From: Councillor Tim Dodds, Lightwater ward

To: Development Control

Surrey Heath Borough Council
Knoll Road, Camberley
Surrey GU15 3HD

6th April 2011

Dear ……..,

Planning application 11/0104, 88-91 Guildford Road, Lightwater

On behalf of many residents and shop owners of Lightwater I register

objections to aspects of the redevelopment of the above property.

Before dealing with the specific objections in relation to planning policy,

it’s unfortunate that the name of the likely eventual occupier is not known
prior to the application being assessed. I urge you to seek to identify the
occupier. This information has a direct impact on the consideration of the
application.

Restriction of competition is not the issue; I doubt there’s anyone

objecting to that. However, should the eventual occupier be a convenience
store outlet of a large grocery chain, then the retail over-provision of
grocery and allied goods is a major concern to residents and shop keepers.

The objections to the proposals are in these areas; retail diversity; retail
space/parking ratio; car parking; trading hours/days; and traffic congestion
resulting from servicing and delivery frequency.

1. Retail diversity: Objection on the grounds of its impact on

commercial vitality and viability.

Policies applying PPS4 policies EC4, EC16 and Local Plan S1.

Policy EC4 states that in planning for consumer choice; authorities

should have regard for a strong retail mix, support diversity, and
support small shops. Policy EC16 directs planners to consider “the
impact of the proposal …., including local consumer choice and the
range and quality of the comparison and convenience retail offer.”

The introduction of a large retail chain’s convenience store format

will not add retail diversity. It will simply put pressure on the
sustainability of smaller shops, such as newsagents, post office, and
crowd out the opportunity for increased retail variety.

2. Retail space/parking ratio: Objection on the grounds of

insufficient car parking to likely customer footfall.

The application is for a net sales area of 3090sqft. This must be

judged in relation to Duffy’s Budgens of net sales area of 5000sqft.
A comparison of parking provision is illuminating, Budgens 24

Letter of objection to planning application 11/0104 1 of 4

 versus 8. A similar ratio for the application site would be 16 parking
spaces.

3. Car Parking: Objection on the grounds of wholly inadequate

car parking provision.

Policies applying: PPS4 EC 8.2, Local Plan M7, Lightwater

Supplementary Planning Document policies B2, B4, B6 and H9.

Policy PPS4 EC8.2 directs that there should be an “adequate level

of car parking” for non-residential developments. Policy M7 sets a
standard for car parking provision as either 10 or 16 spaces,
depending upon interpretation, plus one space for operational use.
While the Lightwater SPD’s policies seek to limit over-development
through increased traffic generation [B2], and the visual impact of
car parking minimised [B4], and any redevelopment or
improvement of the commercial centre should seek to reduce the
impact of car parking on the street scene [B6].

Lightwater SPD policy H9 reflects villagers concern over car

parking and traffic congestion by encouraging a study of the level
and location of car parking in the village. Such an independent
study was produced in July 2009, which provided data on the lack of
parking capacity in the village centre.

The application provides 8 car parking spaces.

Looking at the adequacy of that number soon shows its inherent

inadequacy. Apart from the fact that it’s unlikely that 8 car parking
spaces are possible given the increase in vehicle sizes. The 2.4m
width in the applicant’s plans is fine for long term parking; a more
generous 3.0m width is now becoming the norm, which is preferable
for high turnover car parking. This would result in a maximum of 7
spaces, not 8.

The application plans for two one-bed apartments, let’s assume 2

vehicles. It also indicates that between 20 and 25 full and part-time
jobs would result. Being generous, let’s say only around one quarter
arrive by car, that’s a minimum of 6 cars.

So, the provision of 8 spaces is meant to provide room for 2

residents, 6 staff, and 8 customers. That’s 16 spaces, giving a 50%
under provision, not even taking into account the needs of the
delivery and servicing vehicles.

The number of spaces suggested in 1 above, and from planning

policy M7 also indicates a need for 16 spaces.

