EMPLOYMENT LAND LOCAL PLAN Statement of Consultation and Representations Revised Proposed Submission November 2015 Eastbourne Borough Council Regeneration & Planning Policy 1 Grove Road Tel: 01323 410000 Eastbourne Email: [email protected] BN21 1TW Web: www.eastbourne.gov.uk Statement of Consultation and Representations November 2015 EMPLOYMENT LAND LOCAL PLAN Statement of Consultation and Representations 1.0 Introduction 1.1 This statement is produced in support of the Revised Proposed Submission version of the Employment Land Local Plan. It sets out the details of consultation undertaken on the Employment Land Local Plan under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulation 2012, in order to comply with the requirements for Revised Proposed Submission as set out in Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulation 2012. 1.2 This report identifies: which bodies and persons were invited to make representations under regulation 18; how those bodies and persons were invited to make representations; a summary of the main issues raised by those representations; and how those main issues have been addressed. It also identifies representations made on the soundness of the previous Proposed Submission version. 2.0 Background 2.1 In May 2012, the Eastbourne Core Strategy Local Plan was subject to Public Examination by a Planning Inspector. The Inspector expressed concerns over the evidence that supported Core Strategy Policy D2: Economic, particularly relating to the employment land supply. The Inspector concluded that the evidence lacked clarity and did not demonstrate that Policy D2 was the most appropriate strategy for supporting job growth and economic prosperity in Eastbourne. Furthermore she considered that uncertainty about the viability of directing 30,000 m² of employment floorspace to Sovereign Harbour cast doubt on whether the strategy was deliverable during the Plan period. This raised the question of whether the quantum of office development proposed in the Plan was based on accurate and up to date evidence. 2.2 The Inspector considered that if the adoption of the Plan were to be delayed to allow for the Plan to be revised, Eastbourne would be left without an up-to- date local plan and the Council would be unable to take a proactive, plan led approach to delivering development. To avoid such a delay the Inspector recommended that Policy D2 be the subject of an early review, leading to its replacement with an additional Local Plan to deal specifically with employment land supply. Employment Land Local Plan P a g e | 1 Statement of Consultation and Representations November 2015 Purpose of the Employment Land Local Plan 2.3 The Employment Land Local Plan will guide job growth and economic development in Eastbourne up to 2027 by identifying an appropriate supply of land for future employment development, in order to achieve a sustainable economy and make Eastbourne a town where people want to live and work. It relates to land and buildings within the B1 (Offices and Light Industry), B2 (General Industry) and B8 (Storage and Distribution) Use Classes. 2.4 The Employment Land Local Plan will form part of the Development Plan for Eastbourne, alongside other planning policy documents such as the Eastbourne Core Strategy Local Plan. The Employment Land Local Plan will replace Core Strategy Policy D2: Economy, but will otherwise have to conform to other policies set out in the Core Strategy Local Plan as well as national planning policy. 3.0 Summary of Consultation Arrangements 3.1 Consultation on the Employment Land Local Plan under regulation 18 was undertaken in two stages. Firstly, stakeholders were invited to make representations about what the Employment Land Local Plan ought to contain through a questionnaire, which was conducted in the pre-production stage in summer 2013. Secondly, a Draft Employment Land Local Plan was published for consultation over the winter of 2013/14 and stakeholders were invited to comment on the draft and answer specific questions about a range of issues, including the options considered. 3.2 A Proposed Submission version of the Employment Land Local Plan was published in December 2014 to receive representations on issues of soundness before submission to the Secretary of State for Examination. However, as a result of representations received, amendments were required, particularly to the Sustainability Appraisal, and a Revised Proposed Submission version was published for representations in December 2015. Pre-production Engagement exercise 3.3 The stakeholder engagement took the form of a questionnaire. Stakeholders were invited to make representations about what the Employment Land Local Plan ought to contain by completing the questionnaire. Representations were accepted for a 6 week period between 21 June and 2 August 2013. 