Object

Representation ID: 44939

Received: 11/10/2021

Respondent: Aldi Stores Ltd C/o Turley

Agent: Aldi Stores Ltd C/o Turley

Objection to proposed Policy EMP4

The explanatory text for Policy EM4 , para 7.37 recognises that there are older employment areas throughout the Black Country that are of relatively poor quality , which may be suitable for redevelopment for alternative uses , with housing specifically referenced. Para 7.38 goes further, suggesting that alternative uses could give rise to “significant regeneration benefits” on such sites.
The text suggests that Policy EMP4 sets out a “flexible policy framework” for consideration of such alternative redevelopment proposals. However the set of criteria included in the draft policy, all of which seemingly have to be complied with, set an almost impossibly high bar for the alternative forms of development to surmount before being considered acceptable. The intention of the policy is clear- it is supportive of appropriate forms of alternative development in principle. However, the application of the policy as written will severely undermine the potential for beneficial alternative development to be permitted.
In addition, the policy as worded under 1), sub section b) refers to only two forms of alternative uses being acceptable- housing and “non-ancillary non industrial employment uses”, with no definition of what the latter types of use might encompass.
We propose an alternative form of wording for Policy EMP4 which more appropriately reflects the intention of the Policy and streamlines the relevant criteria so that they become more proportionate and reasonable for alternative proposals to address. The alternative policy wording also explicitly identifies retail use as an appropriate form of development on such sites in principle (subject to compliance with CEN policies) in view of its employment generating potential and ability to enable/cross fund other forms of appropriate uses on such sites, creating wider regeneration benefits.
We note that the supporting text refers to a requirement for marketing evidence to demonstrate non-viability. Such evidence would still be a requirement for criterion b) of our revised policy, but not in cases where net positive employment/regeneration benefits can be demonstrated under criterion a).
PROPOSED ALTERNATIVE WORDING
Policy EMP4 – Other Employment Sites
1) For employment areas that are not designated as either Strategic Employment Areas or Local Employment Areas on the Policies Map, but comprise existing occupied employment land within the BC, development will be supported for:
a) new industrial employment uses or extensions to existing industrial employment uses, or
b) housing, other non-ancillary non-industrial employment or retail uses (subject to compliance with CEN policies).
Development or uses under 1(b) will only be supported where there is robust evidence to demonstrate to the satisfaction of the relevant authority, that:
a) The proposal would give rise to net positive employment or regeneration impacts compared to the existing use; or
b) The site is no longer viable for such uses;
c) The proposed alternative development could be brought forward in a comprehensive manner and would not lead to piecemeal development;
e) The proposed alternative development would not adversely affect the ongoing operation of existing or proposed employment uses on the site or nearby;
f) The proposed alternative development is in accordance with local or national policies relating to these uses.