DM27 Employment Land - Preferred Option

Whilst it may be likely that there will be a predominance of B1 and B2 uses on new employment sites, it is important that in a changing economic climate, this policy should not be used to frustrate or limit job creation via an overly restrictive approach. Indeed, a restrictive approach is very much contrary to the stated employment Vision, which include for example that:

"a new employment park in the west of the District ... has been developed which caters for a range of employment types in a flexible manner that adapts to changes in the economy."

It is also unclear what the policy means when it refers to a "predominance" of B1 and B2 uses, and we are concerned that this phrasing opens up a wide range of interpretation.

In addition, to make new commercial sites attractive to occupiers, experience shows that flexibility of business use is required, and that at least an element of B8 space is necessary for many occupiers. If there are specific sites where B8 (or indeed potentially B2) uses are not suitable, this can be specified in the Site Allocations DPD.

We suggest that the policy should be more positively worded to promote employment uses, whilst still maintaining a focus on the 'B' uses, as follows:

"Within new and existing employment land, development in Classes B1, B2 and B8 will be supported. Alternative uses will be considered having regard to ...."

This alternative wording still makes clear that B1 and B2 uses are favoured uses, but avoids problems of interpretation, and still makes it possible for other employment generating uses to come forward that comply with the criteria listed.

In accordance with the sequential policies contained within PPS4, it is important that new locations for commercial uses are sustainable and have access to public transport (to discourage employees driving to work), and ensure that employees have access to a range services and facilities.

The Green Belt and Countryside

DM10 Existing Businesses in the Green Belt
We support the preferred option

DM11 Rural Diversification
We support the preferred option

DM12 Conversion of Existing Agricultural Buildings in the Green Belt
Whilst you refer to PPS4 and PPG2, current policy seems to ignore PPG7. Policy PPG7 does not rule out the conversion of agricultural premises for business or residential use. Therefore, to encourage skills and growth in the rural economy, we support a less restrictive approach as above. We see this as being potentially good for the local economy both in terms of new business and providing local work for construction and building supplies.

With regard to listed buildings, each case should be judged on its merits.

Tourism Opportunities in the Green Belt

DM13 Green Tourism

Your paragraph which states "appropriate locations should not result in agglomeration of similar facilities" could result in uneconomically viable and restricted businesses. If the authority is serious about encouraging Green Tourism, it must let the market decide. As an example, Southend Sea Front is known for Hotels and B&B accommodation. This grouping ensures its economic viability. Restrictive policy constrains it.

This policy should be less restrictive

Transport

DM25 Parking Standards
In order to attract and keep business in the district, we should relax the maximum car parking standards for key trip destinations. By enforcing this restriction we are directing shoppers out of the district. Example: Fossetts Way, TESCOS, Rayleigh Weir and Lakeside. The public will go where there is car parking. This policy is driving out business development to neighborouring districts, increases car use and congestion.

On page 57 there is mention of the RDC Transport Strategy Supplementary Planning Document. This document has not been issued as a consultation or in draft form. What is the timetable for this?

Economic Development

DM26 Traffic Management
There is no policy to support the increase in traffic generated by the proposed, planned developments. Example: Coombes Farm, Airport Expansion, West Rochford, Ashingdon Road, Christmas Tree Farm and Stambridge Mills. We should at least have a contingency plan in the event of gridlock.

DM27 Employment Land
This appears to be yet another restriction, driving people out of the area for retail activity. (See DM25 above.)

Cases should be judged according to their merits.

Retail & Town Centres

DM29 Town Centre Shopping Frontages
The 75% rule (Guidance) for retail outlets in town centres should be enforced.

The authority should not be in the business of micro managing the market. Shoppers like choice, any vibrant, retail centre will provide choice which is often clustered.

DM30 Upper Floor Locations in Town Centres
Agree preferred option

DM31 Village & Neighbourhood Shops
We agree that "retail use is important to ensure the vitality and vibrancy of any shopping frontage and to meet the needs of local communities".

DM32 Advertisements and
DM33 Advertisements affecting Conservation Areas and Listed Buildings
The authority need to have effective guidelines rather than the subjective judgements which are not user friendly and singularly unhelpful.