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We write on behalf of our client, One Hundred Percent Properties as owners of the Former Honiley Airfield, Oldwich Lane, Wroxall. One Hundred Percent Properties welcomes the opportunity to make representations on the emerging policies contained in the Council's New Local Plan Preferred Options (May 2012), particularly Policy PO8 which states that the Council may consider a site-specific policy to facilitate the delivery of employment land through the development of certain identified Major Developed Sites (MDS) within the Green Belt and we would make the following comments.
Background
The land pertaining to our Client's interests is located within the Warwickshire Green Belt and currently benefits from two planning permissions. The first is for a vehicle testing facility (Ref: W/2002/0762) that also permits vehicle demonstrations and driver training, dating back to 2002. The second is an extant planning permission (Ref: W06/0309), known as "The Fulcrum" for B1(b) use on the site to support a specialist automotive Research and Development facility which is the most recent consent and was subject to an extension of time application (Ref: W10/0893) in 2011. The expiry date for the permission is 30th November 2014.
Condition 19 of Planning Permission W10/0893 restricts the use of the buildings to automotive and motorsport research and development, together with ancillary office provision and ancillary low volume developmental production. No other uses are currently permitted, including any other purpose in Class B1(b) or Part B of the Schedule to the Town and Country Planning (Use Classes) Order 2005, (or in any provision equivalent to that Class in any statutory instrument revoking or re-enacting that Order with or without modification). This restrictive condition has affected the marketability of the Site and is the overriding reason why the permission is yet to be implemented.
Response to the New Local Plan
Paragraph 8.22 of the New Local Plan confirms that there is a requirement for in the region of 23 hectares of employment land, based on the approved housing target of 10,800 new homes. In terms of the type of employment uses required, Paragraph 7.10 of the Council's Employment Land Review (2009) states:
"The addition of 10,800 new homes to the District would result in further allocations of employment land being required in order to meet the anticipated demand, in particular for offices and research and development. This reflects the growth aspirations of Warwick District Council which focus on the knowledge based, advanced engineering and research and development sectors. These sectors have a reliance on office accommodation and this is reflected in the high demand forecasts for B1a / B1b."
This need for additional employment land is reflected in Section 8 of the New Local Plan Preferred Options, which relates to the economy. It confirms that the Council are seeking to ensure the availability of a wide range of employment land and buildings to meet the needs of businesses into the future and lists a number of options for the delivery of additional employment uses. Policy PO8 states that one option is:
"Developing a policy framework to support appropriate development at identified Major Developed Sites in the Green Belt which may include site specific policies for Stoneleigh Park, the University of Warwick, Coventry Airport and the Former Honiley Airfield".
Approximately 6.3 hectares of the Former Honiley Airfield site is designated as an MDS on Warwick District Council's Local Plan Proposals Map. This designated land is subject to 'saved' Policy SSP2 of the Warwick District Local Plan 1996-2011 (September 2007), which states that within the specified MDS, '...appropriate limited infilling and redevelopment for employment or other uses identified in the supporting text as being appropriate for each site will be permitted'.
Our Client has been in discussions with interested parties who are keen to occupy the site at the Former Honiley Airfield. Whilst we support the Council's decision to retain the site as an MDS, the current extent of the designation fails to provide potential occupiers with the flexibility they require to operate efficiently, largely due to the fact that the MDS is separated into two distinct parcels of land. The site falls outside the scope of the Joint Green Belt Review and we would request the Council considers extending the MDS designation to include the test track area, which has a previously developed character due to the large areas of hardstanding associated with it. This would provide potential occupiers with the greater flexibility they require and enable an operator to erect essential track-side buildings and equipment that would amount to limited infilling in line with current planning policy.
