Prepared by Jane Terry, BA(Hons), Dip M, MRTPI DLP ......BA(Hons), Dip M, MRTPI Associate Director...

For and on behalf of Appliance City

DEVELOPMENT PLAN SUBMISSION - RESPONSES TO THE INSPECTOR’S MATTERS, ISSUES AND QUESTIONS

In relation to the following matters:

Matter 3, Employment Land Provision

Bunny Trading Estate, Gotham Lane, Bunny

Prepared by Jane Terry, BA(Hons), Dip M, MRTPI

DLP Planning Ltd Nottingham

NTTS5078/2P November 2018

Response to MIQS – Bunny Trading Estate

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November 2018

Prepared by:

Jane Terry

BA(Hons), Dip M, MRTPI Associate Director

Approved by:

Chris Dwan

BSc, Assoc. RTPI Director

Date: November 2018

DLP Planning Ltd 1 East Circus Street Nottingham NG1 5AF Tel: 0115 896 6620 DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is

confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own

risk.



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CONTENTS PAGE

1.0 RESPONSE TO THE INSPECTOR’S MATTERS, ISSUES AND QUESTIONS (MIQS) 4

APPENDIX A ......................................................................................................................... 10

APPENDIX B ......................................................................................................................... 12

APPENDIX C ......................................................................................................................... 14



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1.0 RESPONSE TO THE INSPECTOR’S MATTERS, ISSUES AND QUESTIONS

(MIQS)

The status of the representation – Objection

MATTER 3 EMPLOYMENT LAND PROVISION

Issue - Does the provision of employment land in Policy 15 (for use classes b1 (a & b)

and new, and relocating industrial and warehouse uses (in Use Classes B1©, B2 and

B8)) accord with Core Strategy Policy 5 and national policy for the Green Belt and is

it justified?

3.1 Would the proposed allocations ensure that the minimum provision of

employment land as set out in Part 1 Policy 5 be achieved?

3.2 Are the proposed specific site allocations justified, effective and consistent with

national policy for Green Belts?

3.3 Are there any significant factors that indicate any of the sites should not be

allocated? Is there a risk that site conditions, infrastructure or access requirements

or constraints …. might prevent development or adversely affect viability and

deliverability?

3.4 In the interest of clarity is it effective to include mixed use allocations under

specific allocation policies and Policy 15 (…. 1.f Former Bunny Brickworks)?

Policy Summary

1.1 Policy 15 Employment Development allocates at 1f) the Former Bunny Brickworks (as part

of a mixed-use development). Criteria 2 confirms that planning permission will be granted

for the expansion, conversion or redevelopment of land and premises for employment uses

on allocated employment sites and other employment sites subject to 3 caveats (use class,

provision of facilities and services to support the functioning of the employment site and the

avoidance of significant impact on the amenity of nearby residents). Criteria 3 refers to the

redevelopment/re-use of existing employment sites and criteria 4 relates to access, parking

and highway safety.



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1.2 Core Policy 5 Employment Provision and Economic Development confirms that the economy

will be strengthened and diversified with new floorspace being provided to meet restructuring,

modernisation and inward investment needs. This is to be achieved through:

1) Providing a range of suitable sites;

3) Identifying and maintaining a supply of good quality land to provide for new and relocating industrial and warehouse uses (in Use Classes B1(c), B2 and B8) across Rushcliffe. As a minimum, 20 hectares of employment land will be identified. We are told that the LPA will work together with other Greater Nottingham authorities to ensure that a sufficient supply of industrial and warehousing land is maintained across the wider economic area;

4) Economic development of a less than significant scale will be delivered in sustainable locations and in accordance with the settlement hierarchy of Policy 3 to ensure a sustainable mix of uses. This is to be identified in the Local Plan Part 2 (Land and Planning Policies) (or Neighbourhood Plans);

6) Encouraging economic development of an appropriate scale to diversify and support the rural economy;

8) Appropriately managing existing employment sites, by:

a) Retaining viable employment sites that are an important source of jobs and cater for a range of businesses particularly where they support less-skilled jobs in and near deprived areas, or have the potential to provide start up or grow-on space; and

b) Releasing poor quality, underused and poorly located employment sites for other purposes.

