'Confidential' representations to LDF preparation

[HarryFossettsHat]

Afternoon peeps,

Heres one for you to mull over, responses are welcome/encouraged.

Has anyone had much involvement in LDF preparation and the submission of representations? A 'friend' is currently working with a large employer. This large employer is looking to relocate, out of the area, but is hoping to get a housing allocation on their site through LDF representations (currently employment allocation) so as to maximise the value of their site once they have vacated.

This relocation is strictly confidential due to previous experience, where news got out, workers went on strike and the employer lost £Xm of business ahead of its scheduled closure date, severely denting profits for the year.

If they make representations to the LDF, the consultation closing date being in two weeks, they will blow their cover.

Is anyone aware of any way in which this large employer could submit a 'late representation' AFTER the relocation news is made public (for arguments sake, 2 weeks after the consultation deadline), so as to avoid losing business in the mean time? Or maybe a confidential representation (which is utterly against policy in PPS12)? Or should they stop being so greedy and grin and bear it?

My 'friend' would be most appreciative of any advice...

[Chet]

What is this LDF that you speak of?

[HarryFossettsHat]

Sorry Chet, I wasn't anticipating much response from that side of the world!

An 'LDF' is a Local Development Framework, a fairly simple guide to which can be found here

Essentially its a folder of documents that provide the statutory plan and planning guidance for a given area (usually a single local authority).

[b3nr]

Ah, I have come across this one before (ish). By the time your at that stage in the process (is the Core Strategy DPD or the Allocations btw?), its surely too late for the Local Authority to take the submission on board to the extent that it becomes a major allocation, especially if they are protecting employment land in the plan. In my very limited experience, officers and some councillors, were aware of the employers plan, but kept 'mum' about it. It did not go into the CS and probably won't go in the Allocations DPD. The council are 'aware' of it though. Plan, monitor, manage. If they want to over supply the RSS figures, perhaps they will put the highest rate of house building in the first half of the plan, if they want to restrict it, then they might do it in the second, the relevance being that if they allow a major site, it might screw up the strategy, or , conversely help them in achieving housing figures whilst reducing urban growth.

But fundamentally, isn't it too late anyway, as it all has to be above board and pass the famous 'soundness test' (groan). If the LA wants to protect the land for employment then theres another problem, if not then I would suggest what I've seen suggested in other cases; close, apply, appeal. Its brownfield and blah blah, the LA will probably ask for 50% retention of employment, based upon higher employment density, with which the developer will probably get away with less, perhaps leave it a few years and reapply for resi on the same site...

We need more brits here, i'd like to see a decent answer to this one.

[Dan]

Moved from the former Planning in the UK forum.