Chapter 7 EMPLOYMENT

Introduction

1. This Chapter sets out the Council’s town planning objectives and policies for employment uses such as industry, warehousing and offices. The major areas within the borough with concentrations of these uses are designated as Defined Employment Areas. Other employment generating uses such as nursing homes, hotels and training centres are also mentioned in this Chapter but the main policy references to these are to be found in Chapter 9, Leisure, Community Facilities and Education. Employment in retail premises as well as in Town Centres is dealt with in Chapter 8 Shopping and Town Centres.

2. The Employment Areas of the Borough were surveyed between February and June 1998. The results are published in a separate background paper. The sites designated as Defined Employment Areas are considered to be: “The main industrial estates and larger core industrial sites and areas which on the basis of condition, environment and location are best suited to long term retention of industry and commerce.”

Part I Policies

STR.EMP 1
To protect and increase the number, quality and range of local employment opportunities having regard to the availability and sustainability of sites and buildings, including appropriate provision for live-work units.

STR.EMP 2
To protect a range of suitable sites for business including industrial uses, in line with sustainability and environmental objectives, especially for new growth areas of the economy.

STR.EMP 3
To promote business clusters particularly for the creative and cultural industrial sector.

Reasons for Part I Policies

3. In 1999 LPAC commissioned consultants to assess the nature and scale of demand for industrial land in London. The consultants considered employment forecasts which suggest that over the period 1996-2015, employment in industry (manufacturing and warehousing) in London could fall by 9.5%. This represents the loss of 46,000 industrial jobs over this period, compared with a forecast increase in nearly 258,000 jobs across the economy as a whole. This is a significant decline, but is considerably less than the rate of decline over the last 30 years. It is considered that the majority of industrial activities remaining in London are less vulnerable to structural decline. In other words, London’s ‘industrial shake-out’ has, to a large extent, already taken place.

4. The research concludes that modern industrial uses in London are largely ‘downstream’ activities, concerned with the ‘delivery of goods to market’. Many of the growth businesses are not ‘traditional’ manufacturing uses, but are service-related industrial activities such as printing, distribution and catering. These types of firms form a significant proportion of the business and industrial activities in the Borough’s Defined Employment Areas, both in the north and south of the Borough. Many of these sites accommodate smaller industrial users serving central London businesses, residents, tourism and leisure markets, and so have an important economic function beyond the markets local to Lewisham.

5. The Council therefore wishes to retain those sites and premises remaining in these types of uses as they form an essential part of the local economy, providing services close to those who need them. They also provide sustainable jobs closer to home, in a context where the majority of local people in employment commute to work. The policies have also been formulated because of the effect of discrimination in the labour market and difficulties local unemployed people face in gaining access to jobs. Local employment land, which is mainly located in the north of the Borough, is close to the wards with the highest rates of unemployment. These wards have faced a consistently high rate of unemployment. Although jobs generated in these areas will not necessarily go to local people, it is considered that a pool of locally available employment opportunities is vital for the local economy, and will to a degree provide jobs close to home for those not able to commute to other parts of the capital.

6. The employment areas in the south of the Borough are considerably more scattered than those in the north. The Council commissioned consultants (GHK Economics and Management) who reported in 1998 that there is considerable demand for premises in these estates from local firms and from space needs not met from within LB Bromley. These areas are also of considerable importance in providing local jobs and services in terms of sustainability and accessibility, and contribute to the variety of the local economy.

7. The policies were also formulated in view of the need for a supply of smaller premises. There has been growth in the numbers of SMEs (Small and Medium Size Enterprises), and a loss of larger business and industrial enterprises in the area (which took place in the wider context of London’s loss of manufacturing facilities over the last thirty years). These smaller businesses need the conditions to be able to thrive, given that in comparison to larger firms they face more obstacles to long term survival. This must include a supply of appropriate sites and premises. Many of the employment sites designated in this Plan provide a good supply of smaller premises.

