RETAILING AND SERVICES CHAPTER EIGHT

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1 RETAILING AND SERVICES CHAPTER EIGHT

2 8.1 Aims The aim of policy for retailing and services is to enhance and support the existing retail and service centres within the Borough, to ensure that they provide focal points for a wide range of facilities for the local community, and to ensure the proper provision of such facilities for Gravesham residents wherever they live. A particular priority is to support and enhance the role of Gravesend Town Centre. 8.2 Objectives The objectives are to: concentrate retail development at the Town Centre and local centres, where they are appropriately located on the transport network; ensure the vitality and viability of local centres and Gravesend Town Centre; make provision for major new development to have access to convenient local shopping facilities where the scale justifies it; and set a policy framework for dealing with applications for Use Class A3 uses. 8.3 Introduction Retailing is a dynamic and changing sector of the economy, and some 84% of the floorspace in the relevant land uses in the Borough is located in Gravesend Town Centre. Services is a broad sector, but is here taken to mean commercial services and built leisure developments which might be found in or around town centres and other local centres. Sports facilities and other similar developments are dealt with in Chapter 13 of this Local Plan Review. 8.4 National and Strategic Guidance Retail is an area where national policy has changed significantly in recent years. Primary guidance comes from PPG6 Town Centres and Retail Developments (1996), which sets out the Government s objectives as follows:- to sustain and enhance the vitality and viability of town centres; to focus development, especially retail, so as to maximise competition and accessibility by means other than the car; to maintain an efficient and innovative retail sector; and to ensure a wide range of shops, employment, services and facilities with access by a choice of means of transport. Town and District Centres should be the preferred location for developments which attract many trips and plan policies should aim to:- locate major trip generators in existing centres where a choice of travel mode is available; Deposit Version 127 Gravesham Local Plan 2 nd Review

3 enable town, district and local centres to meet the needs of residents of their area; safeguard and support existing urban and rural local centres; maintain and improve modal choice; and ensure attractive and convenient car parking The process of finding the preferred location for retail or service development, whether by site allocation in the Local Plan, or by planning application, should follow the sequential test. This test sets out a hierarchy of places for the preferred location of new retail development. Preference should be given in the first instance to sites or buildings suitable for conversion located within town centres, followed by edge-of-centre sites, district and local centres, and finally consideration may be given to out-of-centre locations, provided they are well served by public transport. Special factors need to be taken into account. For example, conservation areas may mean that certain centres are not appropriate for certain types of development If out-of-centre retailing is proposed, the following considerations need to be applied:- the likely harm to the Local Plan strategy; the impact on vitality and viability of existing centres; its accessibility by a range of means of transport; and the overall effect on travel patterns and car usage Current approved Regional Planning Guidance (RPG9) seeks to make the existing network of town centres in the south east the focus for retail development and builds on the framework set out in PPG6 discussed above. Gravesend is identified as one of the regions town centres which should be the primary focus for retail development. The uncertainty caused by the impact of Bluewater regional shopping centre on non food goods expenditure in North Kent is highlighted in studies on trade potentials The Kent Structure Plan (1996) provides a series of criteria for the location and scale of development of retailing in the county. Structure Plan Policy R1 provides a set of general criteria for the evaluation of proposals, namely:- future trade potentials; improving quality and range of centres; ensuring out-of-town developments do not undermine vitality and viability of existing town centres or the rural economy; support economic growth from new retail investment; ensuring accessibility to public transport; and integration with existing centres where possible The other Structure Plan policies then expand on these criteria with particular reference to food stores (R2), comparison goods (R3) and retail warehousing (R4). Provision is also made for Bluewater. The supporting technical work to the Structure Plan Review identified little or no scope for additional food floorspace in Gravesham, and recognised that the scale of Bluewater took away the need for additional comparison goods floorspace. However, there Gravesham Local Plan 2 nd Review 128 Deposit Version