Objection Summary

1.3 In this response, we are particularly concerned with the allocation of Bunny Brickworks

(Policy 15, 1f). We consider that the provision of employment land in Policy 15 (for use

classes b1 (a & b) and new, and relocating industrial and warehouse uses (in Use Classes

B1©, B2 and B8)) accord with Core Strategy Policy 5 and national policy for the Green Belt

and is it justified?

1.4 Our objections are however, twofold – i) The omission of adjacent land at the Bunny Trading

Estate from Policy 15, 1f) and ii) the corresponding failure to remove the Bunny Trading

Estate from the Green Belt designation.

1.5 Our response in relation to Matter 3 Employment and specifically Policy 15 inter-relates with

Matter 2 Housing Land Supply and specifically Policy 23 for the mixed-use allocation of

Bunny Brickworks proposes to allocate Bunny Brickworks for the redevelopment of around

100 homes. I set out our response to the housing elements in separate submissions but due



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to the inter-relationship between the issues surrounding these policies, much of this response

will be similar in nature.

Reasoning

1.6 We consider that the provision of employment land in Policy 15 (for use classes b1 (a

& b) and new, and relocating industrial and warehouse uses (in Use Classes B1(c), B2

and B8)) accords with Core Strategy Policy 5 for the following reasons:

1.7 Policy 15 supports Core Policy 5 Employment Provision and Economic Development in its

objective to strengthen and diversify the economy with new (and improved) floorspace,

through identifying additional sites to meet restructuring, modernisation and inward

investment needs. The list of sites to be allocated through Policy 15 provides a range of

suitable sites both in terms of character and location, in sustainable locations to ensure a

sustainable mix of uses. Core Policy 5 confirms that such sites should be identified through

the Local Plan Part 2 i.e. through Policy 15.

1.8 Bunny has been assessed as a settlement with a good range and basic level of community

services and facilities within it and as such was considered within the Paper – Identification

of Additional Settlements Background Paper, February 2017, as potentially suitable for

additional housing. Bunny benefits from the provision of a primary school, village hall, local

convenience store, petrol filling station, public house and a regular half-hourly bus service

and was identified as having greater accessibility to services than some other villages.

Nevertheless, due to not having the full range of day to day services and facilities (lack of a

post office and GP surgery), it was considered to be sustainable only for limited housing

development. The allocation of the former Bunny Brickworks site for mixed-use development

will therefore comply with this caveat whilst supporting the local rural economy and increasing

the overall sustainability of Bunny through the provision of additional employment

opportunities for local people thus reducing the need for travel. The increased spending

power of both new residents and workers at the site will also support the local facilities and

services already provided within Bunny and will encourage the provision of new ones.

1.9 Core Policy 5 also seeks to encourage economic development of an appropriate scale to

diversify and support the rural economy, an aspiration which again, Policy 15 supports

through the selection of 15, 1f). As previously developed land, this allocation will facilitate it

being brought back into productive use at a scale appropriate to the locality and the mixed-



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use nature of this allocation will assist in diversifying and supporting the rural economy of

Bunny as set out above.

1.10 The site adjoins the existing Bunny Trading Estate and it is logical to rationalise the proposed

Policy 15, 1f) allocation boundary to incorporate both sites.

1.11 Inclusion of the Bunny Trading Estate within Policy 15, 1f) will also contribute towards the

retention of and strengthen its position as a viable employment site providing an important

source of local jobs particularly as it supports less-skilled jobs (Criteria 9a).

