Greater - Browtowe, and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

This response has been written to address a number of key questions raised by Inspector Jill Kingaby on the Greater Nottingham Aligned Core Strategy as part of the Examination into the soundness of the Plan following written objections previously sent in by me on the ACS and refer solely to policies and proposals relating to Gedling Borough Council

Matter 2: The Spatial Strategy and Housing Policy

Q2 Policy 2 itself appears to be consistent with Nottingham's Core City Status in that the policy promotes a strategy of urban concentration with regeneration. Most development will therefore be located in or adjoining the city of Nottingham itself. It is the interpretation of this policy by Gedling Planners that is inconsistent as it appears to promote greenfield development adjacent to the town of rather than advocate development of sites which would better serve Nottingham City. The proportion of Gedling's homes to be built in or adjacent the Principal of Nottingham at less than 40% is low especially bearing in mind that a substantial majority of the population of Gedling live within the PUA of Nottingham.

It is for this reason that the ACS is unsound where as it now stands the development of sites on the periphery of Gedling Borough are given greater priority for development than more sustainable sites elsewhere in the Borough that are adjacent to or within the Nottingham PUA and comprise mostly of brownfield land.

Q5 Whilst the first paragraph of Policy 2.1 may define that Sustainable development in the plan area will be achieved through a strategy of urban concentration with regeneration etc, etc , it is the interpretation of this policy through the sites defined under Policy 2.3 especially those affecting the borough of Gedling that has given rise to my objections ( See Q6 below ) Here Gedling have identified far too much housing under the remit of sustainable urban extensions especially in the Hucknall area which comprises wholly of greenfield sites principally comprising high grade agricultural land currently farmed and highly productive, whilst failing to bring forward in this document more sustainable brownfield sites in the Borough that could be developed.

Notwithstanding the fact that the Borough of Gedling accommodates Arnold and Carlton in which 80% of the borough live and that 50% of the working population of Gedling work in the , there are no housing sites proposed in or adjoining the Nottingham PUA in Gedling Borough

Instead there are two large Sustainable Urban Extension sites proposed on greenfield land adjacent to the urban area of Hucknall, but 15km away from the City Centre.

To make the plan sound these sites should be deleted from the list of sites under Policy 2.3

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Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Q6. I believe that Gedling Borough Council has failed to identify those sites which are most consistent with the emphasis on urban concentration with regeneration.

In my own response to Policy 2.31 Q4 I made reference to more sustainable alternatives elsewhere in Gedling. Whilst not specifically mentioned in my original response, the site I had in mind was the Gedling Colliery /Chase Farm site where it was made clear by the Inspector at the Examination in Public of the extant Gedling Local Plan (Chapter 2.2 section 136) that: -

'I consider that the Gedling Colliery / Chase Farm development is the borough’s highest priority land release (as explained in more detail elsewhere) and that the capacity of that area should be limited only by the ability to deliver the housing within the plan period'

There is no allocation in the Core Strategy for this site which it is stated as being unlikely to come forward for development in the plan period.

Recent developments have indicated that constraints which previously affected this site (such as the building of a relief road) have progressed significantly since the Inspector made his comments in 2004. There is now clear evidence that all this site (total potential 1120 homes) could be developed before the end of the plan period and this site therefore should be included in the ACS as this would accord far better with the strategy of urban concentration with regeneration.

A further site also not included in the list of sites in Policy 2 which is available for development immediately is Teal Close where again constraints which previously held back development of this site are now thought to have been addressed and a planning application for this site is currently being determined by Gedling Borough Council under planning ref 2013/0546

At present the distribution of sites set out Policy 2 does little to promote development of the most sustainable sites in Gedling which are mostly brownfield sites and situated within the PUA. I believe that Gedling Planners have fallen into a mind set of rigidity in refusing to amend their part of the core strategy to include those sites which more fully accord with the principles of the East Regional Plan policy of concentration on sites in the Principal Urban Area. Indeed I believe this rigidity can be shown in a letter (Appendix 1) sent to elected members dated 10 September where in the penultimate paragraph Mr S Bray, Corporate Director, when announcing the package for the new relief road says: -

'The potential to develop the Gedling Colliery Site does not change the position with regard to our Core Strategy. In particular, we must be able to deliver a five year supply, plus 5%

I also believe that in identifying the SUE sites in Policy 2 acts as a disincentive to promote sites within the PUA and usually brownfield. Aside from the low rate of windfall sites allocated in the plan, the distribution of the sites appears to suggest that planners are promoting green field sites ahead of brown. This also appears to be a view shared by some of the elected members of Gedling Borough Council where the development of a further sites capable of accommodating some 1,315 homes mostly on brownfield sites within the PUA have been identified as the second tranch of sites to be

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

developed behind many greenfield sites included in the first tranch - see Extract from the Evening Post 12th Sept (Attached Appendix 2)

For this reason I do not believe the distribution of sites in Gedling under Policy 2 do accord with strategy highlighted in this policy of 'urban concentration with regeneration' and it is for this reason that the plan is unsound.

