Prologis and E.ON

‘B Station’ site, Hams Hall, Coleshill

Planning Statement

June 2016

Contents

1. Introduction ...... 3 2. The Proposed Developer ...... 4 3. Description of Site and Surroundings ...... 5 4. Relevant Background ...... 8 5. Description of Development Proposals ...... 13 6. Relevant Planning Policy ...... 16 7. Pre-application Consultations ...... 29 8. Assessment of Green Belt Harm ...... 32 9. Assessment of Other Harm ...... 37 10. Need for Employment Land and Benefits of the Proposed Development...... 44 11. Planning Balance – The Case for Very Special Circumstances ...... 52 12. Summary and Conclusions ...... 54

Statement produced by:

Delta Planning 1 Chester Court, High Street Knowle, Solihull, B93 0LL Tel: 0121 285 1244 www.deltaplanning.co.uk

June 2016

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 2 1. Introduction

1.1. This planning statement has been prepared by Delta Planning on behalf of Prologis and E.ON to support an outline planning application for the redevelopment of the former ‘B Station’ site at Hams Hall for industrial/distribution uses.

1.2. The application is supported by a suite of supporting information as follows:

 Planning application forms and ownership certificates;

 Planning application drawing package prepared by MSA and BCA;

 Design and Access Statement prepared by MSA;

 Planning Statement prepared by Delta Planning;

 Employment Land and Market Assessment prepared by Cushman & Wakefield;

 Sustainable Design Statement prepared by Yonder Consulting;

 Environmental Statement, associated Technical Appendices and Non- Technical Summary covering matters relating to landscape and visual impacts, ecology, traffic and transportation, air quality, noise and vibration, flood risk and drainage, ground conditions and socio-economic impacts. The ES is authored by various members of the project team and co-ordinated by Delta Planning;

 Statement of Community Engagement prepared by Connect Communications.

1.3. This statement provides information on the developer (Section 2), describes the site and its surroundings (Section 3), relevant background and planning history (Section 4), the proposed development (Section 5) and the relevant planning policy context (Section 6). Section 7 outlines the pre-application consultations that have been undertaken with the Council, relevant consultees and the public. Section 8 provides an assessment of the site against the five purposes that Green Belts serve. Section 9 then seeks to establish whether any other harm would arise from the development. Section 10 sets out what considerations weigh in the proposals favour, before demonstrating at Section 11 that very special circumstances exist to justify the development. Finally, Section 12 provides a summary and conclusions.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 3 2. The Proposed Developer

2.1. Prologis is a leading provider of industrial and distribution buildings in the UK. Working with retailers, manufacturers and third party logistics operators, Prologis owns and manages 25 million square feet of industrial and logistics space in prime locations across the country. Prologis works hard to attract national and international high calibre businesses into its developments. Some of the customers that occupy its buildings include Sainsbury’s, Jaguar Land Rover, Kuehne & Nagel, BMW, Marks and Spencer and the Co-operative Group, amongst many others.

2.2. Prologis has successfully delivered a number of major developments in Warwickshire and the East and West Midlands with major sites at Coventry, Rugby, Ryton, Birmingham (Midpoint), Stafford and Stoke-on-Trent amongst others. Prologis also own, manage and develop DIRFT (Daventry International Rail Freight Interchange). As a business Prologis therefore has an excellent knowledge of the market and its requirements, including sites with rail freight links.

2.3. As a Real Estate Investment Trust, Prologis takes long-term ownership of its buildings and the surrounding business parks. It pays close attention to the management of its property portfolio while maintaining close relationships with each of its customers.

2.4. Prologis is committed to the principles of sustainability as a business approach, recognising its economic, environmental and social responsibilities to its customers, its employees and the communities within which it operates.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 4 3. Description of Site and Surroundings

The Site

3.1. The site at Hams Hall, known as the ‘B Station’ site, is located in North Warwickshire at the western edge of the Borough. It lies in a highly accessible location close to the motorway network (Jct. 9 of the M42 is circa 1.5km to the west) and within easy reach of the West Midlands conurbation (Birmingham City Centre is approximately 13km to the west).

3.2. The ‘B Station’ site extends to approximately 20 hectares and is the last remaining part of the former Hams Hall Power Station that has not been redeveloped following the final closure of the power station in 1992. The north-western boundary of the site is formed by a railway line, which is located in a cutting. To the east are playing fields, a church and a woodland area. The Hams Hall Manufacturing and Distribution Park adjoins the site to the south-east and south. A National Grid 132kV substation compound is located immediately to the west.

3.3. The site is brownfield and comprises the remaining concrete foundations and basements of the former ‘B Station’ and cooling towers which have been left in situ, a disused tarmac car park and a number of other hardstanding areas associated with the former power station use of the site including areas formerly occupied by the switch houses and electricity sub-station. The majority of the site is fenced by wooden, chain link and palisade fencing.

3.4. There are two remaining buildings on the site. Keepers Cottage, a residential dwelling owned by E.ON is located on the eastern edge of the site and is currently used as accommodation by E.ON employed security staff. There is also a small former maintenance building on the eastern part of the site. The Round House, a domed brick building at the north-western edge of the site, has been excluded from the application site boundary and no changes are proposed to this building.

3.5. A substantial landscaping belt and grassed earth bund runs along the northern boundary of the site with the railway line. There is also a landscaped bund along the southern site boundary with Canton Lane and the adjacent BEKO warehouse. Areas of shrub and grassland as well as scattered trees can be found along the eastern site boundary.

3.6. The former ‘B Station’ site was located on two main development plateaus with the former cooling towers located on the northern part of the site and the power station, coal handling and storage areas located on the southern part of the site. There is a level difference of approximately 1.5 to 1.7 metres with the northern development plateau located at approximately 79.4 to 79.7 metres AOD and the southern plateau located at approximately 78.0 to 78.6 metres AOD.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 5 3.7. Access to the site is gained from existing roads within the Hams Hall Manufacturing and Distribution Park from Canton Lane to the south and an access road from the Faraday Avenue/Edison Road roundabout to the west. Faraday Avenue links into the A446, which provides access to the M6 Toll/M42 at Jct. 9 approximately 1.5km to the north and the M6 at Jct. 4 approximately 6km to the south.

