(SSA Planning Ltd obo KFC (GB) Ltd) - Retail and Town Centres

We responded to your consultation on the Pre-Submission Draft in March 2019 in respect of Policy C8, pointing out that no assessment has been made of demand or need for hot food takeaways, or of the impact of that proposed policy on jobs, choice, accessibility or on vitality and viability.

We note the use again of data from the Public Health England 'Density of Fast Food Outlets in England', which captures uses (e.g. bakeries and cafes) that are now in Class E, as well as hot food takeaways. This data is therefore of limited use as a trigger for refusing hot food takeaways.

We further noted the conflicting evidence on any link between exposure to the identified group of uses and obesity, a point made in the Public Health England note itself, and queried how the suggested threshold density was reached. We maintain all of these concerns.

We further point out that, as experience-led uses, food and drink is an increasingly important sector in maintaining town centre footfall and it should be no surprise that more such uses are to be found within town centres. Indeed, it reflects application of the sequential approach.