Cardiff Local Development Plan 2006 – 2026 Hearing Session

10: Economy, Employment & Retail Matters & Issues

Hearing Statement by

Barton Willmore for

Cardiff Gate International Business Park

January 2015

3. Delivery of Employment Land

a) What evidence is there to support the viability of mixed-use sites – will they be delivered?

No comment.

b) Should a phasing policy be introduced to integrate infrastructure

requirements and to ensure that the most sustainable sites are brought forward first?

No comment.

4. Is the scale of employment allocations proposed supported by the

Plan strategy?

c) Does the Plan provide an adequate numerical and geographical correlation between employment land supply and housing provision?

The plan appears to provide a large surplus of employment land particularly for office floorspace. This was set out in our original representations to the Deposit LDP.

The most up-to-date available information from the Council is contained within the Cardiff Employment Land Study by DTZ (2011) which details the employment land requirements and existing supply within Cardiff to 2026. In overall terms, the Deposit LDP seeks to deliver 40,000 new jobs over the Plan period, which the LDP translates into specific requirements for B1, B2 and B8 floorspace, taking into account that employment will be delivered within non-business use classes (i.e. retail, leisure etc). Through this approach, the Deposit LDP identifies (Background Topic Paper No 4 Economic, Table 9) a requirement to deliver between 413,500 sqm to 501,200 sqm of B1 office floorspace over the Plan period. In terms of meeting this requirement, the Deposit Plan (Background Topic Paper No 4 Economic, Table 11) identifies the following sources of supply:

Category Office Floorspace sq m a) Existing vacant stock (including a 30% allowance for

un-lettable stock) 45,200

b) Identified land supply 297,800 c) Cardiff Central Enterprise Zone Proposals (Phase 1

new additional supply) 27,900

d) Completions elsewhere within LDP period 56,100 Total 427,000 sq m

21047/A5 1 January 2015

Accordingly, there already exists a surplus of 13,500 sqm (circa 130,500 sq ft) of B1 office

floorspace identified by the Council, which is in excess of the LDP’s identified requirement for B1

office floorspace of 413,500 sq m.

Since publication of the Deposit Plan, it is also relevant to note that there has been additional B1

office development planning permissions and completions within the City Centre Enterprise Zone,

which will have added to this pipeline of B1 office floorspace.

Notable additions include:

• JR Smart at Capital Quarter, with circa 200,000 sq ft (18,581 M2) B1 office

floorspace available or under construction, with permission in total for 700,000 sq

ft (65,032 M2).

• Rightacres at Central Square, with circa 800,000 sq ft of floorspace (74,322 M2).

• Admiral Insurance at Ty Admiral, with 200,000 sq ft where they have relocated

from Capital Tower on Greyfriars Road releasing circa 200,000 sq ft of B1 office

floorspace (18,581 M2).

This outline of B1 office floorspace supply does not make allowance for the additional land likely to

come forward for significant additional areas of B1 office floorspace comprising:

• The Cardiff Central Enterprise Zone which totals circa 55 hectares including Tyndall

Street and Dumballs Road. The Dumballs Road site has identified capacity for

45,000 sqm from the extant outline permission (LPA Ref 07/1637/0C) of May 2011.

• Other brownfield employment sites throughout the City; and

• The refurbishment of existing vacant stock.

Paragraph 4.62 of Technical Paper 4, identifies that having undertaken additional work the Council

have identified a further supply of 75,839 sqm B1 floorspace through existing planning permissions

and S106 agreements (Paragraph 4.62 of Technical Paper 4).

If these additional sources of supply for B1 office floorspace were included there would be a

surplus of 159,253 sqm of B1 office floorspace in excess of the maximum amount of B1 office

floorspace of 501,200 sqm required over the Plan period (Paragraph 4.61 of Technical Paper 4).

Furthermore, this oversupply excludes land presently promoted through the LDP for B1 office

floorspace at St Mellons and Trowbridge. This area has not been included in the total potential

supply of B1 floorspace as it is subject to further evaluation due to flood risk issues. However the

21047/A5 2 January 2015

flood risk issues appear to be resolved (evidence within the LDP Hearing Session Papers), then this

area will deliver significant additional areas of land for the development of B1 office floorspace

within the City compounding the existing over supply.

Finally, the oversupply identified above also excludes B1 office floorspace within the planned

strategic urban extensions to Cardiff, including North East Cardiff immediately adjacent to CGIBP

and at North West Cardiff which includes 15,000sqm of B1 floorspace. These urban extensions

will, as identified by the LDP, include mixed-use areas including B1 office floorspace in order to

deliver sustainable and mixed developments thereby further increasing the oversupply of office

floorspace in Cardiff.

