Policy EMP4 – Other Employment Sites

Object

Representation ID: 12226

Received: 11/10/2021

Respondent: Mr Ian Flynn

This policy could be updated to better protect local employment uses. The case to retain and renew existing older employment sites will always struggle economically against alternative plans to redevelop for housing. However, these sites often support important supply chain that is either lost or moves far away. For some sites surrounded by resi, it makes sense to release these for housing, but to retain local employment, specialist skills and diverse communities, not all of these sites should be lost to housing.

Support

Representation ID: 13953

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy EMP4 Other Employment Centres

LCP support this policy which seeks to allow other employment uses to be introduced in employment use or to be redeveloped for other uses which could include housing. Such an approach is in line with the advice in paragraphs 122 and 123 of the NPPF.

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.

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.