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Employment Land Review - Consultation Responses

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					Employment Land Review - Consultation Responses
Ref No.   Consultee Name      Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR1/1    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria             The assessment adequately captures the
                                                                                                                          Assessment'.                                                  description of the site, its constraints and
                                                                                                                                                                                        boundaries. No Change.
                                                                                                                           Current use: Site within ownership does not contain
                                                                                                                           residential buildings. Does not abut land in residential
                                                                                                                           use on Ashford Rd to the west and on Canterbury Rd
                                                                                                                           (A2) on the sites northern boundary. Is adjacent to
                                                                                                                           existing employment use (ex KCC works site on
                                                                                                                           Canterbury Rd) and Faversham's recycling centre on
                                                                                                                           Salters Lane and also the Faversham Laundry buildings
                                                                                                                           on Ashford Rd.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




ELR1/2    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria             The assessment adequately captures the
                                                                                                                          Assessment'.                                                  description of the site, its constraints and
                                                                                                                                                                                        boundaries. No Change.
                                                                                                                           Strategic Access: Close to M2 (J6), access onto A251
                                                                                                                           (Ashford Rd) via the land shown on the photograph
                                                                                                                           (attached to rep). Site has frontage onto the A2,
                                                                                                                           Canterbury Road.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




ELR1/3    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria             The consultants views adequately reflect the
                                                                                                                          Assessment'.                                                  highway conditions, however, the reference to
                                                                                                                                                                                        'Brogdale Road' will be amended. Partial
                                                                                                                           Local Road Access: Access points to the site would be        change agreed.
                                                                                                                           from the A2 (Canterbury Road) and via the access strip
                                                                                                                           onto the A251 (Ashford Road). It is not envisaged that
                                                                                                                           any access onto Salters Lane (erroneously referred to as
                                                                                                                           Brogdale Lane in Assessment) would be needed.
                                                                                                                           Development of this site could also provide improved
                                                                                                                           access to the Recycling Plant of Salters Lane which, as
                                                                                                                           pointed out in the Assessment, is extremely narrow. Any
                                                                                                                           traffic would avoid the town centre.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




23 September 2009                                                                                                        Page 1 of 52
Ref No.   Consultee Name      Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                             Council's Response



ELR1/4    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria               The assessment adequately reflects the
                                                                                                                          Assessment'.                                                    location of the site. No Change.

                                                                                                                           Proximity to urban areas, and access to labour and
                                                                                                                           services: the site is within easy walking distance of the
                                                                                                                           town centre facilities and residential areas, close to the
                                                                                                                           bus stops on both Ashford & Canterbury Roads and with
                                                                                                                           excellent road access avoiding the town centre. This
                                                                                                                           locational advantage would reduce travel and consequent
                                                                                                                           pollution in the town centre.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




ELR1/5    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria               The consultant will be asked to re-examine
                                                                                                                          Assessment'.                                                    this issue.

                                                                                                                           Proximity to incompatible users: the residential buildings
                                                                                                                           immediately to the west (fronting Ashford Road) have
                                                                                                                           extensive rear gardens and with adequate design and
                                                                                                                           planting would not be in conflict with an employment use.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




ELR1/6    Jonathan Elworthy                                              10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria               The consultants views are considered to
                                                                                                                          Assessment'.                                                    adequately reflect this issue. No change.

                                                                                                                           Site characteristics and development constraints: 13.35 ha
                                                                                                                           site, set in a slight trough at a lower level to the land to
                                                                                                                           both east and west and is therefore naturally visually
                                                                                                                           constrained. The development already along Ashford
                                                                                                                           Road would also act as a screen.

                                                                                                                           A plan is attached to the representation showing extent of
                                                                                                                           the site within ownership.




23 September 2009                                                                                                        Page 2 of 52
Ref No.   Consultee Name      Consultee Company           Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR1/7    Jonathan Elworthy                                                      10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria             Whilst noting the comments raised, the
                                                                                                                                  Assessment'.                                                  consultants overall assessment is considered
                                                                                                                                                                                                adequate. No change.
                                                                                                                                   Market Attractiveness: Site close to M2, A2 and A251,
                                                                                                                                   excellent access communications to potential employers.
                                                                                                                                   Not a proven employment location purely down to
                                                                                                                                   Swale's resistance to any large scale development south
                                                                                                                                   of the A2.

                                                                                                                                   A plan is attached to the representation showing extent of
                                                                                                                                   the site within ownership.




ELR1/8    Jonathan Elworthy                                                      10               Land East of Ashford Road, Fave They would like to comment on the sites 'Criteria             Noted. Possible change.
                                                                                                                                  Assessment'.

                                                                                                                                   Planning/Sustainability: Site does not need to be
                                                                                                                                   developed for employment all at once. There are
                                                                                                                                   instances of smaller scale development south of the A2.
                                                                                                                                   Site is one ownership and achievable in the short term.
                                                                                                                                   Not within the flood plain, and does not contribute to any
                                                                                                                                   material extent to the special setting of Faversham and
                                                                                                                                   the wider open countryside.

                                                                                                                                   A plan is attached to the representation showing extent of
                                                                                                                                   the site within ownership.




ELR10/1                       E H Nicholls Holdings Ltd                  1.3                                                       Notwithstanding the face-to-face contact which my client Noted. No change.
                                                                                                                                   has had with various Council officers, my clients were
                                                                                                                                   not consulted by the postal survey carried out in respect
                                                                                                                                   of the Employment Land Survey.




ELR10/1                       E H Nicholls Holdings Ltd                  10.9                                                      They support the 'good' grading of the sites at Pheasant     Noted. No change
                                                                                                                                   Farm (east) and Land at Grovehurst Farm.




ELR10/1                       E H Nicholls Holdings Ltd                  10.42                                                     The assessment in respect of Land at Pheasant Farm           This will be checked and any factual matter
                                                                                                                                   west, Bobbing, incorrectly refers to residential potential   corrected. Change agreed.
                                                                                                                                   for approx. 350 dwellings, which was promoted in
                                                                                                                                   respect of land at Pheasant Farm (east) through the
                                                                                                                                   previous Local Plan process and the SHLAA October
                                                                                                                                   2008.




23 September 2009                                                                                                                Page 3 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name   Summary of comments                                               Council's Response



ELR10/1                    E H Nicholls Holdings Ltd                  10.42                                  They support the principle of industrial and distribution        There is inconsistency between the scoring in
                                                                                                             uses, but questions the definition of 'small-scale' and          table 10.4 and Appendix 10 which will be
                                                                                                             considers that the site quality should be good as I believe      checked. The consultants views over the
                                                                                                             that the site has good accessibility to strategic routes and     'small scale' nature of potential uses is
                                                                                                             is accessible to local services and facilities as the existing   considered reasonable given the access and
                                                                                                             industrial uses at the site and on adjoining sites.              location. Change agreed.




ELR10/2                    E H Nicholls Holdings Ltd                  4.1                                    They concur strongly with the acknowledgement of                 Noted.
                                                                                                             difficulties in retaining and relocating expanding firms.




ELR10/3                    E H Nicholls Holdings Ltd                  5.16                                   They support the notion of releasing older industrial sites This position will be reflected. Change
                                                                                                             for alternative development and specifically the            agreed.
                                                                                                             identification of Lydbrook Close. However the document
                                                                                                             fails to acknowledge the existence of an extant planning
                                                                                                             permission for residential redevelopment of the site
                                                                                                             (application references SW/97/623, SW/01/623 &
                                                                                                             SW/03/1378).

                                                                                                             The planning permission has been lawfully implemented,
                                                                                                             but its continuation prevented by the inability to find
                                                                                                             alternative premises to which the haulage depot can
                                                                                                             locate. The key constraint is not addressed in the ELR
                                                                                                             and should be address through the on-going LDF process.
                                                                                                             Furthermore, given the existence of an extant permission
                                                                                                             for residential development, it is unlikely that the site will
                                                                                                             be developed for B1 development, as suggested in the
                                                                                                             report.




ELR10/4                    E H Nicholls Holdings Ltd                  8.31                                   They support the notion of releasing older industrial sites Noted. No change
                                                                                                             for alternative development and specifically the
                                                                                                             identification of Lydbrook Close.




ELR10/5                    E H Nicholls Holdings Ltd                  8.33                                   They support the notion of releasing older industrial sites Noted. No change
                                                                                                             for alternative development and specifically the
                                                                                                             identification of Lydbrook Close.




ELR10/6                    E H Nicholls Holdings Ltd                  8.43                                   They support the notion of releasing older industrial sites Noted. No change
                                                                                                             for alternative development and specifically the
                                                                                                             identification of Lydbrook Close.




23 September 2009                                                                                           Page 4 of 52
Ref No.   Consultee Name   Consultee Company            Support Object Para No. App No. Plan No. Site Name                        Summary of comments                                             Council's Response



ELR10/7                    E H Nicholls Holdings Ltd                   11.23                                                      They support the notion of releasing older industrial sites Noted. No change
                                                                                                                                  for alternative development and specifically the
                                                                                                                                  identification of Lydbrook Close.




ELR10/8                    E H Nicholls Holdings Ltd                   7.26                                                       They submit that E H Nicholls does have immediate         Noted. No change
                                                                                                                                  expansion plans, as set out below and would ask that
                                                                                                                                  these requirements are considered and addressed either in
                                                                                                                                  advance of, or through the LDF process.

                                                                                                                                  "E H Nicholls is a major employer in the area, employing
                                                                                                                                  some 70-75 members of staff. The company has
                                                                                                                                  immediate plans for expansion. They require a site of 10-
                                                                                                                                  12 acres. My client has actively engaged with the
                                                                                                                                  Council over a number of years in the quest to find
                                                                                                                                  alternative premises, and now continuing this process
                                                                                                                                  through the various representations to the LDF process.
                                                                                                                                  To date, no suitable premises have been either identified
                                                                                                                                  or forthcoming."




ELR10/9                    E H Nicholls Holdings Ltd                   10.8                                                       They support the 'good' grading of the sites at Pheasant        Amend wording to read 'an improved' access
                                                                                                                                  Farm (east) and Land at Grovehurst Farm. In relation to         would be needed from the B2005. Change
                                                                                                                                  the former, it should be noted that the site does have an       agreed.
                                                                                                                                  existing access onto the B2005, providing excellent
                                                                                                                                  access to the A249 distributor road.




ELR11/1                    EPS Logistics Technology L                                           Land at Staplehurst Road, Sitting It is evident that exists potential for poorly located          Noted, no change.
                                                                                                                                  commercial sites in Sittingbourne to be released for
                                                                                                                                  employment uses.

                                                                                                                                  Land at Staplehurst Road is recognised as one of the 15
                                                                                                                                  employment sites within the Sittingbourne area. Of these
                                                                                                                                  sites it is placed 2nd to last in terms of its sustainability
                                                                                                                                  for continued employment use. They agree with this and
                                                                                                                                  are continuing to promote the site for a residential lead
                                                                                                                                  mixed use redevelopment through the Core Strategy and
                                                                                                                                  Site Specific Allocations, which is yet to be available for
                                                                                                                                  public consultation.




23 September 2009                                                                                                                Page 5 of 52
Ref No.   Consultee Name     Consultee Company            Support Object Para No. App No. Plan No. Site Name                        Summary of comments                                            Council's Response



ELR11/2                      EPS Logistics Technology L                                           Land at Staplehurst Road, Sitting In terms of the criteria "Market Attractiveness" a score of    The assessment form is an overall reflection
                                                                                                                                    3 out of 5 is in their opinion rather high for the site. The   of the 3 parts of the site and is considered
                                                                                                                                    site is situated in a very low profile location as stated,     reasonable, although reference to modern
                                                                                                                                    however, they contend that the existing buildings are not      buildings should be amended. Para 5.17 does
                                                                                                                                    modern, they date from the early 1950s, nor are they in        make reference to the differing parts of the
                                                                                                                                    good condition, as stated.                                     site. Any potential release would be
                                                                                                                                                                                                   examined further as part of any planning
                                                                                                                                    The buildings are asbestos clad with notifiable asbestos       application. Change agreed.
                                                                                                                                    being isolated in certain locations. It is a poorly located
                                                                                                                                    site in terms of transport links and position in a
                                                                                                                                    residential area. Two of the four access routes into the
                                                                                                                                    site are from neighbouring residential estate roads. Local
                                                                                                                                    residents complain about the undesirable odours and are
                                                                                                                                    encouraged by local residents to change the use to
                                                                                                                                    residential. Noise Abatement Notices under the
                                                                                                                                    Environmental Protection Act 1990 have been served on
                                                                                                                                    the tenants at the site, Macro Industries after continued
                                                                                                                                    local complaints.

                                                                                                                                    They would like the score for "Market Attractiveness"
                                                                                                                                    reduced from 3 to 2 and suggest that the site should be
                                                                                                                                    referenced as being no longer suitable for employment
                                                                                                                                    generating uses given its poor access, proximity to
                                                                                                                                    residential housing, poor quality existing buildings and it
                                                                                                                                    is not in the adopted Local Plan as an employment
                                                                                                                                    generating site which needs to be protected.




ELR12/1 Terry Holtum                                                     9.0     10               Land at Kent Science Park         This is not Kent Science Park land but farmland near the These are matters for the Local Development
                                                                                                                                    science park. They deeply oppose expanding to the south Framework which is principally concerned
                                                                                                                                    side of the motorway. If scheme is successful will this    with commercial judgments. No change.
                                                                                                                                    mean residents living in Bexon Lane who own land
                                                                                                                                    adjacent to there property be successful in submitting
                                                                                                                                    applications to build residential properties? With all the
                                                                                                                                    proposed development there will be a need for local
                                                                                                                                    housing for those people who are to be employed. Lead
                                                                                                                                    to believe this rural location was "green belt" and
                                                                                                                                    therefore couldn't be built on.




ELR13/1 Captain M J Button                                               9.0                      Expansion of the Kent Science P The expansion is unacceptable for the following reasons:         These are matters for the Local Development
                                                                                                                                  The area is designated as being of outstanding natural           Framework which is principally concerned
                                                                                                                                  beauty.                                                          with commercial judgments. No change.
                                                                                                                                  The local roads and country lands are not suitable to
                                                                                                                                  support an industrial complex and major road
                                                                                                                                  improvements would be a disaster for local villages.
                                                                                                                                  The ELR is a back door way of getting protected land
                                                                                                                                  approved for home building which would have a major
                                                                                                                                  impact on local villages.




23 September 2009                                                                                                                  Page 6 of 52
Ref No.   Consultee Name     Consultee Company        Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                          Council's Response



ELR13/2 Captain M J Button                                           9.0                      Expansion of the Kent Science P Kent Science Park is not a science park and does not          Kent Science Park is acknowledged as such is
                                                                                                                              warrant the name; it is an industrial site with no official   a wide variety of documents, most notably the
                                                                                                                              links to a university.                                        South East Plan. No Change.




ELR13/3 Captain M J Button                                           9.0                      Expansion of the Kent Science P The comments of the Highways Agency must be made              These are matters for the Local Development
                                                                                                                              public concerning the impact of the proposed land             Framework which is principally concerned
                                                                                                                              expansion of the "Science Park" on local roads.               with commercial judgments. No change.




ELR14/1 Mrs Teresa Hudson    Bredgar Parish Council                          10               Land at Kent Science Park         The area of land indicated for expansion to the south of  These are matters for the Local Development
                                                                                                                                the M2 falls within the Kent Downs' Area of Outstanding Framework which is principally concerned
                                                                                                                                Natural Beauty (AONB) and other land which is             with commercial judgments. No change.
                                                                                                                                contained within a Special Landscape Area. The Parish
                                                                                                                                Council consider this is proposal completely
                                                                                                                                unacceptable as the primary purpose and priority is the
                                                                                                                                long-term conservation and enhancement of natural
                                                                                                                                beauty, being landscape, wildlife and geological features
                                                                                                                                of this natural asset over and above other planning
                                                                                                                                considerations, as set out in policy E9 of the adopted
                                                                                                                                Swale Borough Local Plan.

                                                                                                                                They do not consider that an adequate and proven case
                                                                                                                                has been made to support the expansion of the KSP
                                                                                                                                beyond the existing security fence and certainly not an
                                                                                                                                expansion of the site south of the M2 into the AONB.




