Wakefield East Consortium City Fields Representations to the Retail & Town Centre Local Plan

31 July 2013

Contents

1. Introduction and Background ...... 5

2. Statutory Policy Context and Other Relevant Policies ...... 7 2.1. Statutory Development Plan...... 7 2.2. National Planning Policy Framework ...... 9

3. Existing Foodstore Provision in the Wakefield Urban Area ...... 10

4. Responses to Specific Questions within the Wakefield Retail & Town Centre Local Plan Early Engagement Consultation ...... 12 4.1. Question 1...... 12 4.2. Question 2...... 12 4.3. Question 3...... 12 4.4. Question 4...... 13 4.5. Question 5...... 14 4.6. Question 6...... 19 4.7. Questions 7-17...... 19

5. Appendix ...... 20

Key

The Site

1. Introduction and Background

Wakefield East Consortium (WEC) are promoting the comprehensive development of an urban extension east of Wakefield, known as City Fields.

The site is allocated in the Site Specific Proposals Document (SSPD) as a Special Policy Area (SPA2) that has been secured through extensive working and negotiation with Wakefield Metropolitan District Council and an Examination in Public.

Spawforths have been instructed to promote the site for development by making representations to the Wakefield Retail & Town Centre Local Plan Early Engagement Consultation June 2013.

The land is approximately 146 ha in extent and is in the east of the Wakefield urban area located between the Aire & Calder Navigation and the existing built up areas of East Moor incorporating both brownfield and greenfield land. The site extends from the A638 Doncaster Road in the south to Ferry Lane/ Aberford Road in the north. The site is irregular with the largest development area to the east of Aberford Road/Bar Lane, close to Pinderfields Hospital.

The completed development will comprise of approximately 2,500 houses, employment and supporting infrastructure including the Wakefield Eastern Relief Road, as well as community services and facilities. As part of the proposals and as identified in the SPA allocation, the site:

“could include neighbourhood or district centres to accommodate ancillary retail, leisure, education and community uses. The scale of these ancillary or complementary uses will reflect the scale and function of the Special Policy Area and should accord with the Core Strategy, Development Policies and national planning policies”.

The scale of the development and extent of the site justifies the need for new supporting facilities, which will be located in a new District Centre close to Pinderfields Hospital. As the site extends to some 3 km from north to south, there is also the potential for a new local centre in the south as well as potential local or neighbourhood facilities part way through the site, as part of a marina development on the canal. These are all set out in the Masterplan Framework document produced by Spawforths on behalf of the WEC. These

elements must be considered and recognised within the emerging Wakefield Retail & Town Centre Local Plan.

2. Statutory Policy Context and Other Relevant Policies

2.1. Statutory Development Plan

The statutory development plan for Wakefield comprises the:

• Wakefield Local Development Framework (LDF):

o Core Strategy (CS), April 2009 o Development Policies (DP), April 2009 o Site Specifics Proposals Document (SSPD), 12 September 2012 • Wakefield Unitary Development Plan First Alteration adopted January 2003 (UDP):

o The LDF replaces many of the policies in the UDP. However the remaining saved policies of the UDP, including Retail, Leisure and Open Space policies, remain part of the statutory plan.

2.1.1. LDF - Core Strategy The Core Strategy identifies the places where most development should take place and those where development ought to be limited, in order to create sustainable communities.

The key policies relating to this application within the Core Strategy are as follows:

• Policy CS1 - Location of Development directs development including mixed-use development to the main urban areas with the ‘largest amount’ within the sub- regional . • Policy CS2 - Retail and Town Centres promotes Wakefield City Centre as the primary centre and then Castleford and Pontefract as secondary centres. It acknowledges the role of other centres and that other retail provision will be of a scale appropriate to the size and function of the centre. • Policy CS4 - Sustainable Transport seeks to ensure that development is located in a way that it maximizes accessibility and reduces the need for travel by the private car. The thrust of the Policy is aimed at identifying how development such as housing may be justified in terms of how it is located close to shops and services. In the case of City Fields (Wakefield East), a large urban extension is proposed in an area with little existing provision by way of shops and services. Provision of these elements within

the scheme may be considered in the following context, “development which generates a large number of passenger movements should be located in Wakefield city centre, in other town centres in the main urban areas or at locations which provide convenient access on foot, by cycle and public transport”. [our emphasis]

2.1.2. LDF - Development Policies The Development Policies document provides more detailed policies that link to the Core Strategy Policies. The majority of Policies relate to detailed design matters and do not need to be set out here.

