Employment Land Workshop Presentation to East Midlands Councils 23 June 2011 John Robertson Colin...

Employment Land Workshop

Presentation to East Midlands Councils

23 June 2011

John Robertson Colin Robinson

Insert presentation title here on master pageEmployment Land Workshop

Aims of Today’s Workshop

• Introduction

• Changing context for ELRs

• Methodology of Audit

• Key Findings

• Local Authority Views on ELRs

• Audit Recommendations

• Challenges for Future ELRs

• Role in a Changing Planning System

• The Way Forward


Purpose of the Audit

EMDA commissioned Audit of ELRs in region in 2010 that would:

• examine consistency of different ELRs

• highlight areas needing update + provide practical advice on doing this

• identify + publicise examples of good practice

• identify any further work required for ELRs to be robust at EiPs

Aim was not to find deficiencies in ELRs that reflected conditions when they were carried out

Key questions:

• do ELRs take account of changing economic conditions?

• do ELRs reflect more recent Government guidance?

• are ELRs consistent with the sub-regional picture?


What has changed for ELRs?

• PPS4 introduced range of new requirements:

- need to assess land requirements of wider range of economic development

- more emphasis on deliverability of sites

- flexible supply to support clusters & emerging sectors

- sequential assessment for new office sites

- reconsider allocations for single use/restricted uses

- combine employment & housing land need studies

- consider needs of rural economy

• but 2004 ODPM Guidance not updated + status unclear

• the recession happened + changed growth forecasts


Study Approach

Stage 1Assessment

Criteria

Stage 2Survey of LPAs

Stage 3Review ELRs

Outputs form evidence base for

LDF

Devised a range of evaluative criteria,

sent out questionnaires and face-face

meetings

How well did the ELR

comply with the relevant guidance at the time?

Does it meet the PPS4

requirements and are its

assumptions resilient to the

recession?

How well does the ELR take

account of and reflect

strategic factors?

Ke

y Q

ue

stio

ns


Methodology of ELR Audit

ELRs assessed against range of criteria in 3 main categories:

• Compliance with 2004 ODPM Guidance

• How well reflect PPS4 / Post Recession Factors

• Strategic Coherence / Fit

Key elements of ELRs given ‘health check’ rating within 6 levels


Consistency of ELRs

36 of the 41 Districts had ELRs

Broadly similar methodologies used, based on 2004 ODPM Guidance

• quite high variation in ages of ELRs

• no district solely reliant on ELR earlier than March 2008

• all ELRs pre-dated PPS4

• some covered one district/others group of districts


Consistency of Approach

• Time Horizons - most cover up to 2026 but 10 only to 2016

• Demand forecasts - most used pre-recession job forecasts with inconsistent time frames;10 with base date of 2004/earlier

• Job densities/plot ratios - ELRs broadly consistent

• Land or Floorspace requirement - most ELRs indicated ‘land’ need but no common approach

• All ELRs included commercial market inputs at some level but not always clear how and with whom

• 10 ELRs did not identify potential new sites or areas of search

• Gross or net land requirement – half of ELRs indicated gross requirements but others net/unclear

• Flexibility factor - additional safety margin or allowance but considerable variation in approach/amount – can exaggerate differences between districts


Consistency of ELRs – Overall Picture

• Many ELRs prepared pre-recession

• Significant areas of consistency - all used commercial market inputs and similar job/land conversion ratios

• But also substantial variations in approach:

- demand forecasting approaches

- base dates of forecasts

- time horizons

- amount of safety margin

- gross/net space requirements

ELRs do not provide a consistent picture of region’s future requirements without update


ELR Compliance with PPS4/ Recession

Limited compliance with PPS4 requirements which post-dated most ELRs

• economic vision for area

• assess local economic strengths/weaknesses

• include low economic growth/recession scenario

• assess needs of Non B uses

• assess deliverability of sites

• flexible supply to support clusters & emerging sectors • sequential assessment for new office sites • reconsider allocations for single use/restricted use

• combined employment /housing land studies

• identify 5 year land supply

• needs of rural economy


ELR Compliance with Guidance, PPS4 & Strategic Fit

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Compliant with 2004 CLGGuidance