It is therefore evident that the LDP substantially over provides for the amount of B1 office

floorspace required in the City over the Plan period.

We have also analyzed the level of B1 office floorspace available from the Council’s employment

land monitors (Appendix 1 and 2). See below.

Cardiff Supply of Office Floorspace - Existing Stock, Permissions and Land

Site Notes sq ft sq m

Total existing B1 office stock available in Cardiff

Agreed level of stock available in Cardiff by property agents 1,000,000 92,937

Under construction as at July 2013 (latest available council data) (2) As per Council data 516,017 47,957

Unimplemented commitments (detailed permissions) (2) As per Council data 361,902 33,634

Outline permissions (3)

Land Bank monitor reports the following outline permissions (not detailed)

Roath Basin LPA Ref 03/99/C - redevelop former operational port land to create mixed use housing, (1010 units), business (class B1) and commercial, leisure…

The level of B1 office floorspace which is left/deliverable here is not stated in the Council’s monitors (2 and 3).

Land west of Dumballs road

07/01637/C - mixed use regeneration including residential, office, commercial…

484,200

45,000

21047/A5 3 January 2015

Plot E04 Callaghan Square

08/2716/C - outline for the development of 46450 sqm of B1 office floorspace

499,802

46,450

Plots 1 and 3 Pier Head Street

06/2799/C - outline permission for 10,262 sqm of class B1 office floorspace

110,398

10,260

Plot 5 Pier Head Street

05/2747/C - outline permission for 22,994 sqm of class B1 office

247,415

22,994

Plot 6 Pier Head Street

05/2748/C - outline permission for 17,658 sqm of office floorspace

190,000

17,658

Outliner permissions sub total

1,047,614

97,362

New schemes 2014 not included in above

JR Smart Capital Quarter Phase 2

80,000 sq ft - not counted within Capital Quarter detailed permission (unimplemented commitments)

80,000

7,435

E04 Welsh Government - Callahan Square

90,000 sq ft - but accounted for in E04

-

-

Rightacres - Capital Square

135,000

12,546

New schemes 2014 sub total

215,000

19,981

Proposed new LDP Allocations

St Mellons Business Park Extension

Total proposed allocation 96 ha. B1, B2, B8. B1 office floorspace not stated.

The amount of B1 office floorspace is not known, but is likely to be very significant

1M sq ft.

Urban extensions

North West Cardiff Urban Extension

161,400

15,000

Junction 33

96,840

9,000

North East Cardiff

The amount of B1 office floorspace is not known, but is likely to be very

significant 1M sq ft?

Total supply (vacant stock and commitments) - Excludes Land at St Mellons Business Park and North East Cardiff.

3,882,973

360,871

Average 2001-2010 take up rate per year (4)

303,432

28,200

Total supply of office floorspace (Note no allowance been made for floorspace at: Land to South of St Mellons Business Park; South of Roath Dock or North East Cardiff) 8.93

8.93

21047/A5 4 January 2015

Sources:

1 Broadly agreed level of office floorspace available in Cardiff from property agents.

2 Cardiff Business Class Office Development 2013 3 Cardiff Business and Industrial Landbank Monitor 2013 4 Cardiff LDP Appendix para 2.25

Note that the supply excludes the likely B1 office floorspace at Land South of St Mellons Business

Park, South of Roath Dock and the North East Cardiff urban extension.

It is therefore evident that the supply of B1 office floorspace is very considerable and will more

than meet the office floorspace requirements of the City to 2026 and beyond.

a. Do the employment allocations reflect the role and function

of settlements? No comment.

b. Does the spatial distribution accord with the Wales Spatial Plan?

Yes.

d) Safeguarding Existing Employment Land

a. Would the Plan’s policies provide adequate protection for existing employment land and property?

The plan’s policies overly protect and unnecessarily restrict the potential to redevelop or reuse surplus employment sites. This is significant given that the Plan already provides for a significant oversupply of office floorspace alongside existing stock and commitments. Planning Policy Wales and particularly TAN23 (para 4.5.2 to 4.5.6) advise against over-allocating or allocating employment land where it will remain vacant for a long period of time. It advises that in this circumstance, sites should be reallocated or released from their employment protection restrictions in order to deliver other beneficial uses i.e. housing. The safeguarding employment land policy does not allow for the potential redevelopment of these sites, if they over the course of the Plan period.

e) Is Policy EC3 ‘Alternative use of Employment Land & Premises’ sufficiently flexible?

