Policy DM11 - Industrial Estates and Employment Areas

On behalf of the Shoebury Residents Association

Members are concerned that Shoebury is not an attractive area for employers and especially for youth employment.
Members wish to see the road access to Shoebury to be further improved, both for holiday makers and businesses, so that business will be encouraged to locate in Shoebury and business and holiday makers will not be put off by access problems.
We are concerned that many roads in Shoebury used by heavy transport are not suitable for heavy transport and wish to see more investment put into our local road infrastructure so that employers will locate in Shoebury.

Paragraphs 1.23 and 1.24 of the proposed Development Management DPD recognise the challenges the economy faces at the present time, and commits to providing a flexible planning framework in response. Set against this background, Part 2 of Policy DM11 notes that those sites listed within Policy Table 7 should be maintained and promoted for modern employment floorspace. This policy is considered to lack flexibi lity as it fails to recognise that viability will be an important consideration in the regeneration of the Prittle Brook Estate (which Is listed within Policy Table 7).

The policy Is not justified as it does not reflect the findings of the Southend-on-Sea Employment Land Review (ELR) 2010. The market appraisal of the site within Appendix 3 of the ELR states the following:
The site is well located and with access improvements could have good direct access from Priory Crescent to the A127. If modern purpose built premises can be provided in this location there should be continued market interest in the location. The site is important to the delivery of the Core Strategy because it represents a major opportunity to provide modern employment units within the borough. I t is acknowledged that to reflect viability issues there may need to be a flexible approach to a mixed use development that contains good quality
commercial premises particularly along the frontage to Priory Crescent.

This recognises the importance of the site whilst also acknowledging the viability issues. The reality is that redevelopment is likely to be dependent upon the consideration of enabling development as part of a mixed-use proposal. In the present market the redevelopment of the site for modern employment purposes would not be viable. In addition, Linpac Ltd has a lease on the site to 2070
and pays a substantial ground rent which further reduces the prospects of securing a viable redevelopment.

Redevelopment will only be a possibility therefore if the viability is taken into consideration and a flexible policy allowing mixed-use development applied. As the proposed policy stands, there is no flexibility to consider other uses for the sites listed within Policy Table 7.

Whilst the Prittle Brook Estate could provide good quality business floorspace as part of a mixed-use redevelopment, it should be recognised that modern business floorspace is developed at a higher density than old stock/industrial floorspace. On this basis, a substantial part of the site would be available for enabling residential development. Given that residential led redevelopment of t he site
may be the only way to bring it back into an active use, the wording of the policy Is ineffective and will prevent redevelopment of the Prittle Brook Estate from taking place.

Allowing mixed use development would be supported by National Planning Policy as set out in PPS 4 (Planning for Sustainable Economic Growth), which at Policy EC2 requires Local Planning Authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development, including mixed use".

Against this advice it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Paragraph 5.14 references the Prit tle Brook Estate as an Employment Growth Area. TWhilst this isaccepted, further clarity is needed to acknowledge that the ability of the Prittle Brook Estate to provide employment opportunities in the future will depend upon the ability for any redevelopment to be viable. The viability arguments for taking a f lexible approach to the redevelopment of Prittle
Brook were presented at the last Development Management DPD consultation in August 2010.

In the present market the redevelopment of the site for modern employment purposes would not be viable. In addition, Linpac Ltd has a lease on the site to 2070 and pays a substantial ground rent which further reduces the prospects of securing a viable redevelopment. As the site Is identified In
the ELR and the Core Strategy as being strategically important and as having potential to meet an identified need for employment land in the area, it is important that the DMD seeks to facilitate redevelopment by acknowledging issues relating to viability and by introducing flexibility to allow proposals which are accompanied by enabling development. It is considered that the text at
paragraph 5.14 is currently ineffective, as it will impose barriers to the viable redevelopment of the Prittle Brook Estate.

The Employment Land Review (ELR) 2010 notes in respect of the site appraisal of Prittle Brook Estate (ELR Appendix 3) "that to reflect viability Issues there may need to be a flexible approach to a mixed use development that contains good quality commercial premises ... ". The review notes that the land would not be allocated today for the same mix of employment uses that existed previously
and that employment use should not be the only acceptable form of development. Considering the conclusions of the ELR, paragraph 5.14 Is neither justified nor effective without recognising the implications of viability.

