Policies NEL1 and NEL2 - New Employment Allocations at West Rayleigh
Introduction
Policy ED4 of the adopted Core Strategy sets out a proposed new employment allocation on land to the south of London Road at west Rayleigh. The text to ED4 explains that the allocation is expected to meet part of the 2.2ha of additional high quality office space identified in the Core Strategy, and meet the requirement for displaced uses from Rawreth Industrial Estate.
In the event, the Council has identified two sites for employment purposes at west Rayleigh, with site NEL1 being south of London Road, and site NEL2 being in the vicinity of west Rayleigh, but not actually on London Road.
Although not strictly speaking 'south of London Road', we do not object in principle to site NEL2, but we do have concerns as to the appropriateness of the site for 'high quality' office uses, given its remote location and also the intention to use the site for displaced uses from Rawreth Lane Industrial Estate. We object in principle to the proposed allocation at NEL1, on the basis that it already substantially used for employment purposes, and the land that is not so used is not suitable for development in the manner suggested.
Taken together, neither NEL1 nor NEL2 provide locations suitable for the proposed high quality office use required by Policy ED4.
Representations
NEL1 - Land south of Rayleigh Road
Of the proposed 5 ha site, some 2.5 ha of land is already occupied by long-established commercial uses. The site allocations DPD seeks the retention of these uses (para 5.14).
Of the undeveloped areas, the allocation includes a slither of land to the west of the existing businesses, of around 0.4 ha, which has no existing means of access, and which would be of limited use, given the shape of the land. To the east of the existing uses, there is a larger parcel of around 2 ha, with a frontage to London Road. However, the majority of this land is affected by the twin pylon lines that cross the site in a north/south direction. Although the pylons would not preclude commercial development as such, the lines themselves hang relatively low of the site, such that two storey development across the majority of the site would be difficult to achieve.
As far as we are aware, there have been no representations on the part of the landowner supporting the development of the site for commercial purposes, and no interest from any developer seeking to undertake a commercial development.
In the light of all of the above factors, we consider that the likelihood of any new commercial development occurring on NEL1 to be extremely limited, and therefore that the Site Allocations is not Justified/Effective since it will not deliver the high quality office development required by ED4.
By contrast, Countryside Properties have consistently argued that an element of commercial development can be developed as part of a mixed-use allocation north of London Road, where the costs of the servicing a commercial development (drainage, utilities, highways) can be shared with the development of the residential element.
NEL2 - West of the A1245
As set out elsewhere in our submissions, it seems highly unlikely that the Rawreth Lane Industrial Estate will be redeveloped, but in the event that this were to occur, our understanding is that this site is allocated in order to provide a suitable location for such uses to relocate.
What is unclear from the wording of the Site Allocations is whether or not this site is reserved solely for the relocation of uses from Rawreth Lane (aside from the proposed recycling centre). If the intention is that the land should be available such that an existing use from Rawreth Lane can relocate there, then the text to the Policy would need to make clear that the site is solely reserved for such uses, and that permission would not be granted for any development for commercial purposes unless it related to the relocation of an existing use.
If that is not the case, and the land is simply notionally available for relocation of existing uses, then there is of course no guarantee that even if an existing use from Rawreth Lane was able to afford the costs of relocation, that there would be space available for them on NEL2 to enable this to happen. If the land is not specifically reserved and left for relocating businesses, then the chances of Rawreth Lane ever being redeveloped are diminished even further, since existing business will stay.
We note that paragraph 5.31 lists one of the possible uses of the site as being for high quality office use". Given the relative remoteness of this site, we would suggest that the site is not appropriate for such high density business uses. Moreover, given that the site is also identified at paragraph 5.32 for 'heavy industry', it seems highly unlikely that it would attract a high quality office use anyway.
We would therefore consider that reference to high quality offices should be deleted from NEL2, since it is not Justified, and that to be Effective, NEL2 requires clarification as to whether or not the land is actually reserved for the relocation of existing business from Rawreth Lane, and not for general industrial use.