Surrounding Area

3.8. In terms of the surrounding area, the Hams Hall Manufacturing and Distribution Park dominates the area immediately to the south of the site. It is home to a number of manufacturing and distribution uses. Current occupiers include Sainsbury’s, BMW, DHL, BEKO, Chubb, Plastic Omnium and Wincanton.

3.9. The Hams Hall multi-modal interchange is located at the southern end of the existing Hams Hall site and comprises a passenger railway station, bus station and associated car parking.

3.10. The Hams Hall Manufacturing and Distribution Park benefits from an on-site rail freight terminal operated by ABP. It provides daily rail services to and from the ports at Southampton, Felixstowe, Ipswich, Mossend and international services via the Channel Tunnel.

3.11. The town of Coleshill is located towards the south of the Hams Hall Manufacturing and Distribution Park. Other main settlements close by include Water Orton and Curdworth approximately 2km to the south-west and north-west of the site separated from the distribution park and Coleshill by the M42/M6 Toll.

3.12. The landscape to the north and east of the site is more rural in character. There are open agricultural fields to the north of the railway line. There is also some remaining E.ON infrastructure to the north-west of Hams Lane consisting of a sub- station and association pylons and powerlines. The village of Lea Marston is located approximately 1km to the north of the site, with access to the village gained via Hams Lane from Faraday Avenue.

3.13. To the east of Saint John the Baptist Church, which is accessed from Lea Marston via Church Lane, lies a woodland area and beyond that the River Tame and Whitacre Heath Nature Reserve. The Hams Hall Environmental Studies Centre, which consists of a series of buildings and gardens surrounded by woodland and the River Tame, is located to the south of the Church and provides indoor and outdoor learning spaces. Tame Valley Wetlands’ offices are also based at the Studies Centre.

3.14. The villages of Whitacre Heath and Nether Whitacre are located approximately 1.5km and 2.5km respectively to the east of Hams Hall.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 6 Proposed High Speed Railway Line (HS2)

3.15. The application site lies in close proximity to proposed HS2 infrastructure. The proposed HS2 scheme in this area comprises three sections of railway line; the main line, the Birmingham spur and the north chord, which together comprise the triangular ‘Delta’ junction to the east of Coleshill. The ‘Delta’ junction consists of complex viaducts crossing over the M6, M42 and A446.

3.16. The HS2 main line will run immediately towards the west of the Hams Hall Manufacturing and Distribution Park and will cut across Faraday Avenue, the access to the business park, close to its junction with the A446. The proposals involve the temporary diversion of Faraday Avenue during the construction of HS2 and subsequent permanent realignment of Faraday Avenue to pass under the constructed HS2 route.

3.17. During the construction of HS2, a temporary railhead will be built at Kingsbury Road approximately 2km to the north of Hams Hall (referred to as the Kingsbury Railhead). This is a large facility involving a construction yard with circa 30 rail sidings with rail connections to the existing railway network and HS2, which will be operational both during the construction of Phase 1 and 2 of HS2. As part of this construction depot, temporary sidings will also be installed at Hams Lane. The proposals also involve significant new drainage infrastructure off Hams Lane to the north of the Birmingham to Derby railway line.

3.18. The HS2 Hybrid Bill is currently going through parliament and it is expected that it will receive Royal Assent by the end of 2016. Once the Bill receives Royal Assent, and becomes an Act, construction on the scheduled works can start. It is therefore expected that construction activity will commence in 2017 with work on Phase 1 completed by 2026 and on Phase 2 by 2033.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 7 4. Relevant Background

Planning History

4.1. Following the demolition of the former Hams Hall Power Station in the early 1990s, planning permission was granted in 1994 for the redevelopment of the majority of the former power station site as a manufacturing and distribution park. That permission included the rail freight terminal at the southern end of Hams Hall.

4.2. The ‘B Station’ site was not included in the original application and thus fell outside the 1994 planning permission. Whilst it was considered that the removal of the majority of the former power station site from the Green Belt was justified as it enabled the development of a nationally important rail freight interchange, the ‘B Station’ site was not removed as at that time PowerGen (now E.ON) wished to reserve the land for future power generation use. As PowerGen had no specific plans for the ‘B Station’ site and the type and scale of energy generation was not known and could therefore not be tested as part of the EIA, the ‘B Station’ site was excluded from the development proposals and was left within the Green Belt.

4.3. Other than temporary approvals for car storage, the site has no subsequent planning approval.

4.4. In 2004 outline planning permission was refused against officer recommendation for the redevelopment of the ‘B Station’ site for warehousing and distribution (Ref. FAP/20025/0962). The decision notice sets out the following two reasons for refusal:

1. The site is in the Green Belt. It is not considered that very special circumstances of sufficient weight have been put forward to override the presumption against the grant of planning permission for inappropriate development. The proposal is thus contrary to Policy ENV1 of the North Warwickshire Local Plan 1995, Policy ENV3 of the Revised Draft Deposit North Warwickshire Local Plan 2004 and to Government Advice within PPG2 on Green Belts.

2. The proposal is considered to be contrary to Policy I2 of the Warwickshire Structure Plan 1996-2011 in that this proposal would lead to the amount of employment land that is being proposed for North Warwickshire being exceeded by a material degree. Such an over provision if permitted would be likely to cause long term supply problems in the local housing market, and to commuting into the Borough leading to an unsustainable form of development.

4.5. A subsequent appeal was made but later withdrawn as E.ON sought to promote the site through the Local Plan instead.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 8 4.6. A second application for a distribution development was made in 2006 (Ref. PAP/2006/0284), but this was also refused by North Warwickshire Borough Council. The decision notice set out four reasons for refusal:

1. The site is in the Green Belt. The Council is not satisfied that there are very special circumstances put forward by the applicant of such weight to warrant the grant of planning permission for this inappropriate development. The proposal does not accord with the Development Plan, namely Policy GD6 of the Warwickshire Structure Plan (1996-2011); Policy ENV1 of the North Warwickshire Local Plan (1995) and Policy ENV3 of the North Warwickshire Local Plan as Proposed to be Adopted (2006). The Review of the 2004 Spatial Strategy has not reach a material stage for any weight to be attached to the West Midlands Regional Logistics Study (2005), and as such, any decision leading to the inappropriate development of land within the Green Belt on the Study, would be premature.

