Object

Local Plan Review: Preferred Approach 2016-2035

Representation ID: 1513

Received: 07/02/2019

Respondent: Linden Homes & Miller Homes

Agent: WYG

Representation Summary:

It is recommended that added flexibility is provided in both policy S8 and in the allocation of 6 hectares of employment space at West of Chichester via policy AL1 to recognise the uncertainty associated with employment provision. It is recommended that instead the allocation of employment space at West Chichester be made more flexible by allocating the areas for mixed use employment and residential uses, with the final amount of employment to be determined by market evidence submitted at the time of the application.

Full text:

Linden Homes and Miller Homes recognise and support the need for an adequate supply of employment land to help provide jobs and services to the residents of the local area and help meet economic goals within the district. In this respect, the provision of some employment land on the West of Chichester allocation is accepted to create a sustainable, mixed-use, community.

However, the Council's planned need for new employment space is add odds with the evidence provided by the Council's own HEDNA. The HEDNA identifies a need for 145,835m2 of new employment floor space where as the plan provides for a supply of 235,182m2 of floor space, an oversupply of over 60%. It is recognised that the difference is to make up for forecast losses in employment space over the plan period, however, the reasons for these forecast losses are not made clear. Reference is made to 'no longer suitable sites for employment' but it is not clear where these sites are or why they may no longer be suitable. In any case, the retention and/or redevelopment of existing employment sites (which would normally be classified as brownfield sites) should take precedent over new allocations, which is endorsed by draft policy DM9 of the draft plan.

Furthermore, if the Council has particular concerns in regards the loss of employment space through
Permitted Development rights allowing Change of Use to Residential (C3) use then, if they can provide suitable evidence, the Council could explore use of an Article 4 direction to help better control the loss of employment space, rather than rely on new, less certain, employment allocations.

Finally, the policy, and allocation policies which provide for new employment space, do not provide sufficient flexibility to allow the plan to adapt to changing local, national and international economic circumstances, which can change quickly and sometimes unexpectedly. Whilst recognition is given to the need for close monitoring and potentially early review of the policy, it is considered that instead flexibility should be built into the policy now to allow developers to show local need.

Therefore, given the above, it is recommended that added flexibility is provided in both policy S8 and in the allocation of 6 hectares of employment space at West of Chichester via policy AL1 to recognise the uncertainty associated with employment provision. It is recommended that instead the allocation of employment space at West Chichester be made more flexible by allocating the areas for mixed use employment and residential uses, with the final amount of employment to be determined by market evidence submitted at the time of the application. This will help ensure that the employment provision provided meets local needs at the time of development and the land is put to its most economically and socially valuable use.