Proposed Modifications to the Thanet Local Plan

Document Section Main Modifications Chapter 2 -Town Centre strategy MM/019 MM/019 [View all comments on this section]
Comment ID 139
Respondent Burnett Planning - Burnett Pla… [View all comments by this respondent]
Agent Burnett Planning - Burnett Pla…
Response Date 27 Jan 2020

Regarding Westwood Town Centre, the proposed Modification makes it clear that Policy E04 presents the criteria against which the acceptability of proposed uses in the Town Centre will be assessed. The retention of the wording - "Any development proposals should ensure there is no net loss in overall commercial floorspace" - is unnecessary and is inconsistent with Policy E04 (as proposed to be modified) which supports residential use (i.e a non commercial use) without requiring there to be "no net loss of overall commercial floorspace." Furthermore, Policy SP07, in referring to "any development proposals" would require proposals for main town centre uses [which is presumably what "commercial floorspace" refers to] to ensure there was no net loss of commercial floorspace. 

The requirement that "any development proposals" (i.e. not just non-commercial development proposals) "should ensure there is no net loss of overall commercial floorspace" is solely a quantitative consideration. Where a proposal is for the replacement of one type of main town centre use with another, Policy SP07 would require the exact amount of commercial floorspace to be replaced. Different main town centre uses would have different floorspace requirements and the prohibition on net loss of commercial floorspace would be unworkable. For example, where a proposed A1 shop is to replace a D2 gym use, it would not be reasonable or necessary to apply this quantitative requirement; and, for example, where a proposal involved replacing outdated Class A1 floorspace with modern more efficient shops, it would not be effective to apply this quantitative requirement as it ignores qualitative considerations (i.e. a smaller modern development could contribute more to vitality and viability than a larger existing development). There should also be no requirement for applicants to provide more commercial floorspace than is proposed in an application as this could affect viability, and could frustrate investment.

The wording - "Any development proposals should ensure there is no net loss in overall commercial floorspace" should be deleted