WEST BERKSHIRE CORE STRATEGY EXAMINATION

INSPECTOR’S AGENDA – MAIN MATTER 5: WEDNESDAY 10 NOVEMBER

MM5 is divided in to 3 separate sub matters to be considered in separate hearings for which there are separate lists of participants.  I expect all the hearings today may be completed by lunch, so participants for later sessions should not delay their arrival unduly.

Having read all the responses to my previous questions, this agenda focuses on matters that I particularly want to clarify and expresses a preliminary view on some matters to focus the discussion and to prompt the Council to look afresh at the wording of policy CS10.

1  Sub Matter – Business Development (CS10)

1.1  Does the Employment Land Assessment (ELA) 2007 (CD09/21) provide a reasonable basis for planning for business development.  My preliminary view is that despite being 3 years old, it is not so out of date as to make it an unsuitable basis to inform the Core Strategy’s approach to business development.  It is essential, however, to have regard to changes since that work, to continue to monitor changes in business development and to retain sufficient flexibility in the policy approach adopted to respond to changing market conditions and site specific matters where relevant (see below).  Any discussion?  

1.2  In relation to monitoring, the Council indicates in its statement a minor change to monitor employment floorspace and employment land by type.  This would seem essential if the trends in different business sectors are to be noted.  Should these indicators have targets related to the changes in demand for land or floorspace projected in the ELA, given that these are intended to be the basis for managing developement within employment areas?  It could be noted that the targets would need to be updated in the light of any new employment study.  Discussion.

1.3  Does policy CS10 adequately address the evidence in the ELA?  The text of the plan suggests, and the Council’s statement more fully confirms, that it is the Council’s intention to manage and facilitate business development to respond to the market changes for land and floorspace projected in the ELA.  This is primarily to be achieved through managing change within existing business sites, rather than allocating new land.  In my view, such an approach is sound and consistent with PPS4.  This should be the overarching strategic policy aim expressed in policy CS10, but it is not clear at present.  The role of the Site Allocations DPD should also be outlined as the means to put this intention into effect.  Discussion.

1.4  Should the policy indicate the scale of change that is being planned for in different sectors?  If it does not, how will the task of the Site Allocations DPD be made clear?

1.5  Within (as a sub-set of) the overarching aim suggested above, policy CS10 should outline the headline approach to some important matters.  Firstly, it should address the locational strategy for new B1 development given that this is the main growth area.  In accordance with PPS4 ,the starting point should be town and district centres.  To accommodate projected change and growth and given the nature and scale of some existing business parks, flexibility may be justified.  The Council should explain these circumstances further at the hearing.  But I consider that the policy is currently too indiscriminate, since it would allow B1 development in all Protected Employment Areas (PEA).  If flexibility is appropriate, there needs to be focussed criteria for where B1 might be acceptable outside the centres eg relationship to the main urban areas; good accessibility by non-car modes.  An embedded addition to CS12 restates the PPS4 position and thus CS10 is inconsistent with it.  Discussion.

1.6  A second sub-set in CS10 under the main aim should be the approach to reviewing and managing change within the PEAs.  This should explicitly include reviewing boundaries of the existing designations and whether sites continue to be fit for purpose.  The text could refer to how this will be assessed, such as the assessments made in the ELA and other local circumstances.  What else is relevant?  Is it the Council’s intention that the Site Allocations DPD would indicate specific PEAs where different uses would be acceptable (eg redevelopment for B1)?  If not, should it?   Any such intention should also be in the policy.     

1.7  I do not understand why the intended review of PEAs would not encompass the designation of existing substantial employment sites built after the local plan designations were made (eg Vodaphone and New Greenham Park) or sites which have come within the remit of the planning system since then (the AWE sites).  The Council seem opposed to this, why?  Unless persuaded otherwise, I consider that policy CS10 should list these major new sites to give them the protection (and positive business focus) of PEA status.  These sites would seem of strategic significance to West Berkshire.  Vodaphone and New Greenham Common are included among the Key Employment Areas on Fig 4 and the 2 AWE sites are specifically marked on Fig 7.  The listing of these key sites would not prelude the Site Allocations DPD including additional smaller sites.  The precise boundaries of all sites would remain a matter of detail for the Site Allocations DPD.  Discussion.

