Policy H1 - The Efficient Use of Land for Housing
Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. The aim of this policy, which seeks the efficient use of land for housing, is supported. However, concern is raised in relation to the redevelopment of employment sites for appropriate uses, including residential development.
The Core Strategy does not clearly justify this element of the strategy and concern is raised that the approach may be driven by the target of achieving 60% of new housing on previously developed land.
Full text: Although the Preferred Options version of the Core Strategy (CS) identified that existing employment sites would be reviewed through an Employment Land Study and consideration would be given to reallocating sites for housing where appropriate, the identification of these sites in policy H1 has emerged at a relatively late stage in the process.
It should be noted that the Core Strategy recognises that there is generally sufficient supply of employment sites but that any de-allocation will have to be compensated for. Consequently additional employment land is allocated under policy ED4 in lieu of the employment land to be redeveloped for other uses. This has resulted in greenfield sites being allocated for employment. Whilst this is not disputed in principle, it is important that a careful assessment is undertaken when changing uses of sites or designating new sites.
Whilst the principle of redevelopment of employment sites to alternative uses in certain circumstances is accepted, careful consideration needs to be given as to whether these employment sites should be lost, whether the sites are sustainable locations for alternative uses and whether other constraints such as land assembly, up front construction costs of the units and associated infrastructure or flooding may prevent these sites from coming forward. The loss of employment sites may result in relocation to sites outside the borough. Such constraints can impact upon delivery and given that the Core Strategy only identifies sufficient sites to meet rather than exceed the minimum housing requirements, if site do not come forward the Council may not be able to meet their requirements. In the absence of the SHLAA it is difficult to comprehensively review these employment sites. However, our knowledge of the Stambridge Mill site leads us to query the allocation of this site for alternative uses for the reasons set out below.
The Employment Land Review was completed in 2008 and identifies that the Stambridge Mills site does not have any bad neighbour issues and recommends that it is safeguarded for light industrial use and it also recognises the possibility of this site to accommodate businesses relocated from the Star Lane Industrial Estate. However just one year later this site is now identified as coming forward for alternatives uses in the Core Strategy Submission document.
As recognised in the Council's Urban Capacity Study (UCS) (2007) this site is "relatively isolated", detached from the main settlement and public transport nodes and services. The UCS also identifies that part of the site lies within a flood risk area, that there are possible issues with biodiversity on the site and that infrastructure improvements may be necessary to accompany residential development. The Adopted Local Plan (2006) also recognised at paragraph 4.38 that the "purpose built buildings and location within a flood risk area pose significant constraints on the site for uses other than milling".
Although it is noted that this site is not currently in use, it is considered that its redevelopment would be inappropriate, having regard to the need to find suitable locations for housing in accordance with PPS3 application of the sequential and exception tests under PPS25.
The summary of the Strategic Housing Land Availability Assessment (SHLAA) identifies that the Stambridge Mill site is capable of delivering 250 units between 2010 and 2012. This is substantially higher than the figure of 60 dwellings identified as the capacity for this site in the UCS in 2007.
In the absence of the full SHLAA it is difficult to review the other sites. However it has been demonstrated that at least one of the employment sites, Stambridge Mills, should not come forward for housing. As currently drafted the Plan lacks flexibility to ensure that sufficient sites come forward. The considerable doubt associated with the suitability of Stambridge Mill means that its 250 capacity may need to be reallocated.
Amendment to Policy H1: In order to make this policy sound, the redevelopment of employment sites should be amended to exclude Stambridge Mill (and potentially other employment sites). As currently drafted the policy is not justified as it is neither founded on a robust or credible evidence base and is not the most appropriate strategy when considered against the reasonable alternatives.

Masterplan/Facilities plan Council ref AE22