Southwold Town Council Planning Group

Submission to Waveney Planning and Development Committee

Application DC/12/0704/COU

1 August 2012

‘No two high streets are the same. The UK has more than 5,400 place named “High Street’’ and many other high streets exist in everything but name. Because there is no such thing as a generic high street there is also no generic solution. And I wouldn’t want it any other way. Each high street will need to find its bespoke response to revival, rather than being prescribed some generic response from on high’. Mary Portas, The Portas Review

Contents

Executive Summary..................................................................................................................2

1 Introduction......................................................................................................................3

2 The issues..........................................................................................................................3

3 Applicable planning principles..........................................................................................4

4 The meaning of the phrases ‘vitality and viability’ and ‘substantial evidence’.................4

5 Costa Coffee has not produced substantial evidence in support of its application...........5

6 Analysis of appeals appendix site specific evidence..........................................................5

7 Evidence in support of STC’s opposition to the proposed change of use..........................7

8 Over-intensification of use..............................................................................................12

9 Costa Coffee will not bring economic benefits to Southwold.........................................17

10 Conclusion...................................................................................................................... 19

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Executive Summary

1. Southwold Town Council opposes this application for a change of use based on CS10, DM10, and NPPF, Paragraphs 23-27.

2. This application can be properly denied if the Committee finds evidence that the change of use will detract from the vitality and viability of the Southwold town centre. This issue is inextricably linked to Southwold’s specific sustainability issues.

3. Southwold has experienced a precipitous drop in population – it now has about 900 full time residents. Southwold with Reydon also has the largest percentage of elderly people in the District – 866 over aged 75 –, who are dependent on the town centre for necessities.

4. Geographically isolated, Southwold has a two-wheel economy (Adnams and tourism) and an unbalanced town centre that has lost many of the shops that supply day to day needs. This has undermined its role as a market town providing services and amenities to surrounding villages, forcing people into cars and buses to shop in Lowestoft, Beccles or Halesworth, and creating hardship for the immobile elderly.

5. With much of its A1 resource taken up by businesses catering to tourism, the chief challenge to the town centre’s vitality and viability is preservation of sufficient A1 retail space for essential services so Southwold can remain a living town with shops for living. This was not considered in the Planning Officer’s original report.

6. The Planning Officer’s original recommendation was based solely on the conclusion that there was no over-intensification of A3 use. This conclusion relied on an unnecessarily narrow analysis that failed to take into account the perspective of town centre users.

7. Adopting their perspective, and using local knowledge, we counted 16 A3 uses. This is more than double the 7 counted by Planning Officers. We included ancillary A3 uses and businesses that were so close to the town centre that they appear part of the town centre.

8. In their presentation to Committee, the Planning Officers relied on a national average that was inappropriate to Southwold’s tiny town centre and unusual retail configuration. They also inappropriately compared Southwold to Woodbridge, which has a population of about 11,000, has direct road and rail links to Ipswich and London, and a diverse economy.

9. Costa Coffee has produced no site specific evidence in support of this application.

10. Having taken professional advice, we are confident that our submission contains substantial evidence to support denial of the application. In the unlikely event that a denial was reversed on appeal, this would not lead to a costs award against the Council.

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1 Introduction1.1 This report is submitted by Southwold Town Council (STC)’s Planning Committee to assist the Planning and Development Committee (the Committee) to come to the right decision on Costa Coffee’s application for a change of use. A right decision is one that takes account of the views and local knowledge of the community and is based on a material planning principle substantiated by convincing evidence. We welcome the opportunity to return to Committee because although we believe that the Committee initially made the right decision, we recognise the need for clarity on the applicable planning principles and the evidence base, especially as the Committee did not follow the recommendation of its planning officers, which, of course, it is not bound to do.1

2 The Issues

2.1 Areas of agreement

2.1.1 We agree that Costa Coffee requires a change of use to A1-A3. However, such change of use is not automatic but requires a determination that it will not detract from the vitality and viability of the Town Centre.