3.4 The purpose of the questionnaire was to ask for comments on the draft objectives and the identified issues that the Employment Land Local Plan should address. It also asked if there were any business-specific issues that they wanted to raise, and if there was anything else that the Employment Land Local Plan ought to contain. Employment Land Local Plan P a g e | 2 Statement of Consultation and Representations November 2015 3.5 The questionnaire outlined a number of draft objectives for the Employment Land Local Plan. The draft objectives of the Employment Land Local Plan identified were: To stimulate sustainable economic growth to meet the needs of the community within environmental constraints and create a new economic image to attract highly skilled talent to come to and stay in Eastbourne To deliver a wide range of new employment opportunities by providing an improved range, flexibility and quality of employment and mixed use business space for use by local firms and speculative investors To support job growth and economic development, and broaden the economic base to enable innovation and entrepreneurship to flourish 3.6 The questionnaire also identified a number of issues that it was considered that the Employment Land Local Plan should address. These issues were: The requirement for additional employment land up to 2027 Identification of sites to assist in meeting the requirement for employment land Need for job creation and diversification Development that provides for start-up businesses Maximising the use of existing employment land in the town Requirements for office space in the Town Centre The suitability and viability of land at Sovereign Harbour for employment use Loss of employment land to residential use The suitability of current commercial premises High levels of travel to work by car Energy efficiency in commercial premises 3.7 The questions that the stakeholders were invited to answer were: Question 1: Do you agree with the draft objectives? Question 2: Are there any other general issues that you think the Employment Land Local Plan should address? Question 3: Are there any other issues specific to your business interest that we should be aware of? Question 4: Is there anything else that you think the Employment Land Local Plan ought to contain? Draft Employment Land Local Plan 3.8 The Draft Employment Land Local Plan was published for a 12 week consultation period between 20 December 2013 and 14 March 2014 in order to obtain the public and stakeholder’s views on what the ELLP ought to contain. As well as identifying the proposed strategy and approach to the employment land supply over the Core Strategy plan period up to 2027, it Employment Land Local Plan P a g e | 3 Statement of Consultation and Representations November 2015 also identified the other options that were considered in the formulation of the plan. The Draft Employment Land Local Plan took into account representations that were received through pre-production stakeholder engagement. 3.9 The Draft Employment Land Local Plan asked consultees to comment on the proposed approach, whether they consider that the correct option has been taken, and whether there are any other options that should have been considered in the formulation of the Plan. It was possible for consultees to comment on any part of the Draft Employment Land Local Plan, however the document identifies particular questions throughout that consultees are specifically asked to comment on. 3.10 The questions that were asked through the Draft Employment Land Local Plan were: Question 1: Are there any other issues that should be taken into account or should influence the Proposed Draft Employment Land Local Plan? Question 2: Do you agree with the Vision for the Employment Land Local Plan? Question 3: Do you agree with the Objectives for the Employment Land Local Plan? Question 4: Do you agree with the assessment of the scenarios for the employment land strategy and distribution? Question 5: Are there any other scenarios that have not been considered but should be? Question 6: Do you agree with the preferred option? Question 7: Do you agree with the proposed approach to the distribution of employment land? Proposed Submission Version 3.11 The Proposed Submission Employment Land Local Plan was published for an 8 week period between 12 December 2014 and 6 February 2015 to receive representations on the soundness and legal compliance of the plan. They were also asked if they would like to take part in the Examination of the Employment Land Local Plan. 4.0 Which stakeholders were invited to make representations? 4.1 Eastbourne Borough Council maintains a mailing list of all bodies, organisations and individuals that have previously asked to be kept informed about the preparation of planning policy documents. All stakeholders on the mailing list were notified by email or letter of the pre-production questionnaire and the consultation on the Draft Employment Land Local Plan. Employment Land Local Plan P a g e | 4 Statement of Consultation and Representations November 2015 4.2 In addition, selected stakeholders who it was considered would have a specific interest in the production of the Employment Land Local Plan were notified of the consultations.