The conclusion draws together the research evidence and summarises the employment land current position and outlook for the borough. The recommendations are based on robust evidence amassed through the research programme. Recommendations are made for office and industrial/warehousing use classes at a generic and site specific level, as appropriate. Recommendations take account of local, regional and national planning framework, strategies and initiatives, and designed to be realistic, actionable and attainable. The recommendations seek to promote regeneration and economic opportunities for residents and businesses in LB Croydon, with the overarching aim of enhancing the borough’s economy.
3 POLICIES AND LITERATURE REVIEW
3.1 Introduction
This section provides an overview of the policies and strategies relevant to employment and employment land in LB Croydon. The review frames the context to the research in terms of national, regional and local policy, the relationship between which is presented in the hierarchy in Figure 3.1 below.
Figure 3.1: Policy and Literature Hierarchy
Source: URS
3.2 National Policy
Planning Policy Statements (PPSs) provide a national guidance framework setting out a range of planning principles and objectives on specific topics.
PPS1: Delivering Sustainable Communities
PPS1 emphasises the important role that the planning system has in the delivery of sustainable development. It encourages local authorities to recognise wider sub-regional, regional and national benefits of economic development and consider these alongside any adverse local impacts.
Local Policy and Literature
• Unitary Development Plan • LDF Core Strategy DPD
• Vision and Economic Development Strategy • Area Action Plans and Supplementary
Planning Guidance
• Evidence Base Documents
Regional Policy
• Strategic Development Plan • Supplementary Planning Guidance • Economic Development Strategy • Other Relevant Studies
National Policy
Reference is given to the UK’s strategy on sustainable development, which emphasises the role of planning to provide attractive places to live and work and development patterns that minimise the need to travel.
PPS3: Housing
PPS3 was released in November 2006 to replace the previous PPG3, and was further updated in June 2010. The Government’s key housing policy goal is to ensure that everyone has the opportunity to live in a decent home, which they can afford, in a community where they want to live. The statement has four key objectives that include:
• To achieve a wide choice of high quality homes, both affordable and market housing, to address the requirements of the community
• To widen opportunities for home ownership and ensure high quality housing for those who cannot afford market housing, in particular those who are vulnerable or in need
• To improve affordability across the housing market, including by increasing the supply of housing, and
• To create sustainable, inclusive, mixed communities in all areas, both urban and rural.
The Statement identifies that to ensure effective use of land Local Planning Authorities (LPAs) should consider a range of incentives or interventions that could help to ensure that previously developed land is developed in line with market trajectories. This should include:
• Planning to address obstacles to the development of vacant and derelict sites and buildings, for example, use of compulsory purchase powers where that would help resolve land ownership or assembly issues
• Considering whether sites that are currently allocated for industrial or commercial use could be more appropriately re-allocated for housing development
• Encouraging innovative housing schemes that make effective use of public sector previously developed land.
PPS4: Planning for Sustainable Economic Development
PPS4 ‘Planning for Sustainable Economic Development’ sets out the Government’s overarching objective of achieving sustainable economic growth. The statement emphasises that planning must help build prosperous communities by improving the economic performance of areas, reduce the gaps between the growth rates between regions, promote regeneration, deliver more sustainable patterns of economic development and promote the vitality and viability of towns and other centres. PPS4 defines economic development as including B Use Classes, public and community uses, main town centre uses and other potential uses where they provide employment opportunities and/or generate wealth and/or produces or generate an economic output or product.
PPS4 prescribes that local authorities should take a proactive approach n planning for the promotion of competitive town centre environments and consumer choice. This should be done by:
• ‘supporting a diverse range of uses which appeal to a wide range of age and a.
• planning for a strong retail mix so that the range and quality of the comparison b.
and convenience retail offer meets the requirements of the local catchment area, recognising that smaller shops can significantly enhance the character and vibrancy of a centre
• supporting shops, services and other important small scale economic uses c.
(including post offices, petrol stations, village halls and public houses) in local centres and villages.