2. The applicant has not given due regard to the impact of the proposal on the local environment and community, and thus the proposal does not accord with Policy CP10 of the North Warwickshire Local Plan as Proposed to be Adopted nor Policies IMP1 and IMP2 of the 1995 North Warwickshire Local Plan.

3. The Environment Agency is not satisfied that the proposal would not give rise to the potential for increased flooding. As such the proposal is not in accordance with Government Guidance in PPG25, Policy ENV18 of the North Warwickshire Local Plan 1995, or Policy ENV10 in the North Warwickshire Local Plan as Proposed to be Adopted.

4. The Highways Agency direct that planning permission be refused as insufficient information has been provided by the applicant to enable assessment of the vehicular impact of the development upon the Trunk Road and Motorway Network as required by Circular 04/2001.

4.7. An appeal was made but again it was later withdrawn as E.ON sought to promote the site through the Core Strategy instead.

4.8. In January 2012, an application was submitted to Warwickshire County Council for the establishment and operation of a temporary wood processing facility for a period of 5 years (Ref. NWB/12CM004). This application was refused for the following two reasons:

1. The proposed development would be contrary to Policy ENV2 of the North Warwickshire Local Plan 2006 because the development would adversely affect the open character of the area and the proposed use constitutes inappropriate development within the Green Belt as defined by paragraphs 88 to 90 of the NPPF and ENV2 of the adopted Local

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 9 Plan. Furthermore it is considered that sufficiently strong very special circumstances do not exist to outweigh the harm done to the Green Belt by this inappropriate development. In addition, the development would be contrary to the guidance contained within PPS10 relating to development within the Green Belt.

2. The proposed development would be contrary to PPS10, Policies 1 and 6 of the Waste Local Plan and Policy ENV11 of the North Warwickshire Borough Local Plan because the development would not be compatible with adjacent land uses resulting in adverse impacts upon neighbouring occupiers by virtue of dust generation.

Local Plan Promotion

4.9. Since 2003, the site has been promoted through the development plan to seek its removal from the Green Belt and allocation of the land for employment uses.

North Warwickshire Local Plan (adopted in 2006)

4.10. Between 2003 and 2005 E.ON sought to secure an allocation for development in the North Warwickshire Local Plan, but this was unsuccessful. The Inspector concluded that the development of the site was premature as the need for regional logistics land should be considered at the regional level through the Regional Spatial Strategy (RSS) Review.

4.11. At Paragraph 5.49 of his report, the Inspector noted however that proposals may be pursued through the normal development control process if progress on the RSS employment evidence base was not completed. He stated that “Demonstrated regional need would no doubt be of weighty ‘very special circumstances’ in that regard”.

West Midlands Regional Spatial Strategy (RSS) Phase 2 Review

4.12. Between 2004 and 2009 E.ON promoted the site as an expansion to the Hams Hall Regional Logistics Site (RLS) through the West Midlands RSS Phase 2 Review.

4.13. The Panel Report, which was published in September 2009, concluded that four to five new intermodal terminals would be required in addition to the three active terminals at Landor Street, Hams Hall and Birch Coppice.

4.14. In referring to Hams Hall, the Panel Report included the ‘B Station’ site as part of the active terminal. It considered at Paragraph 5.28 that “the additional 20 ha on the B site at Hams Hall and the full potential for a further 40 ha to complete phases 1 and 2 at Birch Coppice to be part of the RSS baseline together with Hortonwood”. The Panel recommended that a new paragraph should be inserted

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 10 at ‘Policy PA9: Regional Logistics Sites (RLS)’ to state that “the full potential for the expansion of the existing RLS at Hams Hall, Birch Coppice and Hortonwood” should be utilised.

4.15. The RSS Stage 2 Review was, however, never formally adopted and the RSS was subsequently revoked in 2013.

North Warwickshire Core Strategy (adopted in October 2014)

4.16. Between 2011 and 2014 E.ON promoted the site for employment uses through the emerging North Warwickshire Core Strategy.

4.17. Early consultations on the Core Strategy identified the ‘B Station’ site for employment development consistent with the RSS Panel Report. This allocation was removed in the 2011 consultation of the Draft Core Strategy and the 2012 Pre-Submission version of the Plan. E.ON consistently submitted objections to the Plan seeking the removal of the site from the Green Belt and its allocation for strategic distribution.

4.18. In January 2014 the Local Plan Core Strategy was subject to an Examination in Public. E.ON was represented at the examination continuing to promote the site for employment uses. Following the publication of the Inspector’s Report in September 2014, the Core Strategy was adopted in October 2014. E.ON was unsuccessful in removing the site from the Green Belt and achieving an allocation for employment use, but only due to a perceived lack of evidence on strategic employment land needs.

4.19. In his report, the Local Plan Inspector acknowledged at Paragraph 46 that “The ELR [Employment Land Review] identifies a significant requirement for additional land for logistics use, a requirement that the Core Strategy does nothing to meet”. However, the Inspector considered that there was insufficient evidence before him to set a requirement for North Warwickshire and stated that a regional perspective would be needed on this issue.

4.20. To address the Inspector’s concerns, a commitment to review the Core Strategy was included within the adopted plan should sub-regional and regional studies on employment land requirements indicate that additional RLS floorspace is required.

4.21. Amendments were also made to the plan to remove the presumption against changes to the Green Belt boundary. This addresses the Inspector’s view that an ‘absolute prohibition’ on Green Belt release may prevent the delivery of development to meet objectively assessed needs.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 11 Summary

4.22. Following the closure of the Hams Hall Power Station and redevelopment of the majority of the complex for employment uses, the ‘B Station’ site was initially retained by E.ON for future power generation. Since 2004, E.ON has promoted the site for alternative employment uses and submitted planning applications for redevelopment of the site in 2004 and again in 2006.

4.23. Since 2003, E.ON has also sought to promote the site for employment uses through the development plan. As the site would satisfy regional requirements, the Local Plan Inspector in 2005 deferred the decision whether to allocate the site to the RSS Phase 2 Review. In September 2009, the RSS Phase 2 Panel Report identified the site as being part of the regional baseline, but as the Phase 2 Review was never adopted this requirement was not included in the Core Strategy. In September 2014, the Core Strategy Inspector acknowledged that there was a substantial need for additional land for logistics use, but again considered that a regional perspective was needed.