8. The ‘creative industries’ occupy an increasingly important place in the national economy. However their importance has not yet been fully recognised, partly due to a lack of policy co-ordination across the several Government departments responsible for these activities. As a first step to achieving this co-ordination ‘The Creative Industries Mapping Document’ was published in 1998 by the Creative Industries Task Force which is a body that works across several government departments. This document lists the creative industries as including advertising, architecture, the art and antiques market, crafts, design companies, fashion, film, interactive leisure software and other software, music, performing arts, publishing, and television and radio. New developments at Goldsmiths College and the Laban Centre at Creekside should form a magnet for associated creative business activities. The designation of sites for business/industrial use, and Proposals Sites for a mix of uses within the Unitary Development Plan therefore provides for a range of sites that could potentially be available to these industries, ranging from live/work studios for crafts, to railway arches suitable for printing and screen printing, and smaller industrial units in purpose built estates.

The Council’s Strategy for Employment Areas

9. The Council’s general policies for employment and economic development are set out in the annual Economic Development Plan and the three year Economic Development Strategy. The Lewisham Challenge Partnership’s Regeneration Strategy also provides a useful overview of the issues involved in regenerating the Borough. The UDP concentrates on the land use implications of these strategies and policies.

10. The Council’s land use strategy for employment is -
• to protect viable employment areas and buildings from redevelopment for other land uses;
• to facilitate the expansion in situ of established business;
• to provide opportunities to expand the economic base of the borough by attracting growth sector firms such as those involved in new technology and the cultural industries;
• to recognise and facilitate new work patterns such as those represented by live-work units;
• to direct significant new office development to the Major Town Centres at Catford and Lewisham.

11. Lewisham has recently lost a significant number of employment areas to residential and retail uses. The Borough does not have large areas of land devoted to business use and in order to facilitate a broad based local economy it considers it necessary to protect viable business land from a change of use away from business activity. The sites that are designated as Defined Employment Areas within the current Plan represent well established and well defined business and industrial areas. The Council wishes to protect these locations to ensure a good supply of sites and premises for these uses for the present and future.

12. The Council wants to attract new businesses to the Borough that can be defined as ‘creative industries’. The firm GHK Consultants were commissioned to produce a report into demand for employment floorspace. Their report, entitled ‘Overview of Trends in Demand for Employment Floorspace in Lewisham (April 1998)‘ acknowledges a lack within Lewisham of high quality office premises with good landscaping and facilities, suitable for such uses within this sector as advertising, architects offices, design and fashion design. In addition to designating sites for employment use, and Proposals Sites for mixed use development, the Council will seek to encourage the creation of clusters of arts and media firms through other means such as the management and letting arrangements of Council owned properties. This will also be encouraged by bids under the Single Regeneration Budget co-ordinated by the Lewisham Challenge Partnership, and new projects in the creative field, such as the Laban Centre for Dance at Creekside, which should be a magnet for new activities in this field. Goldsmiths’ College is also seeking to enhance its creative offer, and is proposing new developments in the St. James’s area of the campus at New Cross. They are seeking to provide a new arts centre of international standing, which could result in the creation of an ‘arts quarter’ in the New Cross area, by attracting associated activities.

13. The range of uses of these industries is not reflected as a separate classification in the Use Class Order 1987. Some uses such as ticket agencies associated with theatre and entertainment industries are classified as retail (Use Class A1). However, most of these uses fall within the B1 use class, and occasionally where the use can be viewed as detrimental to a residential area, fall within B2, or are ‘sui generis’ (i.e. they will always require planning permission). These new forms of cultural production can also co-exist with more traditional industrial uses, that already exist on employment sites in the Borough.

14. Government has produced Guidance that deals specifically with issues facing the tidal Thames (RPG 3b/9b). More reference to this can be found in Chapter 2 Urban Design and Conservation. The Guidance states that in London, between Hampton and Crayfordness, local planning authorities should identify in development plans, sites suitable for the loading and unloading of water-borne freight and adopt policies to protect them against permanent development which could jeopardise their future use for these purposes. In parallel with the Guidance on the Thames, the Secretary of State for the Environment issued Directions to local planning authorities under Section 12(7A) of the Town and Country Planning Act 1990, which requires them to have regard to the maintenance of specified wharves in formulating their development plans. Convoys Wharf, within Lewisham, has been identified in the Guidance as a site that falls under this Direction.

15. There are many aspects of regeneration, which are influenced by employment land uses. By protecting viable employment land from redevelopment for other uses the fundamental building blocks for regeneration are put in place. Lewisham has high unemployment and the potential for local jobs is provided if existing firms expand or new business is attracted into the area. One of the main planks of sustainability is that a great amount of energy is wasted by people commuting long distances to their place of work. By providing for a range of local job opportunities close to where people live an element of a sustainable economy can be put in place. It is increasingly recognised that fundamental to social inclusion is paid employment and any opportunity to improve job prospects for local people is to be taken.