Changes to Plan
Part 3 of Policy DM 11 should read:
3. A managed approach will be sought at the Employment Growth Areas through planning briefs that will set ot.it the quantum of development and appropriate uses. An open view will be taken towards enabling development where it can help to meet aspirations for the development of modern employment facilities.

Part 4 of Policy DM 11 should read:
4. The Industrial Estates identified within Policy Table 7 will be mostly retained and protected for Class B uses and those sui-generis uses of an employment nature. Complementary and supporting uses will be considered acceptable at the Industrial Estates where they serve the day-time needs of estate's working population and will not result in a material change to the character and function of
the area. Nevertheless, as part of comprehensive redevelopment proposals, enabling development (including residential if sensitively located) will be considered if it can be proven that a redevelopment to entirely employment uses would otherwise be unviable, and that the proposal meets identified priorities in terms of employment provision.
This will ensure that the policy is sound: both effective and justified.

The final sentence of paragraph 5.14 should be reworded to read: "Progress Road and Prlttle Brook Industrial Estate offer significant regeneration opportunities over the long term. Progress Road, has several vacant units many in a poor state of repair. It is clear that redevelopment for modern employment uses over the long term is required and the Borough Council is already working in partnership to redevelop the site on a plot-by-plot basis in line with the adopted Progress Road
Estate Framework: Design Brief (2009). Prittle Brook Industrial Estate is available for comprehensive redevelopment with a significant proportion having already been cleared. It is acknowledged that to reflect viability issues there may need to be a flexible approach to a mixed use development that contains good quality commercial premises particularly along the frontage to Priory Crescent".

Paragraphs 1.23 and 1.24 of the proposed Development Management DPD recognise the challenges the economy faces at the present time, and commits to providing a flexible planning framework in response. Set against this background, Part 2 of Policy DM11 notes that those sites listed within Policy Table 7 should be maintained and promoted for modern employment floorspace. This policy is considered to lack flexibi lity as it fails to recognise that viability will be an important consideration in the regeneration of the Prittle Brook Estate (which Is listed within Policy Table 7).

The policy Is not justified as it does not reflect the findings of the Southend-on-Sea Employment Land Review (ELR) 2010. The market appraisal of the site within Appendix 3 of the ELR states the following:
The site is well located and with access improvements could have good direct access from Priory Crescent to the A127. If modern purpose built premises can be provided in this location there should be continued market interest in the location. The site is important to the delivery of the Core Strategy because it represents a major opportunity to provide modern employment units within the borough. I t is acknowledged that to reflect viability issues there may need to be a flexible approach to a mixed use development that contains good quality
commercial premises particularly along the frontage to Priory Crescent.

This recognises the importance of the site whilst also acknowledging the viability issues. The reality is that redevelopment is likely to be dependent upon the consideration of enabling development as part of a mixed-use proposal. In the present market the redevelopment of the site for modern employment purposes would not be viable. In addition, Linpac Ltd has a lease on the site to 2070
and pays a substantial ground rent which further reduces the prospects of securing a viable redevelopment.

Redevelopment will only be a possibility therefore if the viability is taken into consideration and a flexible policy allowing mixed-use development applied. As the proposed policy stands, there is no flexibility to consider other uses for the sites listed within Policy Table 7.

Whilst the Prittle Brook Estate could provide good quality business floorspace as part of a mixed-use redevelopment, it should be recognised that modern business floorspace is developed at a higher density than old stock/industrial floorspace. On this basis, a substantial part of the site would be available for enabling residential development. Given that residential led redevelopment of t he site
may be the only way to bring it back into an active use, the wording of the policy Is ineffective and will prevent redevelopment of the Prittle Brook Estate from taking place.

Allowing mixed use development would be supported by National Planning Policy as set out in PPS 4 (Planning for Sustainable Economic Growth), which at Policy EC2 requires Local Planning Authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development, including mixed use".

Against this advice it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Paragraph 5.14 references the Prit tle Brook Estate as an Employment Growth Area. TWhilst this isaccepted, further clarity is needed to acknowledge that the ability of the Prittle Brook Estate to provide employment opportunities in the future will depend upon the ability for any redevelopment to be viable. The viability arguments for taking a f lexible approach to the redevelopment of Prittle
Brook were presented at the last Development Management DPD consultation in August 2010.

