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Economic indicators

4.1 The tourism industry dominates the economy of Torbay and some sectors are in decline, including long stay resort tourism. Over-reliance on the industry has led to a predominantly seasonal, low-wage economy with unemployment significantly above the GB average. As a result, Torbay has almost the lowest GDP in the South West. Parts of Torbay exhibit symptoms of severe deprivation, poor employment prospects being a contributory factor.

4.2 Torbay’s employment structure is shown in Figures 16 and 17. These illustrate the significant dependence on part-time service sector employment. Hotels, restaurants and distribution, which largely account for tourism employment, amounted to 32.6% (13,700) of all employees in 1997 - approximately half of service sector employment. At the height of the summer season this figure expands as a result of seasonal employment. In comparison, the South West average for distribution and catering was 21.4% for males and 27.9% for females. The national percentage is 19.9% of males and 25.3% of females (ONS Annual Employment Survey).

4.3 Figure 18 shows the changes in employment in the various sectors between 1991 and 1997, and the increasing importance of the manufacturing sector to the Torbay economy including the ‘hi-tech’ fibre optics sector. During this time, there was a 60% growth in employment in manufacturing, much of which was full-time employment, and its contribution to the GDP of Torbay (13.1%) was comparable with that of tourism, at 13.5% (Nankivell, 1998). However the decline in employment in the opto-electronics sector, particularly the loss of over 5000 jobs at the former Nortel company in Paignton since 2000, was a severe set back for this trend. It has been estimated that that manufacturing only accounted for 8% of Torbay’s output in 2004 (Nankivell 2004 - see below). Manufacturing employment generates approximately the same wealth per employee as tourism does for the three employees. Therefore the importance of the manufacturing sector to the Torbay economy cannot be overstated. There is still a shortage of readily available serviced sites for light industry. It is important that a range of sites is provided to offer business a choice of location and to meet long term needs.

4.4 Employment in the manufacturing industry is nevertheless low compared with other centres of comparable size. The relative proportion of employees in manufacturing in Torbay is set out in Figure 19.

4.5 Office employment (accounted for under the financial services sector) is also under represented, with poor communications and skills, and a shortage of purpose-built office accommodation cited as contributory factors. However, improvements in telecommunications, including the installation of a comprehensive cable network, coupled with Torbay’s justly earned reputation as an attractive place in which to live and its high quality environment, may stimulate office growth during the Plan period.

4.6 Brixham’s main industry is fishing. With the Country’s second highest landings by value (£14.6 million in 2002/3) and third largest by tonnage (8,770 tonnes in 1998, MAFF 2000), Brixham is a major fishing port. Several boats have been de-commissioned in recent years. The fishing fleet operating out of Brixham fluctuates from year to year, but declined from 139 vessels in 1992 to 101 in 2002. Changes following the review of the EU Common Fishing Policy could lead to a further fleet reduction. Around 600 fishermen work in the industry, many of whom are self-employed. Official figures may therefore not fully reflect the extent of economic hardship in the industry. Approximately 1,000 additional people are directly dependent on the fishing industry for their livelihoods. Currently, however, little value is added to the catch locally, with the majority being exported to other parts of the country or abroad almost as soon as it is landed. Scope therefore exists to increase the value of the industry to Torbay.

4.7 One of the key issues facing the economy of Torbay is the need for more jobs. The Council has become increasingly concerned at the level of unemployment, which was over 10% of the workforce throughout the early 1990s. Although unemployment has not reached these levels recently, this is due largely to the low national rate of unemployment and does not indicate a fundamental improvement in Torbay’s position in relation to other areas. Figure 20 indicates that Torbay’s unemployment is consistently significantly higher than the Devon, regional and national average. There are significant seasonal fluctuations in the unemployment rate, due to the reliance on tourism. Figure 21 gives further details of recent unemployment rates by gender.

4.8 An additional problem is the shortage of full-time employment influenced by the large service and care sectors in the economy. One symptom of this is a high rate of male unemployment in Torbay. Under-employment is also a significant concern within Torbay, with a higher than average level of part time employment, particularly among women.

Figure 16: Torbay economic sector by employees

Source: Annual Employees in Employment Survey 1997 - Office for National Statistics.

Figure 17: Torbay employees by economic sector

Source: Annual Employees in Employment Survey 1997 - Office for National Statistics.