ELR14/2 Mrs Teresa Hudson    Bredgar Parish Council                          10               Land at Kent Science Park         The Parish Council have recently drawn SBC's attention      These are matters for the Local Development
                                                                                                                                to the adverse impact of traffic on the rural highway       Framework which is principally concerned
                                                                                                                                network arising from the current operation of the KSP.      with commercial judgments. No change.
                                                                                                                                Expansion of the site as indicated on the annexed plan is
                                                                                                                                unacceptable and Bredgar Parish Council objects most
                                                                                                                                strongly to the proposal.




ELR15/1 R C Reeves                                                   9.0                      Expansion of the Kent Science P With the economy in a downward trend and employment           This is speculative, and does not alter the
                                                                                                                              rising, with 25% of the units vacant in six months this       underlying conclusions. No change.
                                                                                                                              may well be 50%, that would result in the vacant units
                                                                                                                              being offered, as an incentive to attract tenants free rent
                                                                                                                              and rates for a period, short leases with get out clauses.




23 September 2009                                                                                                             Page 7 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                          Council's Response



ELR15/2 R C Reeves                                            9.0                      Expansion of the Kent Science P The land lying on the Bexon Lane side of the motorway,       These are matters for the Local Development
                                                                                                                       why would this be needed, is there not enough land on        Framework which is principally concerned
                                                                                                                       the science park side?                                       with commercial judgments. No change.




ELR16/1                    Barratt Strategic                  7.0                                                      The ELR presents a broad range of alternative               See main report.
                                                                                                                       employment scenarios and approaches to assessment.
                                                                                                                       Within these scenarios, the precise assumptions made
                                                                                                                       regarding the loss of existing employment sites as a result
                                                                                                                       of the proposals set out within the Draft Sittingbourne
                                                                                                                       Town Centre and Milton Creed SPD are not spelt out. It
                                                                                                                       is not clear whether these are already within assumptions
                                                                                                                       for forecast employment change within the Borough, or
                                                                                                                       whether such losses should be considered over and above
                                                                                                                       the figures identified in chapter seven?




ELR16/2                    Barratt Strategic                  7.27                                                     Paragraph 7.27 makes clear that there is already             See main report.
                                                                                                                       uncertainty in the minds of the reports authors as to how
                                                                                                                       town - regeneration proposals have already impacted
                                                                                                                       upon employment floorspace.

                                                                                                                       As the regeneration of the town centre and Milton Creek
                                                                                                                       is a central part of planning police for the Borough it is
                                                                                                                       vital that this is taken into account in assessing
                                                                                                                       employment land supply for the Local Development
                                                                                                                       Framework and also in setting out options for future
                                                                                                                       employment strategy. Is the assumption that the existing
                                                                                                                       employment uses and jobs will no longer be required
                                                                                                                       within the Sittingbourne are and will be replaced by other
                                                                                                                       employment uses?

                                                                                                                       The Employment Land Review should provide clear
                                                                                                                       guidance on this matter in order that the wider Core
                                                                                                                       Strategy can then make sound assumptions regarding the
                                                                                                                       need for employment land around the town (and indeed
                                                                                                                       for the timing and deliverability of the town centre
                                                                                                                       regeneration proposals).




ELR16/3                    Barratt Strategic                  Table 1 10               Land west of A249, Bobbing Hill They contest the appraisal of land at Bobbing Hill and the Any inconsistencies between the tables and
                                                                                                                       scoring provided. Firstly table 10.1 does not reflect the   appendices will be checked. Change agreed.
                                                                                                                       scoring within appendix 10. It is not clear why the score
                                                                                                                       for Bobbing of 18 (with which they disagree) is further
                                                                                                                       reduced to 16. Score for other sites are likewise similarly
                                                                                                                       inconsistent.




23 September 2009                                                                                                     Page 8 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                           Council's Response



ELR16/4                    Barratt Strategic                          10               Land west of A249, Bobbing Hill The scoring is greatly contested for this site.                It is considered that there may be grounds for
                                                                                                                                                                                      the consultant to re-assess some of the issues
                                                                                                                         Local Road Access - the grading of this site at 2 is         concerning this site.
                                                                                                                         incorrect. This places Bobbing on a par with say land off
                                                                                                                         Church Road, Newington which also merits a score of 2
                                                                                                                         and can only be accessed via a Conservation Area, a sub
                                                                                                                         standard bridge under the North Kent Line and residential
                                                                                                                         areas and rural lanes. In our view Bobbing should be
                                                                                                                         scored consistent with other site with good access to the
                                                                                                                         A249 such as land at Great Grovehurst Farm and be
                                                                                                                         accorded a score of 4.




ELR16/5                    Barratt Strategic                          10               Land west of A249, Bobbing Hill The scoring is greatly contested for this site.                It is considered that there may be grounds for
                                                                                                                                                                                      the consultant to re-assess some of the issues
                                                                                                                         Proximity to urban areas and access to labour and            concerning this site.
                                                                                                                         services - Again the scoring of 2 is contested when other
                                                                                                                         Great Grovehurst Farm in an almost identical setting
                                                                                                                         merits a score of 3. A similar score of 3 should be
                                                                                                                         accorded to Bobbing.




ELR16/6                    Barratt Strategic                          10               Land west of A249, Bobbing Hill The scoring is greatly contested for this site.                It is considered that there may be grounds for
                                                                                                                                                                                      the consultant to re-assess some of the issues
                                                                                                                         Proximity to incompatible uses - land at Bobbing is no       concerning this site.
                                                                                                                         different to land at Great Grovehurst Farm and should be
                                                                                                                         accorded a score of 4 also.




ELR16/7                    Barratt Strategic                          10               Land west of A249, Bobbing Hill The scoring itself is greatly contested:                       It is considered that there may be grounds for
                                                                                                                                                                                      the consultant to re-assess some of the issues
                                                                                                                         Market Attractiveness - again it is hard to conceive how     concerning this site.
                                                                                                                         this site might be less attractive to the market than land
                                                                                                                         off Church Road, Newington or other sites along the
                                                                                                                         A249. A score of at least 3 ought to be accorded.




ELR16/8                    Barratt Strategic                          10               Land west of A249, Bobbing Hill The scoring itself is greatly contested:                      It is considered that there may be grounds for
                                                                                                                                                                                     the consultant to re-assess some of the issues
                                                                                                                         Planning/Sustainability Factors - again there is no logical concerning this site.
                                                                                                                         explanation for why this site should perform any
                                                                                                                         differently to other sites along the A249 which are all
                                                                                                                         equally effected by Strategic Gap policies. A score of at
                                                                                                                         least 3 ought to be accorded.




23 September 2009                                                                                                      Page 9 of 52
Ref No.   Consultee Name   Consultee Company            Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                            Council's Response



ELR16/9                    Barratt Strategic                                   10               Land west of A249, Bobbing Hill It is their view that the score of 18 as set out in appendix It is considered that there may be grounds for
                                                                                                                                10 is unjustifiably low. Taking account of our reasonable the consultant to re-assess some of the issues
                                                                                                                                suggestions above a score of 24 should be accorded to        concerning this site.
                                                                                                                                land at Bobbing. This would reflect the true merits of the
                                                                                                                                site in a manner consistent with the consideration of other
                                                                                                                                sites and would confirm it as either a good or average
                                                                                                                                quality potential employment site.

                                                                                                                                  Given our concerns regarding the scoring we request that
                                                                                                                                  the Council reviews the scoring for land at Bobbing, or
                                                                                                                                  alternatively the scoring accorded to other sites.




ELR17/1                    HXRUK II (Sittingbourne) L                          5                Watermark Business Park, Sitt     The ELR summaries the local property market by stating Noted. No change.
                                                                                                                                  that Swale serves a different market to most (ie the
                                                                                                                                  industrial sector) and the report concedes that there are
                                                                                                                                  no signs of this situation changing - a conclusion that our
                                                                                                                                  client agrees with.




ELR17/2                    HXRUK II (Sittingbourne) L                  5.23                     Watermark Business Park, Sittin The report correctly advises that the circa 4500 sqm            Noted. No change.
                                                                                                                                phase 1 office development (which is known as
                                                                                                                                Conqueror Court) has been built out (of the total
                                                                                                                                consented 27.500 sqm) and remains largely vacant, with
                                                                                                                                only one of the 13 units having thus far been let (on
                                                                                                                                deeply discounted/non commercial terms) despite having
                                                                                                                                been intensively marketed prior to and since completion.
                                                                                                                                The report goes on to state that Watermark Kent's role as
                                                                                                                                an office park is called into question by the current level
                                                                                                                                of its attractiveness to the market.

                                                                                                                                  The report suggests that other facilities and a wider range
                                                                                                                                  of non-B class uses on the site, may assist in generating
                                                                                                                                  interest. They concur with this view and consider that a
                                                                                                                                  pragmatic, market led approach to the remaining
                                                                                                                                  Watermark plots should be enshrined in emerging
                                                                                                                                  planning policy.




ELR17/3                    HXRUK II (Sittingbourne) L                  9.0                      Expansion of the Kent Science P It is noted that Kent Science Park has accommodated             Noted. No change.
                                                                                                                                much of the demand for office accommodation in the
                                                                                                                                Sittingbourne locality in recent years. The ELR makes a
                                                                                                                                strong case for promoting expansion of the Science Park,
                                                                                                                                not least as it has clearly been successful in attracting
                                                                                                                                occupiers beyond the confines of the science and
                                                                                                                                technology sector. They consider this to be a sensible
                                                                                                                                approach to expanding employment provision in Swale.




23 September 2009                                                                                                               Page 10 of 52
Ref No.   Consultee Name   Consultee Company            Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                            Council's Response



ELR17/4                    HXRUK II (Sittingbourne) L                  5.23                     Watermark Business Park, Sittin Whilst the Phase 1 development at Watermark Kent is            Noted. This will be for the Local
                                                                                                                                identified as the only modern, good quality office             Development Framework to consider. No
                                                                                                                                development at Swale, this should not, particularly in         change.
                                                                                                                                light of the ELR's broader assessment and observations,
                                                                                                                                preclude the Council from giving favourable
                                                                                                                                consideration to alternative uses for the wider site and
                                                                                                                                promoting a policy framework, through the Local
                                                                                                                                Development Framework, that provides a platform to
                                                                                                                                advance proposal in this matter.




ELR17/5                    HXRUK II (Sittingbourne) L                  6.0                                                       The ELR predicts a maximum future employment space Noted. No change.
                                                                                                                                 requirement for B1 offices of around 100,000 sqm, for
                                                                                                                                 their period of 2026. The report acknowledges that this
                                                                                                                                 could be accommodated on identified site and that there
                                                                                                                                 is a quantitative oversupply of office space. The build
                                                                                                                                 Phase 1 element at Watermark Kent is a significant factor
                                                                                                                                 in this.




ELR17/6                    HXRUK II (Sittingbourne) L                  5.23                     Watermark Business Park, Sittin The conclusions to the report suggest that the emphasis    The comments in paragraph 5.23 of the report
                                                                                                                                should be on addressing qualitative deficiencies. In terms reflect adequately the need for flexibility. No
                                                                                                                                of offices, this would mean small, cheap and flexibly      change.
                                                                                                                                managed units, ideally in Sittingbourne town centre,
                                                                                                                                alongside the expansion of the Kent Science Park,
                                                                                                                                thereby enabling it to build on its past success.

                                                                                                                                 In this regard, emerging policy should allow for the
                                                                                                                                 principle of release, or reallocation, of employment sites,
                                                                                                                                 such as Watermark Kent, for which it can be
                                                                                                                                 demonstrated, through past and present demand,
                                                                                                                                 predicted patterns of growth and the availability of other
                                                                                                                                 sites, that alternative uses are a more appropriate use of
                                                                                                                                 the land.




23 September 2009                                                                                                              Page 11 of 52
Ref No.   Consultee Name   Consultee Company              Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                            Council's Response



ELR18/1 Pauline Lewis                                                    9.0                      Expansion of Kent Science Park They live in Bell Road and have already noticed the             These are matters for the Local Development
                                                                                                                                 amount of traffic is growing since Highsted Road was            Framework and not the Employment Land
                                                                                                                                 shut. Since the arrival of the traffic lights, cars coming      Review which is principally concerned with
                                                                                                                                 up the road make it more difficult for us to get our car        commercial judgments. No change.
                                                                                                                                 onto the road, and now there is the additional problem of
                                                                                                                                 the Highsted Road closure so more country traffic is
                                                                                                                                 coming down the road into the town.

                                                                                                                                   Having read your figures of 12000 new employees by
                                                                                                                                   2016, I wonder if any Councilors try to negotiate the
                                                                                                                                   town at peak time when it is completely gridlocked. Also
                                                                                                                                   according to your figures alot of the jobs to people who
                                                                                                                                   live outside of Sittingbourne and Sheerness.

                                                                                                                                   If you want to employ people why don't you encourage
                                                                                                                                   retailers to come to the town. This town has less shops
                                                                                                                                   and facilities now than it had in the 1960s. the
                                                                                                                                   population must have grown by thousands.




ELR19/1 Hilary Coleman     Strategy and Planning Divisi                  General                                                   Overall it seems a well written, clear document setting       Noted no change.
                                                                                                                                   out a full assessment of economic land availability in
                                                                                                                                   Swale.

                                                                                                                                   As a general point KCC will be doing an Economic
                                                                                                                                   Assessment report, in consultation with Districts, over the
                                                                                                                                   next year or so, and this Land Review will provide useful
                                                                                                                                   data. The Economic Assessment is part of the Sub
                                                                                                                                   National Review which is directing local authorities to
                                                                                                                                   take a more active stance on encouraging and supporting
                                                                                                                                   economic development in their areas. This Economic
                                                                                                                                   Assessment document could in its turn have an impact on
                                                                                                                                   economic development in Swale.




ELR19/2 Hilary Coleman     Strategy and Planning Divisi                  2.12                                                      When referring to housing growth, it would be helpful to It is agreed that a reference to future
                                                                                                                                   refer to the projected growth in Swale of just over 10,000 population growth should be made. Change
                                                                                                                                   new units.                                                 agreed.




ELR19/3 Hilary Coleman     Strategy and Planning Divisi                  2.24                                                      The point about a lack of knowledge industries in Swale       Noted.
                                                                                                                                   and Swale's lower skills profile is well made.




23 September 2009                                                                                                               Page 12 of 52
Ref No.   Consultee Name          Consultee Company              Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                          Council's Response



ELR19/4 Hilary Coleman            Strategy and Planning Divisi                  4.9                                                       Paragraph 4.9 refers to the partial completion of the NRR It is agreed that further clarity is required
                                                                                                                                          and its beneficial impact on Eurolink Way industrial      here. Change agreed.
                                                                                                                                          estate already. In fact the beneficial impact will only
                                                                                                                                          occur in late Autumn 2011 when the middle section of
                                                                                                                                          the NRR is completed.




ELR19/5 Hilary Coleman            Strategy and Planning Divisi                  4.18                                                      There is a useful analysis in Chapter 4 showing that,       Noted.
                                                                                                                                          although office rentals are low in Swale, this does not
                                                                                                                                          have a positive impact on decisions to locate in Swale as
                                                                                                                                          other negative factors, such as low skill levels, make it
                                                                                                                                          unattractive to business.




ELR19/6 Hilary Coleman            Strategy and Planning Divisi                  9.0                      Expansion of the Kent Science P The KSP section seems accurate given that this site and    Noted, these matters would be taken into
                                                                                                                                         plans for it can be highly contentious. The proposal to    account at a later stage. No change.
                                                                                                                                         make the KSP a priority employment generator in the SE
                                                                                                                                         Plan seems sensible - the KSP is not just a local employer
                                                                                                                                         for Swale but has a potential sub-regional significance.

                                                                                                                                          There is however one other factor that needs to be
                                                                                                                                          brought into the expansion scenarios, as well as road
                                                                                                                                          access - drainage capacity. Major drainage and sewerage
                                                                                                                                          work will be needed if the KSP expands beyond the 4-6
                                                                                                                                          ha extension being debated.




