Draft Economic Development, Employment Land and Premises SPG

Ended on the 1 December 2022

5. Proposals for New Employment Development – Key Considerations

5.1.1. The LDP welcomes new employment proposals for the benefits they provide to the local economy. LDP Policy MD14 – New Employment Proposals supports proposals for class B1, B2 and B8 employment uses, and complementary ancillary uses on existing and allocated employment sites. Elsewhere, Policy MD14 also permits new employment uses where: these are within or adjacent to sustainable settlements where the proposal is complimentary to its location and neighbouring uses; as part of a rural enterprise business or farm diversification; or where the nature of the proposal necessitates its location to mitigate its impact on amenity.

5.1.2. In addition, the following policies offer the main policy framework against which proposals for new employment development will be assessed to ensure they deliver well-designed and purposeful developments that protect the amenity and environment of the surrounding area:

  • MD2 – Design of New Development
  • MD7 – Environmental Protection
  • MD20 – Assessment of Waste Management Proposals

5.1.3. Some key themes are explored further in the guidance below.

5.2. Good Design and Placemaking

5.2.1. Placemaking is about creating great places to live, work, visit and spend time. This will often start with engagement i.e. creatively engaging with people who live, work and spend time in an area (as well as future user groups) from the outset of a project to actively listen, see and understand a place, to inform design choices. Developers must submit a Pre-Application Consultation (PAC) report for any "major" development (i.e. site area is 0.5 hectares or more, or where new floorspace exceeds 1000 square metres) setting out how community consultation has been undertaken and how this has influenced the concept design for the development.

5.2.2. LDP Policy MD2 Design of New Developments seeks to create high quality, healthy, sustainable and locally distinct places and sets out the key principles that developers should consider in respect of design, amenity and access which together contribute to attractive, safe and accessible environments. In particular, development proposals should:

  1. Be of a high standard of design that positively contributes to the context and character of the surrounding natural and built environment and protects existing features of townscape or landscape interest;
  2. Respond appropriately to the local context and character of neighbouring buildings and uses in terms of use, type, form, scale, mix, and density;
  3. Where appropriate, provide new or enhanced areas of public realm particularly in key locations such as town centres, major routes and junctions;
  4. Promote the creation of healthy and active environments and reduce the opportunity for crime and anti-social behaviour. […];
  5. Provide a safe and accessible environment for all users, giving priority to pedestrians, cyclists and public transport users;
  6. Have no unacceptable impact on highway safety nor cause or exacerbate existing traffic congestion to an unacceptable degree;
  7. Where appropriate, conserve and enhance the quality of, and access to, existing open spaces and community facilities;
  8. Safeguard existing public and residential amenity, particularly with regard to privacy, overlooking, security, noise and disturbance;
  9. Provide public open space, private amenity space and car parking in accordance with the council's standards;
  10. Incorporate sensitive landscaping, including the retention and enhancement where appropriate of existing landscape features and biodiversity interests;
  11. Provide adequate facilities and space for the collection, composting and recycling of waste materials and explore opportunities to incorporate re-used or recyclable materials or products into new buildings or structures; and
  12. Mitigate the causes of climate change by minimising carbon and other greenhouse gas emissions associated with their design, construction, use and eventual demolition, and include features that provide effective adaptation to, and resilience against, the current and predicted future effects of climate change.

5.2.3. The Council recognises that business development can be in a variety of forms and the design and layout of premises can depend on the needs of the user and well as the design response to the site. Therefore, it is not possible nor desirable to be prescriptive about design, nevertheless, key design principles set out in policy MD2 should be applied to new employment developments.

5.2.4. Design and access statements, where required, should provide sufficient detail in respect of design alongside how proposals address key planning issues outlined in this and other relevant Supplementary Planning Guidance.

5.3. Context and Character

5.3.1. Criteria 1 and 2 of LDP Policy MD2 set out the importance of new development responding to the context and character of the surrounding environment in terms of use, type, form, scale, mix, and density. This will start with an appraisal of context and character that should be clearly articulated in the Design and Access statements submitted to support planning applications.

5.3.2. Welsh Government has produced guidance in partnership with Design Commission for Wales which sets out how to undertake effective site analysis to achieve an appropriate design response (https://gov.wales/sites/default/files/publications/2018-09/site-context-analysis-guide.pdf) which could assist in this process.