Q11. I do not believe the SUE sites around Hucknall (Land North of Lane or Top Wighay) are capable of delivering the required housing in the plan period.

In the case of the land North of Papplewick Lane site, not withstanding the many reasons why this site should not be developed and included in my original submission, it is my belief that the density of the homes proposed by Gedling BC of 50 homes per hectare on this site could not be realistically achieved nor would be desirable. In fact this assumption of 50 homes per hectare was presumably based on the belief that all of the site would be developed. However following pubic consultation undertaken by the Co-op in July 2013, it has come to my attention that the entire site is not under the ownership of one particular individual/group but moreover there are at least three different landowners within the site. The major landowner (the co-op) owns some ten hectares of the site and has in fact proposed that only that part of the site they own is used for housing. Discussions held with them in July 2013 at a pubic exhibition to promote this site for housing confirmed that the owner of the second largest part of this site (four hectares) was not interested in a joint venture with the Co-op. Furthermore no application has been made under the SHLAA process to have the additional part of the site included as a potential development site. To accommodate 600 homes on barely ten hectares of land is unachievable and unrealistic even without other objections against development of this site.

On the Top Wighay site there are also many constraints outlined in my previous submission. To my knowledge the site has already been marketed for several years without a buyer. This may in part due to an oversupply of building land in the Hucknall area included within both Gedling and Ashfield's own Local Plan. There are several new homes sites with four miles of both Top Wighay and North of Papplewick Lane with many builders with homes for sale on an 830 home on the former Grange Farm site, South of Papplewick Lane. Other sites currently being developed in Hucknall include Garden Road and Nottingham Road. How much new housing does one medium size town need?

Ashfield's own objections confirm that based on a realistic delivery rate of 70 units it will take 15 years to develop the site at Top Wighay. Perhaps there simply is no demand for further homes in the Hucknall area?

Also the 30% affordable housing requirement on both these sites appears unrealistic given that the majority of the housing stock in Hucknall is already within Band A & B and will make these sites commercially unattractive. In addition the concentration of so much affordable housing on the periphery of Gedling Borough will do nothing to address the housing needs of its own residents the Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

majority of which live in Arnold and Carlton. By concentrating so much affordable housing in this part of the Borough, the Borough Council fails to provide a sufficient range of affordable housing options throughout the remainder of the borough

Evidence has now come forward to suggest that alternative sites in Gedling Borough have come forward and can be delivered and accord more fully with the strategy shown in Policy 2 of urban concentration with regeneration.

The Core Strategy can be made sound by including both the Teal Close site and Gedling Coliery Chase Farm site as specific sites under Policy 2.3 and removing the two SUE sites around Hucknall.

Q12. NPPF specifies that an allowance in respect of windfall sites can be made where Local planning authorities may make an allowance for windfall sites in the five-year supply if they have compelling evidence that such sites have consistently become available in the local area and will continue to provide a reliable source of supply.

Previously no allowance had been made in core strategy for Gedling Borough for windfall development except for the last five years of the strategy which allowed for a windfall allowance of 40 dwellings per year. Figures obtained from Gedling Borough Council under the FOI Act confirmed that during the years 2002 to 2012 there was a constant and reliable source of housing from this source ranging from 143 in 2008/09 to 379 in 2007/08. This averaged 250 dwellings per year over the ten year period.

To make the plan sound, the windfall allowance should be increased to at least 175 per year if not more, as by definition most windfall sites are usually found within the urban area and are generally brownfield sites. This increase would significantly reduce the number of greenfield sites that need to be found to accommodate future housing requirements in the Gedling area and accord with Policy 2 to ensure most development is concentrated within the main urban area and makes the most efficient use of brown field land

The Plan can be made more sound by increasing the allocation of homes from this source

Q23 . The SUE sites adjacent to Hucknall namely Land North of Papplewick Lane and Top Wighay do not represent the best option for growth. 80% of the residents of the Borough live in Arnold and Carlton, yet a substantial proportion of the new housing growth in Gedling will be targeted in the Hucknall area away from where the majority of residents live and where services will generally be provided by another authority

Inclusion of the Gedling Colliery/ Chase farm site along with development of the current Golf course for housing will release a significant amount of developer contributions which along with other funding identified will allow for the building of the Gedling Access Road. Indeed in a letter dated 10 September addressed to all members of Gedling Borough Council (see appendix 1) it goes on to make the case that the availability of funds provided by a number of stakeholder is a 'major Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

vote of confidence in the borough and reflects the significant growth opportunities (both in terms of new homes and access to new jobs) that this road opens up'.