ELR2/1    Monique Bonney, Five P Five Parishes Opposition Gr                    General                                                   The Five Parishes Opposition Group have considerable        Noted but no change considered necessary.
                                                                                                                                          reservations regarding some of the data and figures         No change.
                                                                                                                                          previously produced by the owners of the Science Park.
                                                                                                                                          It is noted that the report does make reference to
                                                                                                                                          information provided by the sites owners and therefore
                                                                                                                                          this should be treated with a degree of caution.




23 September 2009                                                                                                                      Page 13 of 52
Ref No.   Consultee Name   Consultee Company             Support Object Para No. App No. Plan No. Site Name                   Summary of comments                                            Council's Response



ELR2/10 Monique Bonney     Five Parishes Opposition Gr                                   10      Land at Kent Science Park     Whilst it is accepted that the plan simply provides a      Noted these are matters for the Local
                                                                                                                               graphic representation of the potential employment sites, Development Framework. No change.
                                                                                                                               and does not represent Council policy until such time as
                                                                                                                               the LDF is further progressed, we wish to express our
                                                                                                                               very grave concerns relating to the potential expansion of
                                                                                                                               the Kent Science Park as noted on the plan.

                                                                                                                               The areas of land indicated include land to the south of
                                                                                                                               the M2 that falls within the Kent Downs Area of
                                                                                                                               Outstanding Natural Beauty (AONB) and land
                                                                                                                               surrounding which is contained within a Special
                                                                                                                               Landscape Area. We believe this is completely
                                                                                                                               unacceptable as the primary purpose of land within the
                                                                                                                               AONB as set out in policy E9 of the adopted Swale
                                                                                                                               Borough Local Plan is:

                                                                                                                               In the Kent Downs Area of Outstanding Natural Beauty
                                                                                                                               (AONB), the priority is the long-term conservation and
                                                                                                                               enhancement of natural beauty (including landscape,
                                                                                                                               wildlife, and geological features) of this national asset
                                                                                                                               over other planning considerations. Suitably located and
                                                                                                                               designed development necessary to facilitate the
                                                                                                                               economic and social well-being of the area and its
                                                                                                                               communities, will be permitted, whilst major
                                                                                                                               developments will not be permitted unless there is a
                                                                                                                               proven national interest and no suitable alternative sites;

                                                                                                                               We do not consider that the case has been made to
                                                                                                                               support the expansion of the Kent Science Park into the
                                                                                                                               AONB, either in terms of demonstrating beyond
                                                                                                                               reasonable doubt that there is a proven national need for
                                                                                                                               expansion in this location or that there are no suitable
                                                                                                                               alternative sites. Furthermore for reasons set out earlier
                                                                                                                               above, we seriously question the basis upon which the
                                                                                                                               forecasts for future demand have been based.

                                                                                                                               We also wish to express concern about the potential
                                                                                                                               expansion of the KSP into areas designated as Special
                                                                                                                               Landscape Areas to the south east and south west of the
                                                                                                                               current site given the policy protection given to such
                                                                                                                               areas in policy E9 of the adopted Local Plan.




23 September 2009                                                                                                            Page 14 of 52
Ref No.   Consultee Name          Consultee Company             Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                          Council's Response



ELR2/11 Monique Bonney            Five Parishes Opposition Gr                  General                  Expansion of Kent Science Park In relation to the number of employees based at KSP.          Noted. The EIA used data available at that
                                                                                                                                       Two recent articles in the Kent Messenger dated 17.04.09      time (Dec 07), whilst these differ from more
                                                                                                                                       and 22.04.09 provided contrasting figures for                 recent figures, the Council has no basis to
                                                                                                                                       employment at the Park. The former article states 1250        challenge them. No change.
                                                                                                                                       employees and the more recent report states 1125
                                                                                                                                       employees. The disparity of 125 employees illustrates
                                                                                                                                       either how bad the local economy must be faring 125
                                                                                                                                       employees had lost their jobs in just over one month or
                                                                                                                                       alternatively the figures are not accurate. It demonstrates
                                                                                                                                       the lack of credibility that KSP has to producing this kind
                                                                                                                                       of data.




ELR2/2    Monique Bonney, Five P Five Parishes Opposition Gr                   9.2                      Expansion of Kent Science Park The Five Parishes dispute the data presented in paragraph Noted. These are matters to be considered at
                                                                                                                                       9.2 in relation to floorspace, number of firms and         the planning application stage. No change.
                                                                                                                                       employees for the reasons given in sections 1 and 3 of the
                                                                                                                                       attached objections to the 4ha extension application (see
                                                                                                                                       related information received).




ELR2/3    Monique Bonney          Five Parishes Opposition Gr                  9.6                      Expansion of Kent Science Park The Five Parishes Opposition Group dispute the figure         Noted. These are matters to be considered at
                                                                                                                                       presented in paragraph 9.6 in relation to vacant              the planning application stage. No change.
                                                                                                                                       floorspace for the reasons set out in section 3 of the
                                                                                                                                       attached objections to the 4ha extension application. (see
                                                                                                                                       attached information received)




ELR2/4    Monique Bonney          Five Parishes Opposition Gr                  9.14                     Expansion of Kent Science park In relation to paragraph 9.14, whilst this indicates the      Whilst this may be so, these are matter for the
                                                                                                                                       Council's strong support to the consolidation and             planning process, not the Employment Land
                                                                                                                                       measured expansion of the Science Park site, the text         Review, albeit that the Employment Land
                                                                                                                                       fails to mention that growth must be carefully controlled.    Review refers to 'measured' expansion. No
                                                                                                                                                                                                     change.




23 September 2009                                                                                                                     Page 15 of 52
Ref No.   Consultee Name   Consultee Company             Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                             Council's Response



ELR2/5    Monique Bonney   Five Parishes Opposition Gr                  9.20                     Expansion of Kent Science Park The Five Parishes Opposition Group have previously               Noted. However, the council's judgment in
                                                                                                                                called into question much of the data presented in the           respect of the analysis provided by the
                                                                                                                                Kent Science Park Expansion Economic Impact                      objector is that some of the underlying
                                                                                                                                Assessment referred to in paragraph 9.20. In particular,         assumptions are flawed. No change.
                                                                                                                                they have questioned the assumptions referred to in
                                                                                                                                relation to the potential future demand. Section 4 of their
                                                                                                                                objections produced in relation to the 4ha expansion
                                                                                                                                proposal provide a more realistic realignment of the
                                                                                                                                Employment Impact Assessment baseline which
                                                                                                                                demonstrates full capacity being reached sometime
                                                                                                                                between 2020 and 2025 assuming a 2.5% annual growth
                                                                                                                                rate, thereby considerably reducing the amount of
                                                                                                                                additional land being required beyond the existing
                                                                                                                                security fence.




ELR2/6    Monique Bonney   Five Parishes Opposition Gr                  9.0                      Expansion of Kent Science Park The Five Parishes Opposition Group do accept that                Noted these are not matters for the
                                                                                                                                growth of the Kent Science Park should be allowed to             Employment Land Review. No change.
                                                                                                                                take place but that this should be undertaken in strict
                                                                                                                                compliance with the existing adopted local plan policy
                                                                                                                                B25 which provides the necessary controls in such a
                                                                                                                                countryside location to enable development to take place
                                                                                                                                in a planned manner.

                                                                                                                                  They consider that all options for expanding with the
                                                                                                                                  existing site must be explored first before consideration is
                                                                                                                                  given to expanding beyond the current site boundaries.




ELR2/7    Monique Bonney   Five Parishes Opposition Gr                  9.27                     Expansion of Kent Science Park The Five Parishes Opposition Group disagree with the             The term 'modest' reflects the consultants
                                                                                                                                term 'modest to describe the 4ha expansion at paragraph          judgment not the Councils. Matters relating
                                                                                                                                9.27 of the report for the reasons set out in section 8 of       to highway capacity are issues for the
                                                                                                                                the enclosed Objections. They further disagree with the          planning application. Indeed the Highway
                                                                                                                                statement that this level of growth can be accommodated          Authority has confirmed that development is
                                                                                                                                within the existing road network for the reasons set out in      acceptable and as such this paragraph can be
                                                                                                                                the enclosed assessment undertaken by Odyssey                    amended. Change agreed.
                                                                                                                                Consulting Engineers on their behalf.

                                                                                                                                  The Odyssey Assessment raises a number of important
                                                                                                                                  issues with the evidence presented by the site owners to
                                                                                                                                  justify the 4ha expansion.




23 September 2009                                                                                                              Page 16 of 52
Ref No.   Consultee Name      Consultee Company             Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                         Council's Response



ELR2/8    Monique Bonney      Five Parishes Opposition Gr                  9.37                     Expansion of Kent Science Park The Five Parishes Opposition Group do not consider that These are matters for the Local Development
                                                                                                                                   the minimum expansion potential of 54,000sqm requiring Framework and not the Employment Land
                                                                                                                                   15ha of land referred to at paragraph 9.37 is acceptable. Review. No change.
                                                                                                                                   They consider that this is a huge additional area of land
                                                                                                                                   that will have a severely detrimental impact on the
                                                                                                                                   countryside and local highway network.




ELR2/9    Monique Bonney      Five Parishes Opposition Gr                  9.38                     Expansion of Kent Science Park In relation to the 4ha expansion referred to at paragraph  Noted, these are not matter for the
                                                                                                                                   9.38, the FPOG have separately questioned the case put     Employment Land Review. No change.
                                                                                                                                   forward by the site owners in their recent application for
                                                                                                                                   planning permission in relation to the highway, public
                                                                                                                                   transport, environmental and other planning factors issues
                                                                                                                                   associated with that proposal.




ELR20/1 B S Cuff & J P Cuff                                                        10               Land at Kent Science Park      Apart from the visual impact, traffic would also cause      Noted , these are matters for the Local
                                                                                                                                   problems in the surrounding country lanes. While we         Development Framework/planning
                                                                                                                                   note that so-called 'road improvements' would also need     application. No change
                                                                                                                                   to be made, it is not the answer. Building on vital
                                                                                                                                   agricultural land is short-sighted. This area is far too
                                                                                                                                   precious to lose for financial gain.




ELR21/1                       A Hinge & Sons Ltd                           10.39                    Danaway Cold Stores, Danaway It is noted that the Company's site at Danaway Cold           Noted. No change.
                                                                                                                                 Stores was assessed and ranked as good, and is one of
                                                                                                                                 only 2 such sites similarly ranked outside of the main
                                                                                                                                 urban area of Sittingbourne and Faversham (table 10.4).




ELR21/2                       A Hinge & Sons Ltd                           10.39                    Danaway Cold Stores, Danaway They are surprised at the suggestion within the               By contrast to these views, the consultants
                                                                                                                                 consultation document that the site might only be             recommendations is that proposals could be
                                                                                                                                 considered as part of a general LDF policy on rural           progressed outside the Local Development
                                                                                                                                 employment without necessarily requiring a specific           Framework process. See also main report.
                                                                                                                                 allocation.

                                                                                                                                   Bearing in mind the existing planning consent for
                                                                                                                                   document storage - which is currently being activated -
                                                                                                                                   the Company is firmly of the view that the site should be
                                                                                                                                   specifically allocated within the ELR, and included as
                                                                                                                                   such in any subsequent Council policy as part of the
                                                                                                                                   Swale LDF.




23 September 2009                                                                                                                Page 17 of 52
Ref No.   Consultee Name   Consultee Company    Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                              Council's Response



ELR21/3                    A Hinge & Sons Ltd                  10.12                    Land at Bobbing Hill           They note the comments in the ELR and are likely to              Noted no change
                                                                                                                       pursue employment uses in respect of these.




ELR21/4                    A Hinge & Sons Ltd                  10.41                    Firs Farm, Deans Hill Road, Bre They note the comments within the ELR and are likely to Noted no change
                                                                                                                        pursue employment uses in respect of these.




ELR22/1 Jeff Holroyd       NFU                                 6.6                                                     The study recognises that one of the key areas for               Noted no change
                                                                                                                       regeneration is the rural areas where tourism and rural
                                                                                                                       development will be developed and this is a policy the
                                                                                                                       NFU support.

                                                                                                                       Swale has established significant rural diversification
                                                                                                                       based on tourism and also the reuse of redundant farm
                                                                                                                       buildings for a variety of light industrial and service
                                                                                                                       uses. It is clearly difficult for the study to consider all of
                                                                                                                       the widely dispersed small sites in such use and specific
                                                                                                                       extension of such sites through formal allocation is
                                                                                                                       probably not practical but clearly policy provision should
                                                                                                                       be made.




ELR22/2 Jeff Holroyd       NFU                                 General                                                 The study highlights the lack of employment in eastern    Noted no change
                                                                                                                       Sheppey and this is an area of future policy that the NFU
                                                                                                                       would support. It may be through the study suggestion of
                                                                                                                       a small allocation supported by public funds near a
                                                                                                                       population service centre or a more generic and positive
                                                                                                                       farm diversification policy.




ELR22/3 Jeff Holroyd       NFU                                 General                                                 Faversham is the one area where we do have more                  Noted, the Employment Land Review does
                                                                                                                       concerns. Historically it has been seen as serving the           respond to future employment needs at
                                                                                                                       extensive rural hinterland of eastern Swale.                     Faversham which will be further tested via the
                                                                                                                       Unfortunately the truth is that current employment land          Local Development Framework process. No
                                                                                                                       policy and this study, do not envisage Faversham serving         change.
                                                                                                                       its own economically active population. As an example
                                                                                                                       an out commuting level of 50%+ should simply be
                                                                                                                       considered unsustainable and clear policy put in place to
                                                                                                                       address the issue. The failure to deliver past policy
                                                                                                                       initiatives seems now to have evolved into a reluctance to
                                                                                                                       take any strategic decisions and the political back ground
                                                                                                                       may mean that remains the case for the foreseeable
                                                                                                                       future. That being the case then clearly the rural areas of
                                                                                                                       Swale must have policy provision to deliver in the
                                                                                                                       absence of any sensible policy for Faversham.




23 September 2009                                                                                                    Page 18 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                            Council's Response



ELR22/4 Jeff Holroyd       NFU                                8.19                                                      A common theme of the study is that rural areas are           Noted, no change.
                                                                                                                        under allocated in respect of employment space and
                                                                                                                        development tends to come from non allocated sites.




ELR22/5 Jeff Holroyd       NFU                                8.39                                                      Under Policy Responses the study flags up the crucial         Noted, no change.
                                                                                                                        role of the emerging LDF with particularly (h) 'in rural
                                                                                                                        areas, encouraging the conversion of redundant rural
                                                                                                                        buildings to employment uses, allowing for expansion of
                                                                                                                        established businesses and or small scale new provision
                                                                                                                        in larger settlements'.

                                                                                                                        This policy area is vital and the NFU would like to see a
                                                                                                                        clear and unequivocal policy lead in the LDF that
                                                                                                                        encourages the reuse of farm buildings not only for
                                                                                                                        tourism but also more general employment, including
                                                                                                                        offices and crucially where this is already a successful
                                                                                                                        business the policy provision to allow expansion into new
                                                                                                                        buildings on site.




ELR22/6 Jeff Holroyd       NFU                                General                                                   The study underestimates the role that rural economy          Noted, this reflects the set parameters for the
                                                                                                                        could and should play because it is so focused on the         Employment Land Review in terms of site
                                                                                                                        urban areas and data for a typical, small, widely spread,     size, however the report does acknowledge the
                                                                                                                        diversified farm sites is not readily available. This makes   role of the rural economy and recommends a
                                                                                                                        the contribution of this Study to the evidence base in        positive planning policy framework. No
                                                                                                                        terms of the rural economy of limited use.                    change.




ELR23/1 Simon Curling                                                   10             Land at Perry Court Farm, Faver Proximity to urban areas - it is better served by services The services referred to in the report do not
                                                                                                                       than suggested. Newly installed South East Water main relate to water/gas etc. The report adequately
                                                                                                                       runs through the site. Transco Gas main runs within        reflects the site general location. No change.
                                                                                                                       about 150m of the site. Electricity supplies both north
                                                                                                                       and south. This site therefore should have an assessment
                                                                                                                       criteria score of 4, backed by its very close proximity to
                                                                                                                       Junction 6 of the M2.