1.8  In the context of the all the above, the similarly worded Proposed Focussed Changes (PFC) 1, 2, 3, 4, 5 etc No net additional employment floorspace… seem a rather passive addition and do not give sufficient emphasis to the (apparently) intended active management and facilitation of change.  In the light of a possible rewording of CS10, the appropriate wording for economic development in other spatial policies may also need amending for consistency.

1.9  I note that PPS4 encompasses both business and town centre uses in its definition of economic development.  I see no reason why this means that all these uses should be addressed in a single policy, provided that the focus and coverage on any particular element of economic development is made clear.  Any comment?  Whilst retail uses are addressed in policy CS12, there is no reference to (commercial/built) leisure uses, which are also a town centre/economic use.  Does the Core Strategy need to address this matter?

1.10  The approach in CS10 (focusing new business development on existing employment sites and previously developed land) would prevent an existing business in the countryside expanding beyond its existing curtilage.  Whilst I accept this is appropriate in terms of substantial new speculative development in the countryside, is it a sound approach in relation to established businesses with local connections which may not be “foot loose”?  I also remain unclear whether there is any tension between this aim and the policy seeking to diversify the rural economy.

1.11  Any other critical points in relation to business development?

1.12  I would strongly encourage the Council to look afresh at the wording of policy CS10 so that it expresses more clearly what appear to be the Council’s intentions, but taking into account my concerns.  Revised draft to be circulated at the hearing for discussion.  The text of the Core Strategy may also need amending, but may this could follow discussion of the policy.

2  Sub Matter – Rural Economy and Equestrian Racehorse Industry (CS11 and CS13)

2.1  A minor change has been embedded at the end of the first paragraph of CS11.  The Council’s statement suggests a further change to make clear that the policy can only protect sites not particular businesses.  This seems sensible.  Any comment? 

2.2  If any new participants, then discussion of 1.9 above.

2.3  Does policy CS11 adequately address national policy in PPS4 for development in rural areas?  (The Statement by the AONB Unit also refers to the advice in paragraphs 17/18 of PPS7, but these have been cancelled by PPS4).  Bearing in mind that development plans do not need to repeat national policy and the intended role of the Site Allocations DPD (see below) my preliminary view is that policy CS11 does not need to set out detailed criteria, but should indicate the approach.  However, the last paragraph of CS11 identifies some specific matters and by highlighting these, but not others (eg impact on the countryside/landscape), it suggests that these are most important, which is not necessarily the case.  Given that CS10 applies to the rural area, is the last paragraph necessary (or consistent with it).  Discussion. 

2.4  The Council’s statement suggests an addition to the text of the Core Strategy at 5.46 to make clear that the Site Allocations DPD will include policies on farm diversification and conversion/reuse. This seems helpful.  Would it benefit from the addition at the end of the new sentence of …responding to (or consistent with) national policy in PPS4 to indicate that no departure from national advice is intended?

2.5  Is policy CS13 justified in seeking to resist the redevelopment away from uses essential to the horse racing industry of suitable existing establishments and facilities?  The statement by Carter Jonas (on behalf of S & F Holding 141606) presents some clear augments which suggests that it may be neither necessary nor helpful to resist redevelopment of yards which are within or abutting the settlement boundary of Lambourn.  Does the Council consider that these particular yards remain suitably located?  On the other hand, the Council’s main point (Statement 2.12) reflects the clear support for the retention of all types of yard set out in the Lambourn Parish Plan pp 46/47 (CD10/58).  Is there a need to enable entry by new/ small enterprises?  Discussion around these points.    

3  Sub Matter – Retailing and Town Centres

3.1  What is the latest position in relation to the redevelopment of Kinglands Centre in Thatcham?  Is there any specific evidence whether this will proceed or not?  Are there any know impediments?  (The case advanced by Barton Wilmore on behalf of Bellway Homes 32006 for more housing at Thatcham to support the town centre is most appropriately addressed under issue MM3.)

3.2  Should the Core Strategy indicate that the existing local plan policies relating to primary shopping frontage will be reviewed in the Site Allocations DPD for the reasons set out in Shire Consulting’s Statement (27 September 2010) on behalf of Barclay’s Bank?

3.3  Does the omission of any reference to culture or arts venues make the Core Strategy unsound?  (See Statement from the Theatres Trust 6 October 2010)?

Simon Emerson

Inspector

27 October 2010