• identifying sites in the centre, or failing that on the edge of the centre, capable d. of
accommodating larger format developments where a need for such development has been identified
•
retaining and enhancing existing markets and, where appropriate, e. re-introducingor creating new ones, ensuring that markets remain attractive and competitive by investing in their improvement, and
• taking measures to conserve and, where appropriate, enhance the established f.
character and diversity of their town centres.’
It also notes that local planning authorities should identify an appropriate portfolio of sites to accommodate identified needs, taking care to ensure that sites are capable of accommodating a range of business models that are appropriate in terms of their scale, format, car parking provision and their scope for disaggregation. In their approach to doing this, local authorities should:
• ‘base their approach on the identified need for development
• identify the appropriate scale of development, ensuring that the scale of the sites
identified and the level of travel they generate, are in keeping with the role and function of the centre within the hierarchy of centres and the catchment served
• apply the sequential approach to site selection • assess the impact of sites on existing centres, and
• consider the degree to which other considerations such as any physical
regeneration benefits of developing on previously-developed sites, employment opportunities, increased investment in an area or social inclusion, maybe material to the choice of appropriate locations for development.’
PPS10: Planning for Sustainable Waste Management
PPS10 requires that a broad range of sites including existing industrial estates should be considered when deciding where to locate new waste and recycling facilities. Effort should be made to locate waste processing facilities close to the producers of waste which are often those operating on existing business and industrial areas.
It also suggests that local waste planners should look for opportunities to locate complementary facilities together on appropriate sites. When identifying sites for waste management facilities the PPS suggests that local waste planners assess sites using the following criteria:
• The physical and environmental constraints on development, including existing and
proposed neighbouring land uses
• The cumulative effect of previous waste disposal facilities on the well-being of the
local community, including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential
• The capacity of existing and potential transport infrastructure to support the
sustainable movement of waste, and products arising from resource recovery, seeking when practicable and beneficial to use modes other than road transport, and
• Give priority to the re-use of previously-developed land, and redundant agricultural
and forestry buildings and their curtilages.’
PPG13: Transport
Planning Policy Guidance 13 (PPG13) sets out the objectives to integrate planning and sets out the objectives to integrate planning and transport at the national, regional, strategic and local level and to promote more sustainable transport choices both for carrying people and for moving freight. The Guidance states that ‘Local authorities should seek to ensure that
strategies in the development plan and the local transport plan are complementary: consideration of development plan allocations and local transport priorities and investment should be closely linked’. This role involves maximising the use of key sites located adjacent
to transport interchanges.
With regard to office uses (B1), it is stated that local authorities should adopt a positive, planned approach to identifying preferred areas and sites for B1 uses which are (or will be) as far as possible highly accessible by public transport, walking, and cycling. In addition, local planning authorities are instructed to adopt a flexible approach to the use of dwellings for home working to protect the amenity of the area for any neighbouring residential uses. For warehousing and distribution uses (B8), the Guidance advocates that local authorities, should aim to locate developments generating substantial freight, particularly bulk goods, away from residential/central areas, and ensure adequate access to major trunk roads. Opportunities for manufacturing (B2) and warehousing and distribution uses to be served by rail or waterways should be promoted wherever possible.
3.3 Regional Policy
London Plan (2008)
The London Plan (March 2008 - Consolidated with Alterations since 2004) is the spatial strategy for Greater London spanning the next fifteen to twenty years. It sets out an integrated social, economic and environmental framework for the future development of London. The relevant policies are stated below.
An overall strategic policy of the Plan provides London Boroughs with guidance on the development of their local plans and states that such strategies should:
• Focus retail, leisure, key commercial activity and services in suburban metropolitan, major, district and local town centres. Where such centres do not already have good levels of public transport accessibility and capacity, improvements should be promoted
• Promote areas around suburban town centres that have good access by public transport and on foot to the town centre as appropriate for higher-density and mixed- use development including housing, and
• Improve the sustainability of suburban residential heartlands by promoting better access to centres, employment and community facilities, improving the public realm, making efficient use of space, and where appropriate, modernising or redeveloping the housing stock.
