Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Supporting a Vibrant and Balanced Economy Economic Land and Development Policy 13 - Supporting a Vibrant and Balanced Economy [View all comments on this section]
Comment ID DLPP912
Respondent Seal Parish Council (Tim Marti… [View all comments by this respondent]
Response Date 06 Sep 2018
Current Status Accepted

6 - Supporting a vibrant and balanced economy

Employment land guidelines

The guidelines in paragraph 6.4 are very precise for each Business Use Class (to 0.1 of a hectare). The requirements of employers and the property market cannot be anticipated with such precession. Also, no provision is made for the many activities that support business uses and have the same location requirements; for example the maintenance and hire of equipment, and accommodation for fitters and fabricators. Flexibility is therefore needed in the type of business use to be accommodated and the scale of provision.

The guidelines in paragraph 6.4 should be expressed in floorspace and jobs, so that the significance of small but higher density town centre office sites for example can be compared with other options.

The Local Plan should assess the employment floorspace that would lost on the sites proposed for housing by Policy 2 so that the net effect of the proposals for employment is apparent.

Policy 13 - Supporting a Vibrant and Balanced Economy

The first sentence of Policy 13 states ‘Non-residential use of land and/or buildings will be retained unless it can be demonstrated that the use is no longer feasible or viable’. It is assumed that this paragraph applies to all land not in residential use, and such a policy could prevent industrial, warehouse or other non-conforming sites in residential areas from changing to housing. The paragraph supports the redevelopment of employment sites ‘no longer fit for purpose’.

The second paragraph of Policy 13 begins ‘Employment sites (allocated or non-allocated) will be retained in existing use…’ and requires market testing of proposals to redevelop such sites with other uses, which by implication are under-occupied and/or not viable.

The policy does not address proposals to develop successful employment sites over time with better buildings and a changing mix of occupiers within the Business use classes and related uses.

The fourth paragraph states that ‘Redevelopment of employment sites (allocated or non-allocated) for mixed use may be permitted …’ This could be interpreted to mean a mixed use retail and residential scheme would be acceptable before alternative business uses, contrary to the previous paragraph.

Policy 13 should therefore be clarified as follows:

"Non-residential use of land and/or buildings will be retained unless it can be demonstrated that the existing use is no longer feasible or viable, or causes loss of amenity for other uses nearby, notably dwellings and community uses."

The proposed redevelopment, conversion or change of use of all employment generating uses will need to be fully considered before a residential scheme. This includes considering the location, existing use, heritage value and local needs of the site and surrounding area.

Redevelopment of employment sites which are no longer fit for purpose to provide for high quality non-residential premises will be supported if the amount of floorspace or total number of jobs are retained, demonstrated to the satisfaction of the Council.

Employment sites (allocated or non-allocated) will be retained in business and related uses to support the economy of the District. Proposals to improve and redevelop existing employment sites to more effectively meet the needs of modern business uses will be supported if the employment capacity and commercial floorspace of the site, are maintained.

Proposals to change the use of and/or to redevelop employment sites (allocated or non-allocated) for other uses, including retail or residential use, will not be permitted unless the following requirements are demonstrated. Such proposals must provide sufficient independent information to show that the site in its existing employment uses is not viable, and that it has been proactively marketed, at the appropriate price using all relevant means, for new occupiers of the existing buildings, or the partial or comprehensive redevelopment of the site for its existing uses. Marketing must be for a period of at least one year at a time when the site is available or will be available shortly. In addition, applicants must demonstrate that forecast changes in market conditions will not result in the take up of all or part of the site.

Where it has been demonstrated, to the Council's satisfaction, through an independent assessment, that the current uses of the site are no longer viable and that there is no reasonable prospect of their take up or continued use during the Plan period, proposals for change of use or redevelopment must consider alternative uses in the following order of preference:

1 Other Business uses (B1a, B1b, B1c, B2, B8 or A2)

2 Other non-residential employment generating uses*

3 Mixed employment and residential uses

4 Residential employment generating uses (C1, C2)

5 Residential schemes (C3).

*Retail schemes will be subject to the retail policies of the Local Plan"


Employment sites for consultation

The guidelines for the economic land needed total 23ha (para.6.4). The sites proposed for consultation by Policy 13 exceed the guidelines and will not all be allocated. However, the draft Plan gives no indication of the preferred distribution of new employment land, nor whether the choice of housing sites will influence the location of employment allocations.

The largest concentration of potential employment sites is in the Sevenoaks area, which total about 22ha including site EM10 at Kemsing, but by far the largest concentration of potential residential sites is in the Swanley area. The Parish Council believes that the scale of allocations for housing and employment uses in each area should be broadly aligned.