2.1.2 We agree that shops which provide coffee house-type facilities (hot drinks and snacks for take-out or eat-in) are beneficial to a town centre.

2.1.3 We agree that a change of use should not be denied merely because the applicant is a national brand.

2.1.4 We agree that competition, in and of itself, is not a material planning consideration since the planning laws should not be used to prefer one business over another in a particular use category. However, a change of use that could force the closure of essential retail services, on which the community depends for its day to day needs, would impact adversely on the vitality and viability of the town centre and would be counter to Waveney’s Core Strategy. The strategy envisages the consolidation of facilities, services and housing in towns in order to reduce car journeys.

2.2 Areas of disagreement2.2.1 For reasons explained in Section 8 below, we disagree with the Planning Officer’s original conclusion that this change of use would not result in over-intensification of use. We note that this was the sole basis for the Planning Officer’s conclusion that granting a change of use would not be detrimental to the vitality and viability of Southwold’s town centre. We invite the Planning Officers to revisit their conclusion in light of the information and analysis contained in this submission.

2.2.2 For reasons explained in Section 9 below, we dispute Costa Coffee’s un-evidenced assertion that it will bring net economic benefits to the local economy.

1 ‘If officers’ professional or technical advice is not followed, authorities will need to show reasonable planning grounds for taking a contrary decision and produce relevant evidence on appeal to support the decision in all respects. ’ Costs Awards in Appeals and other Planning Proceedings, Communities and Local Government Circular 03/2009, p. 17

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3 Applicable planning principles

3.1 The applicable planning principles are DM 10 and CS 10. These enable the Committee to reject an application for change of use if it finds substantial evidence that the change of use would not maintain or enhance the vitality and viability of Southwold town centre.2

3.2 Also relevant are paragraphs 23-27 of the National Planning Policy Framework (NPPF).

‘They should recognise town centres as the heart of their communities and pursue policies to support their viability and vitality.’ This sentence captures the inter-connected causal relationship between a thriving town centre and a thriving community. One drives the other and visa versa.

‘Define a network and hierarchy of centres that is resilient to anticipated future economic changes.’ This sentence captures the understanding that planning policies and decisions should support long-term town centre economic resilience.

‘Define the extent to town centres and primary shopping areas and set policies that make clear which uses will be permitted in such locations.’ This is achieved by DM10.

‘Promote competitive town centres and provide customer choice and a diverse retail offer that will reflect the individuality of town centres.’ This sentences recognises that town centres require different kinds of shops so that all classes of customers can have their varied needs met; and there should not be a one-size-fits-all approach because there will be differences in the circumstances of town centres.

‘Where town centres are in decline, Local Planning Authorities should plan positively for their future to encourage economic activity.’ This sentence recognises that planning decisions should support planning policies that prevent decline and promote regeneration.

4 The meaning of the phrases ‘vitality and viability’ and ‘substantial evidence’ 4.1 ‘Vitality and viability’ must be understood in the context of Waveney’s Core Strategy, which sets out a vision, objectives, and policies designed to promote Waveney’s regeneration.3

4.2 The Core Strategy’s vision for Southwold is that it ‘will prosper as a unique and historic market town and resort town…’4 The word ‘unique’ is defined as ‘being the only one of its kind; unlike anything else’.5 This phrase acknowledges that Southwold is different from Waveney’s other market towns (Beccles, Bungay, and Halesworth), and also is different from many rural towns in other parts of the country.

4.3 We submit that the Planning Officer’s original analysis of over-intensification disregarded the Core Strategy by failing to take account of the factors that make Southwold unique.

2 All 32 DMP policies, including DM10, ‘are interrelated and must be read together and in conjunction with the Core Strategy to understand their combined effected upon a planning proposal’. Waveney Development Management Policies (2011), para. 1.8. 3 Ibid, para 1.6. All Development Management policies, including DM10, are intended to ‘deliver the vision, objectives and policies of Waveney’s adopted Core Strategy (January 2009)’ 4 Core Strategy, para. 3.25.5 http://oxforddictionaries.com/definition/english/unique.

