Cheltenham Plan (Part One): Preferred Options

Response Details

Response Details
From Demoguide Limited (- -)
Agent Deleted User
Date Started: 20 Mar 2017 17:21. Last modified: 12 Apr 2017 16:47
Status Complete
Response ID #529539

Q1

Do you agree with the Vision Themes and Objectives?

  • Yes
  • No

Please enter any additional comments
«No response»

Q2

Do you agree with the Preferred Strategy for the economy? (para 3.16.1)

  • Yes
  • No

Please enter any additional comments
«No response»

Q3

Do you agree with Proposed Policy EM1 Safeguarding Key Existing Employment Land and Buildings? (see also Appendix A, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q4

Do you agree with Proposed Policy EM2 Safeguarding Non-Designated Existing Employment Land and Buildings?

  • Yes
  • No

Please enter any additional comments
«No response»

Q5

Do you agree with Proposed Policy EM3 New Employment Allocations? (see also Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q6

Do you agree with Proposed Policy EM4 Promoting the Cyber-Security Sector?

  • Yes
  • No

Please enter any additional comments
«No response»

Q7

Do you agree with Proposed Policy EM5 Protecting the Route of the Former Honeybourne Rail Line? (see also Proposals Map)

  • Yes
  • No

Please enter any additional comments
«No response»

Q8

Do you agree with Proposed Policy GE8A or GE8B Local Green Space? (see also Appendix B, C, Proposals Map and site maps)

  • GE8A
  • GE8B

Please enter any additional comments
«No response»

Q9

Do you agree with Proposed Policy PR1 Land Allocated for Housing Development? (see also Appendix D, E, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
[see attached]

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Note

If you know of a site which is suitable for housing and should be included in the Cheltenham Plan please submit information via the Call for Sites form.

Q10

Do you agree with Proposed Policy PR2 Land Allocated for Mixed Use Development? (see also Appendix D, E, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

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Note

If you know of a site which is suitable for mixed use development and should be included in the Cheltenham Plan please submit information via the 'Call for Sites' form.

Q11

Do you agree with the preferred options? (para 7.4.1, see also Appendix F, Proposals Map and site maps)

  • Yes
  • No

Please enter any additional comments
«No response»

Q12

Do you think that an Article 4 direction to restrict HMOs is required in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q13

Do you think that an Article 4 direction in any Conservation Area is required to stop the erosion of its special character through householder development in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q14

Do you think that an Article 4 direction to restrict the loss of office or employment uses to residential is required in any part of the Borough?

  • Yes
  • No

If yes then please state where and why
«No response»

Q15

If you have any comments on the Cheltenham Plan evidence base please enter them below.

«No response»

Additional text

REPRESENTATIONS TO THE CHELTENHAM PLAN (PART ONE): PREFERRED OPTIONS

These representations are made on behalf of our client, Demoguide Limited, in relation to the Cheltenham Plan (Part One): Preferred Options, which is undergoing consultation until Monday 20th March 2017.

The representations relates to the former Premier Products site that is identified at paragraph 6.5.8 of the preferred options document as having the potential to support around 70 dwellings.  We’d like to support this potential allocation as part of the emerging Cheltenham Plan and have set out below some of the key planning considerations that should be taken into account as the plan progresses.

Site Location

 

The property is situated in the predominantly residential area of Prestbury, approximately 2 miles north east of Cheltenham town centre. Other uses in the immediate area comprise a primary school, small retail parade and food store. A cemetery is located to the rear of the property.

 

Key Planning Considerations

 

National Planning Policy Framework (NPPF)

National planning policy is set out in the National Planning Policy Framework (NPPF) (March 2012). Relevant policies are as follows:

  • A presumption in favour of sustainable development, including granting permission where the development plan is absent, silent or relevant policies are out-of-date unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, or specific policies in the Framework indicate development should be restricted (para. 14).
  • Avoiding the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses should be treated on their merits having regard to market signals (para. 22);
  • To boost significantly the supply of housing, including the identification of a five year deliverable supply plus an additional buffer of 5% or 20% (para. 47); and
  • Housing applications should be considered in the context of the presumption in favour of sustainable development and relevant policies for the supply of housing should not be considered up-to-date if the LPA cannot demonstrate a five year supply of deliverable housing sites (para. 49).

Cheltenham’s Housing Land Supply

 

Cheltenham’s most up-to-date position on its deliverable housing land supply is set out in its Authority Monitoring Report (December 2015). This indicates a supply of 3.9 or 3.6 years (5%/20% buffer) which equates to a shortfall of 669 - 1,010 dwellings to 2020. As such, it is clear that the Authority cannot demonstrate a five year deliverable supply, meaning that any residential planning applications must be considered in the context of the presumption in favour of sustainable development.

Cheltenham Borough Council’s Housing Monitoring report reveals that the Council cannot currently show a 5 years supply of housing and that this is around 3 years.  This is a very significant shortfall and will need to weigh very heavily in favour of this site being redeveloped for residential purposes. 

 

Key Planning Considerations  

 

This site in question has been marketed since the end of 2014.  As part of the marketing strategy a website was set up to deal solely with advertising the site as well as placing adverts in key property documents to publicise its availability. This has not generated any further interest for its re-use for employment purposes.   This is recognised by the Council, who have considered that due to the lack of interest in the site for on-going employment use that a residential redevelopment would be the most appropriate, and the site is allocated for such purposes in the emerging plan.   