Paragraph 10.20 in the sub-text for Local Plan Policy SSP2 explains the test track area was not included within the MDS designation due to its 'extent' and 'open character'. This is reinforced in the Local Plan Inspector's Report, which confirms that the Revised Deposit Plan originally showed a larger MDS designation of 8.5 hectares. However, in Paragraph 10.4.16, the Inspector confirms that the boundaries of the MDS should be drawn tightly around the existing buildings and hardstanding areas, and exclude the wooded areas (i.e. Nunley Wood and extensive pine woodland to the north) and remains of buildings and infrastructure that have blended in with the landscape over time, thereby explaining the reduction in size. When the MDS boundaries were being established, The Fulcrum planning permission had not been determined and the Inspector states in Paragraph 10.4.16 that:
"The District Council has confirmed in its evidence that the scale of those proposals is too large to be considered within the framework of Policy SSP2 and that if the planning authority is minded to approve the application it will have to be referred to the Secretary of State to determine whether it should be called in."
The Fulcrum permission has since been granted and the area of pine woodland that the Inspector excluded from the MDS is proposed for large industrial and research buildings under this permission. This demonstrates that there is incongruence between the extent of the MDS Designation and the extent of the built development approved as part of The Fulcrum permission. We would request that, as a minimum,the MDS is updated to reflect the most recent proposals.
Mindful that The Fulcrum permission has not been implemented, we consider that there is an internal logic in enlarging the MDS designation and providing occupiers with a greater degree of flexibility (in spatial and usage terms) as this will improve the marketability of the site and bring economic benefits to the area in line with Planning for Growth and the NPPF. In addition, subject to securing an appropriate investment in the site, there is the potential to deliver a number of on-site environmental improvements, including re-laying the test track with a noise reducing surface and providing noise-attenuating bunds. This would ensure future development is sympathetic to the Green Belt designation and respects the amenity of surrounding residents.
We believe there are a number of additional benefits to securing the occupation of the site. Firstly, the Former Honiley Airfield is a permitted employment site in the Council's Employment Land Review (2009). This confirms that the Research and Development permission will provide approximately 360,000-370,000ft2 of light manufacturing and office floorspace. Secondly, Paragraph 8.21 of the New Local Plan states that 8,253 additional jobs are to be provided through the plan period from 2011-2031. The development would provide significant direct and indirect employment opportunities that would benefit the local economy and this reflects one of the key aims of the NPPF, which is building a strong, responsive and competitive economy. Paragraph 19 of the NPPF states that planning should not act as an impediment to growth and that significant weight should be placed on the need to support economic growth through the planning system. Furthermore, Paragraph 21 of the guidance urges local authorities to 'plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries.'
We recognise that it is only limited infilling and redevelopment that are considered not inappropriate in the context of Policy SSP2, which serves to limit the scale of any potential development within the Green Belt. On this basis, we would encourage the Council to give consideration to the establishment of a site-specific policy for the expanded MDS in line with Policy PO8 of the New Local Plan. This would enable the local authority to maintain a degree of control over future development proposals at the Former Honiley Airfield and enable them to define more precisely the quantum of floorspace and/or the range of uses that would be acceptable at this site. This would assist in overcoming the issues associated with Condition 19 of The Fulcrum Planning Permission. Therefore, we would welcome the opportunity to explore with the Council, the potential to develop a site-specific policy, which would provide the basis for a broader range of employment uses at the site, whilst respecting its location within the Green Belt. We would suggest the following wording for a site-specific policy relating to the Former Honiley Airfield:
Redevelopment and limited infilling of the former Honiley Airfield will be permitted for employment and automotive uses, including works to the test track and associated track side development, consistent with the site's status as a Major Developed Site in the Green Belt.
The above policy would support sub-regional objectives relating to economic development as it is in line with the Coventry and Warwickshire LEP Strategy 5 Year plan (2011-2016). This identifies local level, knowledge-driven industries as a priority and seeks to create an environment where it is easy for businesses to start, locate and thrive. It targets certain sectors, including advanced engineering, high value manufacturing and the automotive industries. This is reinforced in Paragraph 8.39-40 of the New Local Plan which states that '...the growth of these sectors must be set in the wider context of delivering a broad based, flexible and diverse economy to ensure that a wide range of employment opportunities are provided'. We consider the above policy would enable desirable automotive industries to occupy the Former Honiley Airfield Site and assist the Council with its wider strategic objectives.
We trust the above comments will be taken into account when producing the final version of this document, and we would wish to arrange an early meeting with you to discuss our comments further. In the meantime, if you have any queries or wish to discuss any of the above in greater detail, please do not hesitate to contact Mark Sitch or myself