2.1.3. LDF - Site Specifics Proposals Document The Council has the Site Specifics Proposals Document (SSPD), as part of the LDF. The SSPD provides a set of site allocations and proposals to take forward the vision, objectives and development strategy of the Core Strategy. The document includes land allocations to meet anticipated development needs relating to housing, employment and mixed use development. These proposals replace equivalent allocations and designations in the saved UDP. City Fields (Wakefield East) is identified as a Special Policy Area (SPA2) within the SSPD. The Policy states that:

“The masterplan proposes a range of developments and uses, including residential, employment (mix of light industrial, warehousing and office uses) and recreational, environmental and community facilities.”

The supporting text states:

“Special Policy Areas are areas that are considered suitable for more than one use, or need to be developed in the context of a primary use, supported by ancillary or complementary uses. Such ancillary or complementary uses could include neighbourhood or district centres to accommodate ancillary retail, leisure, education and community uses. The scale of these ancillary or complementary uses will reflect the scale and function of the Special Policy Area and should accord with the Core Strategy, Development Policies and national planning policies.”

2.2. National Planning Policy Framework

The National Planning Policy Framework directs Local Planning Authorities to prepare positive plans that seek opportunities to meet the development needs of their area and that whilst they should meet objectively assessed needs, there should be sufficient flexibility to adapt to ‘rapid change’. At the heart of the NPPF is the presumption in favour of sustainable development, which should be seen as a ‘golden thread’ running through both plan making and decision taking.

The NPPF places an emphasis on ‘ensuring the vitality of town centres’. It indicates that policies for town centres should be positive and promote competitive town centre environments. They should identify town centre boundaries and primary and secondary frontages. There is also a need to allocate a range of suitable sites to meet the scale and type of retail, leisure, commercial, office, tourism, cultural, community and residential development.

The Framework is led by a need to build a strong and competitive economy which means promotion and positive planning for centres as part of a pro-growth agenda. It recognizes a need to promote sustainable growth.

The key tests for Local Plans, and for them to be considered as ‘sound’, are whether they are positively prepared, justified, effective and consistent with national policy. The NPPF is clear in terms of the need to ensure viability and deliverability of development and related infrastructure.

The ‘needs’ test has was removed from national policy and is no longer a retail test. This was removed as it was felt that it did not sufficiently assess the merits of a scheme and how it impacts on existing centres. It also did not reflect the need for fair competition and choice in any particular area. It was considered that the emphasis for National Policy should be on the sequential approach and the retail impact (both quantitative and qualitative) of new stores. Capacity is still assessed as an indicator of how significant impact may be.

3. Existing Foodstore Provision in the Wakefield Urban Area

The City Fields development will include at least one new centre. The centre is likely to have a range of retail and service uses, which will serve a localised catchment. The Masterplan Framework shows the centre in the north close to Pinderfields. It will be anchored by a foodstore/supermarket to provide a main food shopping function to serve the north-east of the City. The scale is yet to be confirmed but we expect it to fulfill a District centre function in terms of role, offer and scale. However, before responding directly to the question posed by the consultation, it is worth noting the existing foodstore provision in the Wakefield Urban Area and relative proximity to the urban extension.

Existing main food shopping provision in the main urban area of Wakefield is led by large stores close to the city centre. There are two main in-centre stores in the form of Morrisons in the Ridings Centre and Sainsburys in the Trinity development. There is a Sainsburys on Ings Road to the south of the city centre and a Morrisons further to the west on Dewsbury Road. Asda have a large facility at Sandal in the south of the urban area.

A plan of existing supermarkets and larger local stores is appended to this submission.

This demonstrates that the stores are clustered in and around the city centre and in the south and west of the Wakefield main urban area. The outlying areas are served by small facilities that can only provide for ‘top-up’ shopping opportunities and therefore are likely to require travel (or home delivery) for the majority of people living away from the larger stores.

There is little by way of provision even at the smaller scale close to the City Fields site. There is a relatively new Co-op at Outwood, and Asda has recently converted a Netto in Normanton to the north-east following their acquisition of the store portfolio. This is larger than a local convenience store, but does not have the full range of produce that you would expect from a large supermarket. Towns to the north of the M62 such as Castleford and Rothwell have main food shopping provision in the form of large stores, although the M62 can be classed as a physical barrier and these are certainly in no way easily walkable from the proposed urban extension.

