Object

Representation ID: 24367

Received: 30/11/2016

Respondent: AquiGen

Legally compliant? Not specified

Sound? Not specified

The previous criteria based approach to assessing non-employment uses in employment areas has now been deleted. This does not reflect hearing.

Wording provides no flexibility for alternative non-employment uses (with exception of starter homes and small scale services) in employment areas

NPPF Para 22 states - Planning Policies should avoid long term protection of employment sites where no reasonable prospect of employment use exists.

In context of oversupply it is appropriate to allow alternative uses to come forward. The lack of flexibility is inconsistent with NPPF para 22.

It is recommended that the criteria referred to for employment sites outside of employment areas (i.e. f,g and h) also apply to Employment Areas. This approach would ensure protection of employment areas, due to 12 month marketing criteria, whilst bringing the policy into line with NPPF para 22 for sites with no reasonable prospect of employment use.

It is recommended that 9.155 be amended to allow other sui genereris uses to be considered on their merit. The current exclusion of those uses with non-ancillary retail or leisure content, risks excluding trade counters or builders merchants which would typically be acceptable within employment areas.

Object

Representation ID: 24403

Received: 01/12/2016

Respondent: Ashfield Land Limited

Legally compliant? Not specified

Sound? No

Ashfield Land is however concerned regarding the need to provide a "town centre first approach to the location of offices". It is accepted that office uses are a Main Town Centre Use within the NPPF, and sequential testing should be used when assessing appropriate sites.

However, by defining a site as an Employment Area, the requirement to provide a sequential test within these areas should be removed. If a site is seeking to attract
employment, then office uses should also be encouraged.