4 was some demand for retail warehousing provision. Work has begun on the 4th Review of the Structure Plan, which will include a comprehensive reappraisal of the trade potentials, but this is not currently available In 1997, the Borough Council produced the publication Gravesend Town Centre: A Strategy for Action. It provides a vision for the Town Centre from the perspective of the Town Centre Initiative. Updates and more detailed strategies have also been produced, for example on the Heritage Riverside. It provides a very robust point of departure for looking at many of the Town Centre issues, and takes on board many of the elements noted above in Government guidance. Gravesend was a pioneer in Town Centre Management, and has been regularly monitoring its health as a centre for some years. This has involved measuring a series of variables, including leading store turnover, number of transactions, footfall, parking usage and crime. This is enabling detailed monitoring of the impact of Bluewater and the preparation of strategies which are sensitive to what is happening. The Strategy adopts the approach of setting a series of broad objectives to be met and defines a series of distinctive quarters, each with their own appropriate strategy The Local Plan Review strategy takes on board the above approach but from a slightly different perspective, as it is a statutory plan, focuses on land use, has a longer timescale, and has to consider retail issues across the whole Borough. The Local Plan Review also has to bring on board the results of transport work, including the Kent Thames-side Fastrack concept, and the more detailed public transport proposals for Gravesend. These will feed back into the Strategy for Action, which can be updated and reviewed on a far shorter timescale than is possible in this Plan. 8.5 Trends The challenge is to produce a strategy which meets the guidance at national and strategic level, the trends within the retail industry, and local circumstances. These have to be set in the context of the changing emphasis in transport strategy. In general, retailing has followed a path of moving out of town, exemplified by superstores, retail warehouses, regional shopping centres and now factory shopping outlets. Comparison goods have followed the path of convenience goods in becoming dependent on the car. The larger regional centres have in general managed to hold their own in this pattern of dispersal and it is the smaller centres like Gravesend which have suffered At a more local scale, Gravesend Town Centre s role in the retail hierarchy of Kent has been affected in recent years by a number of factors. Investment in existing competing centres has occurred, new ones have been developed (Hempstead Valley, Lakeside in Essex, Bluewater), new forms of retailing have emerged (retail warehousing, factory shopping outlets) and there has been much greater mobility due to increased car ownership amongst the resident population The Borough Council, land owners and retailers have ensured that Gravesend has not remained static, and considerable investment has been directed into Deposit Version 129 Gravesham Local Plan 2 nd Review

5 both the physical and retail infrastructure. King Street and New Road have been pedestrianised, and considerable resources have been invested in the overall townscape, most recently in Windmill Street. The Angelsea and St George s Centres have seen considerable investment in refurbishment and upgrading, necessary steps to retain their attractiveness and competitiveness. The Borough Council has been working with English Heritage and English Partnerships (now part of SEEDA) to achieve enhancements to the buildings in the Town Centre, particularly those within the conservation areas. To be effective, this investment has to be seen as a long term process that has to continue and cannot be seen as a one off The major recent event has been the opening of Bluewater regional shopping centre in March The impact of Bluewater on Gravesend Town Centre has been estimated at various times by a variety of studies, but the suggested figures have generally been in the order of 20% of turnover for non food goods. The Bluewater proposal has been a live issue since the planning application was first made in Therefore, the potential impact has been in the background for a considerable period, and a proportion of it will have occurred prior to opening due to the uncertainty which has been caused. Impact comes from the diversion of expenditure to the new centre, and also in less direct ways such as loss of trained staff. Lakeside, in Thurrock, has also had a significant impact on Gravesend, but it is a reasonable working assumption that much of the expenditure which currently goes to that centre will have been largely diverted to Bluewater The impact of technological change on retailing has been subject to much speculation, particularly in relation to the Internet. This could be via a computer connection or via digital television. The ability to purchase goods from home is attractive, and represents a development of catalogue shopping. Although experiments have been carried out in food retailing, it is probably in non food goods that the greatest impact will be felt. Such services will undoubtedly develop and take some market share. It is a trend and its local impact will need to be monitored in the future A more immediate concern is in relation to banks, building societies and other financial services. Telephone banking and other financial services have been developing, and impacting significantly on organisations with large branch networks. Whereas a few years ago the concern was that such facilities were invading prime retail frontage, the issue is now more likely to be the reverse. That having been said, there may well be demand for units to dispense cash and undertake other services without direct staff involvement. There are a number of significant Town Centre buildings for which alternative uses may be required. 8.6 Floorspace and Expenditure Trends In aggregate terms the total retail and service floorspace in the Borough has risen between 1990 and 1998 by 10% (to 185,932 sq. m.). Within this there has been a 22% increase in food (or convenience) floorspace, a 2% decline in non food (or comparison) floorspace, a 115% increase in vacant floorspace Gravesham Local Plan 2 nd Review 130 Deposit Version