In the present market the redevelopment of the site for modern employment purposes would not be viable. In addition, Linpac Ltd has a lease on the site to 2070 and pays a substantial ground rent which further reduces the prospects of securing a viable redevelopment. As the site Is identified In
the ELR and the Core Strategy as being strategically important and as having potential to meet an identified need for employment land in the area, it is important that the DMD seeks to facilitate redevelopment by acknowledging issues relating to viability and by introducing flexibility to allow proposals which are accompanied by enabling development. It is considered that the text at
paragraph 5.14 is currently ineffective, as it will impose barriers to the viable redevelopment of the Prittle Brook Estate.

The Employment Land Review (ELR) 2010 notes in respect of the site appraisal of Prittle Brook Estate (ELR Appendix 3) "that to reflect viability Issues there may need to be a flexible approach to a mixed use development that contains good quality commercial premises ... ". The review notes that the land would not be allocated today for the same mix of employment uses that existed previously
and that employment use should not be the only acceptable form of development. Considering the conclusions of the ELR, paragraph 5.14 Is neither justified nor effective without recognising the implications of viability.

Changes to Plan
Part 3 of Policy DM 11 should read:
3. A managed approach will be sought at the Employment Growth Areas through planning briefs that will set ot.it the quantum of development and appropriate uses. An open view will be taken towards enabling development where it can help to meet aspirations for the development of modern employment facilities.

Part 4 of Policy DM 11 should read:
4. The Industrial Estates identified within Policy Table 7 will be mostly retained and protected for Class B uses and those sui-generis uses of an employment nature. Complementary and supporting uses will be considered acceptable at the Industrial Estates where they serve the day-time needs of estate's working population and will not result in a material change to the character and function of
the area. Nevertheless, as part of comprehensive redevelopment proposals, enabling development (including residential if sensitively located) will be considered if it can be proven that a redevelopment to entirely employment uses would otherwise be unviable, and that the proposal meets identified priorities in terms of employment provision.
This will ensure that the policy is sound: both effective and justified.

The final sentence of paragraph 5.14 should be reworded to read: "Progress Road and Prlttle Brook Industrial Estate offer significant regeneration opportunities over the long term. Progress Road, has several vacant units many in a poor state of repair. It is clear that redevelopment for modern employment uses over the long term is required and the Borough Council is already working in partnership to redevelop the site on a plot-by-plot basis in line with the adopted Progress Road
Estate Framework: Design Brief (2009). Prittle Brook Industrial Estate is available for comprehensive redevelopment with a significant proportion having already been cleared. It is acknowledged that to reflect viability issues there may need to be a flexible approach to a mixed use development that contains good quality commercial premises particularly along the frontage to Priory Crescent".

DM10
Policy DM10 sets out that development will be encouraged that contributes to the promotion of sustainable economic growth by increasing the capacity and quantity of employment land, floorspace and jobs. This is in accordance with the Government's 'Planning for Growth' agenda which sets out that the top priority is to promote sustainable growth and jobs. Policy Table 6- Employment Sectors sets out a number of employment sectors and the Priority Location Areas which these types of employment development will be directed to.

The sectors which will be guided to employment areas include aviation industries, health and medical industries, business and financial services, cultural and intellectual hub and higher education centre of excellence, and manufacturing, construction and warehousing. These types of uses would be appropriate at Fossetts Farm which, as per our representations on the Proposals Map and Policy DM11, should be designated as an Employment Area.

In relation to Tourism and Leisure, draft Policy Table 6 seeks to direct these into Southend Central Area and the Seafront, whilst these locations may well be suitable for tourism and leisure uses the policy should retain flexibility in order to meet the tests of soundness. There may be some leisure and tourism uses which are more appropriate on the edge of the urban area, for example uses which take up large areas or land such as the permitted football stadium at Fossetts Farm.

The potential for leisure uses on our client's site is identified within the existing Section 106 Agreement which provides a zonal plan and indicates that the Council agree that the area could be comprehensively developed for employment and leisure.

DM11
The draft Development Management DPD Table 7 identifies a number of Employment Growth Areas. This includes existing employment areas and green field land at Shoebury Garrison. However, the plan is unsound as it does not refer to Fossetts Farm which is a Priority Urban Area (Industrial/ Employment Area) in the adopted Core Strategy.