The north and east of Wakefield have seen significant growth in terms of new housing development which will be further added to with the proposed housing at City Fields, Newton Hill and various other significant sites. The 2013 Retail Study indicates that residents in the north-west of the District prefer to shop at Asda in Morley (out of centre facility in District) rather than Wakefield city centre. Similarly areas in the south use the out-of-centre Asda at Sandal.

Sainsburys now have two stores in close proximity after occupying and then re-opening their out-of-centre store on Ings Road.

4. Responses to Specific Questions within the Wakefield Retail & Town Centre Local Plan Early Engagement Consultation

4.1. Question 1

Are there any other specific pieces of evidence that the Council should consider in preparing the Retail and Town Centre Local Plan?

The City Fields (Wakefield East) Special Policy Area has been identified for comprehensive development within the adopted Sites DPD. The allocation has arisen out of a comprehensive masterplan approach to development, which continues to evolve as the development is being promoted through the development management process. Reference should be made to the City Fields Masterplan and its importance in this context, as there will be supporting town centre uses within the District Centre and supporting neighbourhood centres within the urban extension and these need to be acknowledged in this Local Plan.

4.2. Question 2

Do you think these objectives are appropriate, should there be any others?

The objectives are supported in principle with particular support given to the need for growth and prosperity for all sections of the community as well as sustainable development to meet the needs of the population. The principle of creating a retail hierarchy is consistent with national policy.

The objectives fail to directly acknowledge Special Policy Area sites such as City Fields (Wakefield East), although it is indicated that development will be directed to the Wakefield urban area which includes the site.

4.3. Question 3

Should a retail hierarchy be established for the town centres and other shopping locations within Wakefield district? Do you think the order should be different? Are there any other centres that should be included or should any be omitted?

The first two tiers of the retail hierarchy are supported in principle as this reflects Wakefield at the primary centre with Castleford and Pontefract as secondary, but significant, centres.

What the hierarchy does not take into account is the potential for new centres either within existing allocations (e.g. the Special Policy Areas) or within new developments. New District Centres are identified within the SSPD and hence this Local Plan Policy should reflect their potential and mechanisms by which they may be identified as such either in this Plan or future revisions. The typology of centres will need to be reconsidered as it relates predominatly to ‘city’ and ‘town’ centres and makes no reference to where District centres would sit which is inconsistent with adopted policy which identifies the potential for such.

4.4. Question 4

Should any of the retail areas be enlarged or reduced? Should any new retail areas be identified for centres currently without such a designation?

A new District Centre needs to be allocated at City Fields (Wakefield East) as identified in the SSPD Policy for the SPA. This needs to be formally identified as part of this Local Plan. The scale of housing as well as a clear deficiency of main food shopping opportunities in North Wakefield (as confirmed by the Retail Study) indicates that a District scale centre would be appropriate at this location. The exact make up of the centre and quantum of floorspace of any facilities will need to be justified at the appropriate time, but as we set out in response to Question 5, the recently released Retail Study is clear that there is an opportunity for a new foodstore based on the growth being proposed in the primary catchment (the Wakefield urban area including the City Fields (Wakefield East) SPA).

Planning Policy Statement 4 (now replaced by the NPPF) identifies District, Local and Neighbourhood Centres as follows:

“District centres will usually comprise groups of shops often containing at least one supermarket or superstore, and a range of non-retail services, such as banks, building societies and restaurants, as well as local public facilities such as a library.

Local centres include a range of small shops of a local nature, serving a small catchment. Typically, local centres might include, amongst other shops, a small supermarket, a newsagent, a sub-post office and a pharmacy. Other facilities could include a hot-food takeaway and launderette. In rural areas, large villages may perform the role of a local centre.

Small parades of shops of purely neighbourhood significance are not regarded as centres for the purposes of [this] policy statement.”

There is to be a District Centre in the north of City Fields and two smaller centres to the south, which may be local or possibly neighbourhood centres depending on the retail offer to be proposed. The ‘middle’ centre is likely to relate to a character area that incorporates the canal frontage with potential for a marina. There is also potential for a centre in the south on or near Doncaster Road comprising local facilities.

These will be progressed as part of the masterplanning exercise, and then by planning application at the appropriate point in time. However, it is necessary to recognise the firm intention and need to provide these new centres and this should be reflected in the retail hierarchy and on the Proposals Map.

4.5. Question 5

What is your experience of shopping in Wakefield district? What centres do you visit and do they offer a good range of shops and services? Are there any deficiencies?