6 and a 10% increase in service floorspace. The stock of occupied retail floorspace has risen by 4%. During this period two food superstores, at Wingfield Bank and Coldharbour Road, have opened and additional retail warehousing at the Imperial Business and Retail Park has been developed. These together have added some 11% (19,054 sq. m.) to the overall floorspace total in the Borough, so counter-balancing losses which have occurred elsewhere in the stock. Vacancy rates have risen for all floorspace in the Borough from 6% to 11 %, specifically in Gravesend Town Centre (including Imperial) from 5% to 10%, but in the local centres from 11% to 22% The picture which emerges for the decade is one of retail expansion, but mainly by means of building out-of-town superstores and development on the Imperial Business and Retail Park. The local centres and traditional Town Centre have hardly changed in total floorspace (Town Centre has declined by 5%) but with increased vacancy rates (traditional Town Centre from 5% to 12%). When other data is examined, the pattern which emerges is of a Town Centre which has been managing to hold its own. In the context of out-of-town development, two regional shopping centres, and expansion in other neighbouring town centres, this is in fact a positive story. Provided that the Town Centre can develop its own distinctive niche in the market, and invest in its future, there is no reason not to plan for a positive future. The strategy of improving the environment, promoting accessibility, removing traffic, promotion and other measures has provided a sound basis for future development For the local centres, the 12% decline in occupied retail floorspace masks a much more mixed picture, with some centres doing significantly better than others. There is a tendency for some of the outer suburban centres to have done rather less well than the inner suburban ones. This could be related to superstore competition for the car-borne shopper, and the inner centres having a more captive and less mobile market. Two centres have in effect ceased to exist, Waterdales and Old Road West, both of which were very small. The shops in villages have also been under pressure. The most obvious feature in development control terms has been the steady demand for hot food shops (restaurants and takeaways - Use Class A3) Nationally, retail expenditure on food or convenience goods per person in real terms, that is discounting inflation, has only been growing slowly at about 0.4% per year. Non food or comparison goods expenditure has been growing in real terms at 3.7% per year per head, as a long term trend, despite the various recessions and booms of the economic cycle. This means that statistically (ignoring local economic circumstances) Gravesham residents can be expected to have more money to spend on comparison goods, but it does not of course say anything about how or where they spend it Food or convenience retailing, as indicated above, is not an area of growth in spending per capita, unless driven by significant population change. The immediate objective of housing provision policy currently is to stabilise the population decline which is occurring as a by-product of declining household size. Potentials indicate very limited scope for new floorspace. Much will be Deposit Version 131 Gravesham Local Plan 2 nd Review