4.24. As will be demonstrated later in this Statement, the regional employment evidence base is now available and highlights a significant and urgent need for additional employment land and a severe shortage of supply. This now provides a clear case for the redevelopment of the ‘B Station’ site for employment uses as further set out in the remainder of this Statement.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 12 5. Description of Development Proposals

5.1. The proposal is for an extension to the Hams Hall Manufacturing and Distribution Park. The description of development is as follows:

Demolition of existing buildings and redevelopment of site for industrial/distribution uses (Use Class B2/B8) including ancillary offices and associated parking, highway infrastructure, ground engineering works, drainage and landscaping.

5.2. The application is submitted in outline. Although final access design will be controlled by condition, agreement in principle is sought for access from Canton Lane and off an upgraded (unnamed) estate road from Faraday Avenue.

5.3. Due to the scale and nature of the development, it has been agreed with North Warwickshire Borough Council that the proposals constitute ‘EIA development’ for the purposes of the Environmental Impact Assessment Regulations 2011 (as amended). Accordingly, the proposals have been subject to EIA and an Environmental Statement accompanies this application.

5.4. To enable the development to be properly tested for its environmental impacts, a Development Parameters Plan has been prepared and submitted as part of the planning application. The Development Parameters Plan sets out the core development area, the structural landscaping areas, the use classes required and the maximum scale of development.

5.5. In addition, the application is supported by an Illustrative Masterplan, which demonstrates how the site could be developed within the scope of the principles established by the Parameters Plan. A detailed analysis of the site and the design principles which will be followed is set out in the Design and Access Statement which accompanies this application.

Development Parameters

5.6. The key development principles shown on the Parameters Plan are:

 A Core Development Zone in the centre of the site. New employment buildings will be located in this area together with supporting infrastructure;

 An Outer Development Area located around the Core Development Zone. This will only accommodate supporting infrastructure and could include car parking areas, service roads, small ancillary buildings and yards;

 Structural Landscaping Areas along the site boundaries including significant areas of retained and new landscaping on the northern and eastern edges of the site including areas of surface water attenuation;

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 13  A maximum of 85,000 square metres of employment floorspace (GIA);

 A maximum overall ridge building height of 22 metres for buildings within the Core Development Zone (assuming a finished floor level for the buildings of a maximum of 80 AOD, the overall maximum ridge height would be 102 AOD);

 Occupation of buildings for B2 (General Industry) and B8 (Storage and Distribution) purposes together with ancillary offices;

 Vehicular access points: two are envisaged from the upgraded Estate Road off Faraday Avenue towards the west and two from Canton Lane to the south.

Access and Parking

5.7. Agreement in principle is being sought for access including upgrading of the unnamed Estate Road off Faraday Avenue to the west. The proposals will involve the widening of the Estate Road and provision of pedestrian footways.

5.8. Individual development plots on the site would be accessed from the upgraded Estate Road to the west and from Canton Lane to the south as shown on the Parameters Plan. The final number and position of the access points is to be controlled by condition.

5.9. Car and HGV parking will be provided for each development plot at levels that will be agreed at reserved matters stage, but will generally be in accordance with adopted policy. HGV parking will be provided at levels that ensure the occupiers have sufficient trailer parking on site to avoid HGV parking off site.

5.10. Service yards will be designed to occupier requirements and agreed at reserved matters stage. Security gatehouses may be required to some or all of the development plots to control access and egress to the service yards.

Landscaping

5.11. The application is submitted in outline and detailed matters relating to landscaping are reserved for subsequent approval. However, the Parameters Plan identifies landscaping areas including substantial landscaped buffers along the northern and eastern site perimeters to create a structural landscaping edge to the development providing ecological benefits and visual impact mitigation to Lea Marston to the north and Saint John the Baptist Church to the east. Structural landscaping will also be provided along the southern boundary with Canton Lane complementing and strengthening the existing landscaping along this estate road.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 14 5.12. The structural landscaping areas will also include areas for surface water attenuation.

5.13. Whilst landscaping is a reserved matter, an indicative landscaping masterplan has been submitted with the planning application.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 15 6. Relevant Planning Policy

6.1. Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that the determination of planning applications must be made in accordance with the Development Plan unless material considerations indicate otherwise. This chapter provides a summary of the key planning policies relevant to the determination of this planning application.

6.2. The application site is located within the administrative area of North Warwickshire Borough Council. The current Development Plan for the area comprises the North Warwickshire Core Strategy (2014) and the saved policies of the North Warwickshire Local Plan (2006), which are reviewed in detail below.

6.3. The site is located on the western edge of the Borough and its strategic location adjacent to major transport corridors make this site very accessible from the conurbations of Birmingham and Coventry.

6.4. In April 2016, the Birmingham Plan 2031 was found to be sound by the Inspector appointed to examine it. The Birmingham Plan is likely to be adopted by the Council in summer 2016. The Coventry Local Plan was submitted to the Secretary of State for examination in April 2016. Both these Local Plans are looking to neighbouring authorities including North Warwickshire to accommodate some of their housing and employment land requirements as they do not have the capacity within their own administrative areas to meet objectively assessed needs.

North Warwickshire Core Strategy

6.5. The North Warwickshire Core Strategy was adopted in 2014. The Core Strategy sets out strategic planning policies over a 20 year period to 2029.

6.6. The Core Strategy sets out a number of key objectives including:

 To secure a sustainable pattern of development reflecting the rural character of the Borough by giving priority to re-using previously developed land and buildings within Market Towns and Local Service Centres; recognising regeneration opportunities; reducing the overall need to travel; limiting exposure to flood risk; and protecting the Borough’s environmental assets and rural character.

 To develop and grow the local economy for the benefit of local residents by working in partnership with local businesses, landowners and developers to provide land and buildings; improve infrastructure to support economic development; and by facilitating regeneration initiatives that capture local economic benefits for local residents, especially higher skills aspirations.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 16  To deliver high quality developments based on sustainable and inclusive designs, in order to raise the quality threshold of developments; promote sustainable construction practices and address crime and safety issues.

