SS1030 - Land to the east of Tannery Road,
BMSDC Joint Local Plan Consultation Document (Interactive)
Representation ID: 6305
Respondent: Webb & Son (Combs) Ltd
Agent: Carter Jonas
We object to the allocation of Combs Tannery (Site Reference SS0655) solely for employment purposes for the reasons set out above.
1. On behalf of our client, Webb & Sons (Combs) Ltd, we object to the allocation of Land to the East of Tannery Road, Combs, Stowmarket, IP14 2EN (site reference SS0655) purely as an employment site. This is on the basis that the assessment of the site in the Draft SHELAA is inadequate and fails to respond to the many and varied planning merits of a mixed-use redevelopment of this site, which are subject to pre-application discussions at the present time and which were comprehensively set out in the site promotion document "Combs Tannery: A Sustainable Brownfield Development" dated August 2016. We maintain that the site should be allocated for a mixed use redevelopment comprising both new residential and commercial elements. Development Management officers appear to be supportive of this approach via the aforementioned pre-application discussions.
2. The assessment of the site in the Draft SHEELA proposing to allocate the totality of the site for employment uses states that the existing function of the site is an industrial estate. It states that the site currently has some vacancy which draws market attractiveness into question, but on balance is otherwise assessed as suitable for employment uses and that the proposed redevelopment may be a "more suitable" option for employment uses.
3. One of the core principles of the planning system identified in paragraph 17 of the NPPF is to "promote mixed use developments, and encourage multiple benefits from the use of land in urban and rural areas." The redevelopment of Combs Tannery allows for the opportunity to achieve such a mixed use development resulting in reinvigorated employment uses meaning a net gain in jobs and a net benefit to the rural economy whilst providing much needed housing in a sustainable location. Such redevelopment can both conserve and enhance the existing listed buildings on the site and provide the opportunity to achieve the optimal viable use of these heritage assets. As such, redevelopment of the site for a mixed use would be in line with the principles of sustainable development.
4. Whilst it is acknowledged that part of the Combs Tannery site should be retained for employment purposes given the need to provide balanced growth and to contribute towards the vitality of the rural economy, there are a number of factors which would indicate that Combs Tannery is not a suitable location for a large-scale employment allocation. Referring to the Ipswich and Waveney Economic Areas Employment Land Needs Assessment dated March 2016 (ELNA), Stowmarket is described as an industrial market town strategically located on the A14 which makes it an attractive place for industrial-type uses. Outside of major centres, the ELNA observes that the majority of rural employment sites in Mid-Suffolk are relatively small-scale. The ELNA also states that office demand in Stowmarket is relatively static where space tends to be occupied by local firms, often for ancillary purposes.
5. In terms of the prices achieved in Stowmarket, the ELNA states that the town along with Needham Market represents a low price "hollow" between Bury St Edmunds and Ipswich, where the commercial floor space market is stronger.
6. The importance of the proximity to the A14 should not be underestimated as accessibility to the strategic road network is key to the marketability of storage, distribution, and industrial sites as evidenced by the fact that one of the major employment land allocations being brought forward in the town (Stowmarket East) sits directly adjacent to the A14. In contrast with Stowmarket East and other commercial property in and around Stowmarket, Combs Tannery is in a relatively peripheral as far as access to the strategic road network is concerned.
7. The Combs Tannery site can only be accessed via relatively narrow roads which go past residential property. Their ability to support the kind of large-scale HGV movements that redevelopment of the entire site for B2/B8 uses would entail is limited without causing material harm to highway safety, the road network and/or the amenity of residential properties. The presence of a better-located site in closer proximity to the A14 elsewhere in Stowmarket would represent a significant draw from any large-scale employment development/redevelopment in Combs.
8. A planning application for Stowmarket East was lodged in June 2017 and seeks outline planning permission for up to 13ha of business and industrial development comprising up to 50,215 sq m of new build commercial floor space. Clearly this site will provide a significant pipeline of commercial floor space in Stowmarket for the foreseeable future and owing to its location on the A14 and the corresponding visibility and accessibility of the site will be much more attractive for such uses than Combs Tannery.
9. In terms of the prospects of a large-scale office use across the site, the findings of the ELNA on this point are clear. The ELNA states that Mid Suffolk as a whole is not characterised as a particularly strong office location with Ipswich tending to accommodate most of the office supply for the sub-region. In terms of Stowmarket in particular, the ELNA states that "office space tends to be occupied by local firms with office use often ancillary to other uses." Clearly this indicates a limited demand market for offices in Stowmarket itself let alone the surrounding hinterland. Whilst Combs Tannery does accommodate a certain amount of office space at present, these are small scale local users in line with the findings of the ELNA. Clearly the market for such end-users would be limited and would certainly not sustain redevelopment of the entire site for employment purposes, although a proportionate amount of small scale offices could clearly be appropriate and could be readily accommodated within a mixed use development.
10. The available evidence indicates that whilst at present Combs Tannery may meet a certain amount of localised demand for small scale office and warehousing uses, it does not lend itself to 9ha of new employment development and the evidence from the ELNA indicates that use of the entire site for commercial use would not be well-received by the market. Even if B2/B8 uses were deliverable in Combs at the scale envisaged in the draft SHELAA, it would be highly likely that such uses at that scale would have detrimental impacts in terms of both highway safety and capacity as well as residential amenity.
11. The assessment in the SHELAA states that the level of vacancy of the site draws its market attractiveness into question, but that on balance the site is otherwise assessed as suitable for employment uses. The market attractiveness of the site goes to the heart of whether it should be allocated for commercial use in its entirety, noting the NPPF's advice at paragraph 22 that planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of the site being used for that purpose. The ELNA, a very important part of the evidence base for allocating employment land, makes a number of findings with respect to employment uses in and around Stowmarket which would suggest that there simply would not be the demand for large-scale employment development at Combs Tannery. There are also other, better-located employment sites in Stowmarket which will provide a significant pipeline of commercial floor space in the town for the foreseeable future.
12. Despite the generally buoyant nature of the industrial market in Stowmarket itself, it has been highlighted by local agents that the relative values between the cost of land and achievable rents/values are insufficient for speculative development the area. This is reinforced by the generally low rents in Stowmarket which lie at £4.50-£5.00 per square foot for industrial and £8.00 per square foot for office. These values are likely to be lower in outlying areas such as Combs which, in common with other rural employment sites throughout Mid-Suffolk, are relatively small with a predominance of single use occupies which have grown organically over time.
13. Based on the above evidence, the market conditions in the locality would not support a comprehensive redevelopment of the 9ha site solely for employment use. Allocation for a mixed-use development, however, would provide opportunities to retain and grow the existing employment uses on the site providing for both vastly improved facilities and a net gain in jobs in addition to much-needed market and affordable housing. The residential element of the scheme will financially support the delivery of improved employment facilities.
14. A potential allocation of only one small-scale housing site has been identified in Combs. Given that Combs is identified as a Core Village in the settlement hierarchy, one would expect the level of housing growth planned in the settlement to reflect that status particularly given the fact that Core Villages play a role in all of the housing growth scenarios presented in options MHD1, MHD2, MHD3, and MHD 4. The ability of Combs Tannery to deliver new residential development in what is a demonstrably sustainable location should therefore be favourably considered particularly in light of the planning benefits that can be delivered in terms of improving the existing employment facilities, the potential for a net gain in the amount of jobs on the site, and achieving the optimal viable use of heritage assets.