Figure 18: Changes in employment in Torbay 1991 - 1997

Source: Census of Employment 1991 and Annual Employment Survey 1997 - Office for National Statistics (ONS).

Figure 19: Employees in manufacturing in Torbay

Source: Office for National Statistics (ONS) Annual Employment Survey 1997.

Figure 20: Unemployment trends in Torbay - a comparison with Devon, South West and UK (percentage unemployment rates)

Source: Annual Employment Survey 1997 - Office for National Statistics (ONS).

Figure 21: Recent unemployment in Torbay by gender

Source: Office for National Statistics (ONS).

4.9 The heavy dependence on tourism and part-time employment is reflected in low wage rates of nearly 30% below the national average. In 2002, average gross yearly earnings in Torbay were £6,919 lower than in England and Wales. Average gross weekly earnings in Torbay were £340.20 in 2002. This was £81.50 less than less than the South West and £127.90 less than the national average. Almost a third of the Torbay’s workforce earned less than £250 a week in 2002; whereas only 20% of South West and 17.7% of national earnings were under £250 per week.

4.10 Another indicator of Torbay’s economic position is its low Gross Domestic Product (GDP). Figures released by the Office for National Statistics highlight that in 1998, Torbay had a GDP of £8,655 per head - only 71% of the national average, with only Cornwall marginally lower in the South West.

Figure 22: Gross Domestic Product per head 1998

Source: Office for National Statistics (ONS).

4.11 The analysis of local, regional and national GDP figures forms the basis of a series of reports on Torbay by Owen Nankivell, an independent economist. His report ‘Towards a Prosperous Torbay Economy’ (1991) concluded that per capita income levels are well below national and regional levels. The document makes a number of suggestions which have relevance for the Local Plan. It advises that in order to attract new businesses as well as more tourists, Torbay should concentrate on achieving excellence in the things that it does well, rather than attempt, perhaps unsuccessfully, to cover all aspects of economic development. Areas such as financial services, hi-tech information technology, plastics production, care for the elderly and the teaching foreign languages are singled out as areas of excellence which would be developed. The Study was updated by ‘The Torbay Economy Revisited’ (Nankivell 1998) which provided further information on the performance of the Torbay economy. Although it found the local economy to have generally functioned well during the mid-late 1990s, it identified a major need to improve Torbay’s infrastructure, particularly the provision of sites to meet the business needs of the future.

4.12 A further report ‘The Torbay Economy 1992-2002- Back to Square One’ (Nankivell 2004) painted a more downbeat picture, reflecting the decline in Nortel. It estimates that output fell by 6.5% in 2002. Manufacturing output was estimated to have fallen by 42%. By way of comparison, output grew on average by 7.3% per year between 1991-2001. The slump in manufacturing led to per capita income falling to 34% below the national average.

4.13 The Council carried out a survey of local businesses in August 1992. The problems which they experienced were:-

• difficulties with transport and deliveries caused by construction sites, poor service roads and the need to improve access into Torbay from outside;

• high land costs;

• problems with neighbouring uses;

• shortage of parking spaces for their own employees and visitors;

• insufficient land for expansion, although about 25% were contemplating extending their premises in the next 3 years; and

• although the majority of local businesses considered training facilities to be adequate, several companies expressed a desire for more specialist training courses in Torbay.

4.14 The first ViewPoint Survey conducted by the Council (1998) highlighted that 77% of Torbay’s young people aged between 16 and 24 felt that they would have to leave the area to develop their careers, due to the lack of well-paid, high quality full-time employment in Torbay. In contrast, only 25% of the same age group felt they had no difficulty in getting a job in Torbay.

4.15 These economic factors in combination have led to Torbay being ranked 97 out of 354 local authorities in England and Wales under the Government’s 1998 Index of Local Deprivation. The DETR Indices of Deprivation 2000 (IMD 2000) do not provide a district wide rank but give a more detailed analysis at ward level. Seven out of Torbay’s 12 Wards (as they stood in 2000) are in the 20% most deprived wards in England. Two of these Wards (Tormohun and Torwood) are just outside the 10% most deprived wards. The IMD 2000 contains six ‘domains’ of deprivation, and indicates 9,483 people in Torbay who are employment deprived (a rank of 90 out of 354 local authorities) and 34,533 people who are indicated as ‘income deprived’ (a rank of 94). The Indices of Deprivation 2004 updated the 2000 indices. It ranks Torbay as the 94th most deprived local authority out of 354 in England. Both income and employment deprivation were ranked the 95th and 94th most deprived out of 354 local authority areas.4.16 Torbay also has the highest proportion of income support recipients as a percentage of the population in the South West (18%) compared with an overall regional average of 11%. This figure also compares unfavourably with a UK average of 14% (Regional Trends 33, ONS 1998). Whilst the figure for income support recipients in Torbay fell to 13% in 1999 (Regional Trends figures), this reflects the general economic buoyancy rather than an improvement in the relative position of Torbay.