7 met by efficiency gains from the existing stock. There is a need to allow for change in the market, and new large scale development, as for example at Ebbsfleet, will need new local floorspace provision Food provision in the Borough is dominated by five large stores (Asda, Safeway and Sainsbury s superstores, and Marks and Spencer and Tesco in the Town Centre) which account for 56% of the convenience floorspace. Other provision is in smaller-scale outlets (Kwiksave, Lidl) or small individual shops (though these are highly significant where they occur in the villages). In terms of normal retail use, Use Class A 1, there is normally no control on the type of goods sold. Therefore, there is no overall need to make specific allocations of additional convenience goods floorspace provision due to lack of demand in this Plan period The comparison goods sector has more potential for growth as real incomes rise, and without Bluewater there would have been scope for considering additional floorspace in North Kent. Work by SERPLAN has analysed the current and future expenditure and turnover for comparison goods at a sub regional scale for Rest of the South East (ROSE). This estimated Gravesend s 1996 Town Centre non food turnover at 1996 prices as m, with an additional i5.3m being generated by Imperial Business and Retail Park, giving a total of 61.3m. By way of comparison on the same basis, Chatham s turnover is estimated at 224.6m, Maidstone s at 186.2m and Tunbridge Wells at 214.9m. Bluewater was estimated as likely to have a turnover of 45 1 m The SERPLAN analysis looked into the future to 2011, taking account of possible population trends, increasing efficiency in the use of floorspace (1.5% per annum), demand from London and from centres within the metropolitan conurbation and the impact of mail order shopping etc. The latter is expected to rise from 7.5% of current expenditure to 10% to allow for the impact of the Internet and teleshopping. This work generated a negative requirement for additional floorspace. In other words, there is no need for additional comparison goods floorspace in Gravesham in quantitative terms on the assumptions made before The picture is not quite that simple as quality of the stock is as important as quantity, and retailing is constantly evolving. It is not enough to have the floorspace, it needs to be brought up to modern requirements. As indicated above, there may also be a demand for additional retail warehouse floorspace which cannot be met in the traditional Town Centre The Town Centre has capacity for additional turnover both through bringing existing vacant stock into use and opportunities for selective redevelopment or refurbishment. The floorspace stock needs to be kept up to date and modernised, so new development will in general terms be at the expense of the existing stock. This has implications for the geographical distribution of shops in the town centre, and is examined further in Chapter 4 of this Plan (Town Centre). Within the constraints of a historic centre, it is also important to retain long term flexibility for new retail development in the longer term, Gravesham Local Plan 2 nd Review 132 Deposit Version

8 should the historic growth rates be maintained. As a rule of thumb, shopping centres, be they specific developments like the St George s Centre or Gravesend Town Centre as a whole, need refurbishment about every 15 years or less to keep up to date A sub sector of non food goods is bulky goods, as exemplified by the retail warehouse units on the Imperial Business and Retail Park. The concept is retail units which provide goods which cannot be easily carried away, for example sand and cement from a DIY store. Other retailers, such as white goods (electrical) have tried to argue the same way, though in practice most such goods are delivered from a warehouse not from the store itself. The larger floorspace offers the opportunity to display many more goods, such as fridges and cookers, than is possible in the traditional town centre store From the point of view of the Town Centre, there is the question of whether further sites should be allocated for retail warehousing, or whether the existing location on the Imperial Business and Retail Park, and adjoining areas which have not been developed or could be redeveloped, constitutes an adequate floorspace supply. This would have the advantage of keeping such provision in the wider Town Centre, well located on the transport network and potentially providing opportunities for better integration between the traditional Town Centre and the retail part of the Imperial Business and Retail Park Local centres have a key role to play in the community and small retail units in these need to be encouraged. Convenience floorspace is over 60% of the provision in such centres and is the sector which has declined between 1990 and 1998, whilst comparison floorspace has remained relatively stable. Local shops in the rural area are vital for the local community, a matter which the Government has tried to address, for example through rate relief. Where significant new development occurs, it will be appropriate to consider whether a new small scale centre is required or existing ones expanded Work by Kent Thames-side on the potential of some of the large sites has concentrated on the concept of Public Transport Orientated Development (Ptod). This is the idea of a series of public transport nodes, with high density development and retail and services (including such facilities as primary schools) provision at 400m intervals (about 10 minutes walking distance). This concept can be applied to local centres (including the Town Centre, the Imperial Business and Retail Park and the superstores for this purpose). The same approach cannot be taken in the existing built-up area because the built form is already there, but there is none the less a logic in concentration of a range of services and a direct relationship with public transport The concept is relevant to sites where major growth will occur, for example North East Gravesend and Ebbsfleet. At the latter, the Station area (mainly in Dartford Borough) can be expected to provide a major focus, and development on this scale will generate its own local retail requirements. The proposed permission for Ebbsfleet limits the scope for retailing. In relation to Deposit Version 133 Gravesham Local Plan 2 nd Review

