Non Site Allocation Representations Report.pdf

SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES
Policy EMP/1 Meeting B1, B2 and B8 Employment Demand
Rep No Name
People Type
5159 Ainscough Strategic Land. (Mr Nigel McGurk) [2073]
1 Support
Summary Our client generally supports the content of the policly, however, the policy should make reference to the Dogarrog site.
Change Sought: The LDP policy should make reference to the Dolgarrog site and its potential to bring forawrd such uses and its ability to provide for the employment land
requirements of Snowdonia National Park.
823 J Jones [1008]
Summary We would like to register our objection to the above document on the following grounds:-
There is no provision in the plan for the provision of open storage land for local business.
In this report prepared for Conwy Council by JOP Consulting in November 2008 titled "Conwy Employment Land Study" there appears to be no replacement
open storage land which could be utilised in the Llandudno Junction area. In view of the fact that a substantial area of the Tremarl Industrial Estate in
Llandudno Junction has been delegated by you for retail development, this makes this report in direct conflict with the Council's own policy on the Conwy
Employment Land Study element of the Development Plan i.e. sustainable business.
No consideration has been given to the Council's own policies or for the welfare of the local businesses who have all been on this site for many years and
who without relocation will be put out of business causing significant unemployment.
Change Sought: Provision in the plan for the provision of open storage land for local business.
1739 Barton Willmore (Mr Michael Courcier) [44]
1 Object
Summary The Council has not properly justified the proposed split for employment land provision of 80% employment being made in the Urban Development Strategy
Areas and 10% in the Rural Area. In this respect, it is noted that the Deposit Draft suggests that the split for housing should be 90% in the Urban
Development Strategy Areas and 10% in the Rural Area. The difference in approach is not explained or justified.
It is recognised that the Rural Area does have needs for small scale employment opportunities but the bulk of rural employment needs should be met by the
nearby towns such as LLanrwst which act as rural service centres. It is also worth emphasising that employment sites in villages away from the A55 are
unlikely to be attractive to the market except for very small-scale rural industry. Take-up on a hectarage basis will be low.
Change Sought: It is considered that the appropriate split should be a minimum of 90% in the Urban Development Strategy Areas and up to 10% in the Rural Area.
1738 Barton Willmore (Mr Michael Courcier) [44]
Summary Table 7 greatly underestimates likely demand over the plan period at 1.7ha per annum.
The Employment Land Assessment states that "the benchmark demand on past trends" is of the order of 2.6ha (page 11). However, this figure itself is likely
to be a significant underestimate based upon take-up in the recent past, including the Mochdre site. Where good marketable sites have come forward in
Conwy accessible to the A55, they have been taken up. Past low take-up rates have been more a reflection of the poor quality of the employment land offer
than intrinsic low demand.
The basis for the 1.7ha per annum estimate of future demand is said to be set out in the Council's Employment Land Assessment (November 2009). This
document lacks clarity and does not adequately justify its conclusions. In particular, the estimate of future demand does not seem to be based upon any
systematic appraisal of how the economy of the area is likely to change over the plan period or the needs of existing or future businesses.
Change Sought: It is considered that the LDP should plan for a take up of at least 3ha per annum in the coastal urban areas, equivalent to 45 ha over the plan period. To
provide choice and flexibility, a further 45ha should be allocated and made available. This factor for choice and flexibility would also help compensate for the
fact that a significant proportion of the committed supply is constrained physically or is in the wrong place or of the wrong type to be attractive to the market. I
would also provide an element for other uses which are likely to take place on allocated employment land such as waste facilities.
1737
The LDP should ensure that a supply of 5 to 7 years immediately developed land is always available in the urban areas.
Barton Willmore (Mr Michael Courcier) [44]
1 Object
Summary The policy is unclear in its meaning and how it would operate, especially in relation to Policy EMP/2. It uses terms such as "Full Stock" and "Free Stock" which
are not properly explained or distinguished. It further confuses by referring to demand as 58ha whilst Table 7 expresses demand at 24ha over the plan period
Change Sought: The policy should clearly set out the level of employment land release for which the LDP is making provision. The accompanying text should set out how that
level has been arrived at, including the target for take-up and the additional element which is needed to provide choice and flexibility. It should also clarify
whether the figure includes or excludes any requirement for the rural areas, and how much land should be identified in these areas and by what means.
Currently the Plan does not provide for any employment land allocations in the rural areas (outside the designated urban areas which include Llanrwst)
1447 Leith Planning Ltd (Mr Chris Plenderleith) [1791]
1 Object
Summary There is concern that policy EMP/1 would appear to be incomplete; reference is made to a spectrum of figures for employment land of between 80 hectares
with no minimum requirement outlined in the policy.
Change Sought: This should clearly be clarified to ensure that the policy framework is transparent and clear. Furthermore, clarification is sought that the Council have adopted
the most appropriate methodology when calculating employment land requirements, in circumstances where the figure of 80 hectares would appear to be
excessive.
1474 Conwy Children and Young People's Partnership (Ms Alwen Sian Williams) [1867]
1 Object
Summary Regeneration not construction - look at what we have and make it better - not build random silly buildings. Build a more diverse economy - make more jobs
and better transport - how? Clear derelict sights for possible job opportunities.
Change Sought: Review economic strategy and objectives.
7147 Cyngor Cymuned Llansannan (Mr Eifion Jones) [2082]
Summary No land has been earmarked for industrial, retail or commercial purposes. We believe that this is needed.
Change Sought: No land has been earmarked for industrial, retail or commercial purposes. We believe that this is needed.
7238 Welsh Assembly Government (Mr Mark Newey) [2176]
1 Object
Summary The plans text, justification and background paper/s dealing with employment land are confusing. There appears to be provision in excess of demand and
disjointed relation to the level of proposed housing and a distribution skewed away from the hub/key business sectors as set out in the Wales Spatial Plan.
The 'priority issue' to protect the natural environment does not appear to apply in the same way to employment land as it does to housing requiring further
explanation. Clarification is required on how the allocations assist in delivering the identified sustainability issues.
Change Sought: Revise EMP/1
1557 Countryside Council for Wales (Mr Richard Ninnes) [1948]
1 Object
Summary We are concerned that it is not clear whether or not the new allocations have been taken through the SEA process. We therefore consider that this part of the
plan does not appear to meet fully the SEA requirements and to be unsound.
Change Sought: Ensure that the new allocations have been taken through the SEA process and that this is clearly detailed within the Plan.
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