5.3.3. Placemaking requires an informed and critical response to sites and their context. Only through a considered response to context can we make places which are locally distinct, use resources responsibly, take full advantage of the opportunities offered by the site, overcome the challenges of topography and climate and embrace the spirit of a place. Each specific landscape has its own unique qualities - its own topography, geology, microclimate, history, cultures and imprints of human activity - which call for a unique, place-specific response. Developers will need to demonstrate how they have undertaken this analysis and how they have designed an appropriate development as a result.

5.3.4. Developers will need to identify site constraints within and surrounding the site, paying particular attention to preserving and protecting sensitive natural features like trees, habitats, watercourses; and important historic assets such as listed buildings, conservation areas or archaeological resources. The design response should maximise the site's potential, for example, maximising active travel connections / opportunities, recognising solar-gain potential, minimising waste through construction by responding appropriately to site levels.

5.3.5. The layout and design of industrial units should take account of local surroundings. The design and appearance of buildings should consider how they can contribute to enhancement of the public realm, especially where visible from public locations such as primary roads or wider landscapes. The appearance, layout and orientation of new buildings whist meeting the functionality of the business should also reflect its surroundings.

5.4. Public Realm and LandscAping

5.4.1. Commercial development can result in an increased demand for and use of public open space as employees will tend to use these spaces during lunch breaks or before and after work. The provision of attractive open spaces can also contribute to the health and well-being of the workforce and well as providing opportunities for biodiversity protection and enhancement. Green and blue infrastructure in a development provides other environmental benefits including opportunities for sustainable drainage solutions, heat management and carbon capture.

5.4.2. LDP Policy MD2 recognises the importance of quality public realm in securing well designed developments. New employment developments should provide new or enhanced areas of public realm where appropriate to promote the creation of healthy and active environments for future employees and visitors (criteria 3 and 4 refer). Developments should, where appropriate, conserve and enhance the quality of, and access to, existing open spaces and/or provide new public open space.

5.4.3. Policy MD3 (Provision for Open Space) states: "Where there is an identified need for public open space provision, major new commercial developments, where floorspace to be created exceeds 1000 sqm or the site is 1 hectare or more, will be required to provide public open space at a ratio of 16 sqm per full time equivalent employee. In order to create sustainable places areas of open space will usually be required to be provided on-site as part of new development proposals. Where it is not practical or desirable to make provision on-site, appropriate off-site provision or financial contributions for improvements to existing facilities will be required in lieu of on-site public open space."

5.4.4. When planning public realm areas within employment developments, these should incorporate sensitive landscaping, including the retention and enhancement where appropriate of existing landscape features and biodiversity interests. It is essential for the design and layout of commercial units to consider the use of landscaping to reduce the potential impacts that servicing, parking or waste storage areas can have upon the amenity of neighbouring land uses if not designed properly.

5.4.5. Landscape elements can provide a desirable sense of place and character to the proposed development. As well as retaining existing features, the landscape strategy should propose additional native planting to provide a strong sense of place and to soften the urban grain of buildings, roads and service yards often associated with commercial developments.

5.4.6. Soft (green and blue) landscaping provides important biodiversity habitat, visual interest, potential resilience to the causes and consequences of climate change as well as improving the wellbeing of employees and visitors to the development. It must be considered at the outset, with landscaping strategies and plans being submitted at the initial planning application stage as opposed to being controlled by condition as an afterthought. Similarly, developers will be expected to demonstrate long-term provision (minimum 20 years) for maintenance of public realm areas landscaping.

5.5. Biodiversity

5.5.1. Criteria 10 of LDP Policy MD 2 requires new development to incorporate sensitive landscaping, including the retention and enhancement where appropriate of existing landscape features and biodiversity interests. New employment proposals should therefore consider existing green infrastructure and opportunities to incorporate this and new landscape features within the proposal. This includes the retention of trees and hedgerows on or adjacent to a site, whether they are protected or not. Where tree removal cannot be avoided or is carried out prior to the submission of an application, replacement planting will be required in accordance with the Council's Trees, Hedgerows, Woodlands and Development Supplementary Planning Guidance.

5.5.2. Developers will need to carry out appropriate site surveys at the start of their concept design to identify important biodiversity assets on or around the site likely to be affected by the development proposals. There will always be a presumption against development which is likely to harm a protected site or species. However, there may also be instances when the importance of a development proposal will outweigh the conservation value and in such instances, the objective will always be to ensure that the nature conservation value of the site or protected species is preserved and where possible enhanced.

5.5.3. The Council's Biodiversity and Development Supplementary Planning Guidance provides additional guidance on how to incorporate measures to for enhancing biodiversity within developments.

