Policy DM9: Existing Employment Sites
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 459
Received: 28/01/2019
Respondent: Mr Robin Kidd
Why restrict this policy to employment in classes B1-B8? Why not include retailing and leisure and other institutions as sources of employment? This has led to unnecessary inflexibility (e.g. in turning down gym applications), and has encouraged employers to move out of the district e.g. to Portsmouth.
Why restrict this policy to employment in classes B1-B8? Why not include retailing and leisure and other institutions as sources of employment? This has led to unnecessary inflexibility (e.g. in turning down gym applications), and has encouraged employers to move out of the district e.g. to Portsmouth.
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 745
Received: 01/02/2019
Respondent: St Pancras church
Object to the additional requirement that "the use does not prejudice the operation of and market attractiveness of the wider employment area."
Draft Appendix C does not provide guidance, or any definition of, "the benchmarks" against which "market attractiveness" is judged.
In general, this policy does not fully reflect principles embodied in Central Government policy (Use Classes Order and GPDOs), which enable the change of use of offices to residential.
However, the opportunity for proposed leisure or community uses on existing employment sites is welcomed.
Object to the additional requirement that "the use does not prejudice the operation of and market attractiveness of the wider employment area."
Draft Appendix C does not provide guidance, or any definition of, "the benchmarks" against which "market attractiveness" is judged.
In general, this policy does not fully reflect principles embodied in Central Government policy (Use Classes Order and GPDOs), which enable the change of use of offices to residential.
However, the opportunity for proposed leisure or community uses on existing employment sites is welcomed.
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 807
Received: 02/02/2019
Respondent: Mr Graeme Barrett
On the Western Manhood major employment sites have been or are being redeveloped for housing:
Cobham Microwave
Earnley Concourse
South Downs Holiday Park
The Royal Oak Pub
Resident of West Wittering
On the Western Manhood major employment sites have been or are being redeveloped for housing:
Cobham Microwave
Earnley Concourse
South Downs Holiday Park
The Royal Oak Pub
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 1154
Received: 05/02/2019
Respondent: Mrs Fiona Horn
Why have you removed areas near Goodwood that will have no adverse affect on the area and full fill criteria laid down and yet other areas like AL6 have been included that do not full fill the criteria.Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.
Why have you removed areas near Goodwood that will have no adverse affect on the area and full fill criteria laid down and yet other areas like AL6 have been included that do not full fill the criteria.Unless this is adequately addressed in future iterations of the plan, I will raise this with the examiner at the appropriate time.
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).
Support
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 1620
Received: 07/02/2019
Respondent: Anna Khoo
Support exemption for change of use of employment sites to leisure or community use. These facilities are crucial and lacking in the city centre in particular and often do create employment as a by-product.
Support exemption for change of use of employment sites to leisure or community use. These facilities are crucial and lacking in the city centre in particular and often do create employment as a by-product.
Support
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 2611
Received: 05/02/2019
Respondent: Premier Marinas (Chichester) Ltd
Agent: CBRE
Support policy but para 7.59 at odds - Harbour Management Plan not a DPD or a robust policy approach and should not be referenced.
Lengthy marketing periods can leave empty properties creating no employment when change of use could create employment/further benefits.
Para 7.59 should recognise relevance of complimentary uses which support viability of marinas.
See attachment
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 2673
Received: 04/02/2019
Respondent: Mr Mike Dicker
Make no real concrete provision of meeting employment needs of rural communities.
Real opportunity to provide routes of employment that support disconnected north of CDC area within SDNP.
AL4 should be considered.
See attached for full detail.
Full detailed submission for the Local Plan and supporting evidence is attached.
The representations attached to this submission reflect a high level summary of the detailed submission and do not contain the full level of detail received.
High level comments received:
a. The transport study conducted by Peter Brett Associates (PBA) is not fit for purpose and needs to be rewritten. The scope set for PBA is far too constraining and counters the democratic process agreed by the council to seek alternative routes.
b. Many of the documents are inconsistent and in their current form smack of inconsistency and bias. Reasons for excluding some strategic sites are not consistently used for other sites.
c. Many of the evidence documents are not present or are not complete for this consultation. These will need to be re consulted when they are complete.
d. CDC should not be accepting the unmet housing need from the South Downs National Park (SDNP). They should also be going back to government to insist that until certainty is provided on the A27 this area can not accommodate future housing and or employment space.
e. The proposed link road was resoundly rejected last time it was proposed by Highways England. CDC need to respect the voices that rejected what is option 2 by stealth. Particularly as the PBA report states that the building of the link road will offer other "strategic options". This will not be tolerated locally.
Support
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 2766
Received: 06/02/2019
Respondent: Home Builders Federation
Welcome general approach but not clear how sequential test will be demonstrated:
1. which sequential test is it?
2. sequential test refers to new town centre uses not loss of older uses - not consistent with national policy
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 3104
Received: 06/02/2019
Respondent: Chichester Harbour Conservancy
Under points 1. and 2. it is unclear what "no material increase in noise levels" and "unacceptable levels of traffic" means. It is unclear how this would be enforced.
The Conservancy would also like the policy to be extended to include this text:
"Existing marine, coastal and water-based employment sites will be retained to safeguard their contribution to the local economy. Planning permission will only be granted for alternative uses if the site can be demonstrated to be not-fit-for-purpose for a marine-related business and that any marine related business is unviable."
See attachment
Comment
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 3147
Received: 07/02/2019
Respondent: Rolls-Royce Motor Cars Limited
Agent: David Lock Associates Ltd
The scale of development required for RR expansion could not be realistically delivered through DM9 - not a suitable alternative to a bespoke criteria based policy for strategic allocation linked to future expansion.
See attachment
Object
Local Plan Review: Preferred Approach 2016-2035
Representation ID: 3311
Received: 05/02/2019
Respondent: West Sussex County Council
Agent: Savills Plc
Policy wording is overly rigorous and could prevent appropriate development from coming forward.
See attachment