BASE HEADER

No

ID sylw: 108002

Derbyniwyd: 07/03/2025

Ymatebydd: CEG Land Promotion III (UK) Limited

Asiant : Nexus Planning

CEG have serious concerns regarding the implementation of Draft Policy Direction 19 on the delivery of large scale employment sites. Whilst well-intended, the requirement to provide affordable units, which are below the market rate, has no basis in national policy. The Council justifies this by referencing paragraph 85 the NPPF which states that “Policies… should create the conditions in which businesses can invest, expand and adapt.”
This is considered a misguided interpretation of policy. Whilst CEG support the need for provision of smaller units to address demand from SME’s, it is considered that this would be best be addressed by allocating specific sites with the required mixes to address this demand. Expecting larger sites to accommodate such uses needlessly risks the delivery and viability of site. Moreover, there is a high degree of uncertainty of how effective this policy mechanism would be in creating more affordable space. CEG consider that the lack of affordable units is partly a result of a significant undersupply of modern, well located, sustainable employment space. Therefore, in the first instance the SWLP should be looking to boost employment land supply to satisfy this need. It is therefore requested that the Council revisit and remove this policy and instead allocate specific sites to meet the identified need.