Comment

Representation ID: 22563

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy EMP4 - Other Employment Sites

We are in support of the policy with regards to ‘other employment sites and the ability for sites which are not identified as strategic or local employment areas to be used for housing development. Part 1 of the policy acknowledges the need for sites that may not be suitable for employment uses (initially by the fact they are not allocated/designed) to be changed for housing.
Part 2 of Policy EMP4 sets out the criteria for employment sites to be developed into housing, however the criteria itself would require subjective views on what is acceptable evidence or not, as well as requiring substantial work for developments.
Part (a) of the policy as drafted requires proposals to demonstrate that the site is no longer required for industrial employment including the possible relocation of displaced employment uses from other parts of the Back Country. This requirement does not read as reasonable in terms of requiring development to search across the Black Country to see if the need is required, how would this be done in a proportionate and effective way. The Black Country covers a very large geographical area, with each LPA having its own individual requirements for employment space. Non-designated employment sites are generally owned individually and are small scale in nature and fails to meet the BEAR assessment criteria. It is unlikely that a small-scale industrial employer who may be displaced from one unsuitable employment location would want to relocate to another one. It is also unreasonable to expect those who have a business base say in the north west of Wolverhampton on the boarder of Telford to want to relocate to the other side of the Black county say on the border near Birmingham.
Part (b) of the policy requires the submission of viability evidence to demonstrate such uses are not viable. It is not clear what ‘these uses’ refers to as part (a) make specific reference to industrial uses, although the policy as a whole refers to general employment uses. It is assumed that by ‘these uses’ they mean the exiting employment use of the site prior to any change of use.
The policy as written is not practical nor justified, and simply makes it more difficult for employment sites which do not provide the quality of space or type required to be changed into more appropriate or practical uses, especially in urban areas.