Object

Allocations DPD Discussion and Consultation Document

Representation ID: 17982

Received: 14/04/2010

Respondent: Barratt Eastern Counties

Agent: Kember Loudon Williams Ltd

Representation Summary:

PPS4 is new guidance and post dates the Core Strategy. It indicates that existing, well used employment areas should not be redeveloped for housing. Rawreth Industrial estate is in multiple ownerships and delivery is a major constraint. PPS3 and PPS4 encourage only the use of vacant areas.This site neither has a reasonable prospect of delivery for housing and nor should it be identified for housing as it provides a sustainable employment location.

Full text:

PPS4: Planning for Sustainable Economic Growth

This document was published in December 2009 and is material to the extent that it is likely to alter the extent to which RDC can rely on redeveloping its existing employment sites for alternate uses as set out in the SCS. In this context making the most efficient and effective use of sites within the Green Belt is important and justifies the need to plan flexibly by allowing scope for additional housing on identified Green Belt sites.

Policy EC2 of PPS4 provides direct policy advice on planning for sustainable economic growth. Criterion a) seeks a positive approach through identifying priority areas where there is deprivation and where regeneration is urgently required. This is not the case with the this Industrial area. Criterion b) seeks support for existing business sectors and planning for their expansion and contraction. This is a well used estate. A strategy for their removal would be at odds with PPS4. Criterion i) only encourages alternative uses if it is on vacant or derelict buildings. This is not the case at the Rawreth Lane estate.

Rawreth Industrial Estate contains a range of buildings however the existence of ownership constraints or any other legal constraints are unknown. The longevity of leases is important if this site is to be reasonably included. There has been no assessment of the viability of removing the existing uses and whether residential can replace them. The loss of over 5 ha of employment land which constitutes 1 of only 2 main employment areas in Rayleigh would significantly erode the supply of land for economic development in this town and this will be contrary to PPS4 (Policy EC2). I note the aims of SCS Policy ED4 but this site is on the western side of the District and serves a purpose. The appellant's have objected to this policy through the SCS and will be testing it at the Examination. There is therefore uncertainty whether the site will be delivered for housing and the amount. On this basis it cannot be classed, at present, as a development opportunity.

PPS3 criteria focus attention on the reuse of vacant and derelict land or underused employment areas (paragraph 38). This is not the case here. I find, as I have for the Eldon Way site, that the objection lodged to the SCS make the quantum of housing from this source a distinct uncertainty. I conclude that this further reinforces my view that there is insufficient Green Belt land devoted to housing development and that in the monger term more housing will need to be found on Green Belt sites.