ELR23/2 Simon Curling                                                   10             Land at Perry Court Farm, Faver Proximity to incompatible uses - The site is not bounded       The factual error can be corrected however, it
                                                                                                                       by farmland to the north but by playing fields of the          is not considered to affect the assessment
                                                                                                                       Abbey School and existing commercial use at Perry              criteria score.
                                                                                                                       Court Oast. The Abbey School now operates a range of
                                                                                                                       commercial activities and actively promotes itself as a
                                                                                                                       Business and Enterprise College. Adjoining uses would
                                                                                                                       be substantially compatible and this gives an assessment
                                                                                                                       criteria score of 4.




23 September 2009                                                                                                    Page 19 of 52
Ref No.   Consultee Name          Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                            Council's Response



ELR23/3 Simon Curling                                                          10             Land at Perry Court Farm, Faver Site characteristics - Views of the town from the M2 are       These matters will be further assessed via the
                                                                                                                              already affected by the substantial buildings of the main      Local Development Framework, however the
                                                                                                                              Abbey School and recently constructed gymnasium. A             report is right to highlight the potential for
                                                                                                                              well designed high quality commercial development              visual impact. No change.
                                                                                                                              would not significantly alter these views. The site would
                                                                                                                              have low visibility from the A251, as the A251 sits app
                                                                                                                              2.5m below the level of the site which in turn falls away
                                                                                                                              to the west of the A251. An assessment criteria score of
                                                                                                                              4 would be justified.




ELR23/4 Simon Curling                                                          10             Land at Perry Court Farm, Faver Market Attractiveness - This location already adjoins          There has been a consistent approach to most
                                                                                                                              higher quality business uses in Perry Court Oast, the          sites on the periphery of Faversham which the
                                                                                                                              town's largest private sector employers and the small          Council considers accurately reflects the
                                                                                                                              business units at Abbey School which were readily let.         historical absence of land releases in these
                                                                                                                              The Abbey School also undertakes commercial activities         locations. No change.
                                                                                                                              with a restaurant, gymnasium, kindergarten and
                                                                                                                              conference/entertainment facilities in use by the public.
                                                                                                                              They suggest an assessment criteria score of 4.




ELR24/1 Terrafirma Services Ltd                                      General                  Lamberhurst Farm Business Cent Felt that the rural areas should have featured more             See main report.
                                                                                                                             strongly as they do provide valuable commercial
                                                                                                                             facilities. There was also the assumption that they only
                                                                                                                             satisfied a local need and were unlikely to offer
                                                                                                                             expansion possibilities.

                                                                                                                               Conversion and part redevelopment of existing, old farm
                                                                                                                               buildings is what would happen in most cases, however,
                                                                                                                               opportunities to expand some of these sites on adjoining
                                                                                                                               land (particularly where it is owned by the same
                                                                                                                               landowner) and consider more ambitious new
                                                                                                                               developments. They see there site as one which has this
                                                                                                                               potential.

                                                                                                                               They consider their site should be added to the list of new
                                                                                                                               sites. Its close to the A299, excellent access to the M2,
                                                                                                                               Swale and rest of Kent. It has potential for residential
                                                                                                                               development or part development.




23 September 2009                                                                                                           Page 20 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR25/1                    The Crown Estates                          10               Land at Cowstead Corner, nr Qu The Crown Estate owns a significant swathe of land on    Whilst noting the owners aspirations, the
                                                                                                                      the Isle of Sheppey, amounting to some 200ha centred on Council wished to additionally explore the
                                                                                                                      the Neats Court area.                                    potential of the location for employment uses.
                                                                                                                                                                               An option for the Council, if land in the
                                                                                                                      The draft ELR identifies 'Land north of Cowstead Corner' location is required, is to explore the potential
                                                                                                                      as a potential employment site. Approximately 40% of     of either housing or employment or mixed
                                                                                                                      the site falls within the Crown Estate's ownership. They use. No change.
                                                                                                                      would be pleased to accommodate an employment
                                                                                                                      allocation at this location. However wish to highlight
                                                                                                                      two matters:

                                                                                                                        1. They have submitted this site to the SHLAA and
                                                                                                                        envisage that, if developed for housing, could yield up to
                                                                                                                        150 housing units subject to detailed assessment.
                                                                                                                        Housing is likely to be more suitable and would be
                                                                                                                        compatible with existing neighbouring uses. The Crown
                                                                                                                        Estate would prefer to continue to promote the 5.2 ha site
                                                                                                                        for housing if deemed appropriate by the Council and
                                                                                                                        would be pleased to accommodate land for employment
                                                                                                                        purposes without the housing site.




ELR25/2                    The Crown Estates                          10               Land at Cowstead Corner, nr Qu 2. They question the likelihood of the 150 ha site coming Noted, this is presumably a reason why the
                                                                                                                      forward in its entirety, particularly when considering the report refers to the potential of mixed-use as
                                                                                                                      nearby Neats Court employment allocation and the wider the most likely option. NO change.
                                                                                                                      regeneration aspirations at Queenborough and Rushenden.




23 September 2009                                                                                                    Page 21 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                             Council's Response



ELR26/1                    Swan Quay LLP                      5.31/5.3                 Frank and Whittome Site/Land N The review rightly highlights the difficult location of the       Noted. The consultants views are not
                                                                                                                      premises, lying close to a difficult junction with Quay           considered to be significantly at variance to
                                                                                                                      Lane and correctly assesses that the site would be                the view expressed. However, some
                                                                                                                      unlikely to be attractive for redevelopment for larger            amendment is appropriate given the split
                                                                                                                      scale industrial uses, particularly in view of access issues      nature of the site. Also site assessment
                                                                                                                      and proximity to residential areas.                               criteria appears to have been omitted and
                                                                                                                                                                                        should be included in the final version.
                                                                                                                        However, they consider that the remainder of the                Change agreed.
                                                                                                                        Assessment pays little regard to a number of key matters:-

                                                                                                                        The split nature of site between properties lying to the
                                                                                                                        north of Quay Lane, with the reminder of the Frank &
                                                                                                                        Whittome site.

                                                                                                                        The age and generally poor condition of the buildings,
                                                                                                                        rendering them unsuitable for future uses without
                                                                                                                        substantial investment.

                                                                                                                        The split floor space, with many of the buildings being
                                                                                                                        two and three storeys, giving rise to the difficulties
                                                                                                                        servicing and accessing accommodation above ground
                                                                                                                        floor level.

                                                                                                                        The identification of potential creative/cultural industries,
                                                                                                                        in the form of small scale office accommodation or studio
                                                                                                                        workshop space, is made without any realistic assessment
                                                                                                                        of market demand. The report identifies itself the lack of
                                                                                                                        growth within the office sector and Swale as a least
                                                                                                                        preferred location.

                                                                                                                        It also fails to recognise the sub-regional centres such as
                                                                                                                        Canterbury and Maidstone and the Thames Gateway as
                                                                                                                        major competing areas within this field.

                                                                                                                        The review fails to acknowledge these obvious
                                                                                                                        deficiencies, which when combined with the relatively
                                                                                                                        high cost of refurbishment gives rise to the very
                                                                                                                        considerable concerns that an employment based
                                                                                                                        development alone is unviable. Also the creekside
                                                                                                                        regeneration has yet to be agreed and finalised and relies
                                                                                                                        on a number of measure which are not certain of being
                                                                                                                        achievable. This must therefore affect the attractiveness
                                                                                                                        of the area for creative employment uses.

                                                                                                                        They wish to support may of the aims of the Creekside
                                                                                                                        group in fostering a more vibrant creekside area. In
                                                                                                                        seeking to secure this, my clients wish to support the
                                                                                                                        principle of some employment related uses for their sites
                                                                                                                        but that the level of provision should be tempered by the
                                                                                                                        acknowledged lack of demand for employment related
                                                                                                                        uses and the inability of the buildings themselves to offer
                                                                                                                        modern floor space which is easily accessed.

                                                                                                                        They have marketed the buildings since January 2007,
                                                                                                                        this shows the very limited demand for employment

23 September 2009                                                                                                     Page 22 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                           Council's Response


                                                                                                      related floor space, and gives a clear indication that the
                                                                                                      future of the site lies firmly as a mixed use rather than
                                                                                                      solely as an employment site.




23 September 2009                                                                                   Page 23 of 52
Ref No.   Consultee Name   Consultee Company     Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                              Council's Response



ELR27/1                    Quayside Properties                  5.34/5.4                 Standard Quay & Standard Quay The review rightly highlights the difficult location of the        Noted, the consultant will be asked to re-
                                                                                                                       premises with road access problems associated with the             examine their conclusion in respect of
                                                                                                                       need to pass through residential areas and correctly               'proximity to incompatible uses. Potential
                                                                                                                       assesses that the site would be unlikely to be attractive          change.
                                                                                                                       for redevelopment for larger scale industrial uses,
                                                                                                                       particularly in view of access issues and proximity to
                                                                                                                       residential areas.

                                                                                                                          However, they consider that the remainder of the
                                                                                                                          Assessment pays little regard to a number of key matters:-

                                                                                                                          The nature of the buildings on site which require
                                                                                                                          substantial investment to upgrade their facilities for
                                                                                                                          modern day use.

                                                                                                                          The age and generally poor condition of the buildings,
                                                                                                                          rendering them unsuitable for future employment uses
                                                                                                                          which will fail to yield the required sums to secure their
                                                                                                                          long term future.

                                                                                                                          The split floor space, with many of the buildings
                                                                                                                          incapable of meeting the requirements of modern day
                                                                                                                          users.

                                                                                                                          The identification of potential creative/cultural industries,
                                                                                                                          in the form of small scale office accommodation or studio
                                                                                                                          workshop space, is made without any realistic assessment
                                                                                                                          of market demand. The report identifies itself the lack of
                                                                                                                          growth within the office sector and Swale as a least
                                                                                                                          preferred location.

                                                                                                                          It also fails to recognise the sub-regional centres such as
                                                                                                                          Canterbury and Maidstone and the Thames Gateway as
                                                                                                                          major competing areas within this field.

                                                                                                                          The review fails to acknowledge these obvious
                                                                                                                          deficiencies, which when combined with the relatively
                                                                                                                          high cost of refurbishment gives rise to the very
                                                                                                                          considerable concerns that an employment based
                                                                                                                          development alone is unviable. Also the creekside
                                                                                                                          regeneration has yet to be agreed and finalised and relies
                                                                                                                          on a number of measure which are not certain of being
                                                                                                                          achievable. This must therefore affect the attractiveness
                                                                                                                          of the area for creative employment uses.

                                                                                                                          They wish to support may of the aims of the Creekside
                                                                                                                          group in fostering a more vibrant creekside area. In
                                                                                                                          seeking to secure this, my clients wish to support the
                                                                                                                          principle of some employment related uses for their sites
                                                                                                                          but that the level of provision should be tempered by the
                                                                                                                          acknowledged lack of demand for employment related
                                                                                                                          uses and the inability of the buildings themselves to offer
                                                                                                                          modern floor space which is easily accessed.

                                                                                                                          They also suggest that the study should acknowledge the

23 September 2009                                                                                                      Page 24 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                            Council's Response


                                                                                                      potential of other uses to contribute to the long term
                                                                                                      future of the area especially as many of the buildings
                                                                                                      benefit from a retail use.

                                                                                                      Our client welcomes the rough assessment included in the
                                                                                                      document which shows the scoring of both sites to be low
                                                                                                      (14 for both sites) and suggests that these scores on their
                                                                                                      own demonstrate the need to consider high value uses for
                                                                                                      the buildings to overcome these deficiencies. He also
                                                                                                      believes that the assessment has overestimated the score
                                                                                                      for proximity to the urban area and to incompatible uses.




23 September 2009                                                                                   Page 25 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                Summary of comments                                                Council's Response



ELR28/1                    Ordnance Wharf                     5.44                     Creek Basin, Faversham     The review identifies a larger site than in their ownership       Noted, whilst the assessment is unlikely to
                                                                                                                  and the different characteristics of each part of the site        alter significantly, it is agreed that the
                                                                                                                  should be clearly set out as the two areas are entirely           consultant should be requested to re-examine
                                                                                                                  different. Their land is in a difficult location with road        certain assessment criteria. However, as an
                                                                                                                  access problems which would not suit uses generating the          assessment of the current local plan
                                                                                                                  heavy vehicle movements. The review correctly assesses            allocation, it is appropriate to assess the site
                                                                                                                  that the site is heavily constrained by its creek side            as a whole. Potential change.
                                                                                                                  location.

                                                                                                                  However, they consider that the remainder of the
                                                                                                                  assessment pays little regard to a number of key matters:-

                                                                                                                  It fails to give any consideration of issues of poor access
                                                                                                                  to the site for commercial concerns.

                                                                                                                  It fails to take account of the high costs of development
                                                                                                                  of the site, given its location, and the need to strengthen
                                                                                                                  the Creek Walls.

                                                                                                                  It fails to take account of the high costs of
                                                                                                                  decontamination of the site.

                                                                                                                  They welcome the acceptance that the site is a
                                                                                                                  sustainable location, in close proximity to a range of local
                                                                                                                  service and facilities, and also the recognition that it is
                                                                                                                  very narrow and somewhat constrained by its creekside
                                                                                                                  location. However, none of these factors appear to have
                                                                                                                  impacted as the site is proposed for employment uses.

                                                                                                                  They are concerned about the lack of any real assessment
                                                                                                                  of the requirements of potential users which have been
                                                                                                                  identified (boat workshops and repair facilities, studio
                                                                                                                  office space and creative/cultural industries). The failure
                                                                                                                  to accept that the site is totally unsuited to these uses is of
                                                                                                                  fundamental concern, and we require that this site is
                                                                                                                  excluded from the ELR.

                                                                                                                  The identification of potential creative/cultural industries,
                                                                                                                  in the form of small scale office accommodation or studio
                                                                                                                  workshop space, boat repair workshops etc is made
                                                                                                                  without any realistic assessment of market demand or
                                                                                                                  competition from other sites in a better creek side
                                                                                                                  location.

                                                                                                                  It also fails to recognise the sub-regional centres such as
                                                                                                                  Canterbury and Maidstone and the Thames Gateway as
                                                                                                                  major competing areas within this field.

                                                                                                                  It is considered that the review, and more particularly the
                                                                                                                  assessment of their site fails to acknowledge these
                                                                                                                  obvious deficiencies, which when combined with the
                                                                                                                  relatively high cost of refurbishment gives rise to the very
                                                                                                                  considerable concerns that an employment based
                                                                                                                  development is unviable. It should also be acknowledged
                                                                                                                  that the aspirations for the creek side regeneration has yet

23 September 2009                                                                                               Page 26 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                             Council's Response


                                                                                                                                 to be agreed and finalised and relies on a number of
                                                                                                                                 measures which are not certain of being achievable. This
                                                                                                                                 must therefore affect the attractiveness of the area for
                                                                                                                                 creative employment uses and generate the need to look
                                                                                                                                 at the widest range of uses for the site and in particular
                                                                                                                                 those which may generate the higher values.

                                                                                                                                 They are concerned that the scoring of the Creek Basin
                                                                                                                                 incorrectly scores his site as it looks at a larger land
                                                                                                                                 parcel. He suggests that the separate appraisal for his site
                                                                                                                                 along would rate Ordnance Wharf with a low score which
                                                                                                                                 would demonstrate its lack of attractiveness for
                                                                                                                                 employment development.




ELR29/1                    HBC Engineering Solutions                          5                Power Station Road, Halfway Ho Whilst the site and the adjoining site has been given a           The site has already been assessed as the
                                                                                                                              relatively low rating in terms of the scoring against the         lowest scoring site on Sheppey. It is difficult
                                                                                                                              identified Key Criteria, they feel that the total score of 16     to see how the assessment criteria could be
                                                                                                                              is still somewhat over-rated, given the constraints of the        further adjusted. No change.
                                                                                                                              site and in particular, the conflict with the immediately
                                                                                                                              adjacent, relatively new, residential development.