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4.4 The Core Strategy also identifies Southwold as an area in need of regeneration. ‘Southwold may not be perceived as an area in need of regeneration but it has its own issues of an elderly population with limited access to services and facilities, extremely high house prices in the District, a high proportion of second homes, significant pressure and a harbour area under pressure for change.’6 (Italics added.)

4.5 We submit that the Planning Officer’s original analysis of over-intensification disregarded the Core Strategy by failing to take account of Southwold’s particular regeneration needs.

4.6 Substantial evidence is defined as ‘respectable or not inconsiderable’ but not necessarily lengthy.7

5 Costa Coffee has not produced substantial evidence in support of its application5.1 While lengthy, Costa Coffee’s submission is devoid of any evidence specific to Southwold to support its claim that the proposed change of use will maintain or enhance the vitality and viability of Southwold town centre. Instead, it relies on:

A patronage survey of Costa Coffee in Praed Street (next to Paddington Station) in Westminster, London (pop. 8 million)8 that compares the number of people entering Costa Coffee with a nearby Bagel Factory take-away, a lock smith, and a souvenir shop;

Similar surveys comparing Costa Coffee to other national brands conducted in Durham (pop. 43,000), Farnham (pop. 37,000), Horsham (pop. 56,000), Salisbury (pop. 43,000) and Welwyn Garden City (pop. 43,000); and

An appendix of appeal decisions relating to applications for change of use in large towns and cities with populations ranging from 14,000 to nearly 8 million.

5.2 The appeals cited by Costa Coffee in support of its application are irrelevant because;

They relate to relate to large towns or cities with very different sustainability issues;

In some cases, they are based on different Core Strategies and Development Management Policies; or

The inspectors found substantial site specific evidence to support the applications.

6 Analysis of appeals appendix site specific evidence6.1 While it can be helpful to busy planning officers to provide them with appeal decisions so as assist them in avoiding making costly mistakes, this should not be done to throw dust in their eyes. Accordingly, we have analysed the types of site specific evidence that caused the Planning Inspectors to find on behalf of the coffee house appellants in the appeals reproduced in Costa Coffee’s appendix. In italicised text, we compare this to the lack of evidence provided by Costa Coffee in support of its Southwold application.9

6 Core Strategy, para. 5.26. 7 Costs Awards in Appeals and other Planning Proceedings, Communities and Local Government Circular 03/2009, p. 17, ft. 36. 8 Other than for Southwold, population figures are rounded up to the nearest 100,000 or 1,000.9 This analysis does not include appeals cited in the Appendix that are irrelevant because they relate to whether the Costa Coffee is a mixed use (conceded here) or are based on different DM policies.

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6.2 Caffe Nero, High Street, Winchester (pop. 108,000), enforcement notice. Survey evidence of a high level of customer activity at the premises.

In this application, Costa Coffee has not provided any survey evidence to show that a Costa Coffee shop would increase the amount of customer activity in Southwold’s town centre either by increasing the number of people using the town centre or by lengthening the extent of each visit.

6.3 Caffe Nero, High Street, Sevenoaks (pop. 19,000), enforcement notice. Survey evidence finding that ‘Many customers stated that coming to the coffee shop was their main reason for visiting the High Street’; the view of GVA Grimley (an independent consultancy employed by the Council to prepare the Sevenoaks Retails Study) that ‘the proposed use would be unlikely to detract from the current health of the centre’; and GVA Grimley’s advice that ‘there is currently a good range of convenience and comparison goods provision in the town centre, there is not, however, a huge choice of coffee shops’.

See 6.2 above.

Costa Coffee has not provided any evidence that Southwold lacks a sufficient amount of the type of amenity it would be supplying – eat in or take out coffee, other hot or cold beverages, sandwiches and other snacks.

It has not provided an independent assessment of its impact on the future vitality and viability of the town centre.