The role of the Local Plan

4.17 The Local Plan is only one aspect of the Council’s corporate approach towards assisting the local economy. The Local Plan, of itself, cannot directly provide jobs, although it aims to:-

• provide a framework for the development of sufficient land for industry and commerce, in relation to other aspects which have a bearing on the local economy, such as transport, retailing, town centre development, housing and the quality of the environment;

• establish a strong measure of certainty and stability to enable entrepreneurs and developers to make decisions with confidence; and

• set out proposals and management measures to the environment to attract new investment to Torbay;

• reflect Government Guidance that planning should be a positive tool to promote sustainable development.

The Council’s Economic Development Strategy

4.18 The Local Plan and the Council’s Economic Development Strategy (EDS) relate closely to each other and their objectives dovetail. The strategy aims to diversify Torbay’s economy as a major tourist resort, conference and shopping centre, and to develop its official and commercial potential. The Council’s former Regeneration and European Services Division became part of the Torbay Development Agency in 2003. The TDA is a public/private partnership for the regeneration of jobs, business development, tourism and marine services in Torbay. Regeneration priorities include creating job opportunities, start up of businesses, and training. The TDA in partnership with the Council and other stakeholders is in the process of updating the Economic Development Strategy.

4.19 The Council has undertaken a number of successful initiatives, which have helped the economy since the early 1980’s. These include the development of industrial estates at Broomhill Way and Chatto Road in Torquay, and at Yalberton, Kemmings Close and Long Road in Paignton; redevelopment of Brixham Fish Quay; and marina developments at Torquay and Brixham. Cockington Centre has been developed to promote rural skills.

4.20 The Economic Regeneration Strategy has four main strands:

• To strengthen, improve, and expand the manufacturing base and business sector within the economy, and to capitalise on growth sectors, including developing the ‘Electronic Riviera’ theme.

• To ensure that the area remains one of the UK’s premier tourist resorts and a major conference centre, e.g. through continued promotion and development of the ‘English Riviera’.

• To improve and strengthen the role of the area as a sub-regional shopping centre by developing and enhancing the town centres.

• To facilitate the regeneration of the most deprived areas, though community-led local economic initiatives.

4.21 The Strategy identifies a number of key sites that are considered critical to the economic success to Torbay, where full-time, well-paid employment opportunities can be created. These measures are supported in the Local Plan.

Assisted Area status

4.22 In 1993, Torbay Travel To Work Area (TTWA) was granted Assisted Area Status as an Intermediate Area, under the UK Government’s Regional Selective Assistance Scheme. This is a grant scheme primarily aimed at supporting manufacturing business looking to locate or expand in the area. Since its inception, twenty-nine grants have been awarded in Torbay, totalling £8.19 million, for projects worth over £66 million. These projects have created over 1,400 new jobs, and safeguarded a further 275 jobs.

4.23 Torquay’s travel to work area (TTWA) and the Paignton/Brixham/Totnes TTWAs, extends significantly beyond the boundaries of the Unitary Authority.

4.24 A review of the Regional Selective Assistance map was undertaken by the Government in 1999, and Torbay has subsequently been designated as a Tier 3 Area. These areas are eligible for the Department of Trade and Industry’s Enterprise Grant Scheme, which is targeted at businesses with less than 250 employees. Grants are available up to a maximum of £75,000, on projects with up to £500,000 capital investment.

4.25 The Council has in place an action plan, to maximise the benefits of being designated as an Assisted Area, which aims to:-

• attract new firms from outside the area;

• target the food manufacturing sector to achieve a greater degree of ‘value added’ production and employment;

• liaise with South Devon College, Connexions and training bodies to provide courses for management training and for improving workforce skills.

• work with the private sector in seeking support from the European Union for infrastructure works needed to release new employment land at Yalberton, Paignton to create over 1,000 new jobs; and

• alleviate the unemployment problems which could result from a reduction in fishing, through retraining schemes and concentrating new work opportunities in and around Brixham.