Further to this, the London Plan divides London into sub-regions to facilitate the implementation of its strategic policies. LB Croydon forms part of the South-West London Sub- Region along with Lambeth, Merton, Richmond upon Thames, Sutton, and the Royal Borough of Kingston upon Thames. This sub-region Policy 5D.1 in the Plan sets out a number of strategic priorities for South-West London and those particular to LB Croydon and the region. These priorities aim to:
• ‘Strengthen economic linkages throughout the sub-region to the CAZ, especially in
terms of the supply chain, and take maximum advantage of the Strategic Opportunity Areas on the southern fringe of the CAZ
• Promote the sub-region’s contribution to London’s world city role, especially in
relation to the Central Activities Zone including the London South Central Opportunity Areas and strengthen linkages between CAZ and the rest of the sub- region
• Optimise the development of Opportunity Areas and Areas for Intensification as set
out in Policies 5E.2 and 5E.3
• Further exploit the strength of the Metropolitan town centres and encourage
sensitive restructuring of some town centres to reflect changes in the office market and the need for a range of economic activities and housing
• Manage the reuse of surplus industrial land taking into account waste management
requirements
• Consolidate the attractiveness of South West London by addressing areas in need
of regeneration and by improving the quality of the public realm
• Manage the reuse of surplus industrial land taking into account waste management
requirements
• Plan for and secure the necessary financial resources to deliver planned transport
infrastructure for the sub-region including strategic priorities: Crossrail 1, the East London Line extension, DLR extensions, Thameslink Programme, improved bus services, Greenwich Waterfront, Transit scheme, new river crossings, including the Thames Gateway bridge and the Cross River Tram
• Promote improvements in the national rail network, which is of particular importance
in South West London, and the benefits to the sub-region of Crossrail 1, Thameslink Programme, Cross River Tram, Tramlink extensions and the East London Line extension and improvements to the Northern, District and Victoria lines
• Improve orbital movement by public transport, including Croydon Tramlink
• Ensure the sub-region is an attractive business location, and
• Support the strategic co-ordination of the development corridor from Croydon to
Gatwick and collaborate with SEERA, SEEDA and local authorities in the corridor.
Policy 5E.3 refers to Opportunity areas, such as Croydon Town Centre, in the South West London sub-region and states that; ‘Taking account of other policies, developments will be
expected to maximise residential and non-residential densities and to contain mixed uses’.
Croydon town centre is recognised as an Opportunity Area in view of the scale of the opportunities it offers, the strategic challenges it faces and the need for integrated action. The policy considers the following sites in the Opportunity Area to be of strategic importance; Fairfield Halls; Croydon College; Park Place and; the Whitgift extension.
An overall strategic policy of the Plan provides London Boroughs with guidance on the development of their local plans and states that such strategies should:
• ‘Focus retail, leisure, key commercial activity and services in suburban metropolitan,
major, district and local town centres. Where such centres do not already have good levels of public transport accessibility and capacity, improvements should be promoted
• Promote areas around suburban town centres that have good access by public
transport and on foot to the town centre as appropriate for higher-density and mixed- use development including housing, and
• Improve the sustainability of suburban residential heartlands by promoting better
access to centres, employment and community facilities, improving the public realm, making efficient use of space, and where appropriate, modernising or redeveloping the housing stock.’
The London Plan also defines the Strategic Industrial Location (SIL) framework as ‘intended to
reconcile the demand for, and supply of, productive industrial land in London’. The LB
Croydon contains two designated SILs: Purley Way and Marlpit Lane.
Consultation Draft Replacement London Plan (2009)
In October 2009, the Mayor of London published the ‘Consultation Draft Replacement London Plan’. The document was open for consultation until the 5th January 2010. Formal publication of the replacement plan is expected towards the end of 2011.
