IRERE KINGDOM 1 LIMITED & IRERE KINGDOM 2 LIMITED

Representation to the December 2011 South Core Strategy Post-Submission Changes

The Mall/Cribbs Causeway Policy CS14

Introduction

IRERE KINGDOM 1 LIMITED & IRERE KINGDOM 2 LIMITED (IRERE) are the owners of the Galleries Shopping Centre in the centre of .

The Galleries shopping centre opened in 1991. It comprises 29,000 sqm of retail floorspace with a large shoppers’ car park of 932 spaces. Key retailers include Argos, Boots, TK Maxx, Waterstones Laura Ashley and WH Smith.

The Galleries forms a key part of the Bristol City Centre sub-regional shopping centre which includes , opened in 2008, which itself formed a major extension to the shopping centre. The Galleries shopping centre fronts both Broadmead and the Quakers Friars part of the Cabot Circus development.

IRERE made a key investment within Bristol City Centre on the basis that the city centre provides the focus for the sub-regional shopping needs of the Bristol catchment area and that in the context of the ‘town-centre first’ policy embedded in the Government’s retail policy, future development needs of the Bristol sub-region would continue to be focused within the city centre and other designated centres.

Like many other shopping areas in the UK, the Galleries shopping centre has suffered in recent years as a result of: first, the key shift of retail focus in Bristol City Centre as a result of the opening of Cabot Circus; second, the current economic downturn which has resulted in several retail closures; and third, changes in consumer behaviour, from internet shopping to challenges from out-of-centre stores.

Currently the vacancy rate in the Centre is running at nearly 14% of total lettable floorspace which has increased from 8.9% in September 2011, plus there is a further 23% of floorspace in temporary lets.

IRERE considers that it is very important in the current climate to ensure that the prevailing conditions for existing retailers in the city centre are as strong as possible, with no threats from edge- or out-of- centre development. The Galleries Shopping Centre remains vulnerable to further changes in market conditions and to outside threats.

It is on this basis that IRERE has reviewed the December 2011 Core Strategy incorporating Post- Submission Changes, and in particular Proposed Policy CS14 relating to further expansion of the Mall/Cribbs Causeway.

IRERE has also had sight of Bristol City Council’s (BCC) draft representations on the December 2011 Core Strategy and fully supports the comments contained in those representations.

Background to the Core Strategy

South Gloucestershire Council submitted its Core Strategy Development Plan Document to the Secretary of State on 31 March 2011 for Examination.

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Following the submission of the Core Strategy the Inspector appointed to undertake the Examination requested that the Council undertakes further technical work. The Council has now undertaken this work which has resulted in a number of Post-Submission Changes to the Core Strategy.

In December 2011 The Council published the December 2011 Core Strategy incorporating Post- Submission Changes, for consultation. The deadline for making representations is Friday 17 February 2012.

On 19 January 2012 the Council published further retail evidence base documents including:  Report by Nathaniel Lichfield & Partners (Dec 2010) on the catchment area and role of The Mall Regional Shopping Centre, to support their representations to the Pre- Submission Core Strategy;  Report by Roger Tym & Partners/Hollissvincent (July 2011) reviewing the Nathaniel Lichfield & Partners report;  Update to the Town Centre and Retail Study 2010 and Retail Impact Assessment of potential growth in floorspace at The Mall Regional Shopping Centre, Roger Tym & Partners (Dec 2011).

IRERE is concerned that significant changes are being brought forward to the Core Strategy at this late stage in the consultation process. The evidence base which seeks to support these changes was only published on 19 January 2012, some three weeks after the publication date of the post submission changes. The consultation period only provides four weeks to fully review these documents.

On this basis IRERE queries the soundness of the consultation process which prejudices participants to make a full case in response to the proposed significant changes.

Notwithstanding this, IRERE is particularly concerned about proposed Policy CS14 and its related Policy CS26 as follows:

Lack of consideration of impact on Bristol City Centre:

Policy CS14 seeks in the first instance to protect and enhance the vitality and viability of existing and new centres in and these are listed within the policy. The policy also seeks to direct new investment in town centre uses to existing and emergent centres including making provision for 34,000 sqm of new comparison floorspace by 2026.