The Retail Study 2013

The Retail Study 2013 has been produced to inform the Wakefield LDF, in particular the Retail & Leisure Local Plan. It should be noted that this form of development was largely omitted from the previous LDF documents and the Retail Study has not informed the overall strategy for the District. That said, it does provide an up-to-date position and commentary on the retail position within the District including population and expenditure data and an indication of the state of health of the various existing centres. The Study has only just been released for public viewing and whilst the findings will be used to inform the next stages of the Plan there has been insufficient time to fully analyse the recommendations. We will

therefore seek to engage with the Council on an ongoing basis, but also reserve the right to comment further once we have considered the document in greater detail.

At paragraph 8.26 of the Retail Study, it is claimed that there is no quantitative need for new convenience retail provision up to 2026. It then states at paragraph 8.33, that there is no qualitative need for new floorspace in the early phase of the emerging Plan, but that, ‘the critical strategic matter in relation to new foodstore provision in Wakefield city over the plan period is spatially based’ [our emphasis]. We do not support the suggestion that there is no potential for new convenience retail facilities, but will analyse the Study in greater detail and reserve our position to provide further comment once we have done so.

The Study highlights that in Zone 2 of the identified catchment, which includes the Wakefield urban area (and the City Fields (Wakefield East) SPA), there is planned growth of c.6,500 new homes (including 2,500 at City Fields) which the Study estimates will provide c.£26m of additional convenience goods expenditure which would justify a new mainstream foodstore.

The Study (Para. 8.36) recommends that the Council seeks to identify the quantitative needs for a foodstore at a later stage (i.e. 2018). We would reject such an approach as there is a need to understand what the planned growth will mean in terms of need for new facilities. Deferring this consideration is not sound in what should be a positive, pro-growth agenda which is plan-led. The planned growth is being delivered with applications being processed for new housing at City Fields and the Masterplan Framework produced which sets out the later phases of delivery including likely trajectory. In planning for significant strategic sites, there is a need to understand the form of the overall development and likely components to be able to ‘fix’ parameters and to enable masterplanning and Travel Pattern Planning for the urban extension.

It is important that strategic scale development with significant housing provision is planned effectively with the correct mix of services and facilities (particularly including convenience retail). There is a need for certainty as without this, it can impact on delivery in terms of viability and the greater potential for piecemeal development. It will also leads to creation of unsustainable travel patterns which tend to persist even after services and facilities are provided nearby. This Local Plan must therefore include the planned District Centre (and other Town Centre uses) at City Fields and the facilities that will be provided there. It must

also consider early delivery of retail provision with scope for it to grow as the site is delivered.

Current Provision & Patterns of Trade

The position in terms of existing provision is not exactly clear as Sainsburys are operating two stores in close proximity (Trinity and Ings Road) and both are underperforming against the expected benchmark turnover (most likely as a result of the proximity). The Morrisons within the Ridings Centre also performs below company average, but again, there is a more modern (out-of-centre) store on Dewsbury Road, to the east of the City that is performing well. Asda, Sandal is performing above benchmark as is the nearby Aldi. The Asda draws its trade from across the district, particularly the rural south (50% of trade), but 12.8% comes from the Wakefield urban area.

It is identified that Zone 2 retains 82% of convenience goods expenditure for main food shopping. It is considered that this market share could increase to retain a greater level of trade. Leakage is mainly to facilities outside of the District (Morrisons, Rothwell and Asda, Morley – both in Leeds District). The Asda is also out-of-centre.

The Study indicates that there will be capacity for around £9m-£10m for convenience goods floorspace in Zone 2, although it suggests that this might be directed to Ossett which has low trade retention. It then indicates that the impact on existing in-centre facilities arising from a new store in Ossett may not be acceptable. Whilst retention levels are less than the main urban area, the town is small and serves a localised catchment. In our view, any additional expenditure would be better retained in the Wakefield urban area to seek to increase the expenditure retention rate.

The Spatial Imbalance

The Study identifies that in North Wakefield there is a lack of a mainstream foodstore in or close to Stanley and Outwood, meaning that existing centres secure just 2.1% of the main food market share. In terms of top-up shopping, the centres fare no better with just 7.3% of the market share. This is a clear indication of the spatial ‘imbalance’ in the District and the need for a rebalancing in qualitative retail need terms.