 To protect and enhance the quality of the natural environment and conserve and enhance the historic environment across the Borough. This will be achieved by securing good sustainable design that addresses environmental issues and safeguarding important environmental, historic and archaeological assets.

6.7. Policy NW2 sets out a settlement hierarchy. Over the plan period it is expected that more than 50% of the housing (including affordable housing) and employment requirements will be provided in or adjacent to the Category 1 Market Towns (outside of the Green Belt) and their associated settlements including Atherstone with Mancetter and Polesworth with Dordon. Coleshill is designated as a Category 2: Green Belt Market Town where development within its development boundary for employment, housing (including affordable housing), services and other facilities will be permitted.

6.8. The application site is located outside the development boundary within the West Midlands Green Belt. Policy NW3: Green Belt is therefore relevant, which defines the extent of the Green Belt in North Warwickshire and seeks to protect it from inappropriate development. The supporting text to Policy NW3 states that the Green Belt is considered to be a vital component in protecting and enhancing the Borough as an area of pleasant countryside, especially by preventing the incursion of nearby urban areas.

6.9. It is important to note that the Pre-Submission version of the Core Strategy stated that no changes will be made to the Green Belt boundaries. However, the presumption against any changes to Green Belt boundaries was deleted in the adopted Core Strategy following the examination of the Plan which highlighted that not all growth proposed in the Core Strategy may be able to be accommodated without a review of Green Belt boundaries.

6.10. In terms of the Borough’s employment land requirement, Policy NW9: Employment states that a minimum of 60 hectares of local employment land will be provided to 2029. This will be directed towards settlements appropriate to their size and position in the hierarchy. Development is required to be appropriate to the scale and size of a settlement and will only occur if there is sufficient infrastructure to support the development.

6.11. The Core Strategy only allocates land to meet local employment requirement. The supporting text to Policy NW9 at Paragraph 7.35 notes that work is being undertaken at both a sub-regional and regional level to consider employment needs on a wider level. It goes on to state that “As and when these reports

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 17 become available their implications for the amount and type of employment provision set out in the Core Strategy will be assessed. Consideration will be given to a review of the relevant Core Strategy policies should any assessment indicate that this is necessary”.

6.12. It is of note that early consultation on the Core Strategy included the application site as an employment allocation as a result of the evidence base and Panel Report from the RSS Phase 2 Review (now abolished). It was only reviewed following the abolition of the RSS.

6.13. Given the nature of the application proposals, the following Core Strategy policies are also considered to be relevant:

 Policy NW10: Development Considerations – seeks to ensure that new development meets the needs of residents and businesses without compromising the ability of future generations to enjoy the same quality of life of the present generation. Development should, amongst other matters:

o be targeted at using brownfield land in appropriate locations reflecting the settlement hierarchy; o be adaptable for future uses and all users; o maintain and improve the provision of accessible local and community services; o encourage sustainable transport, particularly pedestrian access and cycle provision; o provide proper vehicular access and sufficient parking and manoeuvring spaces; o avoid and address unacceptable impacts upon neighbouring amenities; o protect and enhance the natural environment; o manage the impacts of climate change through the design and location of development; o protect the quality and hydrology of ground or surface water sources to reduce the risk of pollution and flooding on site or elsewhere; o not sterilise viable known mineral reserves; degrade soil quality or pose risk to human health and ecology from contamination or mining legacy and ensure that land is appropriately remediated, and o seek to maximise opportunities to encourage re-use and recycling of waste materials (both in construction and operation).

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 18  Policy NW11: Renewable Energy and Energy Conservation – expects new development to be energy efficient in terms of its fabric and use. Major development will be required to provide a minimum of 10% of its operational energy requirements from a renewable energy source subject to viability.

 Policy NW12: Quality of Development – states that all development proposals must demonstrate a high quality of sustainable design that positively improves the character, appearance and environmental quality of an area; deters crime; preserves and enhances the historic environment; conserves and enhances biodiversity; creates linkages between green space and wildlife corridors; and protects existing rights of way.

 Policy NW13: Natural Environment – aims to protect and enhance the quality, character, diversity and local distinctiveness of the natural environment. This is of particular importance within identified landscape character areas. Development should promote a resilient functional landscape able to adapt to climate change.

 Policy NW14: Historic Environment – seeks to conserve and enhance the quality, character, diversity and local distinctiveness of the historic environment.

 Policy NW15: Nature Conservation – seeks to protect Sites of Regional and Local Importance, Sites of Special Scientific Interest (SSSIs), and habitats and features of importance for nature conservation from development having an adverse effect, unless the benefits outweigh the impacts on these sites. Development that damages habitats and features of importance for nature conservation will only be permitted where there are no reasonable alternatives to the development taking place in that location. Overall, development should help to ensure a net gain of biodiversity and geological interest by, firstly avoiding adverse impacts, and alternatively providing mitigation measures. Otherwise, the Local Authority will seek compensation such as biodiversity offsetting as a means to prevent biodiversity loss.

 Policy NW17: Economic Regeneration – states that economic regeneration will be delivered through employment generating uses, such as redeveloping existing employment sites and farm diversification where there is a need to broaden the employment base in order to improve employment choice and opportunities for local people.

 Policy NW21: Transport – seeks transport improvements, particularly through the A5 Strategy, as well as the re-use of redundant railway lines/corridors where appropriate. In regard to High Speed rail, the traffic implications and impact of growth in adjoining areas must be addressed and

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 19 mitigated through the promotion of sustainable transport solutions such as traffic calming and access constraints on the rural road network.

 Policy NW22: Infrastructure – aims to secure the following: provision of affordable housing; protection and enhancement of the environment and mitigation of the environmental impact of both past and proposed development land; provision of essential services, facilities and infrastructure to meet the demands of new development and communities to include Green Infrastructure, open space, sports and recreation and transport; and, provision of training and upskilling opportunities.

North Warwickshire Local Plan (2006)

6.14. The North Warwickshire Local Plan was adopted in July 2006. The majority of the policies (except Core Policies CP4: Green Belt, CP7: Housing Land requirement and CP9: Employment Land requirement) were saved (Secretary of State Direction, June 2009), but many policies have subsequently been replaced in 2014 by the adoption of the Core Strategy. The remaining Local Plan policies of relevance to this application are outlined below.