1.12 Finally, the allocation of the Bunny Trading Estate in conjunction with the former Bunny

Brickworks site for mixed-use development will not only release a site comprising poor

quality, unused land back into productive use but this in turn will assist the LPA in ensuring

a sufficient supply of industrial and warehousing land is maintained throughout the wider

district. Rather than adversely impacting on the openness of the Green Belt, productive use

of the site has brought about improvements to reinforce the openness of the surrounding

area1. Continuing investment in the Bunny Trading Estate can only continue with certainty

provided through policy allocation.

1.13 We also consider that the provision of employment land in Policy 15 (for use classes

B1 (a & b) and new and relocating industrial and warehouse uses (in Use Classes

B1(c), B2 and B8)) accord with national policy for the Green Belt and is therefore

justified.

1.14 NPPF 2018 confirms the circumstances where the need for changes to Green Belt

boundaries are justified. Where a need for changes to Green Belt boundaries has been

established through strategic policies (i.e. Policy 5 of the Rushcliffe Core Strategy, Local Plan

Part 1) detailed amendments to those boundaries may be made through non-strategic

policies (NPPF para. 136). Paragraph 137 also goes on to advise that a) as much use as

possible should be made of suitable brownfield sites and underutilised land and b) optimises

the density of development (as in the instance of both Bunny Trading Estate and the former

Bunny Brickworks and the scope that these two brownfield sites present). Para. 138 re-

emphasises this: ‘Where it has been concluded that it is necessary to release Green Belt

land for development, plans should give first consideration to land which has been previously

1 This is evidenced by the photos of the site attached at Appendix B.



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developed and/or is well-served by public transport.’

1.15 Further, para. 139 confirms that b) land which it is unnecessary to keep permanently open

should not be included and f) boundaries should be defined clearly using physical features

that are readily recognised and likely to be permanent (again as evidenced through the two

Bunny sites).

1.16 An addendum Green Belt assessment of additional sites received during the preferred

housing sites consultation was undertaken during the autumn 2017. This additional

assessment included the former Bunny Brickworks but did not include the existing Bunny

Trading Estate which lies immediately adjacent to the former Brickworks. When scored

against the 5 purposes of the Green Belt, inclusion of the former Brickworks was found to be

of low-medium justification (a score of 13). This score compares favourably with the other

sites assessed at East Bridgford (Green Belt sites EBR/I, J, K with comparative scores of 11,

13 and 17) although it should perhaps have been scored even lower; the reason being that

as a previously developed site, with well contained and defensible boundaries, and adjacent

to an existing employment site, it is not likely to constitute or contribute to unrestricted sprawl.

The settlement of Bunny was already identified on the proposals map as an inset village

through the 2014 Green Belt Assessment. As a result of the 2017 Addendum to the Green

Belt Assessment, the Bunny Brickworks site was proposed for allocation

1.17 Neither the proposed allocation of Bunny Brickworks or inclusion of the adjacent Bunny

Trading Estate would be contrary to any of the five purposes of the Green Belt:

• To check the unrestricted sprawl of large built-up areas:

N/A to the Bunny sites – Bunny is not a large built-up area and the two sites do not

contribute to the sprawl associated with any large built-up area.

• To prevent neighbouring towns merging into one another;

N/A There are no towns or even defined settlements in the direction of the two sites,

immediately to the south of Bunny and therefore 2 the two Bunny sites would not have

2 See Appendix A List of investments made during 2018 to the Bunny Trading Estate to consolidate this important rural employment site and improve its appearance within the locality. This on-going investment will be jeopardised unless



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any impact on neighbouring towns merging.

• To assist in safeguarding the countryside from encroachment;

Both sites are previously developed land. In the case of Bunny Trading Estate this is

an operational site which has in recent years received significant levels of investment

both to improve the employment offer and to enhance the character of the site,

cleaning it up and improving its appearance more appropriate within the rural

character of the local area. This purpose is therefore relevant, and the release of

both sites and their allocation within Policy 15, 1f) would be entirely appropriate.