16. This strategy recognises the fact that the Borough does not have large areas of vacant or derelict land that can be brought back into viable employment uses. Once lost to housing or other higher land value uses it is unlikely that it would be possible to replace this land locally. However it is also recognised that the Council has other regeneration aims, including meeting targets for provision of housing and the regeneration of Lewisham Town Centre. There is also a new emphasis on mixed use development as a means of achieving economic and environmental regeneration. There will therefore be some circumstances when the redevelopment of employment land for other uses will become acceptable, in order to achieve the regeneration of the Borough.

Part II Policies

Reasons
There is a continuing demand for land and buildings for industrial and commercial use, reflected by the continuous and high level of occupation of our purpose built industrial estates and other buildings in business or industrial use.

Lewisham has a high rate of unemployment compared with many London boroughs, and this is particularly concentrated in the northern wards where most of the Defined Employment Areas are situated. The Borough has lost a great many manufacturing jobs and unemployment amongst its residents has been consistently recorded at a level higher than that of the national or the Greater London average. Over recent years a number of industrial sites have also been lost to other higher value land uses.

The safeguarding and development of employment land will help to meet the accommodation needs of businesses in accordance with Government Guidance.
The sites safeguarded cover a wide range of types of premises, and the uses proposed in the Plan policies cover most forms of business and industrial uses. This is designed to allow for as wide a range of types of business enterprise to develop as possible.

Reasons
The Council is keen to build on the artistic and creative centres such as Goldsmiths College and the Laban Dance Centre, by enabling the creation of a network of supporting cultural and artistic activities.
Other areas of the borough have also attracted nuclei of creative and artistic enterprises, for example, at Creekside using the varied industrial premises available at this location, and at Forest Hill, in particular Havelock Walk. The Council is concerned that this new significant development in the cultural and economic life of the borough will not be able to compete with rising land and property values, particularly in the Docklands Light Railway corridor, and in the future, along the proposed East London Line extension of the London Underground. Section 106 agreements with developers will be sought where appropriate, to ensure the provision of premises for these uses.
The imposition of planning conditions to retain premises used by the Creative Industries relates to the fact that the Use Classes Order 1987 removed the planning distinction between light industrial and office uses (other than A2 uses), through the introduction of the B1 use class, and thus reduced the Council’s powers to prevent changes of use from light industrial to office floorspace. It is recognised that many creative industries fall within a B1 office use, and the imposition of planning conditions will often not be appropriate. These conditions will therefore be applied in appropriate circumstances to protect particular developments containing specialist and often small industries which contribute to the local economic and cultural life of the area, and which might be in danger of being squeezed out by more general commercial development.
The definition of cultural industries for the purposes of this policy is to be found in the Creative Industries Mapping Document 1988 discussed in paragraph 8 of this Chapter.

Reasons
The sites shown on the Proposals Map and listed in the Schedule are considered well suited for employment related development and particularly for business use, industrial use, storage and distribution uses, i.e. uses falling within Classes B1, B2 and B8 of the 1987 Use Class Order. B2 uses will be given permission where appropriate, as many of the Borough’s business/industrial areas are also close to residential areas. The Defined Employment Areas have been identified on the Proposals Map and listed in Schedule 4. Further explanation for the identification of employment areas and employment sites are to be found in the Council’s twin publications: the ‘Survey of Employment Areas in Lewisham 1998’; and the ‘Survey of Employment Sites 1998’.

The Council wishes to preserve the remaining employment land in the Borough as far as is reasonably practicable. Nevertheless, it is recognised that there may be circumstances when new development, either involving a mix of uses, residential, or other employment generating uses will better achieve the wider regeneration aims of the Council. The criteria within the Policy will be used to judge whether a new development involving other uses or a mix of uses will outweigh the benefit of retaining land in employment use. As it is the Council’s intention to preserve employment generating use in these areas, new uses approved under these criteria should not compromise the industrial functioning of the areas as a whole. In particular, in the case of permission granted for live/work units the Council will not seek to restrict any appropriate employment generating use in the area on the basis of the residential element of these schemes. (See Policy EMP 7).

