Local Development Framework Consultation

I have read the guidance notes.

DM22 - Hot Food Takeaways

No

The DPD is not positively prepared

The DPD is not justified

The DPD is not effective

The DPD is not consistent with national policy

Response to Policy DM22
1. Introduction

1.1 We have considered the above policy and its supporting text with regard to the principles set out within the Framework. Local Plans should “plan” positively for development; be justified; effective; and consistent with the Framework.

1.2 We consider that limiting the location and concentration would be unsound.

1.3 The policy is overly vague and provides no set parameters for decision makers.

2. Such an approach is not positive, justified, effective or consistent with the Framework.

2.1 Restricting the concentration and location of new A5 proposals within the borough, is not a positive approach to planning. The Framework “foreword” sustainable development is about positive growth, making economic; environmental; and social progress, for this and future generations.

2.2 The suggested restrictions apply an over-generic approach to restrict development with little sound planning reasoning or planning justification. This is contrary to Para 14 of the Framework which advises authorities to positively seek opportunities to meet development needs of their area.

2.3 Thus it is inconsistent with Para 19 and 21 of the Framework. Para 19 states:
Planning should operate to 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.

2.4 Para 21 states:

Investment in business should not be over-burdened by the combined requirements of planning policy expectations.

2.5 No consideration has been given to other A class uses and their contribution or impact on daily diet or wellbeing. The suggest approach is therefore not holistic and will not achieve the principle aim.

2.6 There is lack of evidence to demonstrate that purchases in fast food outlets are any more or less healthy than purchases in other A Class premises. Evidence confirming this is set out in Appendix C.

2.7 The Framework cannot be interpreted to provide generic restrictions on a particular use class. Moreover, the evidence does not support such restrictions. The need for evidence is emphasised in para 158 of the Framework which states that each local plan should be based on adequate, up-to-date and relevant evidence. Compliance with the soundness test is still required.

2.8 The proposal does not accord with the “golden thread” running through the Framework which seeks to build a strong competitive economy. Such a policy could potentially stifle economic development and is not consistent with the Framework.

3. Soundness - summary

3.1 We consider that restricting the location and concentration would be unsound and fails to meet the four tests of the Framework. It is not a positively approach to planning; justified; effective; or consistent with national planning policy. Such a policy should therefore not be taken forward to the next stage of the plan making process.

3.2 Many restaurant operators have made major steps to expand the range of healthy options and work with the communities within which they are / will be part of.

4. McDonald’s has made major steps in recent years to expand the range of healthy offerings

4.1 As a responsible business, McDonald’s recognises it has a role to play to support its staff, customers, and the communities in which it operates to live healthier lifestyles. For this reason, McDonald’s has invested significantly to evolve its menu over the last 10 years – both to extend the range of choice, and to reformulate our products. For example, McDonald’s has:

- Added porridge, salads, grilled chicken wraps, carrot sticks, fruit bags, orange juice, mineral water, and organic milk to its menu
- Completely removed hydrogenated trans-fats from its menu
- Reduced salt in our Chicken McNuggets by 36%, and our fries by a quarter since 2003
- Reduced fat in its milkshakes by 34% per serving since 2010
- Reduced fat in its deli rolls by 42% since 2011

4.2 McDonald’s has also led the way displaying nutritional information to help its customers make informed choices. Since 2011, McDonald’s has provided calorie information on every one of its 1,200+ menu boards in restaurants across the UK.

4.3 This is in addition to the nutritional information that is already available on its website, on its tray liners, on its packaging, and via McDonald’s mobile phone app. In 2012 alone, McDonald’s received 2.2 million visits to its nutrition web page.

4.4 Furthermore, McDonald’s is committed to responsible advertising, and advertise to children only food items that are not classified by the Government’s nutrient scoring criteria as High in Fat, Salt or Sugar “non-HFSS”. All of McDonald’s advertising to children features at least one portion of fruit or vegetables, and a no added sugar beverage such as milk.

4.5 As a significant customer of British farming, McDonald’s buys quality ingredients from 17,500 UK and Irish farmers. It now spends more than £390 million every year on British and Irish produce, compared to £269 million in 2009.

4.6 All of McDonald’s burgers are made with 100% British and Irish beef. We use whole cuts of forequarter and flank, with nothing added or taken away in the process.

4.7 In addition, McDonald’s only uses 100% British RSPCA Freedom Food Pork across its entire menu. As a result, all pork suppliers are required to meet strict animal welfare standards.

4.8 McDonald’s was also one of the first retailers to switch to using free range eggs – which it did back in 1998. Free range eggs are now used in its entire menu – including its sauces, muffins and the coating on chicken nuggets. Every year McDonald’s use over 100 million free range eggs, sourced from more than 200 UK producers, and for its work in this area they have been awarded ‘Food Business of the Year’ by the British Free Range Egg Producers Association.

4.9 The strength of McDonald’s supply chain – which was clear of any horsemeat – has also been confirmed by Professor Chris Elliott, who said in light of the horsemeat scandal: “McDonald’s invited us to look at farms and abattoirs – it was a very simple supply chain. The other thing I was very impressed about was the length of contract McDonald’s had with its suppliers.”1*

*1 Evidence at Environment, Food & Rural Affairs Select Committee Inquiry, January 2014

5. McDonald’s also contributes to the community

5.1 As the Community Partner of the Football Association, McDonald’s has helped to train and recruit more than 25,000 coaches. These coaches in turn have provided more than 2 million hours of free quality coaching, to one million young players.

5.2 Over 1,000 McDonald’s restaurants across the UK are ‘twinned’ with a local team to provide free kit, equipment, advice and expertise.

5.3 Each of McDonald’s restaurants also conduct a minimum of three litter patrols on a daily basis, and conduct larger Love Where You Live ‘clean up’ events. McDonald’s is also the primary sponsor of the Mayor of London’s Capital Clean Up campaign, to tackle litter across London.

5.4 Last year, McDonald’s restaurants in Greater London organised over 50 community clean-up events, with over 1,400 volunteers taking part.

6. McDonald’s is a major employer of young people

6.1 McDonald’s is a major employer of young people under the age of 25, and for many it provides a first step on the career ladder. McDonald’s offers all staff the opportunity to gain qualifications which include Adult Certificates in English and Maths, a Level 2 Apprenticeship, and a Foundation Degree in Managing Business Operations.

6.2 McDonald’s invest £43 million annually in staff training and development.

7. Conclusion

7.1 Consideration needs to be given to the impact that restricting opening hours could have on the viability of schemes.

7.2 It is unsound to introduce such a widespread land use policy to protect the amenity of such uses, which could be dealt with on a case by case basis via conditions. Further to this, the supporting text itself outlines that there is no direct link between the location of hot food takeaways and such land uses, therefore such an approach is unjustifiable.

7.3 The proposed approach in direct conflict with the Framework. The policy attempts to introduce a widespread land use restriction on a specific use class without providing a single map to outline the specific limitations it would have. Without a map it is impossible to indicate the extent of the policies implications on the borough.