• To preserve the setting and special character of historic towns;

N/A The Addendum Green Belt Assessment 2017 confirms that the site(s) do not

contain or impact on the setting of any statutory or non-statutory heritage assets.

• To assist in urban regeneration, by encouraging the recycling of derelict and other

urban land.

Allocation of the two sites would assist in urban regeneration by encouraging the

recycling of previously developed (and in the case of Bunny Brickworks, derelict) land.

1.18 It is therefore, entirely appropriate within the context of a need to identify sufficient housing

and employment land across the Borough, to remove both sites from the Green Belt.

Remedy

1.19 The remedy sought is for the removal of the Bunny Trading Estate from the Green Belt

designation and its inclusion within the mixed-use allocation at Policy 15, 1f). A Plan

indicating the extent of the enlarged allocation is attached at Appendix C.

some certainty can be confirmed as to the site’s future. Its allocation within Policy 15, 1f) would provide the certainty required.



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APPENDIX A

List of investments made during 2018 to the Bunny Trading Estate to consolidate this important rural employment site and improve its appearance within the locality. This on-going investment will be jeopardised unless some certainty can be confirmed as to the site’s future. Its allocation within Policy 15, 1f) would provide the certainty required. Fully Monitored CCTV system and fully automated security gates, the CCTV covers the perimeter of the estate we add this for a number of reasons, cost £75,000 – - Security, there have been a number break ins on the estate, causing one tenant to closed his

business. - Fly tipping, over the years the site has been used a rubbish dump - Reducing the need to add tall fencing - Reducing vehicle movements at rush hour, password entry allows drivers to leave before traffic

peaks - Discourage unwanted overnight parking and noise Palisade Fence at the front of the estate, cost £12,000. Reasons: - Improves the visual appearance of the estate - Improves security New Site Transformer and internal mains boards, cost £80,000 reason for replacement: - Safety, the previous transformer was 70+ years old and it was suggested would need replacing

as it did not meet current safety standards - Efficiency, the previous transformer was costly to maintain and run - Western Power Distribution, were able to remove old equipment outside our premises which was

vulnerable to collision by large vehicles - 24 hour access required by Western Power, the new transformer has been located at the front of

the estate allowing them safe access at any time - New mains boards added an extra layer of safety for all workers on the estate New Mains Water Supply cost £14,000, reason: - Poor quality drinking water - Adding fire hydrants New Goods In loading Bay, cost £30,000, reason: - Improve efficiency within business - Health and safety less physical interaction loading New well fare facilities cost £25,000, reason: - Staff levels continue to increase - Creating better working environment - Attracting higher calibre business partners



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Approx £250,000 has been spent on the site over the last 14 months which has helped to grow the business by 17% in its last financial year. With an encouraging start to this year a similar growth and increase in staff numbers are anticipated this year. Without the certainty that the site’s removal from the Green Belt and inclusion with the proposed allocation Policy 15, 1f) further improvements on Bunny Trading Estate going forward are unlikely and the company may need to consider relocating, leaving the site.



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APPENDIX B

Bunny Trading Estate – Site Photographs

1) The Site c 2010:

Figs 1&2 : The site in c2010 showing the extent and example of waste left on the site by the previous owner

2) The improved site as it is today following considerable investment over the past 14 months:

Fig 3: Bunny Trading Estate looking south-west from the proposed allocation site



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Figs 4&5: Bunny Trading Estate

Figs 6& 7: Bunny Trading Estate

Fig 8: Bunny Trading Estate



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APPENDIX C

Bunny Trading Estate – Location in relation to proposed Allocation Policy 15, 1f) Bunny Brickworks.

Fig 9: Site Location Plan (Site edged in red, proposed allocation under emerging Policy 23 edged in blue



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Prepared by Jane Terry, BA(Hons), Dip M, MRTPI DLP ......BA(Hons), Dip M, MRTPI Associate Director...

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