Reasons
The pattern of employment land uses in Lewisham is such that there are a large number of small industrial and commercial sites scattered throughout the Borough. In view of their small size these sites have not been shown on the Proposals Map.

The planning system has limited powers to protect existing employment uses. However, it remains a planning objective to retain as many of these small businesses as possible, especially where they support the functioning of Town Centres, and Local Shopping Parades, and provide valuable local employment opportunities. The maintenance of these scattered businesses is also in line with the wider objectives of sustainability by reducing the overall number of car journeys, and the vitality and viability of local communities. Service industries are vital to the local economy, and these premises can also ensure a continued supply of cheaper ‘seed bed’ accommodation.

Mixed use developments including housing uses can help to achieve the aims of economic and physical regeneration of the Borough. Developers should also refer to Policy EMP 7 Live-Work Developments. The Council wants to preserve, wherever possible local employment opportunities and commercial premises, but recognises in the Policy the circumstances when other uses may be appropriate on these sites. Where a mixed use scheme comes forward on an employment site outside a Defined Employment Area it will be expected that residential development should not generally form the dominant land use.

A survey of many of these employment sites was undertaken by the Council, and they have been classified according to location, age and condition of premises. This information is available in the ‘Survey of Employment Sites in Lewisham 1998’.

Reasons
The Council wants to protect as far as possible, the range of employment and economic activity available in the Borough. The Council will encourage the modernisation or intensification of an existing use, provided this is compatible with surrounding uses, particularly residential amenity. This Policy conforms with Government advice particularly that contained in PPG4 (1992) which says, among other things, that local planning authorities should include policies for particular types of development including the expansion of existing firms.

Reasons
The preferred locations for large new office development have been chosen to achieve sustainability objectives of siting major traffic generating activities close to public transport nodes, and to enhance these centres as major locations for employment, and to support their retail and business function. Small scale office developments, which are often in shopfront premises and therefore fall in Class A2 of the Use Classes Order do not usually generate large amounts of traffic, and are also in line with sustainability objectives by reducing the overall number of car journeys made.

The Council does not wish to obstruct or harm business efficiency through its land use policies, and therefore any ancillary office use, which is considered essential to the main business use will generally be permitted.

Developers wishing to convert unused or redundant office space to housing should refer to Policy HSG 10 in the Housing Chapter. Developers should also refer to policies in the Transport Chapter relating to access to large developments.

Reasons
Live-work developments can be defined for the purpose of this Plan as self-contained small business units, with a proportion of the accommodation capable of being used for residential purposes on a permanent or semi-permanent basis. They can provide valuable accommodation for starter businesses, in that housing and business facilities are combined in one unit, representing a substantial cost saving. The Council wishes to encourage these uses as much as possible as an aid to the regeneration and diversification of the local economy. However there are some concerns that these units will be difficult to maintain in business use due to the high turnover in starter businesses. Wholly residential uses may start to be introduced into employment areas.

The Council wishes to keep control of this process and will consent to live-work developments in employment areas in the limited circumstances described. The Council will seek to enter into S 106 Agreements with developers in Defined Employment Areas, and also in buildings covered by Policy EMP 4 to ensure that a proportion of the business floorspace is retained in perpetuity. Town Centre locations, and sites associated with Local Shopping Parades are considered to be particularly suitable for this type of development as they have the advantages of a business location and an environment more suitable for residential use.

The Council will expect live-work developments that meet, and schemes in which such units contribute to meeting, the threshold in Policy HSG 14 to make a contribution to the Borough’s affordable housing provision. Further guidance is available in the Council’s SPG on Affordable Housing.

Reasons
It is important to distinguish between two types of employment that can be covered by the term ‘homeworking’, and which can lead to confusion. The first, which the Council wishes to encourage as valuable economic development within the Borough, is small-scale working from home. This can be an important means of earning a living for some people, including some people with disabilities and people with childcare responsibilities. Self employment is increasing and is a significant provider of employment. It is possible also that ‘teleworking’ will increase, and that office employment will become increasingly more decentralised, away from headquarters buildings.

However, the Council may become concerned, and seek to control through enforcement action, a situation where homeworking intensifies to the point beyond that which can reasonably be accommodated in a residential area. In these situations, where clearly a large scale commercial operation is being run from residential premises, the impact on the neighbours and the overall residential amenity needs to be protected by the Council.