6.15. The Local Plan identifies Hams Hall as an employment site of regional significance under Policy ECON1: Industrial Site where development in line with existing permissions will be supported. The application site is not covered by Policy ECON1 as it did not form part of the original consent for employment uses. The Local Plan Inspector recognised the potential of the former ‘B Station’ site, but considered that as it would satisfy regional needs it should be considered through the Regional Spatial Strategy (RSS) review (now abolished). At Paragraph 5.49 the Inspector noted, however, that proposals may be pursued through the normal development control process if progress on the RSS employment evidence was not completed. He stated that “Demonstrated regional need would no doubt be a weighty ‘very special circumstance’ in that regard.”

6.16. The Local Plan includes a number of policies aimed at protecting and enhancing the natural and built environment. Relevant saved policies include:

 Policy ENV4: Trees and Hedgerows – restricts the loss of trees, woodlands and hedgerows where these features are of a historical, ecological, townscape or landscape significance, and make a positive contribution to the quality of the local environment. This policy requires planting of new trees, woodlands and/or hedgerows within the landscaping of new development.

 Policy ENV6: Land Resources – The development of contaminated land will not be permitted unless it can be demonstrated that it would not expose the occupier to significant risk, threaten structural integrity of existing or

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 20 proposed buildings on site; lead to the contamination of any watercourse or aquifer; cause contamination of adjoining land or allow such contamination to continue; result in unacceptable environmental conditions for surrounding occupiers during remediation works; or expose the site operatives to unacceptable health risks.

 Policy ENV9: Air Quality and Noise – seeks to safeguard and enhance the Borough’s air quality and prevent noise disturbance by refusing development that would lead to new potentially polluting forms of development within and bordering the Borough’s Air Quality Management Areas (AQMA).

 Policy ENV12: Urban Design – permits development that integrates with both the immediate setting and wider surroundings to present a visually attractive environment; incorporates existing natural features as an integral part of the development; provides spaces to improve the public realm, designed to reduce crime; and external illumination including measures to minimise sky glow, glare and light trespass.

 Policy ENV13: Building Design – states that new development should positively integrate into its surroundings in terms of scale, mass, height and appearance.

 Policy ENV16: Listed Buildings, Non-listed Building of Local Historic Value and Sites of Archaeological Importance – seeks to protect the Borough’s heritage assets.

6.17. With regard to traffic and transportation, the following saved Local Plan policies are of relevance to the consideration of the application proposals:

 Policy ENV14: Access Design – prioritises pedestrians, cyclists and public transport users. New development must demonstrate that it can provide safe vehicular access to the site and that the local road network is able to accommodate traffic to and from the development without problems of congestion, danger caused by the size or number of vehicles or an adverse effect on the character of surrounding development.

 Policy TPT1: Transport Considerations in New Development – requires proposals for major traffic generating uses to submit transportation assessments and travel plans to consider and provide mitigation measures. Development will only be permitted where there would be sufficient capacity within the transport network to accommodate additional traffic which would not cause an increased hazard to traffic safety or detriment to access visibility.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 21  Policy TPT2: Traffic Management and Travel Safety – requires traffic management and travel safety such as calming measures (on and off site) for development proposals where the following is necessary: to mitigate the impact of the development; to increase highway safety; to improve efficiency/ease of movement; reduce congestion and enable environmental enhancements. The design of traffic management and calming measures should consider the character and distinctiveness of the locality.

 Policy TPT3: Access and Sustainable Travel and Transport – requires that a proposal’s siting, layout and design must make provision for safe and convenient pedestrian and vehicular access and circulation, and maximise practicable opportunities for the use of sustainable means of travel and transport such as walking, cycling, bus and train.

 Policy TPT5: Promoting Sustainable Freight Movements and Safeguarding Future Freight Opportunities – recognises the rail freight terminal at Hams Hall as strategically significant. It states that the Council is supportive of proposals which facilitate the increased efficient use of this existing site for the transhipment of goods from road to rail. Future development of sites for industrial, warehousing or transhipment purposes located alongside the canal network or served by existing rail freight facility will not be permitted, unless provision is made to maximise the transportation of their associated goods using these facilities. Development will not be permitted if it would result in the loss of, or impair the use of or access to, any site used for the transhipment of freight by rail or water. Planning permission involving the movement of freight by road will include conditions to prevent disturbance and danger in residential areas or other environmentally sensitive locations.

 Policy TPT6: Vehicle Parking – sets out parking standards for each planning use class. In regard to B2 and B8 uses the minimum and maximum parking standards are set out below.

Use Class Max car Min Min Min impaired parking cycle motorcycle mobility parking parking

B2 Industry 1 per 1 space 1 space, plus Up to 200 100m² per an additional bays: Individual bays 500m² space for for each disabled every 10 employee, plus 2 bays B8 Warehousing 1 per 1 space spaces or 5% of total capacity, 150² per required by whichever is greater. 1000m² maximum car Over 200 bays: 6 bays parking plus 2% of total standard. capacity.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 22 Other Material Considerations

National Planning Policy Framework (NPPF) and NPPG

6.18. The National Planning Policy Framework (NPPF) was published in March 2012 and is a material consideration in planning decisions. The NPPF sets out the Government’s planning policies and how they are expected to be applied.

6.19. The NPPF confirms that the purpose of the planning system is to contribute to the achievement of sustainable development, stating that the policies contained within, taken as a whole, constitute the Government’s view of what sustainable development means in practice.

6.20. It reconfirms that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise. Therefore, proposed development that accords with an up-to-date Local Plan should be approved.

6.21. The principles and approach of the NPPF give a clear pro-development message which includes a presumption in favour of sustainable development at Paragraph 14. The presumption requires Local Planning Authorities to:

 ‘approve development proposals that accord with the development plan without delay’; and

 Where the development is absent, silent or relevant policies are out-of-date, granting permission unless:

o any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or

o specific policies in this Framework indicate development should be restricted.