Single Regeneration Budget - A New Deal for Torbay

4.26 A major part of the regeneration of Torbay is the New Deal for Torbay SRB Round 5 Programme. The Council’s SRB bid helped secure £2.66 million towards addressing the economic, environmental, social and community issues facing Torbay. The SRB area covered the Torquay town centre wards of Ellacombe, Tormohun and Torwood. These wards are three of seven wards in Torbay that are currently ranked in the top twenty per cent of deprived wards in England and exhibit many symptoms of severe deprivation (see paragraph 4.15). The SRB area contains Torquay town centre, harbourside business area, residential and tourism accommodation, and embraces about 29,500 residents. The SRB programme is particularly targeted at the area’s 2500 people aged 14-21. SRB funding has now been spent or allocated, largely on neighbourhood renewal projects and the proposed provision of employment starter units.

European Funding

4.27 Between 1994-1999 the southern part of Torbay was designated under Objective 5(b) of the European Structural Funds. This aimed at supporting regions of the European Union which are significantly dependent on declining fisheries and agriculture. 5(b) funding contributed to a range of products in Torbay that have helped maintain the economic base. These developments have included: Long Road, Paignton, Brixham Town Square, Brixham Enterprise Estate, Paignton Community College, Paignton Zoo enhancements and the Goodrington Seashore Interpretation Centre.

4.28 In addition, the European Community Initiative ‘PESCA’, a specific initiative to support the fisheries sector, has supported a wide range of fishing industry and new employment projects in Torbay, including aquaculture grants, training for fishermen, heritage boat projects and sea festivals.

4.29 Following the end of Objective 5(b) and PESCA funding in 1999, six of Torbay’s 12 wards gained eligibility for funding under Objective 2 European Structural Funds. This was the result of Torbay Council working in partnership with Devon County Council, Plymouth City Council, PROSPER and the Devon Districts, in a high profile lobby to obtain Objective 2 status between 2000 and 2006, under an area known as “the Plymouth Devon Arc”. This covers 650,000 people and borders the Objective 1 area in Cornwall. Securing this status could mean as much as £25 million for projects within Torbay, during the Programme period of 2000-2006.

4.30 As a result of this process, and a wide recognition at regional, national and European level of the needs of Torbay, the area has secured Objective 2 eligibility for the wards of St Peter’s with St. Mary’s, Furzeham with Churston, Blatchcombe, Cockington with Chelston, Tormohun and Torwood. In addition, the ward of St Michael’s with Goodrington will be eligible for funding under Objective 5(b) transitional arrangements, to the end of 2005.

4.31 Objective 2 of the European Regional Development Fund covers a range of issues to combat unemployment and regenerate areas of industrial and rural decline. A number of driver groups address specific issues affecting sectors in transition, including Tourism, Agriculture, Fisheries and community regeneration.

4.32 The expansion of the EU means it is likely that the Objective 2 period of 2000-2006 is the last chance for significant restructuring funds from Europe. This represents a crucial window of opportunity for the regeneration of Torbay.

4.33 Torbay is eligible for Objective 3 funding from the EU’s European Social Fund (ESF), which covers employment and retraining issues; and URBAN which covers funding linked to physical regeneration projects.

Other funding issues

4.34 The Torbay Development Agency also provides advice on other funding opportunities. The UK Government provides matched funding via the Regional Development Agency. The National Lottery gives money to a number of ‘good causes’. Smaller grants may also be available for community projects linked to community regeneration and neighbourhood renewal. In addition the TDA is able to provide advice on the availability of grants from other bodies such as the Devon Community Foundation.

Strategic employment provision

4.35 A sustainable balance has to be struck between providing a framework for improving economic prosperity in Torbay and protecting the quality of its environment. The Local Plan Strategy (see Chapter 2) recognises this issue. Current Government guidance, set out in PPG4 ‘Industrial and Commercial Development and Small Firms’ (1992), advises that planning authorities should “aim to ensure that there is sufficient land available which is readily capable of development and well served by infrastructure on a variety of sites available to meet differing needs” (paragraph 6).

4.36 PPG4 also advises on the need for clear land use policies in development plans to achieve this and at the same time secure effective environmental protection. Guidance is given on locating new development where it will minimise the need to travel, reduce congestion and encourage the use of energy efficiency. The location of many industries, especially small-scale developments, within residential areas and the re-use of urban (brownfield) land is also encouraged. The Government is expected to issue revised guidance in the form of Planning Policy Statement 4, in the near future.