ELR29/2                    HBC Engineering Solutions                  5.58                     Power Station Road, Halfway Ho Clause 5.58 clearly acknowledges that this is a lower             Noted no change.
                                                                                                                              quality site for employment uses and that other forms of
                                                                                                                              development, including residential, could be considered
                                                                                                                              if the site became available for redevelopment.




ELR29/3                    HBC Engineering Solutions                  5.58    5                Power Station Road, Halfway Ho As previously indicated, the case for the re-designation of       The site has already been assessed as the
                                                                                                                              surplus employment land on the site to that for potential         lowest scoring site on Sheppey. It is difficult
                                                                                                                              residential development has been clearly stated in                to see how the assessment criteria could be
                                                                                                                              discussions with Officers and Members of Swale                    further adjusted. No change.
                                                                                                                              Borough Council and, indeed, have received some
                                                                                                                              support in this regard.

                                                                                                                                 They respectfully request that the consultants give further
                                                                                                                                 consideration to the observations and scoring allocated to
                                                                                                                                 the site and that they are made aware of the ongoing
                                                                                                                                 discussions and reasons for the proposed residential
                                                                                                                                 allocation of the surplus land at Power Station Road.




23 September 2009                                                                                                             Page 27 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                             Council's Response



ELR3/1    Keith Fuell                                                 9.0                      Expansion of Kent Science Park I feel that the proposed expansion will lead to excessive         Noted, these are not matters for the
                                                                                                                              traffic on the surrounding roads especially those through         Employment land Review, rather the Local
                                                                                                                              Bredgar and Oad Street unless a link to the M2 is                 Development Framework. No change.
                                                                                                                              included in the proposal. We have just spent a large
                                                                                                                              amount of money trying to introduce traffic calming in
                                                                                                                              the village and the limited effect that it is having will be
                                                                                                                              lost when the amount of traffic using the very narrow
                                                                                                                              lanes is increased.

                                                                                                                                 I also feel that the industrial expansion will lead to the
                                                                                                                                 development of housing towards Rodmersham and
                                                                                                                                 Bapchild as previously proposed. The justification being
                                                                                                                                 that if the workers live close to the site they will not add
                                                                                                                                 to the traffic. This is nonsense because they will not only
                                                                                                                                 travel between home and work but will make journeys to
                                                                                                                                 schools, shopping etc.




ELR30/1                    Owners of Bayview Farm, P                  10.20                    Bayview Farm, Painters Forstall They believe that this site does warrant a specific         See main report.
                                                                                                                               allocation because it is in a reasonably sized village from
                                                                                                                               within which some labour supply may well be available.
                                                                                                                               The site could also provide employment for people based
                                                                                                                               in nearby villages such as Eastling, Newnham,
                                                                                                                               Doddington and Sheldwich who could otherwise be
                                                                                                                               travelling further to Faversham or elsewhere to work, and
                                                                                                                               there is still demand for small scale rurally based offices
                                                                                                                               and workshops. They therefore ask the Council to give
                                                                                                                               this site a specific allocation in the forthcoming LDF.




ELR31/1                    FloPlast                                           10               Floplast depot                    This site has been submitted to the SHLAA. Given the           Noted, however as an existing employment
                                                                                                                                 location and the restrictions on the Floplast Depot site,      location it is appropriate for assessment via
                                                                                                                                 the future of the property is more appropriate for             the Employment Land Review. No change.
                                                                                                                                 residential development.




ELR31/2                    FloPlast                                           10               Floplast depot                    Strategic Access - The rating of 4 seems particularly      The scoring is considered consistent with
                                                                                                                                 high. Access to the A249 via Iwade to commercial,          other site assessed by their proximity to the
                                                                                                                                 particularly articulated, vehicles is difficult, unadvised A249. No change.
                                                                                                                                 and obstructive in terms of traffic calming. Commercial
                                                                                                                                 vehicles being prohibited over 7.5 tonnes. The only other
                                                                                                                                 and principal commercial vehicle access passes through
                                                                                                                                 Bobbing village including its primary school and village
                                                                                                                                 hall. It is congested at school times and, hence the
                                                                                                                                 obvious conflict with any intensification of commercial
                                                                                                                                 vehicle movements.




23 September 2009                                                                                                             Page 28 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name        Summary of comments                                          Council's Response



ELR31/3                    FloPlast                                   10               Floplast depot     Local Road Access - The above observations apply, a          The scoring is considered consistent with
                                                                                                          score of 3 against this criteria again appearing overstated. other similar sites. No change.




ELR31/4                    FloPlast                                   10               Floplast depot     Proximity to Urban Areas - they concur with the rating of Noted.
                                                                                                          1 against this criteria, the site being more appropriate for
                                                                                                          residential development.




ELR31/5                    FloPlast                                   10               Floplast depot     Proximity to Incompatible Uses - a score of 4 out of 5      Noted, the overall rating for the site has
                                                                                                          seems not to have fully taken into account the              already been judged as being of poor quality
                                                                                                          relationship of the site to its immediate surroundings.     which appears reasonable. No change.
                                                                                                          Adjoining residential properties place operational
                                                                                                          constraints in terms of hours of working etc, with
                                                                                                          business development having been resisted on the
                                                                                                          immediately adjoining farmland.




ELR31/6                    FloPlast                                   10               Floplast depot     Site Characteristics and Development Criteria - There is a The site score is considered to adequately
                                                                                                          restrictive planning use for the manufacture, storage and reflect these prospective limitations. No
                                                                                                          distribution of plastic building products with further site change.
                                                                                                          restrictions relating to movement/operations on part of
                                                                                                          the site at weekend and evenings/nights. Floplast have
                                                                                                          been able to accommodate these restrictions within their
                                                                                                          current operation of the site, this would not necessarily be
                                                                                                          the case for a future occupier or in relation to the
                                                                                                          redevelopment of the site for Employment use which
                                                                                                          would require a full open B1, B2 and B8 consent.




ELR31/7                    FloPlast                                   10               Floplast depot     Market Attractiveness - Our clients have kept the            The site score is considered to adequately
                                                                                                          property in reasonable condition and appearance and that reflect these prospective limitations. No
                                                                                                          the current operation is relatively low profile, this is due change.
                                                                                                          to how FloPlast have been able to adjust their local
                                                                                                          operation to work within the constraints of the site. They
                                                                                                          have no longer term requirement for the site once further
                                                                                                          expansion has taken place on additional land acquired
                                                                                                          adjoining their main headquarters/manufacturing facility
                                                                                                          on Eurolink and any future use of the site is likely to be
                                                                                                          more intensive, with increased traffic movements. The
                                                                                                          buildings have been kept in good condition but are very
                                                                                                          much first generation and unsuitable for modern
                                                                                                          industrial/distribution needs. The facility was designed
                                                                                                          to accommodate the needs of a single occupier.




23 September 2009                                                                                       Page 29 of 52
Ref No.   Consultee Name   Consultee Company          Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                        Council's Response



ELR32/1                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay It is inconceivable that Four Gun Field is scheduled as a The site should have been assessed as an
                                                                                                                            'potential' employment site when it is already a long      existing employment site. Change agreed.
                                                                                                                            established certified B2 industrial site in current and
                                                                                                                            active use. By definition it cannot be a 'potential new
                                                                                                                            employment site' because it already is an employment site.




ELR32/2                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Current Use - Previously developed land being former         It is agreed that the description should be
                                                                                                                            brickworks. Currently in B2 industrial use. The              amended. Change agreed.
                                                                                                                            photograph alone demonstrates that this is not a
                                                                                                                            'greenfield site'.




ELR32/3                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Strategic Access - Otterham Quay is a good access road       Otterham Quay not part of the strategic road
                                                                                                                            to the A2 within 2 kilometres. Indeed the adjoining          network, access to M2 is 10km. Score
                                                                                                                            industrial estate is served well in addition to Otterham     adequately reflects this.
                                                                                                                            Quay industrial/warehousing area. From the A2 there is
                                                                                                                            main road access to the M2 junction and clearly not a
                                                                                                                            "via narrow road". Score 5.




ELR32/4                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Local Road Access - Otterham Quay Lane is not "a             Delete word 'narrow', however the consultant's
                                                                                                                            narrow partly rural road". Access from Otterham Quay         assessment is considered reasonable. Change
                                                                                                                            Lane to the main A2 road is 10 metres width and in no        agreed.
                                                                                                                            way can e considered narrow. Otterham Quay Road, the
                                                                                                                            access does not pass through any residential area. The
                                                                                                                            site has an industrial access constructed in accordance
                                                                                                                            with planning permission Sw/00/298. Score 5.




ELR32/5                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Proximity to urban areas etc - They manage the adjoining     This site can by no means be judged as
                                                                                                                            Cloverlay Industrial Estate and it is proven to be popular   'ideally located', as services are limited,
                                                                                                                            to businesses and tenant alike with a 100% occupation        however its proximity to labour is reflected in
                                                                                                                            rate. By adjoining the Medway Towns with good road           the score given. No change.
                                                                                                                            access via the A2 and the B2004 Lower Rainham Road
                                                                                                                            together with the local bus service and close to a
                                                                                                                            significant labour force within walking distance, the site
                                                                                                                            is well located and sustainable. It is accordingly ideally
                                                                                                                            located. Score 5.




23 September 2009                                                                                                           Page 30 of 52
Ref No.   Consultee Name   Consultee Company          Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                        Council's Response



ELR32/6                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Market Attractiveness - A high volume of traffic passes      Whilst the locality is acknowledged to have
                                                                                                                            the site which uses the Lower Rainham Road as an             its niche attractions, within the context of
                                                                                                                            alternative to the London A2 as well as to Otterham Quay     overall market attractiveness, the consultants
                                                                                                                            industrial/warehousing area. This site has a high profile    judgment is considered reasonable. No
                                                                                                                            location having a long frontage to Otterham Quay Lane        change.
                                                                                                                            which serves as a local distributor and therefore its
                                                                                                                            market profile is high, now low. Indeed this is
                                                                                                                            demonstrated by the 100% occupation rate of the nearby
                                                                                                                            Cloverlay Industrial Park. It is an established
                                                                                                                            employment location and its attractiveness is clearly
                                                                                                                            demonstrated by the high demand for the existing limited
                                                                                                                            "open" use. Score 5.




ELR32/7                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Planning/Sustainability factors - the Cloverlay Industrial   As this site is to be assess as an existing
                                                                                                                            Estate has met many significant local business needs and     employment site, this criteria will not be
                                                                                                                            the demand for open industrial use of this site confirms.    assessed and no amendment in response to
                                                                                                                            It was zoned by Medway Council for employment use            these points can be made. No change.
                                                                                                                            and its location is obviously not remote. The industrial
                                                                                                                            nature of the site is confirmed by the grant of planning
                                                                                                                            permission for the new industrial access and by the issue
                                                                                                                            of Certificates of Lawful Use for industry by both Swale
                                                                                                                            Borough Council and by the Secretary of State. It is
                                                                                                                            difficult to think of a more sustainable employment
                                                                                                                            location. Score 5.




ELR32/8                    Owners of Four Gun Field                          10               Four Gun Field, Otterham Quay Four Gun Field scores better than any of the other sites     The site is to be assessed as an existing
                                                                                                                            considered and should be formerly zoned as employment        employment site. The Employment Land
                                                                                                                            site.                                                        Review will therefore guide the Council in
                                                                                                                                                                                         respect of whether it remains fit for that
                                                                                                                                                                                         purpose. It's release for other uses would be a
                                                                                                                                                                                         matter for the planning process. No change.




23 September 2009                                                                                                           Page 31 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                             Council's Response



ELR33/1                    Owners of Land at Rodmers                  Omissio                  Land at Rodmersham Green, Sitti They object to their site at Rodmersham Green,                 See main report.
                                                                                                                               Sittingbourne being omitted from the ELR.

                                                                                                                               Site this has current two planning permissions, one for
                                                                                                                               manufacture, storage and distribution of chestnut fencing
                                                                                                                               but will cease on 1st June 2009. The other for the use of
                                                                                                                               manufacture, storage and distribution of eco-friendly
                                                                                                                               coffins. The applicants rejected this site in favour of
                                                                                                                               another local site and the use has not been and certainly
                                                                                                                               will not be implemented.

                                                                                                                               Both sites have restricted uses for which there is no
                                                                                                                               demand, they are preventing from utilizing these
                                                                                                                               premises for commercial use.

                                                                                                                               The site has proved quite capable of coping with full B1
                                                                                                                               and B8 use from the use of manufacture storage and
                                                                                                                               distribution of chestnut fencing. The rapidly shrinking
                                                                                                                               market for chestnut fencing products has rendered this
                                                                                                                               use unsustainable on this site, and the business is being
                                                                                                                               merged with others on a more modern and larger site
                                                                                                                               elsewhere.

                                                                                                                               In the absence of B1 and B8 use for this site, it will be
                                                                                                                               impossible to let or sell the site for commercial use and it
                                                                                                                               will become a brown field site suitable for housing.
                                                                                                                               Perhaps this would be the Council's preferred route.

                                                                                                                               They feel that this site should be granted the benefit of
                                                                                                                               full B1 and B8 use, subject to such conditions as might
                                                                                                                               be required by the Council.

                                                                                                                               Note: Plan attached to rep.




23 September 2009                                                                                                            Page 32 of 52
Ref No.   Consultee Name   Consultee Company             Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                              Council's Response



ELR34/1 Henry Holdstock    George Webb Finn                             Omissio                  Land at Macknade Garden Centr They object to their site at Macknade Garden Centre,               The Employment Land Review would have
                                                                                                                               Canterbury Road, Faversham being excluded from the                 only examined existing sites falling within
                                                                                                                               ELR.                                                               one of the B classes.

                                                                                                                                  The site is 0.3 hectares and is surrounded by existing
                                                                                                                                  employment use land with the filling station to the north
                                                                                                                                  (on the other side of the A2), The Macknade Farm site to
                                                                                                                                  the east and Reads Restaurant to the west and has so far
                                                                                                                                  not been considered suitable for residential use.

                                                                                                                                  The site is also adjacent to an allocated site as referred to
                                                                                                                                  in paragraph 5.72 on page 44.

                                                                                                                                  They feel that this fulfils the criteria outlined in your
                                                                                                                                  draft ELR, and would provide a useful roadside site for
                                                                                                                                  employment use.

                                                                                                                                  Plan of site attached to rep.




ELR35/1                    South Eastern Healthcare Lt                  Omissio                  Land at Ruins Barn Road (The ol They object to their site at Ruins Barn Road (the Old Sale See main report.
                                                                                                                                 Field), Sittingbourne not be included in the ELR.

                                                                                                                                  South Eastern Healthcare together with other medical
                                                                                                                                  service providers which to provide a purpose built facility
                                                                                                                                  consisting a Medical Health Centre, retirement
                                                                                                                                  bungalows and flats, private rooms with facilities for the
                                                                                                                                  elderly, and both social and nursing care facilities,
                                                                                                                                  together with town house style residences for key
                                                                                                                                  workers on site and for other key workers as required by
                                                                                                                                  SBC together with a pharmacy.

                                                                                                                                  Sittingbourne is very short of general practice doctors,
                                                                                                                                  and there are no medical facilities on the south side of
                                                                                                                                  town and none within 1 mile of this site.

                                                                                                                                  They feel that for an employment site use such as
                                                                                                                                  outlined above, this site is ideally suited and the medical
                                                                                                                                  service providers seem to agree.

                                                                                                                                  Note: Plan attached to rep.




23 September 2009                                                                                                              Page 33 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                              Council's Response



ELR36/1 Ian Kemsley        I Kemsley Farms Ltd                        Omissio                  Hooks Hole Farm, Chestnut Stre They object to their site at Hooks Hole Farm, Chestnut           See main report.
                                                                                                                              Street, Sittingbourne not being included in the ELR.

                                                                                                                               They put forward this site for B1 and B8 use. It includes
                                                                                                                               a large building which is partly already in employment
                                                                                                                               use by a local scaffolding company. It is will located in
                                                                                                                               relation to strategic road access. i.e. A249 as well as local
                                                                                                                               road access, close to labour supply in Sittingbourne,
                                                                                                                               accessible by public transport, does not adjoin any
                                                                                                                               sensitive uses and has no significant development
                                                                                                                               constraints.

