Undesignated Industrial Sites

Undesignated Industrial Sites

Reflecting the latest national policy (NPPF 2024) and the significant losses of industrial land that have occurred in the current local plan period; and the increased demand for industrial accommodation; there is an established need for industrial premises in the district and a chronic shortage, particularly in Bath.  An updated Economic Development Needs Assessment has been undertaken to identify the industrial and warehousing floorspace requirements over the Plan period arising from the increased housing growth requirements.  This shows that overall 17-20ha of industrial land and 14-15ha of land for warehousing and logistics is required for the local plan period 2025 -2043.  In the context of this increased need it is proposed that all existing industrial and warehousing premises should be protected from redevelopment to higher value uses, in particular residential.  Many of the existing smaller scale industrial and warehousing premises are within residential areas or closely related to villages and hence serve a local need and are easily accessible to communities enabling the potential for active travel, and the reduction in commuting distance.

In light of the chronic shortage of industrial and warehouse premises, and the increased requirement for industrial and warehousing floorspace arising from the latest evidence, we propose to strengthen the policy on non-designated industrial sites to provide greater policy protection. In particular we are proposing two options:

The first option ensures redevelopment of all undesignated sites will not be permitted unless the development is for an industrial or warehousing use (classes E(g)(ii),(iii), B2, B8) or builders’ merchants; and would not have an adverse impact on the operation of the remaining premises, site.

The second option reflects the chronic shortage and acute pressure for redevelopment of industrial / warehousing premises to housing and other higher value uses in the Bath planning area. There is an acute need for industrial / warehousing and logistics space in Bath and there has been a significant loss of industrial floorspace in Bath. Due to environmental constraints including the World Heritage Site and National Landscape designations affecting Bath City, the potential expansion of Bath to enable the provision of sites for industrial / warehousing is limited (although two site options are outlined to provide some new space in chapter 5, Bath).

It is proposed therefore in this second option that the above policy protection to undesignated (smaller) sites (ie redevelopment only to industrial and warehousing uses (Use Classes E(g)(ii),(iii), B2, B8), or builders merchants applies only in Bath, and the policy approach criteria consulted on in the Options Document 2023 relating to undesignated sites is maintained, as below.

Where the policy protection in Bath would apply in the second option we will still require evidence on the reason for redevelopment for sites outside Bath as set out in the Options Document in 2024. There may also be the potential to redevelop or intensify the use of some of these sites for industrial and warehouse uses and this will be acceptable in principle. In order to assist with the viability of redevelopment or intensification it may be necessary to incorporate an element of higher value uses. Subject to other policies higher value uses may be acceptable as an element of a proposed scheme, but only where there is no net loss of floorspace on the site that is currently used for or, if vacant, last used for industrial and warehousing purposes. In addition, the higher value uses will exclude Purpose Built Student Accommodation.

Undesignated Industrial Sites – Proposed Options

No Options Advantages Disadvantages
1 Light industrial, heavy industrial, warehousing (classes E(g)(ii),(iii), B2, B8), builders’ merchants will be acceptable in principle. 

Development involving the loss of industrial and distribution floorspace/land will not be permitted unless the development is for a use referred to above; and would not have an adverse impact on the operation of the remaining premises, site.
This would assist in  meeting the forecast need for industrial and warehousing /last mile logistics uses and facilitating the forecast  job growth within the Plan period. This reflects the priorities of the Economic Strategy, supports the growing economic sectors and aligns with housing growth.   We recognise that a change of use of one Class E use to another is not development which requires planning permission. It is in some cases beyond the planning system to resist the loss of Class E light industrial uses to other Class E uses.
2 The following types of development will be acceptable in principle:

a) Light industrial, heavy industrial, warehousing (classes E(g)(ii),(iii), B2, B8), builders’ merchants 

b) Planning permission will not be granted for development that results in a net loss of employment floorspace on undesignated industrial sites within the Bath urban area.

c) Outside the Bath urban area within the rest of the district development involving the net loss of industrial and warehousing/logistics floorspace will need to demonstrate the following:
  • if the premises are vacant the reasons for vacancy
  • evidence that the site has not been made purposefully vacant; -details of maintenance demonstrating that the site has not purposefully been left to disrepair;
  • viability assessment which considers the ability of the current or alternative employment use to continue;
  • marketing evidence to enable the determination of whether there is genuinely no demand to continue in its current planning use; and marketing for one year based on a protocol to be set out. 
The criteria relating to ensuring that the development does not adversely affect remaining industrial uses would be retained.
  • This would assist in meeting the forecast need for industrial and warehousing /last mile logistics uses and facilitating the forecast job growth within the Plan period. This reflects the priorities of the Economic Strategy, supports the growing economic sectors and aligns with housing growth.
  • Smaller scale industrial sites on undesignated sites can provide local employment opportunities.  Lower value units can provide opportunities for foundational economy / service uses such as car mechanics, storage and last mile delivery.      
We recognise that a change of use of one Class E use to another is not development which requires planning permission. It is in some cases beyond the planning system to resist the loss of Class E light industrial uses to other Class E uses.
Last updated 1/10/25