4.37 The Local Plan seeks to adopt a sustainable approach to employment developments by seeking to maximise use of brownfield sites and a sequential strategy is set out in Policy ES. However, the pressing need for employment land inevitably necessitates the allocation of some greenfield sites.

Employment land provision

4.38 The Adopted Devon Structure Plan First Review (1999) sets out a strategy for employment. This recognises that the constraints in the Torbay area, which affect the scope for further housing, apply also to employment land. Its objective is to provide for employment at a level consistent with the anticipated growth in population and taking into consideration the high level of unemployment in the area. The Structure Plan provision makes allowance for the need for a structural shift in employment from declining industries such as fishing and tourism to alternative forms of employment.

4.39 The amount of employment land proposed for Torbay in Policy E3 of the adopted Devon Structure Plan First Review is 70 hectares (173 acres) over the period 1995-2011. This makes allowance for the provision for alternative employment in the face of anticipated decline in the fishing and tourism industries. In addition to the above, the Council is also aware of the shortage of available serviced employment land and the urgent need to broaden the employment base with more land for industry, offices and other services. It is essential to identify a wide range and variety of employment sites within Torbay in order to provide opportunities for investment in new businesses, growth among existing companies across the spectrum of business activity and for the attraction of inward investment.

4.40 In order to address Torbay’s worst economic problems and to diversify the local economy, the aim is to provide at least 5000 new jobs within the Plan period. The Council’s total employment land provision falls short of the Structure Plan target of 70 hectares by approximately 7.9 hectares (at 1999). This is due to the shortage of suitable sites, which in turn is a reflection of the high landscape quality of much of the countryside on the fringes of Torbay, the dearth of appropriate brownfield sites and also competition for use of land for other purposes. The take up of new employment land will be monitored closely to see whether an early review of employment land allocation is merited.

New employment areas

4.41 Policy E1 identifies new employment sites in Torbay. Figure 23 below summarises the amount of new employment land identified in the Local Plan.

Figure 23: Torbay employment land provision

Source: Torbay Industrial Monitor April 1999 and Torbay Employment Land Monitor 2004.

Note: *This figure does not include loss of land at Vantage Point, Long Road, Paignton or possible gains of employment land at Yalberton and site of South Devon College, Torquay.

4.42 The heavy existing concentration of employment which can be found along the A3022 Riviera Way/Newton Road corridor reflects its prime locational and access qualities. It is essential that existing employment land and buildings in this highly accessible location are retained and improved. Specific opportunities are identified in the Plan. These will need to be of a high quality, to reflect the prominence of the sites in the ‘gateway’ to Torbay. Policies E1.1(A) and E1.2(B) set out particular considerations at Kerswell Gardens and Riviera Way South (Edginswell) respectively.

4.43 New sites are proposed near the Ring Road in Paignton, at Yalberton, Long Road and Long Road South. These locations are within relatively easy reach of Torquay and Brixham. However, they will also require measures to maximise the use of sustainable means of transport. Policy E1.16(C) sets out particular considerations relating to Yalberton Road. A new major business park (which Torbay does not have at present), is identified at Long Road South, Paignton, and Policy E1.19(D) sets out more detailed policy considerations in relation to this site. There is an important need to attract business and inward investment and for economic diversification. This is especially relevant to obtaining Objective 2 funding.

4.44 There is limited scope to provide sites for new industrial / workshop developments in Brixham. Although there is potential for some refurbishment or redevelopment of the Torbay Trading Estate in New Road, the main allocation is related to the harbourside. Opportunities for the introduction of further employment land may arise in the Brixham Harbour area, subject to the outcome of the study currently being carried out for the Council by consultants. However, the new employment sites in the Yalberton/Long Road area of Paignton are very accessible from Brixham and will help to provide new employment opportunities with relatively low journey to work travel.

4.45 Most of Torbay’s employment sites are suitable for light industry and warehousing. General industrial uses may be acceptable on some sites, provided that they do not cause noise, fumes, smell or other nuisance to adjoining occupiers. The former Lummaton Quarry provides some potential for general industry, although ground conditions and the need to safeguard the SSSI may prevent permanent buildings. Guidance for new employment provision on unidentified sites is set out in Policy E5.