If the objective of the ACS is to select sites which offer the most opportunity for growth surely it is better to select those sites in which developer contributions from those sites will have an obvious economic boost whilst at the same time will help to secure a much wanted relief road benefiting many of the existing residents of Gedling and boosting travel time to Nottingham. Indeed the letter goes on to state that a planning application for the road is expected by June/July 2014.

Yet this site is currently not included as a strategic site in the ACS despite being capable of being developed in the plan period. In fact and Papplewick Parish Councils are aware of the fact that the developers of the Gedling Colliery site, HCA, have indicated that 300 homes could be built on this site by mid 2014 without the need to construct the entire road (adding to 5 year supply of housing land). Obviously once the road is constructed the capacity of this site is much increased and includes an element of employment land much closer to the existing population of the borough close to existing and efficient public transport links.

In addition the Inspector who carried out the Examination in Public of the extant Gedling Local Plan adopted in 2005 stated in respect of the Gedling Colliery/Chase Farm site that:

'In summary, despite the objections to these housing and employment allocations and the access road that will service them, I conclude that the proposed development at GCCF is an important and desirable part of the Local Plan. I conclude that it should be retained in the Local Plan and afforded the highest possible priority' .

Why this site has not been included as a strategic site in the ACS is a question that can only be answered by Gedling planners but there is no doubt that the Inspector at the EIP in the extant Local Plan saw this site as being preferable to development at either Top Wighay or Land North of Papplewick Lane

Whilst it has been noted that sustainability assessments have been carried out on the Gedling Colliery/Chase Farm site, and North of Redhill/New Farm, I believe the Borough Council has not been sufficiently robust in scoring these appraisals which appear to be scored less highly on some issues than the Top Wighay and North of Papplewick lane sites, whilst commonsense would dictate those same scores should be reversed. I understand that Linby and Papplewick parish council will be writing on this issue in more detail.

It is quite clear that certain sites such as the Mapperley Golf Course/New Farm, Redhill appear to have been rejected for no obvious reasons.

It is my own belief that political interference in this whole process of site selection and scoring has compromised the result, leading to all available sites in Gedling not being fully scrutinised, or in some cases removed from the process.

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Q24. The SUE sites around Hucknall are not suitable sites and my original objections to Policy 2.3bi and 2.3b ii set out my reasons why both these sites should not be developed. It was accepted by the Inspector at the EIP of the Gedling Local Plan that Top Wighay farm should be regarded as 'the safety valve' for the borough's housing land supply.

The following is an extract from his recommendations

'Reluctantly I have concluded more housing land should be allocated if an orderly supply of developable land is to be achieved; some because Gedling Colliery / Chase Farm is unlikely to be completed by 2011. Replacement land also needs to be found for other allocations I am not recommending, principally in the Trent valley (H1, H2 and H3 )';

It seems highly inappropriate that if the ACS is left unchanged, the 'safety valve' will be earmarked as the priority target for development, whilst the sites for which it was 'a reserve' are not to be accommodated in this strategy. As the constraints which threatened to prevent development of the Gedling Colliery/ Chase Farm referred to in the Inspectors recommendations have now been addressed along with those at Teal Close, it would be inappropriate to include both the Top Wighay and North of Papplewick Lane sites ahead of those sites which the Inspector at the EIP felt were more sustainable albeit not deliverable in the period up to 2011.

The ACS is currently unsound for this reason.

Both Gedling Colliery/Chase Farm site and Teal Close need to be included as sites under Policy 2.3 and Top Wighay and land North of Papplewick Lane removed.

Q25. I consider that the Teal Close site in Gedling and Gedling Colliery/Chase farm site should be considered as key sites under Policy 2 instead of the sites at Top Wighay and North of Papplewick Lane. These sites fulfil more closely the strategy of urban concentration with regeneration and are located within the built up areas of Nottingham and are mostly brownfeld land. This approach would also be more consistent with NPPF

Regarding the question as to whether public consultation has been carried out the answer is yes as this was a key site in the Gedling Local Plan adopted in 2005.