6.4 Starbucks proposed coffee shop in High Street, Staines (pop. 45,000). Starbucks provided marketing evidence demonstrating the difficulty of letting the premises over a period of some 12 months. In addition, the proposed development was supported by the Chamber of Commerce and a number of local traders.

Costa Coffee has not provided any evidence that 70 High Street was vacant or would remain so if it were not occupied by Costa Coffee.

The Southwold Chamber of Trade and Commerce opposes this application.

No local traders have indicated they support a Costa Coffee coming to the High Street.

6.5 Caffe Nero, Market Place, Rugby (pop. 90,000), enforcement notice. Site specific survey finding that ‘Some 17% of those surveyed indicated that the main purpose of their trip to the town centre was to visit Caffe Nero itself… It is clearly a popular facility. Over 1,200 people have signed a petition to the effect that it is an asset to the town centre’.

See above.

As of 30/7/2012, there were over 300 letters of objection to Costa Coffee’s application.

When members of the Southwold and Reydon Society were handing out leaflets in the High Street , half of the 100 recipients said they were visitors and all but one said they came to Southwold because it did NOT have national shop chains.

6.6 Caffe Nero, High Street, Harpenden (pop. 28,000), enforcement notice. ‘All parties agreed that Harpenden was a thriving and vital place with a consistently low vacancy rate’. Customer surveys showed that for a small percentage (10%) the primary purpose was to visit Caffe Nero whilst 27% of customers visited the High Street more often than they did before the premises opened. Both the Town Council and Chamber of Commerce supported the change of use.

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See above 6.2 and 6.4 above.

Southwold’s town centre is fragile.

The Southwold Town Council and the Southwold and Reydon Society are opposed to Costa Coffee’s application.

7 Evidence in support of STC’s opposition to the proposed change of use

7.1 Introduction7.1.1 Our evidence draws on data and findings contained in the Southwold Town Survey (2006), the STC’s collective local knowledge, the results of surveys carried out by the Southwold and Reydon Society (SRS), other public sources of information, and interviews of local retailers.

7.2 Southwold’s town centre’s primary vitality and viability challenge7.2.1 Southwold is a small, geographically isolated rural town with an aging population and a diminutive town centre. Many of its businesses, both independent and national brands, are operating on the edge due to a declining full time resident population and the seasonal nature of tourism, which is the heart of the local economy. (The other main industry, Adnams, is not, on its own, large enough to support the local economy)

7.2.2 The town centre’s primary vitality and viability challenge is retaining and augmenting its essential services – those A1 uses that provide for the day to day needs of residents (especially the immobile elderly), visitors and businesses.

7.2.3 Any analysis of the impact of Costa Coffee’s change of use application must address how it will impact on this specific vitality and viability issue. The Planning Officer’s original report does not consider this issue.

7.3 Southwold’s declining full time resident population7.3.1 Waveney’s Core Strategy correctly identifies that there is a disconnect between perceptions of Southwold and its social and economic realities. In good weather, on a high summer’s day, holiday makers and day trippers over-spill the town centre’s pavements. Four by fours are parked on the side streets, and estate agents advertise house prices over £1 million and beach huts selling for over £100,000. However, these indicia of wealth are both an illusion and an illness.

7.3.2 Between 1991 and 2009, Southwold lost more than a third (34%) of its full time resident adult population (from 1599 to 1026). Today, we estimate its full time resident adult population at about 900.10

7.3.3 This steep decline is due to an increase in the number of second home owners and the emergence of a buy to let holiday home market stimulated by government tax policies that have made house prices unaffordable to local residents, who have been displaced to Reydon (which is beginning to experience the same trends) or beyond.11

10 This estimate is based on electoral roll information provided to Town Councillor candidates at the last local election. 11 STC defines second homes as properties occupied by persons who live there part time; buy to let holiday homes are owned by persons who let them commercially to holiday makers.

