resisted the trend towards disappearing small shops but faced with an expanded Tesco selling a much wider range of products only 10 minutes up the road the situation could change for the worse. This is certainly a concern of the Emsworth Business Association and one shared by businesses for the same reason in Mengham and Greywell.
Tesco have made much in their application of linked trips to their store and the town centre. They suggest (misleadingly) that 80% make linked trips and that this supports their case that an enlarged store would be good for the town. The trouble is that their figures do not support this conclusion. Question 7 in their survey asks 'even if you are not doing so today, do you ever combine a trip to this store with a trip to Havant Town Centre?'
Given the store has been open for 10 years, pretty well everybody calling into Tesco could recall a time when they combined it with visit to the town centre. In the event only 20% say Yes frequently while the rest of the responses range from 'occasionally', 'rarely' or 'never'.
Some of the 'linked trips' could have more to do with using Tesco's free car park while visiting the town. The real objection is their attempt to apply these results to their new store. The probability of more or even the same number of linked trips to the new store could be lower than at present because everything will be under one roof and the temptation that much bigger. From our own observations made on various days of the week pedestrian traffic between the existing store and town centre could best be described more as a trickle than a flow.
The Section 106 package includes a crossing, new pavement and a bus subsidy and other contributions totalling over £600k. Viewed against the likely diversion of business from Havant retailers to Tesco mentioned in the DTZ report, this sum should be viewed more as compensation for the £3-4m of lost business rather than investment. But if investment, then its sole purpose is to promote Tesco's new store and not the town centre.
Tesco is fostering the notion that the new development will deliver real benefits to Havant's local economy. New jobs are promised and no doubt there will be some but at the expense of many of the businesses already established in the area thus making for no net new jobs to the borough. Smaller businesses generate more new jobs than large chains.
There are a number of direct and indirect disbenefits including even greater congestion along Park Road South discouraging visits to the town centre, deterioration in air quality from more traffic emissions and the general decline in the town centre.
PPS6, the main national planning policy guidance, says applications like Tesco's must satisfy five tests:
- There must be a proven need for the development, if not in the town centre (and it is not according to the Havant Local Plan)
- It must be shown that the impact on existing town centres will not be too great
- It must satisfy the sequential test (that there are no more central sites appropriate for development)
- The size of the development must be appropriate
- o The location must be acceptable. It is our view that the Tesco application fails to satisfy four of these tests.
- 1. The DTZ study clearly shows that the need has been overstated and based on post codes and various hypothesis that are open to questionable interpretations on the retail choices throughout the area
- 2. The impact of the new store-put at £3-4m- could damage the town centre's present fragile retail base triggering further closures. The impact could ripple out to other centres, namely, Hayling, Emsworth and particularly Leigh Park
- 3. The size of the development is out of proportion to both the need both qualitative and quantitative and Havant's position in the retail hierarchy as defined in PPS6
- 4. The location is suitable for the present operation but not for one of twice the size because of traffic congestion that could further isolate the town centre and the expanded range of goods in Tesco Extra and do little towards achieving the aims of the Havant Urban Design Study published as an SPD in 2006
The recent discovery that a further 1000 sq.m of retail capacity is to come on line in December from Messrs Aldi on the Wickes site adds still further confusion and serous doubts as to whether the defined town centre has any future at all There are other issues of an environmental and sustainability nature and social inclusiveness which will no doubt be addressed by other objectors.
We firmly believe that the council has adequate grounds for refusing this application and should take a strategic view and accept the recommendations of its own independent retail consultants.
Yours etc
R.B Cobbett FCMI FCIPS MILT
Secretary
LocalShop Local First Campaign
Write or email your views to the HBC planning office
The planning application reference is 06/58840/014 and it can be viewed HERE on Havant Council's web site. type or paste the application number into the first box and click search. To view the details click the application number in the pale green box on the next screen.
The deadline for comments is 18th October but the officer may accept later submissions. You can send your comments to Havant Council by email or post . Address and email HERE
The main government policy documents relating to the application referred to in Havant Borough District Wide Local Plan are PPS1 (delivering sustainable development) referred to by HBC here and PPS6 (maintaining the vitality of town and local centres) referred to by HBC here another guideline used by HBC is PPG13 (on transport) referred to by HBC here, of the the . There other relevant sections of the plan.
Objection must be material to the planning application. You can apply to form a deputation to address coucillors when they consider the matter on 1st November.
Published by shoplocalshop Campaign, 26 Beach Road, Emsworth, Hants PO9 2JE email: tescopoly@havantfoe.org.uk