Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 1241
Received: 07/02/2019
Respondent: Nova Planning
The policy needs to make provision for mixed use development to include higher value uses in response to the Council's own viability evidence.
Please see associated comments in relation to Policy S8.
Fundamentally, the policy ignores the advice contained within the Council's CIL Viability Assessment (2014) by only allowing the redevelopment of existing employment sites in scenarios which are already known to be unviable. New employment floorspace is generally unviable in the absence of accompanying higher value uses and the policy should plan for this reality.
In addition, the policy ignores scenarios where the continued employment use of a site may be harmful for environmental reasons (inc. incompatibility with neighbouring land uses). Left unchanged the policy is at odds with Paragraph 118 of the National Planning Policy Framework (2018).