                                                                                                                               Note; Plan attached to rep.




ELR37/1                    Owners of Conyer Brickwor                  Omissio                  Conyer Brickworks, Conyer       They object to their site Conyer Brickworks not being           This site is not an existing employment site.
                                                                                                                               included in the ELR.                                            Its previously development land status is not
                                                                                                                                                                                               relevant to this consideration. No change.
                                                                                                                               The consultants draft survey fails to identify Conyer
                                                                                                                               Brickworks despite there being no change in the state of
                                                                                                                               the land since the 2003 NLUD survey that identified the
                                                                                                                               same or the last NLUD survey in 2007.

                                                                                                                               The long accepted status of the brickworks land already
                                                                                                                               identified is compliant with the PPS3 "previously
                                                                                                                               developed land" definition. That is conceded by the
                                                                                                                               subsequent 2007 NLUD survey (PPS3 is 2006).

                                                                                                                               To exclude this site is clearly an oversight and needs to
                                                                                                                               be corrected.

                                                                                                                               Note: Attached to the rep is the full NLUD survey 2007.
                                                                                                                               The part that refers to Conyer Brickworks was printed out.




ELR38/1                    Blakedew 736 Limited                                 5      5.3     Oare Road Industrial Estate     The site benefits from extant planning permission for           The site has been assessed as part of a large
                                                                                                                               DIY retail and industrial use, as approved in April 2006        existing employment area and as such the
                                                                                                                               (SW/05/1491). In approving the scheme, the committee            consultants views are considered reasonable,
                                                                                                                               did not consider the loss of employment land as an issue.       although it is acknowledged that quality may
                                                                                                                               The committee report noted that the site is "clearly of         vary in certain parts. However, the
                                                                                                                               poor utility for modern employment uses, and the scheme         assessment score for this area has been
                                                                                                                               itself will support additional employment". It should be        omitted and needs to be included. Change
                                                                                                                               noted that retail use on the site will generate significantly   agreed.
                                                                                                                               higher employment number than employment use.




23 September 2009                                                                                                            Page 34 of 52
Ref No.   Consultee Name   Consultee Company      Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                         Council's Response



ELR38/2                    Blakedew 736 Limited                          5        5.3     Oare Road Industrial Estate     The site has remained vacant for a number of years and      Noted, however the consultants overall
                                                                                                                          has been marketed consistently for industrial employment judgments for this area are considered
                                                                                                                          uses since 2004 with very little interest shown from        reasonable. No change.
                                                                                                                          prospective occupiers. Availability of other, higher
                                                                                                                          quality industrial land in the vicinity, as well as in
                                                                                                                          Sittingbourne, has lead to this site remaining vacant, with
                                                                                                                          speculative industrial development highly unlikely at this
                                                                                                                          secondary industrial location.




ELR38/3                    Blakedew 736 Limited                          5        5.3     Oare Road Industrial Estate     The document identifies a significant surplus of            See main report.
                                                                                                                          employment land within the Borough. The surplus
                                                                                                                          identified ranges between 409,700 sqm (75ha) and
                                                                                                                          219,700sqm (28ha) surplus employment floorspace by
                                                                                                                          2026, depending on the low and high demand growth
                                                                                                                          projections. Given this surplus, the document proposes
                                                                                                                          release of potential poorly performing sites for other non-
                                                                                                                          employment uses.




ELR38/4                    Blakedew 736 Limited                          5        5.3     Oare Road Industrial Estate     The site does not form part of the Oare Road Industrial    The site forms a natural block of employment
                                                                                                                          Estate as suggested in the document. The site has          uses. No change.
                                                                                                                          separate access from Bysing Wood Road, rather than the
                                                                                                                          Western Link, and does not contain large warehouses of
                                                                                                                          modern construction as the rest of the industrial park.
                                                                                                                          The site is separate in character and function from the
                                                                                                                          distribution warehouses present on the Oare Road
                                                                                                                          Industrial Estate.




ELR38/5                    Blakedew 736 Limited                          5        5.3     Oare Road Industrial Estate     The site is demonstrably a poorly performing               The Employment land Review post dates
                                                                                                                          employment site, as has been previously accepted by        previous consideration of the site. No Change.
                                                                                                                          Swale Borough Council, and given the above comments,
                                                                                                                          should not be considered as part of the proposed Oare
                                                                                                                          Road Industrial Estate allocation.




23 September 2009                                                                                                       Page 35 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                           Council's Response



ELR39/1 Mandy Bearne       Locate in Kent                     General                                 Locate in Kent feels that greater growth potential is      Noted. See also main report.
                                                                                                      required if a step change in the local economy and market
                                                                                                      demand is to be achieved. There is a need proactively
                                                                                                      improve the image of Swale and Sittingbourne as a
                                                                                                      business location. Currently no activity is carried out in
                                                                                                      this respect and a presentation made by Locate in Kent to
                                                                                                      Council officers and Members as well as private sector
                                                                                                      companies demonstrated why this was the case and how
                                                                                                      it could be done. This was not acted upon. Activities
                                                                                                      carried out in other areas show that demand from
                                                                                                      companies can be created and that this can make a very
                                                                                                      positive contribution to the local economy.




ELR39/2 Mandy Bearne       Locate in Kent                     General                                 Ability to compete with surrounding areas                    Noted. See also main report.

                                                                                                      Maidstone, Medway and Ashford currently and in the
                                                                                                      future compete with Swale/Sittingbourne particularly for
                                                                                                      offices. these areas are forging ahead due to growth point
                                                                                                      status, major regeneration investment, and private
                                                                                                      investment respectively. Sittingbourne in particular loses
                                                                                                      out to these areas in terms of investment in employment,
                                                                                                      retail, housing and leisure investment. If Swale does not
                                                                                                      allocate sufficient quality land for all uses particularly
                                                                                                      offices, and promote the area, the gulf between these
                                                                                                      areas and Sittingbourne will continue to grow.




ELR39/3 Mandy Bearne       Locate in Kent                     General                                 Preferred level of employment land provision                 Noted. See also main report.

                                                                                                      In our view and with our knowledge of local sites, the
                                                                                                      ELR significantly under estimates the potential loss of
                                                                                                      current employment land to housing. As a result we feel
                                                                                                      the preferred level of employment land provision is too
                                                                                                      low since it does not seem to take account of competition
                                                                                                      from surrounding areas, planned losses of employment
                                                                                                      land or the need to effect a step change in employment
                                                                                                      provision. Neither does it take account of PPS4
                                                                                                      (December 2007) which elevates the role of economic
                                                                                                      development within a local authority and encourages
                                                                                                      them to act proactively in fostering entrepreneurship,
                                                                                                      employment, innovation, investment, competition, skills,
                                                                                                      creativity, competitiveness etc in order to raise the
                                                                                                      productivity of the local and hence UK economy. These
                                                                                                      conclusions are supported intuitively and by the main
                                                                                                      players in the business property market in the area.




23 September 2009                                                                                   Page 36 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                             Council's Response



ELR39/4 Mandy Bearne       Locate in Kent                     9.0                      Expansion of Kent Science Park Over recent years there has been a lack of new, quality    Noted no change.
                                                                                                                      office accommodation in Swale. Before the Watermark
                                                                                                                      park was built, Kent Science Park was often the only
                                                                                                                      option, and for science or other knowledge based
                                                                                                                      companies it was clearly the only option. KSP is the only
                                                                                                                      science park in Kent and is the best that Kent has to
                                                                                                                      offer. As a result Swale has attracted and continues to
                                                                                                                      attract quality science and increasingly environmental
                                                                                                                      technology companies and quality jobs that would
                                                                                                                      otherwise probably have been lost to Kent and certainly
                                                                                                                      to Swale. The Park's popularity and suitability for high
                                                                                                                      tech companies was illustrated by the quick letting of the
                                                                                                                      technology units recently built there where other
                                                                                                                      commercial property in Kent was slow to let.




ELR39/5 Mandy Bearne       Locate in Kent                     9.0                      Expansion of Kent Science Park KSP offers the main means by which much needed high Noted no change
                                                                                                                      quality jobs can be attracted to Swale, including from
                                                                                                                      overseas companies - eg Esai who shortlisted KSP as one
                                                                                                                      of their two preferred locations. KSP lost out mainly
                                                                                                                      because of uncertainties around the future and future
                                                                                                                      access arrangements.

                                                                                                                       The sectors which KSP attracts are growing sectors
                                                                                                                       which offer high quality jobs and are those outline in the
                                                                                                                       ELR as those which Swale aspires to attract.

                                                                                                                       The attraction of new companies to KSP will help grow
                                                                                                                       the cluster that attracts other companies to the Park and to
                                                                                                                       Kent.

                                                                                                                       This is the only science park/science cluster offering
                                                                                                                       Kent has.

                                                                                                                       the Park offers everything these companies need
                                                                                                                       including other similar companies and unlimited
                                                                                                                       broadband as well as FE training facilities tailored to
                                                                                                                       their needs.

                                                                                                                       More companies may assist the Park in extending the
                                                                                                                       further/higher education offer in Swale.




23 September 2009                                                                                                   Page 37 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                           Council's Response



ELR4/1    Pam Watts        Sweeep Ltd                                 10               Land Fronting Milton Creek, Gas We currently recycle most of the electronic waste from       These concerns are noted, but cannot be
                                                                                                                       London, Kent, Sussex, Essex, Herts, and part Oxford and      addressed as part of the Employment Land
                                                                                                                       Dorset. Our recovery rate is 97% and we are considered       Review. The writer is encouraged to contact
                                                                                                                       the industry leader. We are also an award winning            the Council's Project Officer for Sittingbourne
                                                                                                                       company                                                      Town Centre regeneration. No change.
                                                                                                                       We operate under the strict provisions of our Waste
                                                                                                                       Management License and are controlled by the
                                                                                                                       Environment Agency

                                                                                                                       I understand the area around Milton Creek has been
                                                                                                                       zoned for residential use which at the moment I am not
                                                                                                                       concerned about as I assume this is many years off.
                                                                                                                       However please understand in your review of
                                                                                                                       employment land the seriousness of Sweeep having to
                                                                                                                       relocate, which includes the following issues:

                                                                                                                       We are the major processing facility in the south east
                                                                                                                       providing this service. Alternatives would mean
                                                                                                                       transporting waste electronics over greater distances for
                                                                                                                       processing, defeating the concept of reducing carbon
                                                                                                                       emission and increasing the cost. Remember we are
                                                                                                                       recycling most of electronic waste produced in the south
                                                                                                                       east. This would be very difficult to replace

                                                                                                                       Alternative sites suitable for this operation are few and
                                                                                                                       far between. We need proximity to the motorway
                                                                                                                       network, operate outside normal hours and must comply
                                                                                                                       with the provisions of a Waste Management License
                                                                                                                       which is site specific and requires a lot of investment to
                                                                                                                       reach the standards required to protect the environment.

                                                                                                                       We have invested heavily in the plant we use to process
                                                                                                                       and this could not easily nor economically be relocated.

                                                                                                                       Most of our workforce arrive on foot or by train,
                                                                                                                       therefore we need to be near the centre of town

                                                                                                                       Clearly we would be unwilling to consider voluntary
                                                                                                                       relocation given the difficulty in finding suitable
                                                                                                                       alternative sites, the cost to the business and the
                                                                                                                       disruption . 110 people are employed here and their
                                                                                                                       livelihoods depend on us.

                                                                                                                       We would appreciate assurances that we will be able to
                                                                                                                       continue our operation at this site and that there are no
                                                                                                                       plans to pursue residential development of this area in
                                                                                                                       even the medium term




23 September 2009                                                                                                   Page 38 of 52
Ref No.   Consultee Name   Consultee Company           Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                          Council's Response



ELR40/1                    Laselle Investment Manage                  General                                                    General comments about growth & step change,             See response to other representations and
                                                                                                                                 Maidstone, PPS4, (see other representations). Additional main report.
                                                                                                                                 comments on these issues below.




ELR40/1                    Laselle Investment Manage                  4.17                     Expansion of Kent Science Park Whilst low rental levels may be seen as a competitive          The consultant will be asked to review this
                                                                                                                              advantage, there is a need to drive up yields if there is to   point.
                                                                                                                              be new property investment.




ELR40/1                    Laselle Investment Manage                  5.71                     Expansion of Kent Science Park Draws attention to a number of errors/omissions                The consultant will be asked to review these
                                                                                                                                                                                             points.




ELR40/1                    Laselle Investment Manage                  5.80                     Expansion of Kent Science Park Class B1(c) should be added                                    Change agreed




ELR40/1                    Laselle Investment Manage                  5.82                     Expansion of Kent Science Park Omissions highlighted in table 5.7 for Kent Science Park       The consultant will be asked to review these
                                                                                                                                                                                             points.




ELR40/1                    Laselle Investment Manage                  7.29                     Expansion of Kent Science Park Support                                                        Noted. No Change.




ELR40/1                    Laselle Investment Manage                  7.31                     Expansion of Kent Science Park Consider the effects of 'off shoring' likely to be limited     Noted. No change.




ELR40/2                    Laselle Investment Manage                  11.34                    Expansion of Kent Science Park Need to add to the list in this paragraph, the need to         A reference to image could be included in the
                                                                                                                              proactively improve the image of Swale and                     3rd bullet. Change agreed.
                                                                                                                              Sittingbourne as a business location.




ELR40/3                    Laselle Investment Manage                  8.0                      Expansion of Kent Science Park Kent Science Park floorspace figures should be separate This will be reflected in the final report.
                                                                                                                              from general provision. This is not always the case in the Change agreed.
                                                                                                                              Employment Land Review. Kent Science Park figures
                                                                                                                              should be in addition to the need for additional general
                                                                                                                              increases.




23 September 2009                                                                                                             Page 39 of 52
Ref No.   Consultee Name              Consultee Company           Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                         Council's Response



ELR40/4                               Laselle Investment Manage                  9.23 &                   Expansion of Kent Science Park Comments made in respect of implications of constrained The consultant will be asked to review the
                                                                                                                                         growth, future role of Kent Science Park, growth sectors, Kent Science Park section in section 9.0.
                                                                                                                                         expansion/redevelopment within the existing fence,
                                                                                                                                         floorspace density, vacancy rate, start up space, multi site
                                                                                                                                         modal, gateway policy, M2 junction, LDF, image, Kent
                                                                                                                                         Science Park Economic Impact Assessment, PPS1.




ELR40/5                               Laselle Investment Manage                  2.3                      Expansion of Kent Science Park Comments about 12,000 planned jobs is misleading and         This issue is subject to a separate piece of
                                                                                                                                         arbitrary.                                                   work and the final report will need to reflect
                                                                                                                                                                                                      it. Change agreed.




ELR40/6                               Laselle Investment Manage                  2.5                      Expansion of Kent Science Park Omission of reference to Kent Science Resource Centre        Change agreed.
                                                                                                                                         in providing for courses and a foundation degree at Kent
                                                                                                                                         Science Park.




ELR40/7                               Laselle Investment Manage                  2.12                     Expansion of Kent Science Parkq Planning reduction in housing provision to 2026 should      The paragraph refers to recent trends. No
                                                                                                                                          be recognised.                                              change.




ELR40/8                               Laselle Investment Manage                  2.37                     Expansion of Kent Science Park Kent Science Park is probably not the only location for      Changes agreed.
                                                                                                                                         wet laboratories in Kent, but is the largest concentration
                                                                                                                                         for rent in the South East. Also the potential of Kent
                                                                                                                                         Science Park to attract Foreign Direct Investment should
                                                                                                                                         be mentioned.




ELR40/9                               Laselle Investment Manage                  2.88                     Expansion of Kent Science Park Support                                                      Noted.




ELR41/1 Various Clients, see list i                                              11.3                                                      Job estimate of 12,000 jobs is not based on rigorous       Noted. The question of job numbers has been
                                                                                                                                           assessment of evidence.                                    the subject of other research and this will be
                                                                                                                                                                                                      incorporated into the final report or published
                                                                                                                                                                                                      separately. (See also main report). Change
                                                                                                                                                                                                      agreed




23 September 2009                                                                                                                       Page 40 of 52
Ref No.   Consultee Name              Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                            Council's Response



ELR41/2 Various Clients, see list i                                      7.44                                    Despite seeking a step change in provision, the report        See main report. However, in respect of
                                                                                                                 acknowledges that none will be achieved in the level of       office provision this is based on the
                                                                                                                 office provision. Greater growth potential is required if a   consultants assessment of that sectors likely
                                                                                                                 step change is to be achieved.                                future contribution in Swale. No Change.




