NPPF Changes Consultation 2015

Ensuring Housing Is Delivered On Land Allocated In Plans - Page 7

Question 13.

What evidence would you suggest could be used to justify retention of land for commercial development or similar use? Should there be a fixed time limit on land retention for commercial use?

  • We are very concerned at the growing imbalance between providing land for housing, including permitted development changes from commercial floorspace to residential on the one hand and the lack of firm policies on providing other forms of essential land use on the other. Hundreds of new homes are being provided each year in the South East with little regard to the provision of adequate employment floorspace except in the retail trades.
  • We are opposed to the release of good employment land which could well be required in the next 5-10 years. 3 years is too short a time frame, particularly if there is a recession, when housing development land is allocated for 10-15 years ahead in most local plans. We would strongly object to the short time frame as it appears to put pressure on greenfield/ Green Belt land for commercial development because all the potential employment land has gone for housing.
  • We support the requirement for need assessments and evidence of market demand for employment floorspace, but this should cover a longer time frame than 3 years and include an element of growth where population levels are increasing. A major problem in the South East, including London, is that residential values are far higher than that of other forms of land use, resulting in the loss of mixed-use land uses including employment.
  • If greenfield sites are allocated for employment in a Local Plan and then not used they must be returned to their former status. To do otherwise would be to create an easy way for owners of Green Belt and other green field sites to convert their land for housing.

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