5.6. Active Travel and Accessibility

5.6.1. LDP Policy MD 2 requires new developments to provide a safe and accessible environment for all users, giving priority to pedestrians, cyclists and public transport users and have no unacceptable impact on highway safety nor cause or exacerbate existing traffic congestion to an unacceptable degree (criteria 5 and 6 refer).

5.6.2. The location, scale, layout and design of a new development will directly influence the mode of travel that employees and visitors will use to get to and from the site. New developments must provide the opportunity to encourage people to change their travel habits towards active and sustainable travel modes to avoid the unnecessary use of private motor vehicles to travel to and from the development. Moreover, it is recognised that individuals are more likely to change their travel habits when they are making a significant change to their lifestyle such as starting a new job, therefore employment proposals with good facilities for walking, cycling and public transport offer a real chance to influence travel patterns.

5.6.3. One way of influencing travel behaviour is through the adoption and implementation of a workplace travel plan, which provide opportunities for employer and employees to adopt sustainable travel initiatives that can be economically beneficial for an organisation or individuals.

5.6.4. A Travel Plan is a package of practical measures aimed at effectively managing the long-term transport and travel needs of a site or organisation with the specific aim of improving access to the site by all modes of travel. A successful Travel Plan will improve travel choice, reduce the impacts of transport on the local environment and increase the overall accessibility of the site. A Travel Plan can address journeys to and from work and also business travel, fleet management, visitor's arrangements and deliveries. Each Travel Plan is tailored to the specific needs and characteristics of the site and/or organisation.

5.6.5. The Council will usually require a Travel Plan to be prepared for the following commercial and business uses, however the Council encourage the adoption of a Travel Plan for proposals of any size:

  • Business > 2,500 m2 gross floor area
  • Industry 5,000 m2 gross floor area
  • Distribution and warehousing > 10,000 m2 gross floor area

5.6.6. To assist employers in developing a Travel Plan, the Council has prepared detailed guidance on the preparation of Travel Plans which includes a standard Travel Plan template and a toolkit giving examples of measures that are commonly used. Further details on the requirements are set out in the Council's Travel Plans Supplementary Planning Guidance.

5.7. Parking Provision

5.7.1. Car parking is a major influence on transport choice. If car parking is readily available people are more likely to opt to use the private car instead of more sustainable forms of transport. The Council has adopted parking standards for a range of land uses including office, commercial and industrial development; these are set out in the Council's Parking Standards Supplementary Planning Guidance. These providemaximum (rather than minimum) levels of parking across the Vale of Glamorgan reflecting location and accessibility for a range of developments. The guidance also includes standards for the provision of cycle parking facilities which can help reduce demand for car parking alongside the adoption of workplace Travel Plans.

5.7.2. When considering the parking requirements for employment proposals the Council will consider a number of factors in relation to the development and its location. These could include:

  • Accessibility to and from the service provided by public transport.
  • The availability of private buses, taxi services or the extent of car-pooling.
  • The relative proportions of full time / part time / local catchment of labour.
  • Accessibility by walking and cycling to everyday goods and services.
  • The production of an agreed Travel Plan supported by appropriate financial investment and staff commitment.
  • The existing and possible future parking provision, traffic volumes and congestion on streets adjacent to the development.
  • Potential impacts on highway / public safety.
  • Accessibility to and the availability of public and/or private car parking spaces in the vicinity.

5.7.3. The Council recognises that Ultra Low Emission Vehicles and Plug-In Hybrid Vehicles (ULEVs and PHEVs) currently constitute a relatively small proportion of vehicles on our roads. However, advances in technology have resulted in increased popularity in electric vehicles and it is anticipated that as technology and government initiatives develop, their use and popularity will increase further.

5.7.4. To encourage the take up of these vehicles and increase the number and geographic spread of ULEV charging infrastructure, the Parking Standards SPG (as well as Policy 12 of Future Wales) requires the provision of electric vehicle charging points (EVCPs) infrastructure, within new non-residential development proposals at a minimum of 10% of the total required parking for the proposal. For example, if the parking requirement for a development is 20 spaces two of the 20 spaces will need to accommodate EVCP infrastructure. The development area thresholds are reproduced below:

Thresholds for Electric- Vehicle Charging Parking Access

Use

Threshold

Business

>2,500 sq.m gross floor area

Industry

>5,000 sq.m gross floor area

Distribution and warehousing

>10,000 sq.m gross floor area

5.8. Sustainability and Climate Change

5.8.1. LDP Policy MD 2 (10) requires new developments to mitigate the causes of climate change by minimising carbon and other greenhouse gas emissions associated with their design, construction, use and eventual demolition, and include features that provide effective adaptation to, and resilience against, the current and predicted future effects of climate change.