6.22. The NPPF identifies 12 core planning principles at paragraph 17. Those particularly relevant to the determination of this application are:

 Be genuinely plan-led

 Proactively drive and support sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs;

 Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings;

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 23  Contribute to conserving and enhancing the natural environment and reducing pollution;

 Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable.

6.23. The policy direction within the NPPF follows a number of broad themes which help to ensure that development is sustainable. The key theme relevant to this application is ‘building a strong, competitive economy’.

6.24. The NPPF aims to cut red tape, encourage investment and promote jobs. It stresses that “investment in business should not be over-burdened by the combined requirements of policy expectations”. In drawing up Local Plans, authorities are expected to:

 set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth;

 set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period;

 support existing business sectors, taking account of whether they are expanding or contracting and, where possible, identify and plan for new or emerging sectors likely to locate in their area. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances;

 plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries;

 identify priority areas for economic regeneration, infrastructure provision and environmental enhancement; and

 facilitate flexible working practices such as the integration of residential and commercial uses within the same unit.

6.25. In respect of decision taking, the NPPF states that local planning authorities should look for solutions rather than problems and decision takers at every level should seek to approve applications for sustainable development wherever possible. Local planning authorities should work proactively with applicants to secure developments that improve the economic, social and environmental conditions of the area.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 24 6.26. The application site is located in the Green Belt and Section 9 of the NPPF is therefore relevant. The NPPF reiterates previous national policy relating to the Green Belt and confirms at Paragraph 79 that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.

6.27. Paragraph 80 of the NPPF sets out the five purposes Green Belts serve:

 check the unrestricted sprawl of large built-up areas;

 prevent neighbouring towns merging into one another;

 assist in safeguarding the countryside from encroachment;

 preserve the setting and special character of historic towns; and

 assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

6.28. Paragraph 83 of the NPPF asserts that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. In doing so, local authorities should consider the Green Belt boundaries permanence in the long term, to ensure this is sustained beyond the plan period.

6.29. Paragraph 87–88 of the NPPF establish a presumption against ‘inappropriate development’ (which is, by definition harmful to the Green Belt) and that such development should only be approved where very special circumstances exist. Very special circumstances will only exist where both the harm of ‘inappropriate development’ and any other harm are clearly outweighed by other considerations.

6.30. Paragraph 89 of the NPPF states that the construction of new buildings in the Green Belt should be regarded as inappropriate other than for limited, specified exceptions. The proposed development does not meet any of the listed exceptions and in this regard constitutes inappropriate development in the Green Belt.

Local Plan Review

6.31. In light of changing sub-regional circumstances with regard to development requirements, the Council have commenced a Local Plan Review. This will focus on the Core Strategy’s adopted strategic policies including ‘Policy NW3: Green Belt’ and include site allocations.

6.32. A committee report considering various growth options for North Warwickshire was recently considered by the Council’s Local Development Framework Sub- Committee. The presented growth options are briefly outlined below.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 25 Growth Options for North Warwickshire

6.33. The report to the LDF Sub-Committee clearly acknowledges that the Borough is facing pressures to grow to address needs arising both from within and outside of the Borough. The committee report aims to set out the challenges and present growth options to address the identified needs dealing with the requirements arising from within the Borough separately from the needs arising outside the Borough.

Amount of Growth

6.34. The report states that North Warwickshire will need to plan for at least 5,280 dwellings to accommodate its own housing needs and some redistribution from Coventry. A further 3,790 dwellings might have to provided in the Borough to meet Birmingham’s needs. The overall housing requirement could therefore increase to 9,070 homes (an annual requirement of 454 dwellings).

6.35. The Council’s Employment Land Review (ELR) identifies the need for 58 hectares of employment land to meet local needs (ELR is subject to review and the requirement is likely to increase). A further 43 hectares of employment land might have to be provided in the Borough to meet the requirements of Tamworth and Coventry, who have approached North Warwickshire Borough Council to assist with delivery due to their own capacity constraints.

6.36. The committee report refers to the findings of the Coventry and Warwickshire Employment Land Use Study and the West Midlands Strategic Employment Sites Study, which both identify a significant (wider than local) need for additional employment land, but notes that this need does not necessarily have to be provided within North Warwickshire.

Growth Options

6.37. To address the needs arising from within the Borough, the committee report sets out the following five options:

 IN1: Development in accordance with the Core Strategy settlement hierarchy;

 IN2: Development in and around the Main Settlements. This option includes Coleshill;

 IN3: Focus growth along the A5 Corridor;

 IN4: Development around transport hubs; and

 IN5: New Settlement.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 26 6.38. To address the needs arising from outside the Borough, the committee reports sets out the following five broad options:

 OUT1: Development against the relevant borough, district or city boundary;

 OUT2: Develop in and around the closest settlements;

 OUT3: Add the housing to the overall North Warwickshire Borough figures and distribute according to the preferred option for the whole of the Local Plan;

 OUT4: Development around Public Transport hubs; and

 OUT5: New Settlement.

6.39. The growth options were considered by the LDF Sub-Committee on 25 April 2016. The Council will now undertake a Sustainability Appraisal of these growth options and prepare a draft Local Plan for consultation later in the year.

Site Allocations Draft Pre-submission Plan

6.40. Work previously undertaken with regard to the Site Allocations document will be taken into account in the current review. This includes the Site Allocations Draft Pre-submission Plan, which the Council consulted on from June to August 2014. Key policies and proposals of this consultation document are outlined below.

6.41. The Site Allocations Draft Pre-submission Plan June 2014 sets out the Council’s preferred site options for the strategic delivery of housing, employment, open space and renewable energy throughout the Borough up to 2029.

6.42. With regard to employment land, the Plan refers to the updated Employment Land Review (ELR) published in September 2013, which indicates that the Council needs to deliver 58 hectares of new employment land between 2011 and 2029 to meet local needs. This includes 31 hectares of extant permissions and allocations, thereby leaving 27 hectares of employment land to be allocated through the Site Allocations Plan.