Provision is made for 18,000 sqm of this 34,000 sqm to be provided at the Mall Regional Shopping Centre. However, the policy then goes on to allocate a further 17,000 sqm of new comparison floorspace provision at the Mall by 2026; resulting a total allocation of 35,000 sqm at the Mall in the period to 2026.

Thus the total retail provision for the South Gloucestershire area to 2026 is 51,000 sqm; which is 20,000 sqm more than the proposed figure in the March 2011 Submission Document (31,000 sqm net of new comparison floorspace by 2021, with no reference to emergent centres or to any additional provision at Cribbs Causeway/the Mall).

Cribbs Causeway is now listed as an emergent Centre. The December 2011 policy provides no consideration of the impact of promoting further development of emergent centres, which currently have no town centre status, on other centres within the sub–region, including Bristol city centre. BCC

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in its representations states that the approach of the policy is flawed as it fails to recognise that the catchment for Cribbs Causeway is much wider that the South Gloucestershire boundary and no account has been taken of the impact of extending a sub-regional shopping attraction at Cribbs Causeway, including the impact on Bristol city centre. IRERE agrees that it is not justified for South Gloucestershire to adopt a unilateral approach and on this basis the policy is unsound.

BCC in its representations comments that the proposed increase in the retail allocation for the South Gloucestershire area is not supported by the advice of the Councils retail consultants, Roger Tym and Partners (RTP), this compounding the impact of the proposals.

IRERE supports BCC’s comment in relation to the assessment of retail needs on the basis that the assessment should take account of the need for retail floorspace across the whole area, including quantitative and qualitative indicators and that there should be a series of options for accommodating development within existing centres, including those within the sub-regional catchment area, including Bristol City Centre.

IRERE agrees that the conclusions drawn from the evidence base and thus the Post Submission Changes are fundamentally flawed.

No justification for the change in emphasis of approach

The Post Submission changes are based on the assumption that Cribbs Causeway/the Mall is the largest retail destination in South Gloucestershire and its importance needs to be recognised.

The previous approach of the Core Strategy was that there is a need to serve local new communities which are to be developed. However the emphasis has changed with recognition in the Core Strategy now that the out of centre Mall had a wider sub-regional role which should be recognised. However no consideration is given to how the shopping needs of the area could be accommodated in more central established locations such as Bristol city centre.

If the Cribbs Causeway/the Mall is able to secure town centre status this will remove any future barriers to further expansion, given PPS4 does not require retail need or the sequential approach to be justified in the case of town centre development. This has not been considered in the evidence base or the policy justification.

PPS4 is clear in that it seeks to ‘promote the vitality and viability of town and other centres as important places for communities’. It promotes the sequential approach placing out of centre locations as the last resort. Cribbs Causeway/the Mall falls within that category.

The emerging NPPF also seeks to promote the vitality and viability of town centres and does not mark any shift in the Government’s approach away from ‘town-centre first’. The draft policy requires authorities to ‘recognise town centres as the heart of their communities and pursue policies to support the viability and vitality of town centres’. In the context of the Bristol sub-region, it is incumbent on South Gloucestershire Council to take account of impact of its emerging policies on established town and city centres, including Bristol city centre.

IRERE’s Key Concerns

IRERE, as a major investor in Bristol city Centre is concerned that the potential large scale expansion of the sub-regional shopping centre at Cribbs Causeway/the Mall will have a significant detrimental

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impact on Bristol City Centre on the basis that it will divert trade from the city centre and prejudice the bringing forward of new retail investment in the city centre.

There is no basis in PPS4 or emerging national policy to support directing new retail floorspace to emergent centres. IRERE is very concerned about the potential allocation of Cribbs Causeway/the Mall as a town centre in the future on the basis this would provide the basis for unfettered further expansion in the future. Whilst there may be justification for small scale additional retail provision to meet local needs in the Cribbs Causeway area, to allocate 35,000 sqm to an out of centre site that has a sub-regional catchment flies in the face of well established and emerging national policy.

The change in emphasis of the Core Strategy since 2010/2011 has not been justified and it is not supported by the evidence base.

The Proposed Post Submission Changes are thus unsound on the basis that they take no account of impact on established centres, do not consider other options for growth and the need to take account of local and sub-regional needs.

IRERE thus objects to Policy CS14 of the December 2011 South Gloucestershire Core Strategy Post Submission Changes.

GL Hearn February 2012

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