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7.3.4 According to a 2010 Southwold and Reydon Society Housing Survey (SRS Housing Survey), 45% of domestic dwellings in Southwold were second homes or buy-to-let homes. (See Appendix A.) The SRS Housing Survey estimated that, if this trend were not reversed, in eight years time (2020) 50% of Southwold’s housing stock will be second homes/holiday lets, with a comparable decline in its adult resident population.12

7.4 Southwold’s elderly population

7.4.1 Southwold with Reydon has the highest concentration of elderly people in the District. Forty-four percent of the combined population is over 65. The number of people over 76 years of age is 866 – 22% of the combined population!13

7.4.2 Rightly so, social inclusion is an important theme of Waveney’s Core Strategy. Due to mobility issues, the elderly population of Southwold with Reydon is especially dependent on Southwold’s town centre for their day to day needs. A Southwold town centre that lacks services and amenities for such a large proportion of the population cannot be described as having vitality and viability. In the language of NPPF, it cannot be described as ‘the heart of its community’.

7.5 Southwold is not ringed by a retail shopping park 7.5.1 Southwold’s town centre serves as the shopping and services centre for Reydon (the largest of the adjoining villages), Walberswick, Wangford, Wrentham, Frostenden, South Cove and Covehithe. Many of the residents of Reydon and Walberswick cycle or walk to Southwold to use its services.

7.5.2 Unlike the typical southeast English town, Southwold, due to its geography, does not have an exterior ring of retail parks. All retail use is consolidated in its centre. The nearest retail shopping parks are in Beccles and Lowestoft, approximately 12 miles away by car or bus. When Southwold town centre loses an essential service, residents of Southwold and Reydon are forced to travel by car or bus to shop in Halesworth (about 8 miles away), Beccles or Lowestoft. Waveney’s Core Strategy and supporting Development Management Policies are intended to use spatial planning principles and decisions to alter this trend.

7.5.3 For example, Southwold has just lost its only launderette. This essential amenity was used by residents, campsite visitors, B&B owners, hairdressers, the managers of holiday lets, and others.

Southwold’s launderette, a vital amenity, closed abruptly two week ago after being bought by commercial property developer.

12 Southwold and Reydon Housing Report, 2010. 13 Great Yarmouth and Waveney Housing Market Assessment, Project 2, Profile 13: Southwold and Reydon, September 2007. See www.waveney.gov.uk/site/scripts/download.php?fileID=721.

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7.5.4 How does the loss of this vital amenity affect the Southwold with Reydon community?

Example 1. A resident of Reydon who regularly used the launderette to wash her partner’s industrial work clothes unhappily reports that she will now have to go to Halesworth where she will also do her shopping.

Example 2. A disabled man who cares for his 90 year old mother is now taking a bus to Lowestoft to do their laundry.

7.5.5 Reportedly, the launderette closed after it was bought by the national property development company that also bought the W.H. Smith premises and 70 High Street. This is not relevant to the merits of Costa Coffee’s application and is used solely to illustrate the sensitivity of Southwold’s small town centre to any changes.

7.6 To remain a living community, Southwold’s town centre needs shops for living7.6.1 In 1991, the day to day needs of Southwold with Reydon were serviced by two butchers, a bakery, two ironmongers, two houseware shops, three green grocers, two small supermarkets, a delicatessen, two shoe shops, a book store, a department store, two chemists, and several clothes shops. Southwold even had two garages that sold petrol. Now we have one butcher, one houseware shop, no ironmonger, no bookstores, etc.

7.6.2 The loss of ordinary shops is partly due to the growth of out of town retail centres in Beccles and Lowestoft but a major cause is the decline in Southwold’s population, and the advent of commercial property speculation, which is driving up rents. Today, instead of supplying our day to day needs, our ‘high street’ is imbalanced in favour of tourism. We have, for example, 13 clothing shops including two dedicated exclusively to children.