This appears to be an omission as Paragraph 5.10 refers to the same employment target as the Core Strategy (creating 2750 jobs) which assumed the inclusion of Fossetts Farm. The potential of Fossetts Farm to meet the future development needs of Southend is well established. Core Strategy Policy KP1 confirms that growth will be focussed in a number of locations including the Priority Urban Areas, and the supporting text at paragraph 2.4 confirms that Fossetts Farm is an industrial/employment location which has potential to make a significant contribution to regeneration and growth objectives. Fossetts Farm is also identified as Safeguarded Land in the Southend-on-Sea Local Plan Saved Policies (Policy G1a). Furthermore, a Section 106 Agreement dated 8th January 2004 provides an indicative zonal plan showing areas of Fossetts farm for employment and leisure recognises that the land could be comprehensively developed for these uses.

The omission of Fossetts Farm from the identified Employment Areas is not justified as it is the most appropriate strategy when considered against reasonable alternatives, nor is it effective or consistent with National Policy as it does not encourage sustainable economic growth in this location.

PROPOSALS MAP
We write on behalf of our client C and S Associates who own land off Fossetts Way, as shown on the red line plan provided. This land includes the B&Q, the retail units to the south of B&Q, land to the north of the B&Q, part of the scheduled ancient monument, and additional land to the west of Fossetts Way.

The land to the north of the B&Q, part of the scheduled ancient monument, and land to the west of Fossetts Way is designated as High Grade Agricultural Land, despite the terms of the Core Strategy. This proposed designation is unsound as it is not justified, effective or consistent with National Policy. Whilst there is a need to protect the scheduled ancient monument, the other areas are suitable for development.

The High Grade Agricultural Land designation is inconsistent with both the adopted Local Plan 1999 alterations, which designates the site as Safeguarded Land to meet future development needs (Policy G1 a) and the Core Strategy (2007) which designates the site as a Priority Urban Area (Industrial/ Employment Area). Neither of these adopted plans designate the site as High Grade Agricultural Land.

On the contrary, the Core Strategy seeks to encourage employment growth at Fossetts Farm.
Core Strategy Policy KP1 confirms that growth will be focussed in a number of locations including the Priority Urban Areas, and the supporting text at paragraph 2.4 confirms that Fossetts Farm is an industrial/employment location which has potential to make a significant contribution to regeneration and growth objectives. Core Strategy Policy CP1 confirms that 2,750 jobs will be provided within the Priority Urban Areas which includes Fossetts Farm.
The proposed High Grade Agricultural Land designation is also inconsistent with a Section 106 Agreement entered into by our client and the Council dated 81
h January 2004 which provides an indicative zonal plan showing areas for employment and leisure.

The Agreement restricts promotion of the land for retail, cinema, amusement arcade centre/funfair, night club/casino or housing, but states that:-
"The Developer the Owners B&Q and the Council recognise that the Restricted Area could in principle be comprehensively developed and such comprehensive development could include the indicative uses illustrated on the Indicative Zonal Plan ... " (Paragraph 4.5.2)

A copy of this Section 106 Agreement is submitted in support of these representations and
relates to the B&Q at Fossetts Farm which was granted at appeal(APP/D1590N/03/11113372).
The Inspector's report for this appeal recognised the importance of achieving comprehensive development at Fossetts Farm, and the application was partially approved on the basis that it would enable a link road to be constructed which would unlock the safeguarded land and therefore ensure that it is capable of meeting any of the development needs generated bySouthend.

The zonal plan identifying our clients land for employment and leisure clearly shows that the Council agreed with the principle of these uses, this is carried forward in the Core Strategy designation.

Since this Section 106 Agreement, Fossetts Farm has developed further as an employment location with jobs provided within the B&Q, Waitrose and Majestic Wine. The employment opportunities will be enhanced further when the Football Club permission is developed, with jobs provided within the Stadium, hotel, retail and health club.
Planning permission for a vocational training college was also granted planning permission was granted in March 2005 on land north of the B&Q (SOS/05/00070/FUL). The committee report confirms that this use was considered to be in the spirit of the Local Plan Second Alteration and the Thames Gateway as it would provide the opportunity for, primarily, young learners to
develop skills that would directly benefit the local economy. It would take up 1.6 hectares of land, leaving the majority of the wider Fossetts Farm area open to further employment specific development in the future.