5.8.2. Designing buildings, and the spaces in between, to mitigate their contribution to and be resilient to the consequences of climate change is key to delivering sustainability. New development should be ready for the warmer, drier summers and wetter winters of the future climate.

5.8.3. Considering the environmental impact of the materials used to construct new development, will be key to delivering sustainability across its whole lifecycle.

5.8.4. Responding to what has been learned from analysis of the site is also important from a sustainability point of view. If the topography and climate have been understood, the designer can employ passive design strategies to reduce the development's energy demand and carbon emissions. A carefully sited, oriented and composed development will make use of the natural resources from the sun, wind, earth and sky. The demand for mechanical heating, cooling and electric lighting is then reduced, meaning that complex high-tech building services are not required.

Low Carbon and Renewable Energy Technologies

5.8.5. PPW (paragraph 5.8.7) highlights the role of the development industry has in contributing towards climate change, stating that "Developers should take into account future requirements for carbon reduction in new buildings when designing their schemes, as a result of changes to Building Regulations in Wales; being mindful of any future changes will ensure design aspects of requirements are considered as early as possible".

5.8.6. Policy MD19 (Low Carbon and Renewable Energy Generation) supports proposals which incorporate measures that contribute towards reducing its impact on climate change. Developers should look to maximise opportunities for renewable energy generation and energy efficiency throughout their design.

5.8.7. Through the adoption of construction techniques that reduce energy consumption or reliance on conventional heating or cooling systems, and through the incorporation of renewable energy technologies new developments can embrace the climate change challenge. The Council's Renewable Energy SPG contains advice on how to consider renewable energy in development proposals.

Local and District Heat Networks

5.8.8. Heat networks are one of the most cost-effective ways of reducing carbon emissions from heating, supplying heat from a central source via a network of underground pipes carrying hot water and avoiding the need for individual boilers or electric heaters in individual buildings. Once in place, heat that would otherwise go to waste such as waste heat from industrial processes can be utilised.

5.8.9. Future Wales Policy 16 (Heat Networks) recognises the role that heat networks can play in contributing to national climate change goals, and requires large scale commercial development of 10,000sqm or more floorspace to consider the potential to incorporate a heat network within the development. Accordingly, applications for such development should prepare an Energy Masterplan to establish whether a heat network is the most effective energy supply option and, for feasible projects, a plan for its implementation.

5.8.10. The Welsh Government has produced practice guidance to assist developers in considering options for adopting low carbon and renewable energy technologies within their development proposals, including district heating (Practice Guidance: Renewable and Low Carbon Energy in Buildings).

Sustainable Drainage Requirements (SuDS)

5.8.11. Surface water flooding is a serious problem, identified in WG's National Strategy for Flood and Coastal Erosion Risk Management as a major cause of flooding. The impact on citizens, communities and cost to the Welsh economy is significant. The risk of flooding is on the rise owing to climate change and urbanisation. In particular, local flooding, due to the overloading of volume constrained drainage systems and sewers, is of increasing concern. Surface water runoff can be an important source of diffuse pollution. The potential damage to our groundwater and rivers from polluted surface water runoff increases with each new development.

5.8.12. From 7th January 2019, all new developments where the construction area is 100 square meters or more, will require sustainable drainage systems (SuDS) for surface water. The SuDS must be designed and built in accordance with Statutory SuDS Standards published by the Welsh Ministers and SuDS Schemes must be approved by the local authority acting in its SuDS Approving Body (SAB) role, before construction work begins.

5.8.13. An application demonstrating compliance with the Statutory SuDS Standards for the design, construction, operation and maintenance and operation of surface water systems serving new developments, must be submitted to the Council as SAB. Applications may be submitted to the SAB for determination either directly as a free-standing application or alongside the planning application via the Local Planning Authority (LPA) (a combined application). It is important to note that construction work which has drainage implications must not be commenced unless the drainage system for the work has been approved by the SAB.

5.8.14. For every new development, the SAB will seek an overall reduction in, or significant attenuation of, surface water volumes reaching public sewers and combined systems as part of the aim of ensuring the stability and durability of drainage systems in a sustainable way.

Sustainable Waste Management

5.8.15. Future Wales recognises the importance of sustainable resource management, it states: "We depend on high quality natural resources to fuel our industries, provide our food, clean air and water and create jobs and wealth. We must carefully manage the use of our natural resources and ensure that through a strong circular economy, we maximise their use and contribution to society."