The following extract is taken from the recommendations of the Inspector who chaired the E I P for the extant Gedling Local Plan who stated

'In summary, despite the objections to these housing and employment allocations and the access road that will service them, I conclude that the proposed development at GCCF is an important and desirable part of the Local Plan. I conclude that it should be retained in the Local Plan and afforded the highest possible priority' .

Yet this site is currently not included as a strategic site in the ACS despite being capable of being developed in the plan period. In fact we are aware that the developers of this site have said that 300

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

homes could be built on this site by mid 2014 without the need to construct the entire Gedling Access Road. Obviously once the road is constructed the capacity of this site is much increased and includes an element of employment land much closer to the existing population of the borough close to existing and efficient public transport links.

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Matter 3: The Green Belt

Q3 All of the site at Top Wighay and the land North of Paplewick Lane has been designated as safeguarded land as a result of the recommendations from the Inspector who resided over the EIP for the extant Gedling Local Plan and in the case of Top Wighay as a last resort in the event that sites at Teal Close and Gedling Colliery/Chase farm were not developed.

In his report the Inspector stated: -

'The first thing I have to say about a policy to control development in areas of Safeguarded Land is that in my view it is very definitely not a housing policy. I say this for three reaso ns. First, its purpose is to control (and prevent) permanent development during the plan period. Second, it is not a foregone conclusion that all (or any) Safeguarded Land will need to be developed – that will depend on the need to find greenfield land for development in future Local Plan reviews. And third, even if development does eventually take place, it may not be housing. ”

Whilst ever there is a readily available swath of safeguarded land at Top Wighay, or Land North of Papplewick Lane there will remain the temptation to see these sites as a prime target for development 'next time round' as I believe they have been targeted now.

The NPPF also provides guidance in respect of Green Belt and the purposes served by the Green Belt. These include: to prevent neighbouring towns from merging into one another, to assist in safeguarding the countryside from encroachment, to preserve the setting and special character of historic towns, and to assist in urban regeneration by encouraging the recycling of derelict and other urban land.

We would contend that Land at Top Wighay and North of Papplewick Lane continue to fulfil many of the purposes of Green Belt and should continue to remain as so.

A review of the Nottingham/ Green Belt undertaken in 2006 confirmed the green belt to the north of Hucknall was one of the most vulnerable in the county and therefore it would make sense to review the amount of land safeguarded to help reduce that vulnerability. GB policy states that gaps should be several miles wide, yet at present we have a gap which is 200 meters wide at its narrowest point. (Map showing the areas of greatest vulnerability included in appendix 3)

A further function of the Green Belt is the protection of the historic conservation villages of Linby and Papplewick where development on the current safeguarded land would detract from the setting of these villages. We note that in response to the consultation paper previously issued by Gedling BC in 2011 entitled 'Gedling Locally Distinct Housing Issues' English Heritage raised concerns regarding 'the enlargement of Top Wighay Local Plan site allocation into the safeguarded land to the north in terms of the potential impact on the setting of a number of designated assets'. In summary these were setting of three Grade 2* Registered Historic parks & gardens ( Hall, Newstead Abbey and Papplewick hall and the settlements of Linby and Papplewick. They proceeded to state that 'In our response to the Option of Consultation Document in April 2010, we expressed concerns Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance regarding the impact of a strategic urban extension in this location on the setting of a number of designated heritage assets, specifically in the conservation areas of Linby and Papplewick (including many listed buildings and the Grade 2* Registered Historic Park & garden of Papplewick Hall). We remain to be convinced of the suitability of allocating and developing on the safeguarded land in terms of the environmental impact'

In summary therefore any safeguarded land both at Top Wighay and North of Papplewick Lane not earmarked for development within the current plan period should be returned back to the Green Belt to ensure that the green belt to the North of Hucknall continues to be given the highest level of protection and continues to protect the setting and special character of the historic villages of Linby and Papplewick, which both include significant conservation areas and listed buildings.

Finally residents have already lived with the uncertainty of the fate of these sites for almost 20 years. We deserve some respite.

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Appendix 1 - Letter concerning Gedling Access Road Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance Appendix 2 - Extract from Evening Post, September 12 2013

Greater Nottingham - Browtowe, Gedling and Nottingham City Aligned Core Strategy Publication Version June 2012

Response of Mrs Jane Johnson to Inspectors Matters, Issues and Guidance Appendix 3 - Extract from Green Belt Review, 2006

Top Wighay lies partially under label 6 - an area of high importance for green belt purposes