9 development at Springhead, it is logical to consider the role of Sainsbury s at Wingfield Bank as providing a focus for a local centre. 8.7 Local Plan Review Strategy The current Local Plan Review seeks to maintain the role of the Town Centre and local centres by not permitting retail development outside such locations unless they can be justified according to a set of criteria. Since the Plan was adopted, this basic approach has been successful and no further superstore or retail warehousing outside the designated locations has been developed. Pressures for retail warehousing have been contained within the Imperial Business and Retail Park. There is no reason to change this basic approach, enhanced and modified as appropriate The prime requirement must be to maintain and enhance the vitality and viability of the Town Centre and local centres in order for them to perform their roles better and more efficiently. The concept is to provide readily accessible basic retail facilities, which are ideally within walking distance for as many residents as possible, thereby minimising unnecessary travel. This objective is less achievable in the rural area where the population is more spread out, and the provision of any retailing at all is the issue. Policy RS1 General Policy on Retail and Service Proposals Retail and service proposals will be evaluated according to the following criteria: i. the sequential test on location (with Gravesend Town Centre as the primary town centre, followed by edge-of-town centre, local centres and only in exceptional cases, out-of-town); ii. a balance between uses should be maintained in centres to ensure that as full a range of facilities as possible is offered, subject to the scale and character of the centre concerned; iii. the impact of the proposals, both individually and cumulatively, on the vitality and viability the Town Centre and local centres; iv. the implications for public transport, parking and highways, in particular the range of means of accessibility and overall effect on travel patterns and car usage; and v. the other policies and proposals of this Local Plan Review Chapter 4 of this Plan deals with the Town Centre as an overall entity and considers its role with regard to retailing and services, its relationship with the rest of the Borough and issues that span all centres. The spatial definition of the Town Centre in this Plan, as shown by the Town Centre Inset, has been amended from the Local Plan First Review to focus on the core area of retail and service activity and therefore make sense of the PPG6 sequential test. This change has resulted in the inclusion of the retail development at the Imperial Business and Retail Park, and the exclusion of some of the housing areas to the east, west and south of the Town Centre. The traditional Town Gravesham Local Plan 2 nd Review 134 Deposit Version

10 Centre for retail purposes is defined as the area covered by the primary, secondary and tertiary shopping policies, which are set out below The Town Centre is seen as the prime location for retailing, whether by use of existing premises, major refurbishment or new-build. In considering this general stance, the specific site policies in Chapter 4 will need to be considered. This is in the context of a Town Centre specialising as an historic riverside town, and offering easy access to a range of food and convenience goods, as well as a full range of services. Opportunities exist for additional retail warehouse development or redevelopment in and around the Imperial Business and Retail Park to complement the Town Centre, and exploit opportunities to achieve more integration between them. Policy RS2 Gravesend Town Centre Gravesend Town Centre, as defined on the Town Centre Inset to the Proposals Map, will be the prime location for any new or redeveloped retail floorspace. The primary, secondary and tertiary frontage policies define the traditional Town Centre for retail purposes. The Imperial Business and Retail Park is for those businesses involved in bulky goods which the public normally collect directly from the store. Any site specific policies on land use have precedence. All proposals for retail or service uses will need to:- i. contribute to the vitality and viability of the Town Centre; ii. be of high quality design, and be acceptable in terms of the built environment and conservation policies (see Chapter 10 of this Plan); iii. not seriously detract from the amenity and functioning of any adjoining property and uses; iv. not cause the cumulative impact of any one use in a particular street to detract from the retail function or range of facilities provided; v. not cause the loss of existing, or the possibility of reinstatement of, separate accesses to upper floors; and vi. meet the requirements of transport policy, in particular car parking and access as appropriate to the location and use Within the Town Centre, it is possible to identify primary, secondary and tertiary retail areas. In view of the trade potentials and their physical condition, it is appropriate to focus on different policies in respect of each of these. In general terms, the amount of retailing, the quality of the stock and the environment declines as one moves away from the core retail area. In the primary area (New Road, the Angelsea and St George s Centres), the intention is that the composition and integrity of the core shopping area is maintained and enhanced, especially in the period of greatest impact from Bluewater. There is, however, considerable pressure for Use Classes A3 (restaurants, pubs, bars etc.) and D2 (leisure) uses, which if not resisted could seriously Deposit Version 135 Gravesham Local Plan 2 nd Review