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7.6.3 In order to survive, essential retail shops have diversified what they offer. Thus Mumfords, the remaining houseware shop, sells ironmongery, paint, garden and camping supplies. The Farm House Bakery sells eat-in or take-out coffee and snacks. Hutsons, the remaining butcher, has becomes a baker, a deli, and a take-out coffee and snack bar. The Black Olive, a deli, does take out expresso and snacks

Hutson’s, a favourite of workmen and campers, does a lively take-out trade in expresso type coffee and baguettes

7.6.4 This development of ancillary uses reflects changes in habits and the need for Southwold’s town centre retail outlets to provide services and goods catering to the tourism industry to compensate for the lack of custom caused by the decline in population. When every sale can be ‘make or break’, businesses multiply the variety of what is sold.

7.6.5 Shop-keepers consistently report that about 40% of their business comes from tourists and the bulk of their sales are generated in the 10 weeks of the summer high season when business is described as ‘very good’ or ‘good’ (a 14 week period). The remaining 28 weeks of the year are described as ‘quiet’.

7.6.6 How is ‘quiet’ quantified in terms of footfall? In the winter, or even during a rain-sodden June and July, ‘quiet’ can mean only one or two customers per hour.

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‘The big companies think the streets of Southwold are paved with gold. But in the middle of winter, the manager of Tesco asked a neighbouring independent, “Have we done something wrong? Is this it?’ She said, ‘Welcome to Southwold”’. The truth is we have 14 really good weeks, 10 average, and the rest of the time is really quiet’.

Interview of independent retailer

7.6.7 The sustainability of Southwold’s town centre requires reversing population decline. Southwold is now undertaking a Town Plan. The emerging issues are no surprise: regeneration requires a virtuous circle of affordable housing, more job opportunities for the young, and a resilient town centre with sufficient A1 space to cater to tourism and also supply all ordinary needs at a competitive price because Southwold with Reydon, as a retirement destination, will always have an elderly population.

A new member of our Southwold community

7.6.8 Granting Costa Coffee’s application would contribute to the vicious circle that Southwold with Reydon is trying to reverse. It would take out of circulation an A1 use that could provide essential retail space for day to day needs that we have lost (our book store, launderette, and iron monger are just three examples) while providing us with something that adds nothing to the diversity of services currently available.

7.6.9 We anticipate that Costa Coffee may argue that its opening hours will be somewhat longer than some of our current coffee/snack providers, and that this will contribute to the town’s vitality and viability by increasing footfall during the very early morning and evening hours. But there is no need to increase footfall in the town centre during the high season when the town is bursting at its seams and pedestrians over-spill into the roadway. As for the quiet months, when the town centre requires heightened activity, longer hours cannot generate footfall because Southwold’s population has shrunk to its normal size. Witness the experience of Tesco and the Co-op. Their nationally set opening hours of 6:00 a.m. to 11:00 p.m. have not increased early morning or late evening pedestrian activity in the town centre; out of season, they operate a skeleton staff (two people).

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8 Over-intensification of use

8.1 The Planning Officer’s analysis of over intensification is flawed

8.1.1 We believe that the analysis of over-intensification of use in the Planning Officer’s original report is flawed because: a) it calculated only the formal use categories, ignoring informal ancillary uses; b) it measured use only within the designated town centre, ignoring significant A3 ancillary use that, for all intents and purposes, appears to be in the town centre; and c) it measured over intensification by using a national average that is based on a retail configuration that does not exist in Southwold.

8.1.2 Planning law does not require such a narrow approach. Since the issue of over-intensification is about the degrading of a town centre’s vitality and viability, planning officers are entitled to consider common sense factors, including the perspective and behaviour of town centre users and the variety of options available to them.

8.2 Ancillary uses should have been included in the over-intensification analysis

8.2.1 The Pubs8.2.1.1 The Planning Officer’s analysis did not count pubs because they are formally classified as A4, ‘drinking establishments’. While this category had an economic rationale 30 years ago, today’s pubs – at least those in Southwold – are all day family restaurants. Southwold’s pubs pride themselves on the quality of their food, and the restaurant side of their business is a major visitor draw. The Red Lion pub (130 seats) is actually the largest restaurant.14 About 50 percent of its profits are derived from sales of food and non-alcoholic beverages.