In line with the guidance in the NPPF, alternative uses proposed should be treated on their merits.  The proposed residential allocation will result in a sustainable form of development. Further to this, the NPPF at paragraph 51 also states that changes of use of sites currently in ‘B’ use classes should be considered where there is an identified housing need. In this case, Cheltenham Borough currently has a shortage of housing and shows a deficit of approaching two years in its five year housing land supply.

 

Deliverability of the site

 

The National Planning Policy Framework states that for sites to be considered ‘deliverable’ means they will be available now, in a suitable location now and achievable within five years and viable, as per footnote 11 of paragraph 47.

Available

 

The site is un-used and in single ownership. Apart from the former employment use of the site there are no physical constraints that would prevent or delay development coming forward. It can, therefore, be considered to be available now.

 

Suitable

 

The site is suitably and sustainably located for residential development with good accessibility to local services, facilities and employment opportunities via foot and other sustainable modes of transport.

Achievable

Residential development represents a viable future use for the site which can be delivered quickly.

Conclusion

 

We would like to support the emerging allocation of the site in question for residential development. 

The above assessment demonstrates that the former Premier Products site is available now and in a suitable location for residential development. Similarly, it would be viable for residential redevelopment to be delivered at the site and there are no constraints that would prohibit the site from coming forward.

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REPRESENTATIONS TO THE CHELTENHAM PLAN (PART ONE): PREFERRED OPTIONS

These representations are made on behalf of our client, Demoguide Limited, in relation to the Cheltenham Plan (Part One): Preferred Options, which is undergoing consultation until Monday 20th March 2017.  This letter is to specifically promote the reuse/redevelopment of Lansdown Industrial Estate for mixed use development comprising residential and employment.  

Summary of the Proposals

 

The site has a total area of 5.41ha and it is suggested that the site is redeveloped to comprise a mixed use development that includes a range of existing and proposed employment opportunities, residential and associated open space. 

Suitability of the site for employment redevelopment in its entirety

 

As matters stand, this site is protected under existing policy EM2 of the current Cheltenham Plan and will continue to be in the emerging plan.  However, it is considered that this site should be included within the plan for mixed use development and the reasons for doing so are set out below.    

In simple terms, it is not possible to retain/redevelop the site for employment purposes in its entirety because it is just not a viable proposition.  The only way the estate can be taken forward practically at this stage is if the site is advanced as a mixed use redevelopment that comprises part residential and part employment.  The capital returns associated with the residential units can be used to invest in the employment element of the site that will be retained.  Moreover, due to the poor nature of a large proportion of the buildings that occupy the site that are no longer fit for purpose, providing a mixed use scheme is the only credible way to take this site forward. 

Further to the above, it is recognised, due to the location of the site and its existing access, which can’t be changed, that the estate presents itself poorly in terms of general viability and the access is far from ideal for servicing the estate.  

Vacancy Rates

 

Many of the leases are due to expire in 2018 which coincides with the fact that many of the buildings will need upgrading at that stage as it will be illegal for them to be let due to their Energy Performance Certificate (EPC) rating.  From April 2018, it will be unlawful to lease commercial property which has less than an E (125) Energy Performance Rating. Currently around 24% of buildings on the estate have an EPC of F or below and as 92% of the leases expire in 2018 investment will need to be undertaken at that stage otherwise the buildings will become obsolete.  In this respect, the need for investment through redevelopment is clearly pressing.

EPC Ratings and Condition of Buildings

As matters stand, significant work is required to bring the EPC rating of the buildings down.  In essence, the combination of the poor state of repair and EPC ratings mean that many of the buildings are coming to the end of their life cycle and, as discussed, it is going to become increasing difficult to let a significant proportion of the units legally from 2018.  Moreover, given that the majority of tenancies are coming to a natural end their renewal will not be possible due to the state of the buildings and this therefore provides the opportunity look at the refurbishments and redevelopment proposed. 

Displacement of Existing Businesses

 

Tenants are choosing to leave Lansdown as it no longer provides the accommodation required or being sought, and requires modernisation and considerable improvement.  All of which is not possible without the redevelopment proposed, and any new potential occupier will look elsewhere due to traffic, access, poor accommodation, non-compliance with future legislation beyond 2018 and the fact there are more modern premises available in Gloucester.  In this respect, the displacement of tenants is occurring already and will continue without the redevelopment proposed.  Moreover, as already highlighted, existing tenancies run out at the end of 2018 and, as a result, tenants will naturally be displaced anyway with or without redevelopment. 

Deliverability of the site

 

The National Planning Policy Framework states that for sites to be considered ‘deliverable’ means they will be available now, in a suitable location now and achievable within five years and viable, as per footnote 11 of paragraph 47.

Available

 

The site is un-used and in single ownership. Apart from the employment use of the site there are no physical constraints that would prevent or delay development coming forward. It can, therefore, be considered to be available now.

 

Suitable

 

The site is suitably and sustainably located for mixed use development with good accessibility to local services, facilities and employment opportunities via foot and other sustainable modes of transport.

Achievable

Mixed-use development represents a viable future use for the site which can be delivered quickly.

Conclusion

 

Given the above, it is considered that the Lansdown Industrial Estate can’t be realistically retained for employment land in perpetuity and should be considered for a mixed use redevelopment as part of the Cheltenham Plan Review. 

I trust that the above and enclosed information is of assistance at this stage. However if you require any further information or have any queries please don’t hesitate to contact me.

Yours sincerely,

Giles Brockbank MRTPI

Hunter Page Planning