The proposals map as currently drafted is therefore unsound as it should reflect the designations of the adopted policy and take into account the planning history of the site. The Planning Inspectorate guidance, 'LDFs - Examining DPDs: Learning from Experience' (September 2009) confirms that the proposals map does not have DPD status in its own right because anything it conveys must be identified in a DPD or saved development plan. Therefore, the proposals map can not designate the site as High Grade Agricultural Land.

The Development Management DPD is also not the proper DPD to make strategic decisions about specific sites and therefore should not designate our client's site as High Grade Agricultural Land nor remove the adopted Core Strategy designation as a Priority Urban Area. Any change to the designation should be done through the Core Strategy and/or Site Allocations DPD.

We also note that there is no evidence base to support the proposed High Grade Agricultural Land designation of our client's site. The site is not currently agricultural land but has been fallow for many years, awaiting development.

The potential of the site to meet the future development needs of Southend is well established both in terms of adopted policy and planning history, and should be made clear on the proposals map.

The site is suitable for both employment and leisure uses as identified in the Section 106 Agreement and the Core Strategy designation as a Priority Urban Area and should therefore be identified on the proposals map as an employment area, with the uses to include employment provided by both B class uses and leisure facilities.

This designation will enable the creation of jobs in line with the Core Strategy target and the Government's 'Planning for Growth' agenda which sets out that the top priority is to promote sustainable growth and jobs, and sets out that the answer to growth wherever possible should be 'yes' except where this would conflict with sustainable development principles.

The designation of this site as an employment area including leisure uses is also in accordance with PPS4 which seeks for development plans proactively encourage sustainable economic growth. It also retains flexibility in line with the Southend Core Strategy Inspector's Report (October 2007) which considered that the future uses for Fossetts Farm should remain flexible because the site represents a scarce resource in terms of undeveloped land (Paragraph 6.5).

We recognise that this is not a site allocations DPD but our suggestion simply reflects the adopted designations of the site as a Priority Urban Area and safeguarded land. It is noted that the proposals map does identify future designations, for example the green field land at Shoebury Garrison. The fact that the Development Management DPD proposes to replace all of the Southend-on-Sea Local Plan Saved Policies, including Saved Policy G1 a Safeguarded Land (Second Alteration), which seeks to safeguard Fossetts Farm for future development needs, is also an important consideration and should not be deleted without a satisfactory replacement designation.

In conclusion, the proposals map as currently drafted is unsound as it does not reflect the current designations and history of the site.

PARAGRAPH 5.16

Question 4
Paragraph 5.16 reflects the analysis provided in the Employment Land Review (ELR) so the text is broadly supported. However the text does not extend to include all of the relevant commentary in the ELR with regard to the Phase 2 site being suitable for a mix of uses. For example, the ELR refers to land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Paragraph 5.16.

The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity on the remaining land to contribute to Southend's housing targets.
Paragraph 5.16 notes that "the use of remaining land should be determined through the production of the Shoeburyness AAP, which can consider this site alongside other employment sites in Shoeburyness, such as Campfield Road and Vanguard Way". However, our client is concerned that the Phase 2 Garrison site is available to come forward now in advance of the Shoeburyness AAP with a planning application due to be submitted in 2011. The original LDS Timetable 2009 anticipated that progress on the AAP would commence at the start of 2010. The revised Interim LDS Timetable 2011 now shows that the AAP was meant to have been published for initial consultation in February 2011 with adoption anticipated in February 2011. However as we understand, only preliminary work has been undertaken on the progress of the AAP to date with resources only being directed
to its preparation in Summer 2011 at the earliest, with adoption assumed for later in 2013.
Even with its original timetable for production, the AAP process for exploring the use of the remaining Garrison land would seem too uncertain and slow.
Paragraph 5.16 needs to include alternative text in order to ensure a flexible approach to the Phase 2 Garrison site coming forward in the interim.