ELR41/3 Various Clients, see list i                                      3.40                                    Maidstone is the main competitor for                          Para 3.40 acknowledges the Maidstone threat.
                                                                                                                 Swale/Sittingbourne not Ashford. Maidstone has                As such no change is needed. However, the
                                                                                                                 embraced growth agenda for housing and employment in          'step change' point is considered in the main
                                                                                                                 contrast to Sittingbourne. This does not bode well unless     report.
                                                                                                                 there is a 'step change'.




ELR41/4 Various Clients, see list i                                      General                                 PPS4 should be built into any revised document.               The consultants will be asked to review, but
                                                                                                                                                                               this is likely to be a factual update. Change
                                                                                                                                                                               agreed.




ELR41/5 Various Clients, see list i                                      8.0                                     The Employment Land Review incorporates a natural             See main report.
                                                                                                                 replacement allowance of 1% and a safety margin of
                                                                                                                 25%, but the fundamental quantum is significantly
                                                                                                                 understated.




ELR41/6 Various Clients, see list i                                      8.0                                     Cannot reconcile employment land supply figures with         The consultant's figures will be checked,
                                                                                                                 factual inaccuracies and that intuitively the figures of 366 however, see also main report.
                                                                                                                 ha net of employment land is much too large.




ELR41/7 Various Clients, see list i                                      5.24                                    Due to errors and changes the figures for                     The consultant's figures will be checked,
                                                                                                                 Ridham/Kemsley are not correct. Available land is 31ha        however see also main report.
                                                                                                                 not 135.




ELR41/8 Various Clients, see list i                                      General                                 Between 100 - 120 ha of land will be lost to housing.     See main report
                                                                                                                 Planned loss should be made good. Represents a double
                                                                                                                 whammy ie. employment land and jobs would be lost and
                                                                                                                 insufficient attempts made to replace them. Specifically
                                                                                                                 it is considered that about 200 ha should be added to the
                                                                                                                 requirement.




23 September 2009                                                                                              Page 41 of 52
Ref No.   Consultee Name   Consultee Company              Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR42/1                    E J Mackelden & Sons                                                   Land off Sheppey Way, Bobbing In respect of Land off Sheppey Way, Bobbing, given              See main report
                                                                                                                                conclusions of the Employment Land Review, this site
                                                                                                                                (not originally included in the Employment Land
                                                                                                                                Review) should be considered for employment.




ELR43/1                    F D Attwood & Partners                                                 Land at Duke of Kent junction, L Sites commended within context of general comments           Noted. No Change.
                                                                                                                                   made.




ELR44/1                    Mr S C Batt                                   10.28                    Land at Neatscourt/Cowstead Co The reference to use classes in paragraph differs to that in This will be checked. Potential change.
                                                                                                                                 table 10.3. The latter is correct.




ELR44/2                    Mr S C Batt                                   10.28                    Land at Neatscourt/Cowstead Co Although planning permission was refused for an                Whilst noting these views, these are not
                                                                                                                                 agricultural access, the decision indicated that it would      judged to materially affect the sites overall
                                                                                                                                 have been granted for an access to an appropriate service      scoring. However the specific access point
                                                                                                                                 are for the travelling public. Development at Neatscourt       will be checked and amended if appropriate.
                                                                                                                                 is now underway and allocation would be a logical              Change agreed.
                                                                                                                                 rounding off. Its immediate availability enhances its
                                                                                                                                 score.




ELR45/1                    Fletcher Challenge Forest In                                           Land south of Kemsley Mill       Site is incorrectly plotted and excludes SNCI.               This will be corrected. Change agreed.




ELR45/2                    Fletcher Challenge Forest In                                           Land south of Kemsley Mill       The Local Plan inspector did not reject the site on visual   The 'doubts' expressed by the Inspector on
                                                                                                                                   impact rather the lack of need for its release               these issues indicate concerns even if they
                                                                                                                                                                                                were not central to his decision. No Change.




ELR45/3                    Fletcher Challenge Forest In                  10.6                     Land south of Kemsley Mill       Concerning impact on residential amenity site is over        Whilst noting the views, the consultants views
                                                                                                                                   200m from housing, until such time as a noise study          reflect likely market perceptions. Visual
                                                                                                                                   indicates that B2 would be unsuitable it should not be       impacts will be further reassessed by
                                                                                                                                   ruled out. Topography is likely to limit the use of small    landscape studies, whilst the Employment
                                                                                                                                   scale buildings and uses. Issues can be addressed by         Land Review does not refer to limiting the site
                                                                                                                                   design.                                                      to B1 uses. The Employment Land Review
                                                                                                                                                                                                acknowledges that the site is reasonable, but
                                                                                                                                                                                                its comments about its relative merits to
                                                                                                                                                                                                others is relevant. However, the comments in
                                                                                                                                                                                                the latter part of the final sentence of
                                                                                                                                                                                                paragraph 10.6 may need re-assessment. No
                                                                                                                                                                                                Change.




23 September 2009                                                                                                               Page 42 of 52
Ref No.   Consultee Name   Consultee Company              Support Object Para No. App No. Plan No. Site Name                     Summary of comments                                            Council's Response



ELR45/4                    Fletcher Challenge Forest In                  10.6                     Land south of Kemsley Mill      Proposed extension to countrypark outweighs impacts.          These are matters for the LDF. No Change.




ELR45/5                    Fletcher Challenge Forest In                  10.6                     Land south of Kemsley Mill      Factual update required to reflect changes as a result of     These will be acknowledged. Change Agreed.
                                                                                                                                  the commencement of the Sittingbourne Northern Relief
                                                                                                                                  Road.




ELR46/1                    G H Dean & Co                                 General                  Land at Great Grovehurst Farm a In the light of the general comments on land supply, these Noted. No Change.
                                                                                                                                  sites are commended.




ELR47/1 Natalie Wells      Barton Willmore                               General                                                  Potential site do not accord with adopted criteria of the     In response to individual points, the Council
                                                                                                                                  South East Plan ie:                                           would respond as follows:
                                                                                                                                  1) Greenfield land before exploiting potential of existing    1) The review has examined sites in both
                                                                                                                                  urban employment land;                                        urban and greenfield context;
                                                                                                                                  2) Existing consents and the potential of future              2) Existing consents and the Borough's
                                                                                                                                  redevelopment areas (Milton Creek) are not explored;          relationship with adjacent areas is examined.
                                                                                                                                  3) Location close to the mainline rail links and Northern     The consultants will be asked to examine the
                                                                                                                                  Relief Road are not explored;                                 implications of the recent Kingsnorth consent.
                                                                                                                                  4) The South East Plan requires avoidance of                  3) The review has examined potential in
                                                                                                                                  coalescence between Sittingbourne and settlements to          these locations;
                                                                                                                                  west, it is not given regard;                                 4) The South East Plan only requires
                                                                                                                                  5) The need to diversify its service and science sectors is   avoidance of co-alescence between
                                                                                                                                  given little credence.                                        Sittingbourne and Medway. In any event,
                                                                                                                                  6) Regard should be given to other evidence eg. Strategic     these are matters for the Local Development
                                                                                                                                  Flood Risk Assessment.                                        Framework not the Employment Land Review;
                                                                                                                                                                                                5) The Employment Land Review explores
                                                                                                                                                                                                the potential of the service sector and
                                                                                                                                                                                                concludes that its potential is modest. With
                                                                                                                                                                                                respect to science, the Kent Science Park is
                                                                                                                                                                                                discussed at some length. It is difficult to see
                                                                                                                                                                                                how this can be viewed as not giving the issue
                                                                                                                                                                                                credence.
                                                                                                                                                                                                6) Noted.
                                                                                                                                                                                                No change.




23 September 2009                                                                                                              Page 43 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR47/2 Natalie Wells      Barton Willmore                    General                                                   Small scale offices can easily be accommodated into          The Employment Land Review already
                                                                                                                        mixed use activities in urban context and that more work     concludes that office provision can be made in
                                                                                                                        should be undertaken to explore these sectors before         such areas. Recommendations for greenfield
                                                                                                                        greenfield land is explored.                                 sites are made on the basis of a review of
                                                                                                                                                                                     future trends and employment potential. The
                                                                                                                                                                                     future product cannot be provided wholly on
                                                                                                                                                                                     brownfield land and the RSS specifically
                                                                                                                                                                                     acknowledges that greenfield land will be
                                                                                                                                                                                     required. No change.




ELR47/3 Natalie Wells      Barton Willmore                    General                                                   Consideration should be given to recent consents that are These consents have been taken into account.
                                                                                                                        unimplemented. E.g. Watermark, Eurolink 4 and             The consultation will be asked to examine the
                                                                                                                        Kingsnorth.                                               Kingsnorth consent. No change.




ELR47/4 Natalie Wells      Barton Willmore                                             Land off Northern Relief Road a The sites lie outside of the settlement boundary, within      No justification is given as to why scores
                                                                                                                       the allocated Strategic Gap. Demand for the proposed          should be down-graded. Other matters fall
                                                                                                                       uses of B1, B2, B8 are questionable and not in                outside the scope of the Employment Land
                                                                                                                       accordance with the aspirations of the South East Plan for    Review. No change.
                                                                                                                       the reasons set out above.

                                                                                                                        A landscape character assessment is yet to be completed
                                                                                                                        and should be referred to in any future considerations.
                                                                                                                        This is acknowledged in the Review as a significant
                                                                                                                        material consideration weighing against the future
                                                                                                                        allocation of the sites for employment use (paragraphs
                                                                                                                        10.9 and 10.10). It is considered that the scores graded
                                                                                                                        for its proximity to incompatible uses, market
                                                                                                                        attractiveness, sustainability and development constraints
                                                                                                                        should be downgraded to 1, this would give a lower
                                                                                                                        overall total (approx 14 and 15 respectively) - in
                                                                                                                        conclusion, both sides are therefore classified
                                                                                                                        average/poor. This conclusion should be incorporated in
                                                                                                                        table 10.1.




23 September 2009                                                                                                    Page 44 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                             Council's Response



ELR47/5 Natalie Wells      Barton Willmore                                             Land at Pheasant Farm East, Bob The sites lie outside of the settlement boundary, within         No justification is given as to why scores
                                                                                                                       the allocated Strategic Gap. Demand for the proposed             should be down-graded. Other matters fall
                                                                                                                       uses of B1, B2, B8 are questionable and not in                   outside the scope of the Employment Land
                                                                                                                       accordance with the aspirations of the South East Plan for       Review. No change.
                                                                                                                       the reasons set out above.

                                                                                                                        A landscape character assessment is yet to be completed
                                                                                                                        and should be referred to in any future considerations.
                                                                                                                        Furthermore the assessment criteria identify significant
                                                                                                                        access issues which are as yet unaddressed, furthermore
                                                                                                                        the sites lie adjacent to existing residential development
                                                                                                                        with significant amenity impact considerations. These
                                                                                                                        are acknowledged in the Review as significant material
                                                                                                                        considerations weighing against the future allocation of
                                                                                                                        the sites for employment use (paragraphs 10.8 and
                                                                                                                        10.11). It is considered that the scores graded for its local
                                                                                                                        road access, proximity to incompatible uses, market
                                                                                                                        attractiveness, sustainability and development constraints
                                                                                                                        should all be downgraded to 1, this would give a lower
                                                                                                                        overall total (approx 15 and 11) - in conclusion sites are
                                                                                                                        therefore classified as poor sites. This conclusion should
                                                                                                                        be incorporated in table 10.1.




ELR47/6 Natalie Wells      Barton Willmore                                             Land at Pheasant Farm West, Bo It is considered that this site should not be considered for      No justification is given as to why scores
                                                                                                                      future allocation. It is located within the strategic gap         should be down-graded. Other matters full
                                                                                                                      and in an acknowledged unsustainable location. It is              outside the scope of the Employment Land
                                                                                                                      therefore of poor suitability for future employment               Review.
                                                                                                                      development. It is also subject to all of the
                                                                                                                      considerations set out for sites 1-4 above. This location
                                                                                                                      is well within the strategic gap and breeches the natural
                                                                                                                      boundary which the A249 offers. Consideration of
                                                                                                                      allocation of this site is not in accordance with the Local
                                                                                                                      Plan or the South East Plan.

                                                                                                                        Again, a landscape character assessment is yet to be
                                                                                                                        completed and should be referred to in any future
                                                                                                                        considerations. These are acknowledged in the Review
                                                                                                                        as significant material considerations weighing against
                                                                                                                        the future allocations of the site for employment use
                                                                                                                        (paragraph 10.42). It is considered that the scores graded
                                                                                                                        for its local road access, proximity to incompatible uses,
                                                                                                                        market attractiveness, sustainability and development
                                                                                                                        constraints should all be downgraded to 1, this would
                                                                                                                        give an overall total of far less (approx 10) - in
                                                                                                                        conclusion, a poor site. This conclusion should be
                                                                                                                        incorporated in table 10.4.




23 September 2009                                                                                                     Page 45 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name                Summary of comments                                            Council's Response



ELR48/1                    Vinson Trust                       General                  Land at Lady Dane Farm     Draws attention to errors due to confusion between this       Noted. The consultant will be asked to check
                                                                                                                  site and adjacent Attwood Trust site e.g. land is in single   this. Potential change.
                                                                                                                  ownership and not adjacent by the A2 and farmland.




ELR48/2                    Vinson Trust                       11                       Land at Lady Dane Farm     Trust supports many overall conclusions on Swale's            Noted. No change.
                                                                                                                  potential to attract more firms if more speculative sites
                                                                                                                  are available and that it should also seek to raise the
                                                                                                                  quality of employment space. The proposed site at Lady
                                                                                                                  Dane Farm supports these conclusions.




ELR48/3                    Vinson Trust                       11.20                    Land at Lady Dane Farm     Trust supports conclusions on need for further land at        Noted.
                                                                                                                  Faversham and considers that Lady Dane Farm is ideally
                                                                                                                  suited.




ELR48/4                    Vinson Trust                       10.11                    Land at Lady Dane Farm     States that figures in F3.7 reflect outdated material.        Whilst this may be so, this appears not to be
                                                                                                                  Proposal could include 8.5ha of employment space, 6.5         reflected in the illustrative material provided.
                                                                                                                  ha housing and 11ha of landscaping.                           No change.




ELR48/5                    Vinson Trust                                                Land at Lady Dane Farm     Draws attention to a schedule of factual errors judged to     Whilst noting the factual points which can be
                                                                                                                  affect overall scoring.                                       addressed, these are not judged to affect
                                                                                                                                                                                overall scoring. No change.




ELR49/1                    Asda Stores Ltd                    General                                             Asda notes the Borough has a modest retail offer and is As the writer notes, the Employment Land
                                                                                                                  under-represented. Moderately high retail growth should Review does not address non - 'B' class
                                                                                                                  be expected to provide Swale with provision consistent  employment generating uses. No change.
                                                                                                                  with surrounding Boroughs.




ELR49/2                    Asda Stores Ltd                    General                                             Asda notes the Employment Land Reviews conclusion             This is in contrast with the views of most
                                                                                                                  that there is a substantial provision of employment land      other observations. These are addressed in
                                                                                                                  that results in an oversupply when compared with              the main report. The Employment Land
                                                                                                                  demand. Flexible policies to change away from non-            Review has reviewed all employment sites
                                                                                                                  strategic employment sites should be brought forward,         and made appropriate responses. No change
                                                                                                                  having reviewed, and where appropriate, released sites.       (but also see main report).




