HTC6 - Priory Quarter, Havelock Road

Background

Royal Mail, formerly Consignia plc, is the successor to the former statutory corporation, The Post Office. Although its management operates independently, Royal Mail is wholly owned by the Government through the Secretary of State for Business, Innovation and Skills. Its services are regulated by Ofcom. Its letters business, Royal Mail, is the operator of universal postal functions through the Royal Mail letterpost delivery and collections services, handling letters, postal packets and high value (registered) packets. Royal Mail Group also operates Parcelforce Worldwide, which is a parcels carrier. Post Office Limited (a "sister" company to Royal Mail) operates the national network of post offices and sub post offices.

The United Kingdom letter post business has been fully liberalised since the Postal Services Act 2000 and Royal Mail now operates in a highly competitive market place. As such, it effectively operates like any other business and is continually seeking to find ways to improve the efficiency of its business (e.g. increased automation) and respond to the changes in communications technology (e.g. email and internet). Put simply, the nature of the mail industry has, and continues to change and Royal Mail's real estate needs to response accordingly.

Royal Mail Properties

Royal Mail has a statutory duty to provide efficient mail sorting and delivery services for the administrative area of Hastings. The following leasehold Royal Mail properties are located in Hastings:
* St Leonards Delivery Office, Drury Lane, St Leonards On Sea, TN38
* Hastings Delivery Office, Braybrooke Road, Hastings, TN34 1AD
* Hastings Vehicle Park, Priory Street, Hastings, TN34 1EA
* Hastings Vehicle Park, Station Approach, Hastings, TN34 1BA

Policy Considerations

Our representations set out in this letter accord with the National Planning Policy Framework (NPPF) (2012) which "provides a presumption in favour of sustainable development" from which we consider the following to be of particular relevance:

* That plan-making should "positively seek opportunities to meet the development needs of their area...with sufficient flexibility to adapt [to] rapid change, unless:
* Any adverse impact of doing so would significantly and demonstrably outweigh the benefits" (paragraph 14);
* That planning should "encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system. To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century" (paragraphs 19-20);
* That planning policy should "support existing business sectors, taking account of whether they are expanding or contracting...policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances" (paragraph 21); and
* "Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore, developments should be located and designed where practical to accommodate the efficient delivery of goods and supplies" (paragraph 35).

Representations

We set out our representations in relation to the draft Hastings Development Management Plan Publication document (January 2013) as follows:

Site Allocation HTC6

We note that the draft document identifies three of the above Royal Mail sites as forming part of Site Allocation HTC6: Priory Quarter Havelock Road. These are Hastings Delivery Office and the vehicle parks on Priory Lane and Station Approach.

We understand that Site HTC6 forms the remainder of what is known as the Priory Quarter where outline planning permission has already been granted and partially implemented for a large scale mixed use development of offices, education, retail and leisure uses (ref. HS/OA/06/00896).

We note that the proposed allocation for Site HTC6 is primarily for business development and allows for complementary uses including retail, hotel, education, leisure and car parking.

Royal Mail object to the allocation of Hastings Delivery Office and the vehicle parks on Priory Lane and Station Approach as falling within Site Allocation HTC6 unless Royal Mail's existing operations on these sites are relocated/re-provided at suitable alternative sites or retained as part of the proposed scheme.

In terms of the former, it would be essential that any new facilities are provided prior to the demolition of those existing, to ensure Royal Mail's continuity of service. This will ensure that Royal Mail's operations will not be prejudiced and that they can continue to comply with their statutory duty to maintain a 'universal service' for the UK pursuant to the Postal Services Act 2000.

In order for the sites to be brought forward for redevelopment, relocation will need to be viable for Royal Mail. There will need to be a commercial attractiveness that would incentivise the business to relocate the operations.

Should Hastings Delivery Office and the Vehicle Parks on Priory Lane and Station Approach be retained as part of the proposed scheme, it would be essential that any new development adjacent to these sites is compatible with Royal Mail's existing operations. This is necessary to ensure Royal Mail's continuity of service and to preserve the amenity of those occupying any neighbouring new development.

Royal Mail will not accept responsibility for remedying any noise, transport and/or amenity complaints from those occupying any new neighbouring development which may arise as a result of activity within the Hastings Delivery Office and the two Vehicle Parks. In the event of any such future complaints, any retrospective mitigation measures will need to be delivered within the neighbouring development site(s) and at the expenses of the developers (or future landowners).

In this respect, we formally request that the following text is added after Paragraph 6.316 on Page 169:

"The redevelopment of the sites currently occupied by Royal Mail will be dependent upon the relocation/ re-provision of the existing Delivery Office on Braybrooke Road and Vehicle Parks on Priory Street and Station Approach to alternative viable and commercially attractive locations prior to the redevelopment of the sites.

Should the sites currently occupied by Royal Mail be retained as part of the proposed scheme, it would be essential that any new development adjacent to these sites is compatible with Royal Mail's existing operations. This is necessary to ensure Royal Mail's continuity of service and to preserve the amenity of those occupying any neighbouring new development".

Next Steps

We formally request that these representations are taken into account in the preparation of the draft Development Management Plan to ensure that it is legally compliant and meets the tests of soundness i.e. that it is positively prepared, justified, effective and consistent with national planning policy.

Royal Mail reserves the right to amend or supplement these representations at a later date if necessary.

Royal Mail will continue to closely monitor plans for growth throughout Hastings and would welcome further discussion with the Council on the delivery of new infrastructure as the plans for the administrative area evolve.