While the preparation of the Plan is ongoing, the ‘London Plan’ published in February 2008 will be in force, and will have legal status until the replacement plan is formally published. However, the ‘Consultation Draft Replacement London Plan’ will gather weight for development control purposes further into the replacement process.
The overall thrust and direction, with regard to employment land, of the ‘Consultation Draft Replacement London Plan’ is broadly similar to the current ‘London Plan’. Some degree of greater protection is given to SILs, through more detailed guidance on their protection. Thus, Policy 2.17, ‘Strategic Industrial Locations’ states that ‘Development proposals in SILs should
be refused unless they:
• Fall within the broad industrial type activities outlined in Paragraph 2.71
• Are part of a strategically coordinated process of SIL consolidation through an
• Propose employment workspace to meet identified needs for small and medium
sized enterprises (SMEs) or new emerging industrial sectors; or
• Proposal small scale ‘walk to’ services for industrial occupiers such as workplace
crèches or cafes.
Policy 2.17 also states that ‘Development proposals within or adjacent to SILs should not
compromise the integrity or effectiveness of these locations in accommodating industrial type activities’.
A key evidence base document for the Replacement London Plan is the 2010 London Industrial Baseline Study, undertaken by URS/DTZ, being used to inform its forthcoming Examination in Public (EIP) and as material consideration for planning applications on industrial land.
GLA Industrial Capacity Supplementary Planning Guidance (SPG) (2008)
Originally published by the GLA in 2003, the Industrial Capacity SPG has been updated in March 2008 following the publication of the London Plan - Consolidated with Alterations since 2004. The SPG defines industrial employment as activities relating to manufacturing and wholesale distribution and seeks to:
• ‘Ensure that there is an adequate stock of industrial capacity to meet the future
needs and functional requirements of different types of industrial and related uses (including waste management, logistics, utilities and transport functions) in different parts of London, including that for good quality and affordable space; and
• Plan, monitor and manage the release of surplus industrial land so that it can better
contribute to strategic and local planning objectives, especially those to provide more housing (including affordable housing) and, in appropriate locations, to provide social infrastructure and to contribute to town centre’.
The SPG categorises LB Croydon is categorised as a borough for restricted transfer, which is defined as ‘typically having low levels of industrial land relative to demand (particularly for
waste management or land for logistics) and/or low proportions of industrial land within the SIL framework.’
The SPG highlights the success of the Strategic Industrial Locations (SIL)4 Framework in protecting London’s principal industrial locations. At the same time, it recognises that the SIL frameworks run the risk of being too successful and potentially maintaining land as industrial when there is no longer demand for this use. However, the monitoring aspect of the approach to maintaining industrial land could keep the framework in tune with market requirements and broader planning objectives.
In reference to SILs, Policy 2 (SPG 2) states that ‘Boroughs and other partners are asked to:
• Promote the SILs as the prime locations for industrial activity in London
• Where relevant in their strategies, DPDs and other plans, identify the components of
the SIL framework namely the Preferred Industrial Locations and Industrial Business Parks
4
• Manage the differing offers of PILs and IBPs through coordinate investment,
regeneration initiatives, transport and environmental improvements and the use of planning agreements, and provide local planning guidelines to meet the needs of different types of industry appropriate to each having regard to paragraph 4.3, and
• Resist the development of non-industrial uses within the SIL other than as part of a
strategically coordinated process of consolidation (see Section 3) except where they provide local, small scale, ‘walk to’ services for industrial occupiers e.g. workplace crèches, or office space ancillary to industrial use.’
The study confirms that LB Croydon has two London Plan designated SILs – Purley Way and Marlpit Lane – which both fall within the Preferred Industrial Location (PIL) sub-categorisation.
Policy 3 (SPG 3) addresses Locally Significant Industrial sites, which fall outside of the SIL
framework. Councils are advised to identify sites of particular local importance, which they wish to enhance and protect for industrial uses, subject to robust strategic and local evidence