We have already identified a likely significant oversupply of B1 office floorspace within the Plan. Policy EC3 should therefore provide a more permissive and supporting framework to enable the

21047/A5 5 January 2015

redevelopment of employment land and premises, particularly within the context of TAN23. It should also identify that sites protected by EC1 should be capable of being tested against Policy EC3. Indeed, this situation applies at Cardiff Gate International Business Park, where Plot 12 in particular along with other residual plots (as set out in our representations to the Deposit Plan) have remained vacant for over 10 years, despite continued marketing. This is important given that the Plan relies significantly upon windfall sites to meet the overall housing requirement.

a. Are the requirements of the supporting text consistent with those set out in the Policy or are they more stringent?

The supporting text introduces additional criteria (5.66 to 5.72) and requirements which are more stringent and not reflected in the policy. This is not appropriate as the supporting text is not policy.

f) Supporting Existing Business

a. Does the Plan provide adequate flexibility to support existing business expansions?

Yes the plan provide large flexibility for existing businesses to expand given the large oversupply of likely B1 office floorspace in the City through existing stock, commitments and new allocations.

g) Retail

a) Is the Plan’s Retail strategy consistent with the vision and objectives of the Plan and the overall development strategy? No Comment

b) Is the Plan’s retail strategy founded on a robust, credible and up to

date evidence base?

• Is the Retail Capacity Study 2008 (and associated 2011 Updates) sufficiently up to date to inform the LDPs Retail Strategy? What are the implications of the improvement in the economy since these dates?

No comment

c) Is the Plan’s Retail Strategy consistent with national Policy, including that set out in Planning Policy Wales (PPW) and Technical Advice Note 4: Retail?

• Is the retail hierarchy realistic and appropriate and should it

be set out in Policy? No comment

21047/A5 6 January 2015

d) Policy R1: Retail Provision within Strategic Sites - Is the Plan suitably clear and flexible enough to allow retail uses to effectively integrate within the strategic sites without any adverse implications on protected retail centres? No comment

e) Policy R2: Central Shopping Area – Does Policy R2 strike an

appropriate balance to enable the protection of the Central Shopping Area whilst maintaining the flexibility to enable the development of complimentary uses? No comment

f) Policy R3: Protected Shopping Frontages - Does Policy R3 strike an

appropriate balance to enable the protection of the shopping function of important frontages whilst also being flexible enough to respond to changing market demands? No comment

g) Policy R5: District Centres & Policy R6: Local Centres - Are the identified District and Local Centres appropriate and are they founded upon a robust and credible evidence base/ consistent with the advice set out in Technical Advice Note 4: Retail Development?

• Policy R5: District Centres - Should the criteria for assessing

non-retail uses in paragraphs 5.283- 5.285 of the reasoned justification be included within the policy wording?

• Policy R6: Local Centres – Should the criteria for assessing

non-retail uses in paragraphs 5.492- 5.494 of the reasoned justification be included within policy wording?

No comment

h) Policy R7: Food and Drink Uses – Could/ Are the provisions of Policy

R7 covered under Retail Policies R1-6 above? No comment

i) Policy R8: Protection of Local Shopping Parades – Does Policy R8

apply to the potential loss of all ‘local shops’ or just those that meet the criteria of being classed as within a ‘Local Shopping Parade’?

• Should the marketing exercise required at paragraph 5.309

of the reasoned justification be clarified within policy wording?

21047/A5 7 January 2015

No comment

j) Policy R4: Retail Development (Out of Centre) – Is the Plan’s

approach to ‘out of centre’ retail development consistent with national planning policy set out in Planning Policy Wales (PPW) and Technical Advice Note 4: Retail Development? No comment

k) Is the Plan’s Retail Strategy sufficiently flexible enough to respond

to changing circumstances and does it include clear and appropriate mechanisms for the implementation and monitoring of the Plan’s objectives? No comment

6. Monitoring Framework

a. Are there robust monitoring and review mechanisms in place

that will enable the Plan to respond to changing circumstances?

The monitoring framework is important for employment land supply and take up. We have identified that the Council’s existing monitors for office floorspace only appear to count sites with detailed planning permission for offices within the overall office supply data. For example – Plot E04 at Callaghan Square – the business class monitor only counts the reserved matters approval for phase 1 of this site of 10,769 sqm. However, the overall site has outline permission as recorded in the Business and Employment Land Monitor for 46,450 sqm of B1 office floorspace. The same situation applies for various Cardiff Bay sites, which are included in the land monitor but not within the overall floorspace monitoring.

21047/A5 8 January 2015

Appendix 1

Appendix 2