Site Proposals document

InfraRed notes the submission, made by Iceni Projects Ltd, for the mixed-use redevelopment at Anglia Square (site GNLP0506). While InfraRed appreciates the redevelopment of Anglia Square has long been an aspiration of Norwich City Council, InfraRed believes that the 20,000 sqm of retail floorspace promoted at the Centre is unjustified.
Anglia Square is considered a "Large District Centre" outside the City Centre in retail terms. It sits below the City Centre in terms of the retail hierarchy, and the adopted Joint Core Strategy (JCS) Policy 19 supports retail floorspace that this location, but at a scale that is appropriate to its form and function.
Anglia Square was formerly allocated pursuant to the Northern City Centre Area Action Plan (NCAAP); however this AAP reached its 10 year limit in 2016 and is no longer adopted policy. Notwithstanding this, it is noted that the AAP supported (in former policy AS2) some 3,600 sqm of retail development, principally in the form of a foodstore with more limited, complementary retail provision of units below 200sqm.
Following expiration of the NCAAP, the Council issued non-statutory guidance, in the form of the Anglia Square and Surrounding Area Policy Guidance Note (March 2017) (hereafter, PGN). Though not policy, this document is used as a "material consideration" in the determination of planning applications in this area. While this no longer identified appropriate retail floorspaces within any development at Anglia Square, the PGN states (para 7.27) that,
"The Council will encourage the provision of a higher quality retail environment with additional retail floorspace, whilst acknowledging that Anglia Square will continue to perform a different role to the primary retail area of the City Centre, with a greater focus on serving the convenience needs of the largely residential areas to the north, east and west." (Our emphasis).
The stance of both the NCAAP and the PGN, in identifying Anglia Square as a "complementary" offer to the City Centre is supported in the evidence base, notably the Council's 2007 Retail Study.
In terms of the 2017 Retail Study in support of the GNLP, this concurs with the approach that supports the redevelopment of Anglia Square, but considers that (para 5.1) Anglia Square's role remains one of "meeting more localised shopping needs". As noted above, InfraRed also notes the Retail Study's identification of an over-supply of retail floorspace, at least in the short-term.
Accordingly, InfraRed considers that the quantum of additional retail floorspace outlined by the site promoters is not properly justified. Anglia Square performs a role and function consummate with its allocation as a District Centre, within the hierarchy of centres. InfraRed contends that additional retail capacity, should it be needed, should be accommodated within Town Centre Sites (i.e. within Norwich City Centre) first.
Anglia Square performs, and should perform, a localised, complementary shopping role, which must be reflected in any resulting allocation.
InfraRed is concerned that, given the additional quantum of residential development that is being proposed in Iceni's submission at GNLP0506, that the very significant increase in retail floorspace being proposed might not be subjected to proper scrutiny and assessments as to retail impact on the City Centre. InfraRed therefore opposes the quantum of retail floorspace proposed in that submission on this basis.
Conclusion
InfraRed is broadly supportive of the Growth Options as a document which seeks to support the role and function of Norwich City Centre. As explained InfraRed seeks to ensure that there is the necessary flexibility within the forthcoming GNLP allowing for a mix of town centre uses within Primary Shopping Area.
Within the Site Proposals document, InfraRed considers that the site promoter's identification for 20,000 sqm of retail floorspace at Anglia Square is unjustified. This in in light of both the changing town centre and retail environment and capacity identified in the representations on the Growth Options identified above, and also
the appropriate role of Anglia Square as a District Centre, intended to complement, not compete with, the Retail and Town Centre offer of the City Centre and provide for local shopping needs.