Submission on Behalf of the Rutland Group (No.342) re Session 2 – Economic Development Question 1a Rutland are clear that the Plan will be unsound if it fails to indicate clearly how the shortfall of 90,000 sq.m. of offices will be made up. The West Area contains at least one strategically significant office location at Bedfont Lakes and other land nearby that could contribute to meeting the shortfall. The West Area, which will remain strategically significant for at least the life of the Local Plan, should be identified as the location for a major part of the 90,000 sq.m., just as it has been identified as the likely location of 4500 dwellings. A proportion of the office floorspace could be provided on the Great West Road. Question 1b Rutland consider that there should be a target of 90,000 sq.m. which should be apportioned between the West Area and the Great West Road. Question 1c The target proposed against Q1b should be matched by an appropriate monitoring target. Question 1f The Employment Land Review (ELR) recognises clearly that there are two distinct office markets in Hounslow: one for Grade A offices which are occupied by nationally and internationally trading and mobile firms, which is met in the out of centre business parks and one for more local occupiers which is met mainly in the town centres. (ELR paras 8.2.2-8.2.7). The existence of these two markets lies at the heart of the apparent conflict between Policy ED1 and town centre policies. NPPF recognises that these circumstances may arise (para 23, bullets 7 and 8) and provides for the Local Plan to “set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.” The need for offices located outside town centres has been recognised in the ELR: they provide a choice of locations for firms which themselves have choices over where they locate and they enable Hounslow to be competitive in the market for mobile firms which tend to trade nationally and internationally, at least beyond purely local markets. The Local Plan should provide expressly for such offices, recognising that many firms will not locate in town centres and that they will go elsewhere, in London or further afield, if their requirements are not met within Hounslow. The Plan should also support the provision of services, hotels, catering and some retail, to complement such uses; on certain terms, housing might also be an appropriate complement. Question 1g Rutland is of the view that small-scale offices in out-of-centre locations are inappropriate, unjustified and unlikely to be effective: small firms thrive on the proximity of supporting services such as are found in town centres, not only shops and catering but also other small firms with whom they may network or trade for mutual benefit. Rutland have seen no evidence in support of locating small firms outside town centres. No provision need be made. Question 1h Incubator space is rarely if ever viable in new development. The Workspace Group, which has developed about 100 business centres for small firms within the M25, does not develop new premises for small firms; all its premises are conversions and adaptations of existing premises. Not only is the development of new premises for small firms not viable financially, small firms also flourish on different lease or licence terms from those typically offered in a larger office development: short and flexible leases or licences are the norm for small firms. Mixing this type of tenant and the covenant they provide (or not) with more conventional larger tenants will also make the funding of the development more difficult. Incubator units pose further challenges in that they are designed for start-up businesses, which have a high rate of failure and require intensive (and expensive) management. Rutland suggest strongly that the Plan should not provide for incubator units to be developed within office developments; they are unjustified and will not be efffective. Policy ED2 - Maintaining the Borough’s Employment Land Supply Question 2a Rutland do not think the location and scale of additional office development is sufficiently clear for the Plan to be effective. There is no indication of how or where the requirement for 90,000 sq.m. will be accommodated. Question 2b The question is one for the local planning authority to answer. However Rutland wish to stress the importance of sites or locations for office development being identified: Hounslow is very well located to attract major firms active in leading sectors in national and international markets, but only if premises can be delivered immediately they are required; that means that sites need to be identified in the Local Plan (or the proposed Partial Review of the Local Plan). Rutland suggest that the Local Plan set out the broad amounts of office floorspace, for which each of the West Area and Great West Road plans should identify sites. Question 2c Whatever further examples are provided, it is important that each of them be defined, depending on local circumstances, in a manner that provides space for new development. Bedfont Lakes business park is fully developed but there is land nearby that could be suitable, subject to evaluation through the proposed West Area Plan, for further commercial development. This will enable the Plan to be positively prepared. Question 2e The question hints that there may be ambiguity between town centre and office location policies, an ambiguity which could be a cause of considerable delay when office development proposals are brought forward for decision. In order to avoid such ambiguity, Rutland suggest that express provision be made for out-of –town office development, using the provision in NPPF (para 23, bullets 7 and 8), which has been spelt out in Rutland’s response to Question 1f above. The evidence that firms located in out-of-town office developments, such as Bedfont Lakes, are an important and distinctive feature of the Hounslow economy is very clear and the Local Plan provides a critical opportunity to enable the Borough to continue being competitive in this market. If the ambiguity remains, it risks making the Plan ineffective and inconsistent with national policy. Question 2g “necessary level of expansion and intensification”, as Rutland have asserted in their Reps, are unduly limiting terms. “Necessary” begs the question of necessary against what criteria, judged by whom. And “expansion and intensification” are selected elements of the development process, with no justification of why those elements of the process were selected. Rutland suggest that the word “development” be used in place of the whole phrase. There is no justification for a limiting definition and the ambiguity implicit in the current wording will lead to costly delay in the future, costly for the economy of Hounslow and costly for the participants in the development process. The identified phrase undermines the notion that the Plan should be positively prepared and risks making it ineffective. Question 2o Rutland support the notion that ancillary uses of appropriate scale should be allowed and provided for within the Local Plan on sites allocated for office use, especially where they are outside town centres. On the Great West Road much effort has been expended over the last ten years to improve access for firms and their staff to shops and services such as catering and hospitality. This has taken the form of either firms providing services on their premises (e.g. the Street in GSK’s HQ) or improved access to the services of Brentford town centre (e.g. the canal towpath linking the Great West Road with the High Street). Whilst nowhere in Hounslow is very far from a town centre, there is a place for making office locations more sustainable and more competitive by including services in their development. For the avoidance of doubt acceptance of ancillary uses in office locations should be made explicit. Question 4a The provisions in Policy ED4 are not consistent with NPPF unless use is made in the Local Plan of the provision in NPPF para 23 bullets 7 and 8, which has been set out in Rutland’s response to Q 1f. Rutland have suggested that provision for out-of-town-centre offices should be made in response to Question 2e above. The same approach should be applied to hotels i.e. an explicit provision in the Local Plan. It might apply to certain types of hotel e.g. those above a certain size (number of bedrooms) those with major conference facilities or those particularly targeting the business market.