The resultant parking overspill will be to the severe detriment of

householders and other businesses in Guilford Road and All Saints
Road.

Letter of objection to planning application 11/0104 2 of 4

 4. Trading hours and trading days: Objection to hours and days
of trading to minimise inconvenience and nuisance to
nearby housing.

The applicant notes that there are no restrictions on trading days or

hours of trading, and seeks agreement to trade from 0700 to 2300
Monday to Sunday, including Bank and Public Holidays. The current
store operates shorter hours, closing at 1730 Monday to Saturday,
and 1330 on Sundays, and closing on Bank and Public holidays.

The difference between the frequency of customer visits to a

homewares/DIY store and a convenience grocery store should not
be overlooked. By its very nature a 7-11 convenience store attracts
late evening custom, creating noise and disturbance for the
neighbouring houses.

Later opening hours has the potential to re-introduce nuisance to

Lightwater village centre. An earlier convenience store elsewhere in
the village centre saw congregations of disorderly youths into the
late evening, attracted by the availability of cheap alcohol and soft
drinks. It is likely that the achievements of the ‘Section 30’ notice
put into the village by the Police in 2008 to curb this anti-social
behaviour would be jeopardised with the late evening opening hours
requested.

Also, it shouldn’t be overlooked that opposite the development site

is the village war memorial, which is the focus of an annual
remembrance service. A small thing, but the many hundreds who
turn out to pay their respect at the service by the war memorial
would be dismayed at anything that might mar the solemnity of that
event.

5. Traffic congestion/road safety: Objection to the probable

traffic congestion and heightened accident risk resulting
from the service/delivery schedule.

The policies that apply are PPS4 EC8.2, EC10.2, Core Strategy
DM11, and Lightwater SPD H1.

The application indicates between 3 to 5 service and delivery

vehicles per day, noting a voluntary restriction of servicing to
between 0700 to 2200 on Mondays to Saturdays, and 0900 to 1900
on Sundays, Bank and Public Holidays.

The application makes no provision for service vehicles in the

parking area, and suggests that the delivery schedule would be no
different to that of the existing store. No proof of this is provided. A
convenience store selling perishable goods is likely to receive a
higher frequency of replenishment than a homewares store.

PPS4 Policy EC8.2 and 10.2 directs planning authorities to

consider “the need to tackle congestion” and local traffic levels.
Policy DM11 states, “Development which would adversely impact
the safe and efficient flow of traffic movement on the highway

Letter of objection to planning application 11/0104 3 of 4

 network will not be permitted unless it can be demonstrated that
measures to reduce and mitigate such impacts to acceptable levels
can be implemented”. While the Lightwater SPD policy H1 on
transportation and access says, “Development proposals which
cause an unacceptable impact of traffic generation will not be
permitted”.

The development site sits opposite a road junction, adjacent to a

road table vehicle restriction, and adjacent to a bus stop.

Experience of local convenience store service delivery - M&S West

End – is that the use of large vehicles is the norm. Therefore, the
combination of cramped area for rapid-turnover car parking, large
delivery vehicles, and a road junction, provides the perfect recipe
for regular traffic congestion and probable increased accident risk.

I believe that these arguments are sufficient for you to ensure any
redevelopment seeks to add retail diversity to the village shopping centre,
makes greater provision for car parking, and introduces limitations to the
trading hours and days.

This village community supports the local shops, valuing their presence,
and also values the efforts of the local business community to create a
village feel to the shopping centre. Over-reliance on one retail sector is
likely to put these efforts at risk.

In constructing the Lightwater SPD, the village contributed to a

questionnaire about what they’d like to see in their village, page 7 of the
SPD states, 2more specialist shops such as a baker, greengrocer, florist
and cafes or restaurant.

Finally, I hope that you will consider carefully the impact of this
application on Lightwater village. It may seem a small application, but has
potential huge adverse impacts on a village.

Yours sincerely

Councillor Tim Dodds

Lightwater Ward
Surrey Heath Borough Council

Letter of objection to planning application 11/0104 4 of 4