11 undermine the retail core. It is also possible that a number of premises currently containing Use Class A2 uses (professional and financial services) may come forward for a change of use in the Plan period. The physical design of some of these properties would not make for an easy conversion to conventional retail use and, therefore, it may be appropriate, in specific circumstances, to consider Use Class A3 or other high footfall generating uses as offering a range of choice, diversity and vibrancy. This would need to be dealt with on a strictly case by case basis. Policy RS3 Primary Retail Area In the area indicated as primary retail frontage on the Town Centre Inset of the Proposals Map, the Borough Council will resist change of use at ground floor level or principal trading level for uses other than those within Use Class Al Within the secondary area, the aim is to retain the shopping character and function of the area and to complement the uses found in the core shopping area, in order to provide diversity within the Town Centre as a whole. The area has been reduced compared with the previous Local Plan Review, in the light of current levels of vacancy. The objective is to focus additional investment in the area to secure an improvement to the environment, though this has to respect the conservation area status of some of the streets involved. Policy RS4 Secondary Retail Area In the area indicated as secondary retail frontage on the Town Centre Inset of the Proposals Map, the Borough Council will not permit change of use at ground floor level or principal trading level for uses other than those within Use Classes Al, A2 or A3. All proposals will be subject to the relevant criteria of Policy RS2 of this Local Plan Review The tertiary shopping areas include the most marginal sectors of the Town Centre, and are the first thing shoppers and visitors see. They would benefit most from regeneration. In these areas a greater range of flexibility is proposed, to allow a range of uses which would not necessarily be appropriate at ground floor level in the primary or secondary areas. This approach is complementary to that adopted for those areas, and is in the context that most retail areas are within 400 metres of the geographic centre of the Town, and so are readily accessible by foot. Policy RS5 Tertiary Retail Area In the area indicated as tertiary retail frontage on the Town Centre Inset of the Proposals Map, the Borough Council will permit change of use to uses appropriate to an edge-of-town centre location, provided that the proposal meets the relevant criteria of Policy RS2 of this Local Plan Review. Gravesham Local Plan 2 nd Review 136 Deposit Version

12 8.7.8 There is a considerable amount of vacant floorspace throughout the Town Centre in the upper floors of shops and commercial buildings. This is clearly an under-used asset and the policy aim is to create a more sustainable Town Centre by securing better use of its buildings, which in turn will lead to economic and townscape improvements. There are practical problems to do with acceptability of the juxtaposition of some uses, which can only be handled by the development control process in the light of circumstances at the time. Policy RS6 Upper Floors Within the Town Centre Inset, the Borough Council will permit the use of upper floors of premises as residential, business, leisure or uses appropriate to the area provided that the proposal meets the relevant criteria of Policy RS1 of this Local Plan Review and: i. results in better utilisation of the building as a whole; and ii. does not lead to the loss of any existing residential accommodation, unless the building is unsuitable for such a purpose The local centres are defined on the Proposals Map. Due to the change in the definition of the Town Centre boundary, the Wrotham Road shops are now shown as a separate local centre. Local centres at Old Road West and Waterdales have been removed. Local centres should be regarded as foci for the local community, with each ideally also having a range of other social and community facilities located at or near them. Each centre has its own characteristics and it is not possible to be prescriptive. The policy is to attempt to enhance local centres by:- maintaining their retail and service mix and floorspace; encouraging intensification of uses where appropriate; treating them as transport nodes if practicable; and encouraging the provision and/or maintenance of other services (libraries, primary schools, doctors surgeries etc.) Policy RS7 Local Centres Local centres, as defined on the Proposals Map, will be supported, enhanced and protected from a loss of floorspace from retail or service uses. Where appropriate, local centres will be encouraged to develop their own distinctive characters but not at the expense of their local walk-in function. Over dominance of service uses will be resisted Superstores are a special case of a local centre, since they can function as local walk-in centres, as well as their more obvious role as bulky food shopping centres for a much larger catchment. Given their wider role, they have scope by means of diversification and/or expansion to damage the Town Centre and existing local centres. At Wingfield Bank, there is scope to expand the existing facilities as the development of the Springhead Quarter of Ebbsfleet goes ahead to serve the new community to which it must be closely related. In Deposit Version 137 Gravesham Local Plan 2 nd Review