Offices and small businesses

4.46 The Local Plan promotes Torbay as an office relocation centre in line with the Devon Structure Plan First Review. Several office sites are proposed, mainly in and around the town centres in Policy E1. Policy E2 provides general guidance on office development in town centres, often as part of mixed use developments (see also Policy S2). The flexibility of the B1 use class in the 1987 Use Classes Order enables offices (other than financial and professional), research and development uses to locate into traditional industrial areas. Moreover, PPG1 ‘General Policy and Principles’ (1997) (paragraph 8) promotes the principle of mixed use.

Older industrial areas

4.47 Policy E3 designates of some of Torbay’s established industrial locations as Business Investment Areas. These areas are intended to provide a focus for revitalisation and the attraction of fresh investment. However, implementation is likely to depend on partnership arrangements with the private sector.

4.48 In some older districts, such as Ellacombe in Torquay, Coombe Road in Paignton and Castor Road in Brixham, small scale workshops exist alongside established housing. The Local Plan recognises the importance of these pockets of employment to the local economy and aims to consolidate them by designating Small Business Areas where small scale workshops, well related to the main areas of population, can be encouraged (Policy E4). Reduction in the need to travel is central to the Government’s sustainable transport policies as set out in PPG1 (paragraph 8) and PPG13 ‘Transport’ (both 1994 and 2001 versions). However, it is clearly important to limit the activities in these areas to those which will not cause serious loss of amenity to nearby residential areas.

4.49 In recognition of the fact that employment land is a scarce resource in Torbay, Policy E6 seeks to stem the loss of industrial land and buildings to other uses.

The fishing industry and the port of Brixham

4.50 The Local Plan aims to promote a sustainable fishing industry and the port of Brixham (Policy E7), and proposes a small area of further land reclamation adjacent to the Fish Quay. This is intended to help meet the needs of the port and to encourage port related regeneration and employment in the town on a limited scale. This reclamation is envisaged as part of the long term Policy E8 to construct a northern arm breakwater for Brixham harbour, which itself is subject to an environmental impact assessment.

Layout, design and sustainability

4.51 High standards of layout and design along sustainable principles are important in employment areas and the relevant criteria are set out in Policy E9.

4.52 It is anticipated that the number of people who will wish to operate their business from home will increase and Policy E10 sets out a framework to ensure maximum flexibility whilst safeguarding residential amenity.

EMPLOYMENT AND THE LOCAL ECONOMY POLICIES AND PROPOSALS

ES Employment and local economy strategy

The development of a sustainable and competitive business sector in Torbay, comprising office and industrial uses will be implemented through:-

(1) securing a balance in all three towns between:-

- economic regeneration and the protection of environmental quality; and

- new jobs and housing

(2) achieving a wide range of provision to meet the needs of all sectors of the economy, in particular in the transition and growth sectors; and

(3) implementing a sequential approach to make full and effective use of urban sites by:-

- retaining existing employment areas and buildings where that would make efficient use of them;

- securing new business uses on suitable urban sites which are well served by public transport; and

- allocating new business uses on greenfield sites only where there are no suitable or available sites on previously-used land to accommodate the scale and type of development proposed; such sites will be accessible by sustainable transport and sensitive to the character of the surrounding countryside.

Explanation:

4.53 Whilst the need for business sector development is recognised, Torbay has a shortage of greenfield sites and landscape and environmental protection policies limit the availability of suitable land. The employment strategy therefore seeks to meet the need for jobs in as sustainable a way as possible. The retention and improvement of businesses within appropriately located existing business areas will be supported.

4.54 Where possible, new businesses should be located within existing employment or built up areas. It is accepted that this will not always be possible. For example, some uses may harm residential amenity and require locations away from built up areas. Prestige proposals such as business parks require high quality settings and sites of sufficient size to achieve a critical mass. It is accepted that the scope for meeting this need on brownfield sites is limited.

4.55 The Local Plan makes provision for some employment on greenfield sites (see Policy E1). Proposals for employment use of other sites will be considered on the basis of their accessibility via a range of means of transport and must be acceptable in terms of their wildlife and landscape impact. In any event, applicants for proposals on greenfield sites will be expected to demonstrate that the site is accessible to non-car transport and to prepare a travel plan (see Policy T1). In all developments, consideration should be given to any possible impact on groundwater recharge (see Policy EP11).