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Employment Land
Workshop
Presentation to
East Midlands
Councils
John Robertson
Colin Robinson
23 June 2011
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
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Employment
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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?
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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
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Study Approach
Stag
e1
Asse
ssme
nt
Crite
ria
Key Questions
Devised a range of
evaluative criteria,
sent out
questionnaires
and face-face
meetings
Stag
e2
Stag
e3
Surv
ey of
LPAs
Revi
ew
ELRs
How well did
the ELR
comply with
the relevant
guidance at
the time?
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Does it meet
the PPS4
requirements
and are its
assumptions
resilient to the
recession?
Outp
uts
form
evide
nce
base
for
LDF
How well does
the ELR take
account of and
reflect
strategic
factors?
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
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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
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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
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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
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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

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ELR Compliance with Guidance, PPS4 & Strategic Fit
100%
90%
% Districts Compliant
80%
70%
60%
50%
40%
30%
20%
10%
0%
Compliant with 2004 CLG
Guidance
Additional PPS4/Post
Recession Factors
Strategic Coherence / Fit
3: Covered, but only to a limited degree
4: Covered in some detail/some modest omissions
5: Up to date and addressed in full
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ELR Performance by District
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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
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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
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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)
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Way Forward
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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
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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’.
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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
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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
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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
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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?
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NLP Assessment Framework for Local Employment Space
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