Additional PPS4/PostRecession Factors

Strategic Coherence / Fit

% D

istr

icts

Com

plia

nt

3: Covered, but only to a limited degree

4: Covered in some detail/some modest omissions

5: Up to date and addressed in full


ELR Performance by District


Views on ELRs by LPAs/Users

Questionnaire survey & interviews of LPAs

Aimed to obtain user feedback on effectiveness of ELRs & how to improve

Key findings:

• Some ELRs overly mechanistic and constrained by the guidance

• Result that many completed ELRs, whilst sound, would have limited value to LPA

• Widening scope of ELRs resulting from PPS4 - further guidance on what to include/exclude required


Key Issues Emerging from the Audit

• No ELR in region tested at appeal has been found deficient

• Majority of LPA officers appear happy with their ELRs

• ‘Building blocks’ appear to be relatively consistent across the region

BUT:

• Almost all ELRs deficient to some degree re: PPS4 compliance

• Impacts of recession have not been taken into account

• Many ELRs provide insufficient advice re: preferred locations for new sites


Identified Areas to Update/Strengthen

• Any LPA without ELR coverage should undertake one

• Scope for region-wide methodology for consistency

• Should cover wider range of ‘employment’ uses

• Update demand forecasts to reflect recession/slower growth

• All ELRs should provide district level breakdowns

• Ensure forecasts match Core Strategy timeframe

• Clarify difference between gross and net

• Integrate housing /economic studies (e.g. SHLAA)


Way Forward


Challenges for Future ELRs

• Changing national policy background - without PPS4 or ELR guidance + greater flexibility/less prescription?

• Localism + different evidence base for new Local Plans

• Relating to Business Neighbourhood Plans

• Impact of EZs + proposals to convert vacant employment space to residential

• Major changes in economic outlook & job growth

• Changing prospects for some economic sectors

• Changing employment densities - 40% less office space per job, but higher industrial space needs


Role of ELRs in Changing Planning System

The proper planning of employment land needs is likely to remain a key element of the future planning system and has a key role to play in delivering economic growth:

• Plan for Growth /draft NPPF indicate ongoing role for some form of ELR and stress importance of economic development

• LPAs should take account of ….the need to maintain a flexible and responsive supply of land for key sectors…(Ministerial Statement, 23 March)

• New presumption in favour of sustainable development

• LPAs should ‘prepare local plans on the basis that objectively assessed development needs should be met, and with sufficient flexibility to respond to rapid shifts in demand or other economic changes’.


Why ELRs are still important?

• Important role in post PPS4 appeals involving employment land

• Range of uses proposed - housing, retail, healthcare, leisure, mixed

• Only 4 out of 21 allowed including only 1 residential scheme

• 13 dismissed despite creating jobs in PPS4 terms

• Key factor was need to retain good site backed by recent ELR

• Weight given to the PPS4 aim to maintain range of sites for broad range of economic development

• Marketing evidence indicating no demand given limited weight during depressed market

Lessons

• PPS4 not obviously overriding/undermining ELRs

• Robust, up-to-date ELR vital to protecting employment sites


Consequences of not having a Robust ELR

• Core Strategy can be found unsound• Windsor & Maidenhead• Medway

• Lost appeals + costs• Sunderland

• Difficulty in defending B class land from other uses• Wear Valley, Hart + many others


What Next?

• If you don’t have an adequate ELR within evidence base, get one

• Consider whether current ELR needs to be updated

• Ensure update covers key requirements for “future proofing”

• Build in tests of robustness

• Relate to housing needs assessment if possible

• Ensure deliverability of allocated sites is assessed

• In times of financial constraints, explore cost effective / targeted options for partial update rather than full review


Lower Cost Approaches to Updating ELRs

Focus on discrete elements rather than comprehensive review?

- only what is needed by the district (or sub-regional group)

- update demand forecasts, fill specific gaps, address key issues

- identify land needs of Non B Uses

- assess implications of use class changes

- aligning job growth/land needs with planned housing development

- delivery of major employment sites through new funding /policy mechanisms (e.g. TIF, EZ, LDO, Neighbourhood Plans)

- a Workspace Strategy including delivery, rather than an ELR?


NLP Assessment Framework for Local Employment Space

Employment Land Workshop Presentation to East Midlands Councils 23 June 2011 John Robertson Colin...

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