13 the main core of Ebbsfleet around the international and Domestic Station, retail provision will also be needed but the majority is likely to be located within Dartford Borough. Policy RS8 Superstores Superstores, as defined on the Proposals Map, will be treated as other local centres, provided that any proposals for expansion and/or alteration can be demonstrated as not having a significant impact on the vitality and viability of the Town Centre or other local centres. At Wingfield Bank, expansion of facilities will be encouraged in the context of, at a form appropriate to and at a rate commensurate with, the development of the Springhead Quarter of Ebbsfleet. Village Shops Village shops, where they form a cluster, are treated as local centres. in some cases, however, there is only one shop, the loss of which would be highly significant for the local community. The Borough Council cannot guarantee the continued existence of such shops, since this requires a willing retailer, but changes of use or redevelopment will be resisted where possible. The relevant policies are set out in Chapter 11 (see Policies RA17 and RA18) of this Local Plan Review. Use Class A There has been a great deal of pressure in the Borough for conversion of retail units to Use Class A3, restaurants, take-aways, pubs, bars etc. This can be an effective way of enhancing a local centre, but it can also create dead frontages, traffic problems, and noise and disturbance (particularly at night). Adjoining residential uses pose a particular problem and a balance has to be struck between the various factors, especially where the level of background noise is low. Extraction flues, ventilation equipment, plant and machinery are problematic in the case of listed buildings and conservation areas because of their impact on visual amenity. It should be noted that much of the Town Centre lies within a conservation area, and there are many listed buildings. Take-aways can give rise to highway and parking problems, due to demand for short-term parking outside the premises Once planning permission has been granted for a use within Use Class A3, there is considerable flexibility as to the actual type of establishment which can operate. The Borough Council is keen to promote places to eat and drink within the Town Centre, within the constraints of the policies above and residential amenity. Conditions will be imposed on any Class A3 use to reduce the impact, for example by removing the take-away facility, controlling hours of operation. If such problems cannot be satisfactorily overcome by the imposition of conditions, planning permission will be refused. Amusement Centres Amusement centres also give rise to similar issues due to the creation of dead frontages, noise and disturbance, and are specifically covered in an annex to PPG6. This emphasises that their most appropriate location is in secondary Gravesham Local Plan 2 nd Review 138 Deposit Version

14 shopping areas, but that account has to be taken of their impact on visual amenity, noise and disturbance, adjoining uses and their appropriateness in conservation areas. They will be judged against similar criteria to Use Class A3 uses and refused where the imposition of conditions cannot overcome any problems. Policy RS9 Food & Drink Uses and Amusement Centres Planning permission will be granted for changes of use to Use Class A3 (Food and Drink), and amusement centres within the secondary and tertiary areas of the Town Centre and the local centres, subject to the following criteria:- i. the proposal should not adversely affect the amenity of residential occupants by virtue of the emission of noise, smell, fumes or other disturbance associated with the use of the premises; ii. the proposal shall not be detrimental to highway safety; iii. any extraction equipment, plant or machinery required in connection with the use shall be discreetly located on or in the building; iv. the proposal shall not create or add to a concentration of non retail uses within a particular area and cause harm to parking or residential amenity in the vicinity; and v. the proposal shall respect the character and amenity of the location. Footnote: As defined in the Town and Country Planning (Use Classes) Order 1987 as amended. 8.8 Sustainability Appraisal This chapter contains policies which seek to protect the retail and service functions of the Town Centre and local centres and only allow new facilities where these are in line with the sequential approach and do not adversely affect existing centres. The sustainability appraisal indicates that the policies generally have positive impacts in terms of the various sustainable development categories and this is particularly the case in terms of providing facilities for use by the community The effect of the policy relating to the tertiary retail area on economic considerations, social stability and choice is unknown at this stage, given the uncertain nature of uses which will come forward. Deposit Version 139 Gravesham Local Plan 2 nd Review

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