Policy E1: Sustainable employment
Policy E1: Sustainable employment
The provision of 3,200 additional B class (see glossary) jobs to 2033 will be supported. In order to deliver these, land will be allocated for a net gain of between 37,000 and 47,000 sq m of floorspace for B1a and B1b uses and between 4.7 and 5.3ha land for B1c, B2 and B8 use class floor space to ensure an adequate supply of land is available for employment purposes. This will provide a range and choice of employment floor space over the plan period and accommodate the predicted future growth in economic development required for Guildford’s economy to develop and increase.
The Plan aims to ensure sustainable employment development patterns, promote smart growth (see glossary) and business competitiveness, and allow for flexibility to cater for the changing needs of the economy.
B Class Uses
Strategic Employment Sites
The seventeen designated sites that together make up the borough’s current core supply of employment land will be protected as Strategic Employment Sites and changes of use from employment to non-employment uses resisted. The retention, intensification and employment based regeneration of these sites is encouraged. The Strategic Employment Sites are:
Office (B1a) and Research & Development (B1b) Strategic Employment Sites
When developed, the new employment site at Gosden Hill Farm will be treated as a Strategic Employment Site.
Industrial (B1c, B2 and B8) Strategic Employment Sites
When developed, the new employment site at Burnt Common will be treated as a Strategic Employment Site.
Locally Significant Employment Sites
The Locally Significant Employment Sites will be protected and within these sites changes of use to non-employment uses resisted. The retention and regeneration of these sites is encouraged and intensification where possible will be considered to be appropriate. The Locally Significant Employment Sites include all sites which meet the definitions set out below and include:
The Strategic Employment Sites and the Locally Significant Employment Sites are shown on the borough Policies Map.
We OBJECT because:
We OBJECT to this policy.
We need to distinguish between wanting to increase the added value of the economy and physical expansion, especially given the scarcity of land in Guildford. Guildford is not the place for large space hungry businesses. We believe Guildford should target high added-value small and medium sized enterprises or the headquarters of larger corporations, but not provide low added value warehousing and industrial space.
No proper analysis has been made of data held by GBC in respect of different B classes in terms of planning applications granted or evidence gathered by the economic development function at GBC without any attempt at real market demand apart from vague references to freely available market research undertaken by commercial estate agents. (See definitions of B classes at end of this policy response).
What we are left with is a fairly clumsy and poorly informed plan which clusters B classes without any appreciation of widely different employment impact and economic sustainability. E.g. B1 (mostly local office use/R&D) generates at least 5 times as much employment as B8 (distribution and warehousing).
This draft Local Plan is partly based on new findings by Aecom in the latest ELNA 2015 [Employment Land Needs Assessment 2015]. This includes the recasting of the ELNA by Aecom in 2015 which updated the ELNA 2013 prepared by GBC. We have had regard to the evidence base provided by Aecom in the 2015 ELNA and find it a more reliable evidence base for overall projected employment in the borough over the plan period in overall numbers than done previously by GBC in 2013. However, we have concern that the survey work by Lambert Smith Hampton is in the form of high level free property research that is used for the purposes of marketing their services over a wide area not specifically commissioned for the borough of Guildford and undertaken for ELNA purposes.
However, we are concerned that the research undertaken by Aecom is generally superficial and lacks sufficient detail and analysis between B1a, B1b, B1c, B2 and B8 use classes and that no reliable individual analysis has been undertaken of the widely different supply and demand dynamics of office, research and development, light industrial, general industrial and warehousing and distribution floor space.
The lack of appreciation by GBC as to the opportunity for widely different uses being generated within B class clusters defeats the whole point of proper planning of employment uses and can significantly endanger previously good planning put forward in the previous 2003 plan. We support the concept of seeking increased investment in our local knowledge-based, high technology economy. This will provide well paid, creative jobs and generate the wealth necessary to fund the infrastructure and environment this sort of industry requires.
We need to promote the idea of new knowledge transfer in incubator units and small premises for new start up enterprises. We need to be on the wave of innovative new technology as opposed to older established businesses. High value-added industry is desirable; low tech, land-hungry older businesses which will increase congestion are not desirable.
We have concern as to the ill-informed clustering of all B classes. This is unclear in terms of market evidence required to inform effective planning. There is a failure to provide a clear understanding of business needs within the relevant area as required under Section 160 of the NPPF.
Little regard has been given in the plan to the economic reality of falling demand for B2 industrial space which is clustered with other B classes almost randomly throughout the plan.
Little regard is had to the opportunity of B1 b space as an opportunity for research and development which needs to be nurtured and preserved without the detrimental and confused clustering with other B classes both in terms of planning and promotion of a research hub
We do not support the policy of creating Strategic Employment sites outside the urban centres.
Some of the strategic industrial sites would be better classified as brownfield land suitable for use as a residential area, eg Woodbridge Park, Woodbridge Road and Merrow Lane.
This study varies very significantly from the previous Guildford Borough Council ELNA 2013, which after two years has been completely re-written. This leads us to question the reliability of the evidence base here which has been used to justify the assumptions and plans; it is unclear that the current evidence base is any more reliable than that used previously. This calls into question the general reliability of the process of collection and interpretation of data in the overall forward planning process by GBC.
B1 building use is use for all or any of the following purposes:
(a) as an office other than a use within class A2 (financial and professional services),
(b) for research and development of products or processes, or
(c) for any industrial process, being a use which can be carried out in any residential area without detriment to the amenity of that area by reason of noise, vibration, smell, fumes, smoke, soot, ash, dust or grit.
B2 building use is for the carrying on of an industrial process other than one falling within class B1 above or within classes B3 to B7 below. (Note: B3-B7 relates to very heavy industry such as oil refining, smelting etc).
Distribution or Storage
B8 building use is for storage or as a distribution centre.