23 September 2009                                                                                               Page 46 of 52
Ref No.   Consultee Name    Consultee Company          Support Object Para No. App No. Plan No. Site Name                   Summary of comments                                                Council's Response



ELR5/1    David Wilkinson                                                       10             Land at Kent Science Park     I am righting to lodge my strong objection to Swale               Noted. No change.
                                                                                                                             Borough Council proposing to use the land opposite our
                                                                                                                             home as "Land for Employment" in particular the land
                                                                                                                             between the M2 and Bexon Lane, Bredgar

                                                                                                                             It is wrongly described as "Land at Kent Science Park",
                                                                                                                             when it does not belong to them, it is farmland and
                                                                                                                             countryside. I believe the Council's description has been
                                                                                                                             purposely done to mislead the public into thinking that
                                                                                                                             the Science Park already owns that land.

                                                                                                                             There is no need to destroy our countryside and good
                                                                                                                             agricultural land to create industrial estates when 25% of
                                                                                                                             the Science Park is unused and a lot of it is misused e.g.
                                                                                                                             call centres do not need to be in a Science Park.

                                                                                                                             I think it is typically sly of the council to not let the
                                                                                                                             people nearby know about this and give only a few weeks
                                                                                                                             to make any comments. It was only a member of my local
                                                                                                                             Parish Council who bought it to my attention.




ELR50/1                     Hillreed Land Ltd                         8.39                                                   Although related to Brogdale, the writer raises general           See main report. However, it is not envisaged
                                                                                                                             issues concerning the rural area in that the review               that there would be a conflict with current
                                                                                                                             proposes no allocations at all; proposing a suitably              Local Plan policy as this would potentially be
                                                                                                                             worded policy to address the issue. Large rural sites are         replaced via the Local Development
                                                                                                                             considered by the report (Painters Forstall, Danaway              Framework. The Core Strategy will not be
                                                                                                                             Cold Stores), but no rural allocations are proposed. They         able to make allocations on small areas such
                                                                                                                             consider that there is no realistic possibility that a criteria   as this. Whilst the possibility of a future site
                                                                                                                             based policy would be anything other than restrictive as,         allocations DPD has yet to be resolved, it is
                                                                                                                             in the case of Brogdale, it would set rules that failed to be     clear that Government expects Councils to
                                                                                                                             site specific. This would be a problem as the Council has         produce a Core Strategy that is capable of
                                                                                                                             not included an allocations DPD in the Local                      addressing many of the issues needing to be
                                                                                                                             Development Scheme. Its approach is contrary to RSS               addressed.
                                                                                                                             Policy RE3 and emerging PPS4. Request that a site
                                                                                                                             specific policy for Brogdale be maintained with use of
                                                                                                                             development brief.




ELR51/1                     Trenport Investments Ltd                  General                                                Well researched.                                                  Noted. No change.




ELR51/1                     Trenport Investments Ltd                  10.47                                                  Highlights the inconsistent inclusion of sites from across        This will be reviewed with the consultant and
                                                                                                                             the Borough in table 10.5 which shows the geographical            corrected as necessary. Potential change
                                                                                                                             distribution of 'better quality potential sites'.                 agreed.




23 September 2009                                                                                                          Page 47 of 52
Ref No.   Consultee Name   Consultee Company          Support Object Para No. App No. Plan No. Site Name    Summary of comments                                         Council's Response



ELR51/1                    Trenport Investments Ltd                  General                                 Concludes by highlighting merits of additional allocation Noted.
                                                                                                             at East Hall Farm.




ELR51/2                    Trenport Investments Ltd                  General                                 Only limited reference to national and regional planning   The consultant will include an annex to this
                                                                                                             policies                                                   effect and provide a statement that they have
                                                                                                                                                                        taken them into account. Change agreed.




ELR51/3                    Trenport Investments Ltd                  4.9                                     Supports references in paragraphs 4.9 and 5.22 in respect Noted. No change.
                                                                                                             of Eurolink.




ELR51/4                    Trenport Investments Ltd                            5                             Questions the low score for local road access              The views reflect the position at the time of
                                                                                                                                                                        writing, but comments are noted. No change.




ELR51/5                    Trenport Investments Ltd                  8.42                                    Supports references to 8.12, 8.25 and 8.42                 Noted. No change




ELR51/6                    Trenport Investments Ltd                  10.5                                    Supports 10.5                                              Noted no change




ELR51/7                    Trenport Investments Ltd                            10                            Questions assumption concerning ecology, flooding and      Whilst detailed studies can potentially address
                                                                                                             highways.                                                  site constraints, the consultants overall
                                                                                                                                                                        assessment is reasonable and indeed the site
                                                                                                                                                                        represents one of the highest scoring. No
                                                                                                                                                                        change.




ELR51/8                    Trenport Investments Ltd                            10                            Highlights inconsistencies in Appendix 10 scores as        This issue appears to affect a number of sites.
                                                                                                             apposed to those in the main report.                       The consultant will be asked to review.
                                                                                                                                                                        Change agreed.




ELR51/9                    Trenport Investments Ltd                            10                            Highlights differences between scores for Eurolink IV      It is considered that the differences reflect the
                                                                                                             and potential new area.                                    circumstances where the new site requires
                                                                                                                                                                        new access and is closer to constraints. No
                                                                                                                                                                        change.




23 September 2009                                                                                          Page 48 of 52
Ref No.   Consultee Name    Consultee Company           Support Object Para No. App No. Plan No. Site Name                      Summary of comments                                           Council's Response



ELR52/1                     Owner of Mayfield, London                                           Land at Mayfield, London Rd, T Seeks inclusion of land adjacent Mayfield, London Rd,          See main report
                                                                                                                               Teynham in the Employment Land Review.




ELR53/2 Ian Butter          Rural Urban Planning                                                Site at Harts Park, Leysdown     Proposes part of site at Harts Park (submitted also to the   See main report
                                                                                                                                 SHLAA) for 12,000 sqft of B1 development. Seeks
                                                                                                                                 inclusion in the final Employment Land Review.




ELR6/1    Paul Summerbell   Christopher Harris                         General                                                   Rethink the rigid planning attitudes of the Council          The Employment Land Review does not
                                                                                                                                 towards applications for change of use for buildings         address retail matters, however comments are
                                                                                                                                 already in existence in the High Street locally.             noted. No change.

                                                                                                                                 Those premises exclusively ring fenced for retail use are
                                                                                                                                 constantly opening and closing with the inherent
                                                                                                                                 downtrodden look that they give the High Street with
                                                                                                                                 whitened windows and the recessionary feel that they
                                                                                                                                 generate whilst those service industries of long standing
                                                                                                                                 that are withstanding much that the recession throws at
                                                                                                                                 them are struggling to find affordable High Street
                                                                                                                                 premises from which they can operate and provide
                                                                                                                                 employment and wealth for the local communities.

                                                                                                                                 Whether the wish is to purchase or to lease High Street
                                                                                                                                 property the service industry is being ignored and it is
                                                                                                                                 these small to medium sized business’ that provide much
                                                                                                                                 of the wealth upon which this nations foundations have
                                                                                                                                 been built yet the planners and Councils seek to frustrate
                                                                                                                                 them at every turn no matter how much such business’s
                                                                                                                                 seek to survive the recession.

                                                                                                                                 The large scale plans and ambitions for the area are
                                                                                                                                 misplaced and have been for a number of years.




ELR7/1    Attwood Trust                                                General                                                   The study clearly supports what the Attwood Trust has        Noted, although as to whether the
                                                                                                                                 said in its previous representations on the Local Plan.      Employment Land Review supports previous
                                                                                                                                 The Borough performs poorly in terms of employment           views of this writer is not necessarily the case
                                                                                                                                 outputs with a narrow employment base focused on the         in terms of the recommended
                                                                                                                                 manufacturing sector and is not an attractive place to       response/recommendations from the
                                                                                                                                 invest in employment infrastructure. The study correctly     consultants. The writer's interpretation of the
                                                                                                                                 identifies Swale's most favoured employment sites being      office market is not fully shared. The report
                                                                                                                                 concentrated in Sittingbourne and Faversham and lastly       highlights the overall relatively limited
                                                                                                                                 Sheppey. Neither Sittingbourne nor Faversham are seen        potential for Swale, but it sees potential at
                                                                                                                                 as strong office locations.                                  both Sittingbourne and Faversham never the
                                                                                                                                                                                              less. No change.




23 September 2009                                                                                                              Page 49 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                          Council's Response



ELR7/10                    Attwood Trust                      10.15                                   The site area of the land referred to in paragraph 10.15 of This will be checked. Change agreed.
                                                                                                      the study is wrongly stated as 27 ha.s when in fact it is
                                                                                                      67.5 ha.s.




ELR7/11                    Attwood Trust                      11.3                                    The report also recognises that certain site in Faversham   Noted. No change.
                                                                                                      perform so poorly that they should be considered for
                                                                                                      release for redevelopment totallling an area of 2.8 ha.




ELR7/2    Attwood Trust                                       5.27                                    So far as Faversham is concerned the report recognises    Noted. No change.
                                                                                                      that land to the east of Love Lane has ready access onto
                                                                                                      the M2 and redevelopment of the 3.9ha. site north of
                                                                                                      Graveney Road and the adjoining allocated site of 2ha,
                                                                                                      has a good potential to provide new employment space.
                                                                                                      The Attwood Trust also have their land interest to the
                                                                                                      east of the town, which as you know, has in the past been
                                                                                                      promoted for employment use.




ELR7/3    Attwood Trust                                       5.43                                    So far as Faversham is concerned the report recognises    Noted. No change.
                                                                                                      that land to the east of Love Lane has ready access onto
                                                                                                      the M2 and redevelopment of the 3.9ha. site north of
                                                                                                      Graveney Road and the adjoining allocated site of 2ha,
                                                                                                      has a good potential to provide new employment space.
                                                                                                      The Attwood Trust also have their land interest to the
                                                                                                      east of the town, which as you know, has in the past been
                                                                                                      promoted for employment use.




ELR7/4                     Attwood Trust                      5.42                                    The report recognises that Faversham town centre            The Employment Land Review does not
                                                                                                      employment sites are constrained by poor road access. It    recommend its release and notes the role that
                                                                                                      is doubtful whether the largest employment allocation in    hope value for higher value uses plays and the
                                                                                                      Faversham at the Western Link (8.3ha) will ever come        need for a more pro-active public sector
                                                                                                      forward as an employment site and the emerging LDF          response. No change.
                                                                                                      should recognise this and make up the deficit with an
                                                                                                      alternative location. The Study comments on the
                                                                                                      situation in paragraphs 5.42 and 5.87




23 September 2009                                                                                   Page 50 of 52
Ref No.   Consultee Name   Consultee Company   Support Object Para No. App No. Plan No. Site Name    Summary of comments                                            Council's Response



ELR7/5                     Attwood Trust                      5.87                                    The report recognises that Faversham town centre              The Employment Land Review does not
                                                                                                      employment sites are constrained by poor road access. It      recommend its release and notes the role that
                                                                                                      is doubtful whether the largest employment allocation in      hope value for higher value uses plays and the
                                                                                                      Faversham at the Western Link (8.3ha) will ever come          need for a more pro-active public sector
                                                                                                      forward as an employment site and the emerging LDF            response. No change.
                                                                                                      should recognise this and make up the deficit with an
                                                                                                      alternative location. The Study comments on the
                                                                                                      situation in paragraphs 5.42 and 5.87.




ELR7/6                     Attwood Trust                      2.35                                    What is not made clear in the study as far as Faversham is    Whilst the report does not provide more
                                                                                                      concerned is that unsustainable level of out commuting        localised out-commuting figures, its statement
                                                                                                      from the town, 55% (see topic paper 3 to Local Plan           about the areas self-containment is relevant,
                                                                                                      Inquiry) whereas the Study quotes a Borough wide figure       indeed it being higher than many other areas.
                                                                                                      of 33% (para 2.35). It is quite clear that any reduction in   It notes that many work only in adjoining
                                                                                                      this trend, which should be an objective, requires more       Boroughs and is particularly the case at
                                                                                                      employment floorspace at Faversham.                           Faversham - a situation not unusual for a
                                                                                                                                                                    small market town. No change.




ELR7/7                     Attwood Trust                      8.26                                    The insertion at para 8.26, that a further industrial         The consultants view is based upon its
                                                                                                      allocation of 5 ha is sufficient, seems to owe more to the    assessment methodology taking into account
                                                                                                      preferred Borough Council approach (8.26)m then to            both its considered view on Faversham's
                                                                                                      addressing the reality of the problems faced by               employment market and its role in the sub-
                                                                                                      Faversham.                                                    regions. No change.




ELR7/8                     Attwood Trust                      7.5                                     To make the necessary step change to Swale's                  The issue of junction 7 needs further
                                                                                                      employment base, attractive sites, well related to the        investigation as it is unclear as to what scale
                                                                                                      transport network are required. In this respect we support    of development would trigger the need for
                                                                                                      the study's conclusion at para 10.15 that the Attwood site    junction improvements. If a smaller scale of
                                                                                                      is one of the better located sites around Faversham with      development failed to trigger a junction
                                                                                                      few development constraints. This advantage was               improvement the dynamics of development in
                                                                                                      canvassed in the site's favour when being promoted at the     this location could change. The consultants
                                                                                                      Local Plan Inquiry. The Study refers to the cost of           views will be sought. Potential change.
                                                                                                      improving Junction 7 of the M2 as ruling out a small
                                                                                                      development and suggests the site has the potential for
                                                                                                      mixed use, something the Attwood Trust supports.




23 September 2009                                                                                   Page 51 of 52
Ref No.   Consultee Name           Consultee Company   Support Object Para No. App No. Plan No. Site Name                       Summary of comments                                          Council's Response



ELR7/9                             Attwood Trust                      10.15                                                     To make the necessary step change to Swale's                 The issue of junction 7 needs further
                                                                                                                                employment base, attractive sites, well related to the       investigation as it is unclear as to what scale
                                                                                                                                transport network are required. In this respect we support   of development would trigger the need for
                                                                                                                                the study's conclusion at para 10.15 that the Attwood site   junction improvements. If a smaller scale of
                                                                                                                                is one of the better located sites around Faversham with     development failed to trigger a junction
                                                                                                                                few development constraints. This advantage was              improvement the dynamics of development in
                                                                                                                                canvassed in the site's favour when being promoted at the    this location could change. The consultants
                                                                                                                                Local Plan Inquiry. The Study refers to the cost of          views will be sought. Potential change.
                                                                                                                                improving Junction 7 of the M2 as ruling out a small
                                                                                                                                development and suggests the site has the potential for
                                                                                                                                mixed use, something the Attwood Trust supports.




ELR8/1    Gary & Valerie Pilcher                                      9.0                      Expansion of the Kent Science P It makes no sense in a time of recession to be proposing      Noted no change
                                                                                                                               such excessive developments in the hope of gaining
                                                                                                                               further potential employment in Sittingbourne at the
                                                                                                                               expense of the environment.

                                                                                                                                There are numerous developments and most of the new
                                                                                                                                builds seem to be still empty awaiting future potential
                                                                                                                                companies, given the current economy are becoming
                                                                                                                                rarer and rarer.

                                                                                                                                The destruction of a peaceful and tranquil area. The
                                                                                                                                decimation of a remote agricultural landscape.




ELR8/2    Gary & Valerie Pilcher                                      9.0                      Expansion of the Kent Science P Accidents will go up as the current staff at the science      Noted no change
                                                                                                                               park treat the local roads as a high speed rate run, which
                                                                                                                               with hundreds if not thousands more workers would
                                                                                                                               continue to get worse.




ELR9/1    John and Lin Stevens                                        9.0                      Expansion of the Kent Science P The land adjacent to the M2 and Bexon Lane is                 Noted no change
                                                                                                                               agricultural land and should remain fit for this purpose
                                                                                                                               only. As you are aware this land is situated in an area of
                                                                                                                               outstanding natural beauty and all such areas covered in
                                                                                                                               this category should remain green to protect the land for
                                                                                                                               future generations. The country lands in this area are
                                                                                                                               already overloaded with large industrial vehicles and
                                                                                                                               there has been substantially damage to the verges and
                                                                                                                               hedgerows as a result. The lanes are constantly used by
                                                                                                                               cars travelling to and from the Kent Science Park
                                                                                                                               destroying the tranquility and peace of the countryside
                                                                                                                               for all to enjoy. We very much appose this proposal.




23 September 2009                                                                                                             Page 52 of 52

				
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