The Council's approach needs to now take into account the Government's latest planning policy and guidance set out in the recently published PPS4 : Planning for Sustainable Economic Growth. You will be aware of the advice contained in para 3 thereof "it is only necessary for the development plan to reformulate development management policies in this PPS if there are specific factors justifying variation of these policies". Also, under policy EC10 you should "adopt a positive and constructive approach towards planning applications for economic development".

The first paragraph of the policy appears to require any development in the whole of the District, as opposed to the Weston-super-Mare area only, to be employment-led; also employment provision that leads to greater self-containment and reduces out-commuting is to be prioritised. If this is the intention then these are inflexible and unreasonable requirements to impose, particularly without greater flexibility in relation to any phasing of housing (particularly where it could be an enabler) and the quantification of the factors to be encompassed within the self-containment/out-commuting issues. Also not all development can be employment - led.

All economic development should be positively encouraged, the comments regarding the predominance of B uses in para 3.300 are flawed and the intended strategy fails to secure the greatest range of opportunities for economic development within the District. All job creating opportunities should be encouraged and accommodated, particularly in the Weston-super-Mare area. Otherwise there may actually be a disincentive in coming to the town.

In all the stated categories regarding the broad location of employment development, a more flexible approach to economic development, in line with PPS4, should be promoted rather than the inclusion of restricting criteria as proposed.

Again, the prioritising of previously development land in all circumstances may not be the most sustainable and/or viable option for encouraging such development.

The requirement for existing and proposed employment generating sites to be safeguarded must be subject to the proper consideration of the likelihood of such uses continuing/coming forward in the future as per the advice in PPS4. In the absence of the proposed Site Allocations DPD and the SPD for the masterplanning/phasing requirement, the right must be reserved to make further representations/objections in this respect once such information is made available. In any event, should an employment-led proposal come forward then that should take precedence over phasing considerations etc if no significant harm would be caused.

The indicative employment land requirements for this policy need to be considered in conjunction with the above comments and therefore it is axiomatic that these may change in the event that such comments prevail.