The Red Lion opened a new wing to its restaurant in January, 2012.

14 Southwold and Reydon Society, ‘Amenities Survey’.

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8.2.2 Hotels

8.2.2.1 Southwold’s two town centre hotels were not counted because they are classified as C1. However, given the seasonal nature of Southwold’s tourism industry, neither could survive as a business if they functioned only as a hotel. Both have developed substantial restaurants seating 40 (the Crown) and 70 (the Swan).

8.2.2.2. The Crown, which is best known in the District as a coffee house and restaurant, has only 12 rooms. About seventy percent of its business comes from its restaurant and coffee bar.

Best known as a restaurant and coffee bar, the Crown dominates the High Street

8.2.3 Other – Buckenham Coffee HouseBuckenham Coffee House was classified as A1 even though it is signed and advertised as a Coffee House.

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8.3 Businesses on the town centre rim should have been included in the analysis8.3.1 The purpose of the designated town centre is to establish a zone where use is protected. But town users do not decide whether or not to visit a shop based on whether it falls within or without a blue line on a planner’s map.

8.3.2 In evaluating over-intensification, the planning officers omitted the Adnams Cellar and Kitchen, which is only a 15 second walk from the town centre boundary, and from the perspective of a user, indistinguishable from the town centre. This shop is one of the town’s iconic features due to the Adnams brand and its exceptional modern architecture. It is a tourist attraction in its own right.

The Adnams Cellar and Kitchen has a prominently advertised coffee house that seats 80 people.

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Here is a comment about the cafe posted on https://foursquare.com/v/adnams-cellar--kitchen-store/4b377bd5f964a520604125e3.

8.3.3 Visitors to Southwold would also assume that both the Red Lion and the Nelson pub restaurants were a part of the town centre.

The Red Lion Pub is a 16 second walk from the town centre boundary!

The Nelson Pub is a 24 second walk from the town centre boundary!

8.3.4 The map below shows the designated town centre, bordered in blue, with the above three locations marked by red dots.

8.3.4 As shown in Table 1 on the next page, when the above considerations are taken into account, the number of A3 and A3 ancillary uses that a user would perceive to be in the town centre totals 17. This is more than twice what was calculated by the Planning Officers (7).

8.3.5 This provides 847 seats for residents and visitors between the hours of 7:30 and 23:00.15

15 Appendix B. The opening hours and number of seats are obtained from the Southwold and Reydon Society Costa Coffee Survey, July 2012.

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Table 1: A3 and A3 Ancillary Uses in Southwold Town Centre and Rim

A3 and A3 ancillary uses

In Designated Town Centre

On Rim of Town Centre

Formal Use Class Number of seats

The Nelson Inn

Yes A4 100

The Red Lion Yes A4 130

The Kings Head

Yes A4 94

The Crown Yes C1 40

Swan Hotel Yes C1 70

Munchies Yes A3 30

Farmhouse Bakery

Yes A1 6

Coasters Yes A3 40

Tillys Yes A3 50

Squires Yes A3 28

Sutherland House

Yes A3 45

Buckenham Coffee House

Yes A1 34

Fresh Bite Yes A3 18

Adams Kitchen & Cellar Cafe

Yes Unknown 80

Trinity Tea Rooms

Yes A3 42

The Lighthouse

Yes A3 130

Total = 16 847 seats

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8.3.6 The total of 16 is more than twice the number of A3 use (seven) counted in the Southwold Town Centre 2011 survey used by Planning Officers in their analysis.16

8.3.7 In addition, take out expresso, sandwiches and snacks are available from Hutsons and the Black Olive delicatessen, both located in the designated town centre.

8.4 In evaluating whether there is over-intensification, the analysis used a national average inappropriate to measuring over-intensification in ‘unique’ Southwold8.4.1 The national average is weighted to large towns and urban centres where day to day uses have moved out of town centres into retail parks, leaving leisure uses such as coffee shops and restaurants, for example, to occupy town centre premises. As a result, the national average shows A3 predominating in town and city centres. This is the opposite of Southwold, which has not developed this type of configuration because of its physical isolation.