5.8.16. Development proposals should minimise waste during construction by sustainably sourcing materials and designing buildings in a way that uses resources efficiently. Applicants will be expected to demonstrate through their submissions how they have explored opportunities to incorporate re-used or recyclable materials or products into new buildings or structures in accordance with LDP Policy MD2.

5.8.17. When operational, employment developments have the potential to generate significant amounts of waste. Therefore, new development should provide adequate facilities and space for the collection, composting and recycling of waste materials (LDP Policy MD 2 refers).

5.9. Environmental Protection

5.9.1. Where new commercial and industrial uses are proposed it is important to ensure proposals do not lead to unacceptable impacts on the environment or on the operations and amenity of existing nearby uses. Accordingly, LDP Policy MD7 (Environmental Protection) adopts a precautionary approach to development proposals to ensure that it is demonstrated that they will not result in an unacceptable impact on people, residential amenity, property and /or the natural environment.

5.9.2. Pollution of all types can cause significant damage to human health, biodiversity, quality of life and residential amenity. LDP Policy MD7 Environmental Protection sets the requirements for all new developments including commercial and industrial uses to consider the likely impacts of their proposals. In determining the suitability of proposals, the Council will also consider the compatibility of the proposal to existing adjacent and the likely impact the proposal would have on adjacent users or uses.

5.9.3. All development proposals will therefore be required to identify potential impacts and set out how any affects shall be mitigated or minimised to acceptable levels. Where development is approved, conditions will be used to control any potentially unacceptable impacts and where appropriate monitor the effects of the development.

5.9.4. Applicants should consider the 'agent of change principle' which states: "a business or person responsible for introducing a change is responsible for managing that change. In practice, for example, this means a developer would have to ensure that solutions to address air quality or noise from nearby pre-existing infrastructure, businesses or venues can be found and implemented as part of ensuring development is acceptable" (PPW, para.6.7.5) This means the developer is responsible for ensuring that the proposal includes appropriate solutions to address issues such as air quality or noise from nearby existing uses to make the development acceptable.

5.10. Planning Obligations

5.10.1. The Council will also consider the need for planning obligations to provide necessary infrastructure to support and mitigate the impacts of new development. Details of the types of infrastructure that may be sought are set out in Policy MD4 Community Infrastructure and Planning Obligations and Supplementary Planning Guidance on Planning Obligations, and in most cases, the Council will encourage developers to provide facilities and infrastructure on site to serve the future occupiers of the development.

5.10.2. Policy MD4 sets out the type of planning obligations that may be sought, depending on the nature and scale of the proposal, in respect of employment proposals these could include:

  • Transport infrastructure and services for pedestrians, cyclists, public transport and vehicles;
  • Public open space, public art and recreational facilities;
  • Service and utilities infrastructure;
  • Environmental protection and enhancement;
  • Recycling and waste management facilities; and
  • Employment opportunities and complementary facilities including training.

5.10.3. The threshold for planning obligations is usually new employment proposals with a floorspace greater than 1000 square meters or the where the site area is 1 hectare or more.

5.11. Local Employment, Training and Procurement

5.11.1. New developments can make a significant contribution to the economic well-being of the local community and provide opportunities for training and employment to maximise the economic benefits to the locality. In this regard developers must consider opportunities to maximise benefits for the local work force and businesses. For example, the construction phase of new development provides opportunities for local employment, apprenticeships and work experience placements, while commercial developments also bring new employment, apprenticeship and work experience opportunities for residents during the operational phase.

5.11.2. The Council may also seek to secure employment and training measures through planning obligations and / or conditions to provide training opportunities or local supply chain initiatives. For example, developers will be required to commit to a Labour Recruitment Strategy to include measures aimed at facilitating best available access for people to the opportunities for employment arising from the construction and operation of a development, such as the provision of a local 'job shop'.

5.11.3. Developers should also provide the opportunity for local businesses to benefit from the construction and operational phases of new developments through promoting and advertising tender opportunities locally as well as other bespoke local procurement strategies.

5.12. Sub-division of Existing Employment Sites and Premises

5.12.1. The Council's employment land study (2013) identifies a shortage of small to medium premises (up to 98sq.m) which are aimed at start-up and growth businesses. Accordingly, the Council will support the subdivision of larger underused sites or premises to smaller class B1, B2 or B8 premises. Subdivision may also assist in bringing forward vacant sites or premises with little or no market interest; viability issues, or to make better use of under used / surplus floorspace.

5.12.2. Where subdivision of an existing site or premises is proposed, the Council's default position will be for any newly created units to be for B class uses. In cases where non-B class uses are proposed, applicants will be required to justify this in accordance with the criteria set out in Policy MD16, explored further below.

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