The Retail Study confirms that the City Centre, Central & West and South & East areas of Wakefield are each directly provided for in terms of large convenience retail facilities. The retention rates vary depending on the location, but ultimately this relates to their respective positions and catchements. Central stores retain their higher market share from Zone 2. Asda in the south serves the southern District, hence a 12.8% market share from Zone 2. The West is served by Morrisons (which also appears to serve western settlements such as Ossett).

However, the North is not directly served by main food shopping facilities and has a negligible retention rate and market share. There is no available facility without need for travel.

The proposed significant planned housing create an imperitive for focusing new provision in that area. As indicated above, direction to Ossett is not necessary and would do more harm than good.

Additional provision could be considered at Outwood, but it has an existing Co-op store, and provision of a significant facility at this location could lead to increased competition for the western settlements including Ossett. It is not considered that there are any suitable sites in Outwood in any regard. Stanley has little in the way of provision, but would not be appropriate in itself as a location for a District scale facility. The proposed District Centre at City Fields will provide a location that is far enough away from existing facilities and centres to minimize adverse impact, but sufficiently well related to the main urban area (including significant planned population areas) to be sustainable and acceptable in terms of Policy requirements.

The Proposed Approach

The North of Wakefield is characterised by significant, planned population growth alongside a lack of quality main food shopping opportunities. The City Fields District Centre provides an opportunity to locate a new food retail facility to serve the northern area and the new proposed housing areas as allocated by the SSLP at Newton Hill and City Fields. The District Centre will be located to relate to the existing ‘health hub’ at Pinderfields Hospital (a significant and established destination serving the wider District and the Region), and in an area of sufficient prominence, but also least provision, at the Junction of the Wakefield East Relief Road.

A small facility would simply provide additional top-up offer and do nothing to retain trade in the north of the Town. A larger facility would compete directly with other large facilities on a like-affects-like basis and would claw back trade flowing out of the District and increase the District’s overall market share. Claw back would also be expected from out of centre facilities within the District (not a material consideration in impact terms), particularly Asda, Sandal. That store is currently overtrading according to the Retail Study and impact would be acceptable.

It is considered that the centre would be of a similar scale to the out-of-centre retail and commercial uses at Asdale Road, Sandal, anchored by a main supermarket and complementary facilities. Other similar examples would be Seacroft in Leeds, located on the Leeds Ring Road and serving the east of the City with a main foodstore and a range of other unit shops, or Holderness Road District Centre in Hull which has a range of shops anchored by an Asda at its southern end, but including other unit shops – the form of this centre is linear and not what is proposed at City Fields, but the Centre provides a good example of what is appropriate in line with the PPS4 (NPPF) description.

There is a need to rebalance the retail regime in the District which will rduce leakage and provide sustainable development through reduction of the need for travel which will mean reduced CO2 emmissions. The District Centre at City Fields will provide that in a sustainable location.

The District Centre will be delivered as an early phase of development (the first phase involves housing and related infrastructure). The centre will also facilitate the delivery of new infrastructure and housing and enhance the overall deliverability and viability of the important strategic scheme.

Summary

In summary, a District Centre will be provided at City Fields and needs to be formally identified within this Local Plan. This is consistent with national Policy, but also with the current adopted LDF (particularly the SSP DPD). There is a clear deficiency in the north and east of the city and provision of a main food facility here is appropriate and necessary. This will helps to deliver the wider strategic scheme, but also builds on an established

regional destination at Pinderfields. The proposals are sustainable and appropriate in Policy and in terms of rebalancing existing deficiencies.

4.6. Question 6

Do you have concerns about non-retail uses in shopping frontages or the over- concentration of particular uses?

It is fairly well established that centres should be protected and predominantly provide a Class A1 retail function. Overconcentration of non-retail uses can have a negative impact on a centre, evidenced by the large proportion of residential uses on main frontages in Featherstone, for example.

However, it is acknowledged that retail is no longer a guaranteed occupier in centres and there is a rise of café culture and ‘dwell time’ whereby other uses can contribute to a vibrant centre. The Portas Review identifies that the role of the centre is changing and there is a need for greater flexibility to allow units to be brought into use rather than lay vacant especially where Policy restricts alternative uses. Proposals should be considered on their individual merits, although can be subject to a criteria based policy.

4.7. Questions 7-17

No comment at this stage.

5. Appendix

Plan of Existing Facilities

[add stores and key]

L

L

Key

L The Site

Sainsburys (L = Local)

Morrisons

Asda

Tesco Express

Lidl

Aldi

Co-operative