Question 5
1.6 The Paragraph should be expanded to include all of the text set out at Paragraphs 6.8 and 6.9 of the ELR. Reference should also be made to the table proforma appended to the ELR which considers that the site "can be protected and developed when necessary for future employment use or mixed use (our emphasis)". Residential should be referenced as an appropriate and viable use for the remaining land.
Given the need to ensure a flexible approach in advance of the Shoeburyness AAP being prepared, the text should also make reference to the remaining non-employment land at Shoebury Garrison being determined in accordance with other national and local planning policy objectives and other material considerations, with the focus on the creation of sustainable, mixed-use communities.
Greater flexibility is also needed to ensure that the DPD allows for changing circumstances with regard to employment land supply and demand. In the event that the land does not come forward for employment purposes, the text should include the provision to review alternative, viable uses including residential.

POLICY DM11

Question 4
The Policy is not justified as it fails to reflect the findings of the Employment Land Review (ELR) with regard to the Shoebury Garrison site (which is listed within Policy Table 7 as an Employment Growth Area).
Whilst it is acknowledged that the ELR "found a future employment land demand gap across the Borough in the long term", the Policy does not reflect the further findings of the ELR in that not all of the Shoebury Garrison site is required for employment purposes. Indeed, as stated at Paragraph 5.16, "whilst all employment land in Southend is a valuable commodity, the ELR suggests that in the medium term to 2021 there is a lower demand for employment land in this location and the Garrison Phase 2 land could contribute to an oversupply.
Oversupply in this location could potentially compete with other priorities within the Town Centre and at the Airport in the medium term".
To this end, the ELR recommends that a figure of around 3 hectares is required to support 19,000 sqm employment floorspace by 2021 in order to contribute towards the Core Strategy objective of 1,500 jobs in Shoeburyness. This figure is significantly less than the whole 11.27 hectares making up the Phase 2 land as currently suggested in the Policy and the corresponding Proposals Map. Indeed, the ELR refers to other uses coming forward on the remaining land with reference to some of the land coming forward for a new primary school (which has since been granted permission) and part of the Phase 2 site being promoted to the SHLAA (CON111) for residential use. This information is absent from Policy DM11.
The Council is aware that there has been significant interest in bringing forward the Phase 2 site for mixed-use purposes including residential. Discussions have been progressing with the Council with regard to bringing forward a scheme which meets the current requirements of the ELR whilst providing a significant opportunity to contribute to Southend's housing targets. The site provides the potential to build on the existing residential development that has come forward as part of the wider outline planning permission and complement the mix of uses across the Garrison site. Indeed the site proforma table appended to the ELR
considers that the site "can be protected and developed when necessary for future
employment use or mixed use (our emphasis)".
Mixed-use development is supported by national policy as set out in PPS4 (Planning for Sustainable Economic Growth), with Policy EC2 requiring local authorities to encourage sustainable economic growth. PPS4 encourages policies to remain flexible to respond to the needs of emerging employment sectors and to allow a quick response to changes in economic circumstances. Policy EC2 notes that whilst employment land can be safeguarded from other uses, this safeguarding should "facilitate a broad range of economic development,
including mixed-use". Against this advice, it is considered that the proposed Policy DM11 is not compliant with national policy as it fails to provide the desired level of flexibility to plan for sustainable economic growth.

Question 5
The Policy currently allocates the whole of the Shoebury Garrison site (Phases 1 and 2) as an Employment Growth Area. Given that only part of the site is currently supported for employment purposes for reasons set out on in the ELR, the site should be more appropriately allocated as a 'Mixed-Use Site to include Residential'.
In circumstances where the DPD has no other Section on mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.
This would ensure that the Policy is justified and sound.
In addition to this, whilst Part 7 of the Policy sets out that "the Council will plan, monitor and manage the function of the industrial estates and employment areas so that these areas can continue to contribute to strategic and local economic objectives", greater flexibility is needed to ensure that the policy allows for changing circumstances with regard to employment land supply and demand.
In the event that the land does not come forward for employment purposes, the Policy should include the provision to review alternative, viable uses including residential.
This would ensure that the Policy is effective, in conformity with national policy and sound.

PROPOSALS MAP

Question 4
The allocation currently shows the Shoebury Garrison Phase 1 and 2 land as an EmploymentGrowth Area. This is not considered to be justified and effective nor consistent with national policy for the reasons set out in our representations on Policy DM11.

Question 5
The Shoebury Garrison land should be identified as a 'Mixed-Use Site to include Residential'.
In circumstances where the Proposals Map has no other provision for mixed-use sites (or housing sites for that matter), we would request at minimum that the employment allocation for the Garrison land be reduced to the figures referred to in the ELR.