Reasons
Part of Convoys Wharf is a protected wharf covered by two Directions made by the Secretary of State for the Environment. It is identified as one of the essential minimum number of wharfs required to support the strategic objective of ensuring continued use of the river for freight transport (RPG3b Strategic Planning Guidance for the Thames).
Convoys has special characteristics compared with other berths in this part of the Thames and is therefore particularly worthy of safeguarding against redevelopment in the long term for uses not related to use of the wharf. Convoys is one of only two roll-on – roll-off /load-on – load off terminals upstream of the Thames Barrier, the other being Victoria Deep Water Terminal. Navigationally, Convoys is the better of the two ro-ro/lo-lo opportunities in terms of water depth at the berth. Convoys has water depth of between 7.4 and 7.8 metres at the pier head at low tide while Victoria Deep Water terminal, also a deep water wharf worthy of protection, has around 6.4 metres.

The Port of London Authority (PLA) has done trade forecasts to the year 2020, set out in the Development Strategy for Cargo Handling in the Port of London 1998, which indicate that cargoes likely to be handled in berths such as these are very likely to grow significantly over the next decades.

The geographical characteristics of Convoys are particularly attractive since it provides the best opportunity to bring ro-ro/lo-lo cargoes to the heart of London. There are no opportunities to develop this sort of terminal upstream of Lewisham. Convoys has a relatively large adjoining land parcel compared to many safeguarded terminals, which adds significantly to the flexibility with which the terminal can be used.

The Council will seek to protect commercial wharf use at this site by applying the above policy in line with the Government’s and the PLA’s objectives of safeguarding sites useful for maintaining transport by river. Proposals for development affecting the wharf will be referred to the Mayor for London before permission is granted. The information requirements listed in the policy will be required from developers who will need to prove that the wharf is no longer required for cargo handling when applying for permission for other uses on the site. Information will also be required on the physical, social and economic contribution to the regeneration of the borough that might be made by any new development as the loss of such an important facility will need to be balanced by a substantial positive contribution to the future of the Borough. It is recognised that new wharf uses can require a significant lead in time for development. Evidence will therefore be required that the site has been marketed for an appropriate length of time, including an assessment of current and future market demand before alternative redevelopment proposals will be considered. This stretch of the Thames also has historic importance as it includes the former Deptford Royal Naval Dockyards. For more information developers should refer to relevant policies in Chapter 2: Urban Design and Conservation and Schedule 3 Area of Archaeological priority for more information.

Under the provision of the Town & Country Planning (Mayor of London) Order 2000 the Borough is obliged to refer any application of strategic importance to the Mayor for London. Any application that affects the protected wharf status of Convoys Wharf would be considered of strategic importance. If the Mayor considers that to grant permission on an application which has been notified to him would be contrary to the Spatial Development Strategy or prejudicial to its implementation, or otherwise contrary to good strategic planning in London, he may within a specified period direct the Council to refuse the application. Developers should refer to Annex 2 The Blue Ribbon Network of the draft London Plan 2002.

Reasons
This Policy will apply if the whole Convoys Wharf site, including the Protected Wharf area, becomes available for redevelopment by proving that the Protected Wharf is no longer needed for cargo handling. In these circumstances the Council is concerned to ensure that this major site is developed to provide the maximum contribution to the regeneration aims of the Borough, and will produce a comprehensive master plan, subject to public consultation to ensure this. The range of uses proposed is considered to meet these aims by providing a mix of uses that will take maximum advantage of the opportunities offered by the site. The Council is concerned that businesses replacing cargo handling on Convoys Wharf will use the River as part of their commercial functioning, thereby contributing to sustainable transport objectives, and that a net gain for the number of people employed on the site is achieved.

New developments will need to comply with all other policies in the Plan. Developers should refer especially to Policy TRN 1 Location of Development. Public transport provision for this site is poor. New provision would need to be implemented as part of the development.

Reasons
This Policy provides for development on Convoys Wharf in the circumstances of the Protected Wharf remaining in use as a wharf, or required to remain in that use. The Council wishes to ensure that new uses on the surrounding site do not interfere with wharf operations, and also to ensure that the rest of the site is developed to the maximum advantage of the Borough in meeting physical, social and economic regeneration aims.