Re: Employment Land - Public forum - Planning Advisory Service (PAS)

Hello, I'm afraid I don't have an answer to this, but I think it is a good question! Has anyone else followed a criteria based approach (or thinking about doing so)? If so, how are you running with it? Answers please! You don't even need to fork out for a postcard! Adam

If i've understood the question correctly (apologies in advance if I haven't), I would guess that trying to allocate a strategic site through the means of a criteria-based policy would be frowned upon when tested at Examination. Inspector's would want detailed guidance concerning its delivery including a schedule of any associated infrastructure required to ensure it is able to come forward in a timely manner as set out by the LPA. I find the approach outlined at Para 21 of the Framework a little confusing as it looks far more relevant to the now dated multi-document LDF approach of plan making. By that I mean you'd firstly set out any relevant criteria for identifying suitable non-strategic sites within the Core Strategy, and then go about allocating them through a later site allocations DPD. Of course, any strategic site would need to be properly identified and allocated through the Core Strategy. I recognise that I haven't helped give a specific answer. Just wanted to throw my thoughts on the original question into the mix for consideration.

Hi Adam (and Adam!), thanks for your replies. As you say, the paragraph in the NPPF isn't worded very clearly and we assumed, rightly or wrongly, that the best approach would still be to allocate the larger strategic sites for the reasons you've given. I guess my question really relates to smaller, non-strategic employment sites. There are currently several of these allocated in our current Local Plan which have sat undeveloped for several years. The policy protecting them for employment use puts the onus on a developer, wishing to develop them for other uses, to prove that the site will not come forward for employment. Our Authority is working towards a single Local Plan document which will encompass allocations, strategic policies and development control policies. Our existing employment sites will obviously be re-assessed as part of the development of that document and if they are found to be non-developable it is likely that will not be re-allocated. The wording of Paragraph 21 has just got me thinking whether we need to allocate such sites at all or whether a criteria based policy would be more suitable. Whilst allocating specific sites supports the 'plan, monitor, manage' approach and lets people know where employment uses are likely to go, a criteria based policy could be seen to be more 'pro-growth' and flexible, allowing greater movement between uses subject to certain criteria being met. Thanks, Leanne

I suppose it depends on how important these smaller sites are to establishing and maintaining a strong and resiliant local economy within your own locality. As you've said, your authority has a number of larger, more strategic sites which are suitable for allocation. However, if the development of the non-strategic sites are necessary to facilitate the growth of a particular employment sector or there are strong locational reasons why land should be safeguarded (proximity to a major transport hub or a site may be needed to harness specific skills in the local workforce), then it might be worth considering their allocation to ensure that economic aspirations are not sterilised through the inevitable pressure for non-employment uses. If the smaller sites you have mentioned are more suited to general forms of what i'd call more 'traditional' forms of employment, then I suspect that a less prescriptive approach to encouraging their development may be a better bet. As you say, this approach allows more flexibility when managing the use of land locally and may help your authority to respond positively to any sudden economic changes or a need to look for land to accommodate additional housing requirements should new evidence necessitate that. Not sure whether there is a right or a wrong answer to the query you've posed as there are pro's and con's connected to both. As long as you can justify the approach you ultimately take then that should hopefully form the basis for a sound planning outcome.