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Representation by Blueco Limited

Date submitted
31 March 2021
Submitted by
Members of the public/businesses

We are instructed by Blueco, the owners of Bluewater (‘the Owners’), to register as an Interested Party in the examination of the London Resort application for development consent. We submitted representations to the London Resort Statutory Consultation on 19 October 2020 and at that time set out our concerns about the lack of information and clarity on the impacts and controls in respect of the resort. We have now reviewed the submitted information and outline the principal matters that we may wish to make in relation to the application. As set out in our representations to the Statutory Consultation, we noted that despite Bluewater being a major shopping centre destination in the UK, it is not immune to the changes in the retail sector such as the growth of online shopping and changing customer demands. Even before the impact of COVID 19, the Owners were exploring options to respond to the restructuring retail sector by reinforcing the retail offer and introducing other uses including leisure, hotels, employment and residential. This could potentially overlap with the London Resort project, specifically for attractions outside the payline. We note at page 72 of the Applicants Planning Statement (‘PS’) that the scheme has been revised ‘to provide to local communities and businesses a more diverse range of entertainment and amenities outside the park gates’ and Table 8.1 in the PS outlines a total of 26,695 sq.m of retail and leisure floorspace is proposed outside the payline. This comprises food and beverage facilities (including bars, restaurants and cafes), a cinema, music venue, two retail units and a conference centre. Paragraphs 8.171 - 8.179 notes that these uses intend to attract visitors during the afternoon and evening from the local area and are necessary as they have an intrinsic locational and functional connection to enable successful operation of the London Resort. The attractions proposed outside the payline have the potential to become a free-standing destination which would more likely compete with local leisure and retail destinations, including Bluewater. A high level sequential test and impact assessment is referred to and this will need to be interrogated, along with the assumptions made in the Retail and Leisure Impact Assessment to understand the potential impacts to Bluewater and established town centres. The Owners are currently reviewing the transport impacts of the London Resort. To inform this review, clarification has been sought from the Applicants about the potential impacts and mitigation on public transport. Subject to this review, it may be necessary to provide a detailed response on this matter. In summary, the Owners intend to make representations to cover: • The proposed facilities outside the payline and how this impacts Bluewater • The application of the sequential test and impact assessment in respect of town centre uses. • Subject to further information, transport impacts and mitigation.