8.4.2 By using a national average, the planning officers are effectively dictating that Southwold should have a few more restaurants. This dictat ignores our economic reality – namely, that much of the current A1 use is taken up by shops catering to tourists, which diminishes the number of A1 premises available to businesses supplying our day to day needs.

8.4.3 The use of the national average also does not take account of Southwold’s tiny town centre, roughly 500 yards in length, which can be walked from one end to the other in 10 minutes. This small area magnifies the impact of each single use since they are all crowded together. It explains why residents are so puzzled and ask of each other, ‘How can the planning officers not see that we already have too much of this sort of thing?’

8.4.4 Instead of relying on a national average, we think that the Committee would be better served by following the advice of the Portas Review:

‘No two high streets are the same. The UK has more than 5,400 place named “High Street’’ and many other high streets exist in everything but name. Because there is no such thing as a generic high street there is also no generic solution. And I wouldn’t want it any other way. Each high street will need to find its bespoke response to revival, rather than being prescribed some generic response from on high.17

9 Costa Coffee will not bring economic benefits to Southwold9.1 In its re-application, Costa Coffee states: ‘ Importantly, subject to planning permission being granted Costa Coffee are looking to make a firm commitment to the Southwold community and to employ local people for the new jobs that will be created by the opening of this branch’.

9.2 Since Costa Coffee has raised this issue, we will now address the cumulative economic impact of Costa Coffee on Southwold.

9.3 Costa Coffee’s direct contribution to employment will be modest.

9.3.1 During the period of the ‘very good’ and ‘good’ 24 weeks of the year, it will probably employ one or two more people on a shift basis than were previously employed in the dress shop that

16 See Appendix C. 17 The Portas Review, p. 15.

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occupied 70 High Street before it was bought, and redevelopment commenced on behalf of Costa Coffee.18 However, during the remaining 28 weeks of the year, it is likely to operate a skeleton staff – probably one barrista, on a shift basis – because, contrary to perceptions, the streets of Southwold are not lined with gold. However, this will be off-set by the fact that all profits will be taken out of the community, and services and supplies will not be locally sourced. (We note that the branch of Savills employed to submit this planning application is located in Cardiff.)

9.3.2 Moreover, long term, if Costa Coffee was to displace another A3 business, any employment gain would be wiped out.

9.3.3 Contrast this with the economic contributions made by our independent shop sector. In addition to employing local people, they are owned and operated by local people, who source services and supplies locally, and spend their profits locally. Just one small example – a number of independent suppliers of hot drinks and snacks buy their coffee and coffee making equipment from Freshpac, a Halesworth family business. As explained in the Portas Review, ‘A pound spent in aretailer with a localised supply chain that employs local people has far greater domestic economic impact than a pound spent in a supermarket or national chain.’19 (Italics added.)

9.4 Regarding the phrase, ‘looking to make a firm commitment to the Southwold community’, no weight should be given to this nebulous promise. Did W.H. Smith and Tesco contribute people or money to decorating the town for the Queen’s Jubilee, which brought many visitors into the town centre? Is the answer important? Yes. It takes more than footfall to create a vital and viable town centre in a rural small town. It takes businesses with a sense of civic duty that care about the community and contribute to the common good. A prime example is Squire’s Tea Room. There, a group of elderly women, fondly known as the ‘Youth Club’, meet each week to have tea and cake and to collect donated yarn which they use to knit garments. These are displayed for sale in the restaurant, with the proceeds donated to Cancer Care.

Knitted garments for sale in Squire’s Tea House to benefit Cancer Care

18 It is not known whether the shop was bought for the express purpose of redeveloping Costa Coffee, a fact which, in any event, is not relevant to this application. 19 The Portas Review, p. 31.

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10 ConclusionWaveney’s spatial vision for the future, set out in its Core Strategy, calls for local people to be fully engaged in decision-making for their communities. This report is our effort to meet this vision in a responsible and supportive fashion.

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