6.43. Paragraph 2.13 notes that the land available to meet employment needs is limited, constrained by the presence of Green Belt across two thirds of the Borough and the necessity to be located close to good road and rail transport links. Consequently, this limits the potential expansion to primarily the A5 corridor surrounding the main settlements at Polesworth/Dordon and Atherstone. The Plan allocates 25 hectares of employment land as available and deliverable in these locations.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 27 6.44. Paragraph 2.11 of the consultation document recognises the Borough’s accessible location within close proximity to major roads and rail transport routes and acknowledges that it is a highly suitable area for logistics and distribution businesses and operations. It is acknowledged that the Borough has previously been identified (in evidence for the abolished RSS) as a suitable location to accommodate some further Regional Logistics growth due to the pressure for expansion and the need to accommodate growth from these industries and supporting industries (including the automotive sector).

6.45. Paragraph 2.23 notes that the evidence supporting the abolished RSS indicated that the former ‘B Station’ site, the last remaining part at Hams Hall, could deliver part of the identified logistics requirement for the Region. However, the draft Plan states that the need for further logistics development will be delivered through the existing consent at Birch Coppice (40 hectares) and other site redevelopment and expansions.

6.46. The Plan states at Paragraph 4.24 that the national need for renewable green energy generation is increasing and considers that the former ‘B Station’ site would provide an appropriate location for energy generation. The Plan retains the ‘B Station’ site in the Green Belt, but identifies it as a potential site for renewable energy generation schemes (excluding Wind or Nuclear) at Policy EMP10. It should be noted that in their consultation response E.ON, the site owners, objected to Policy EMP10 as the site is surplus to E.ON requirements. The site was promoted by E.ON for employment uses.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 28 7. Pre-application Consultations

Pre-application discussions

7.1. Extensive pre-application discussions have taken place with officers at the Council regarding the principle of developing the site for employment uses and the planning application requirements. This has included discussion on the scope of work to be undertaken in the Environmental Impact Assessment.

7.2. In addition to discussions with planning officers, consultation has also been carried out with other relevant stakeholders including the highways department, Highways England, the Lead Local Flood Authority, Environment Agency, utilities companies and Tame Valley Wetlands Trust.

7.3. Meetings have also been held with local Councillors and the local MP to keep them informed of the emerging proposals.

Public exhibition

7.4. Public consultation has also been undertaken consisting of a public exhibition held on 22 March 2016 at Nether Whitacre Village Hall to the east of the Hams Hall.

7.5. The purpose of the consultation event was to present and discuss the emerging proposals with the local community.

7.6. The event was widely advertised. A total of 6,500 leaflets inviting residents to the exhibition were distributed locally covering an area stretching from Marston to the north, Furnace End to the east, Coleshill to the south and Water Orton to the west.

7.7. Representatives of Prologis and the project team covering specialist technical areas such as design, planning, highways, landscape and ecology were present at the exhibition to answer any queries by local residents.

7.8. Comment forms were available and could either be completed at the consultation event or returned at a later date by email or post.

7.9. Approximately 87 people attended the exhibition and 26 comment forms were received in response. Of the 26 feedback forms completed, 21 forms were returned by local residents, one by a local councillor, one by a local business and five by community representatives.

7.10. The majority of respondents who completed the feedback forms were supportive of the ‘principle’ of the proposals; 10 expressed support and a further 5 were supportive ‘with reservations’. 5 respondents did not support the principle of bringing the site back into economic use.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 29 7.11. The following aspects were most often supported both verbally at the exhibition and the written comments:

 Private sector investment;

 New logistics, industrial and manufacturing job opportunities;

 Redevelopment of a derelict, brownfield site;

 On-site HGV parking;

 Environmental and ecological sustainability; and

 High quality landscaping.

7.12. On-site HGV parking and high quality landscaping were seen as very positive aspects of the scheme, with 18 respondents stating that they were supportive of both elements. 15 of the respondents’ feedback forms were specifically positive of the private sector investment that the scheme would provide and 13 were supportive of the new logistics, industrial and manufacturing jobs. There were only two respondents who specifically said that they would prefer to see manufacturing on the site rather than logistics.

7.13. A number of attendees raised objections or concerns which mainly focused on the following issues:

 Impact of additional traffic on the roads and the ability of existing infrastructure to cope;

 Cumulative effects of the scheme and HS2 on the number of HGVs in the area;

 Concerns that the existing HGV parking problems may be exacerbated by the scheme;

 Increased air pollution caused by additional traffic;

 ‘Rat running’ in the surrounding area;

 Noise pollution during construction; and

 Impact on bats nesting near the site.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 30 7.14. A number of respondents made some suggestions to address their concerns with regard to parking, traffic and the environment. These included:

 Funding of traffic calming and speed reduction measures;

 Turning the A446 into a dual carriageway;

 Redevelopment of the site for housing as the area cannot cope with more HGVs;

 Commitment to sustainable ecological and environmental management of site; and

 Working with Warwickshire Wildlife Trust/Tame Valley Wetlands Partnership to develop a flagship sustainable development.

7.15. All comments received from the public consultation have been reviewed by the project team and considered in the refinement of the proposals. Many of the issues raised are covered in the supporting documents accompanying this planning application including issues raised with regard to transport, noise, air quality, ecology and landscaping.

7.16. Full details of the consultations that have been undertaken are set out in the Statement of Community Engagement submitted in support of this planning application.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 31 8. Assessment of Green Belt Harm

8.1. The former ‘B Station’ site at Hams Hall is located in the West Midlands Green Belt. Paragraph 89 of the NPPF states that the construction of new buildings in the Green Belt should be regarded as inappropriate other than for limited, specified exceptions. The proposed development does not meet any of the listed exceptions and in this regard constitutes inappropriate development in the Green Belt.

8.2. Paragraph 87 of the NPPF notes that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.

8.3. To demonstrate very special circumstances it needs to be shown that the potential harm to the Green Belt and any other identified harm are clearly outweighed by other considerations.

8.4. This Planning Statement firstly seeks to define what harm to the purposes of the Green Belt the proposed development would result in. The five purposes are identified at Paragraph 80 of the NPPF as follows:

 check the unrestricted sprawl of large built-up areas;

 prevent neighbouring towns merging into one another;

 assist in safeguarding the countryside from encroachment;

 preserve the setting and special character of historic towns; and

 assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

8.5. The Planning Statement then seeks to determine what other harm might arise from the proposal, before outlining considerations that weigh in the proposed development’s favour.

Coventry and Warwickshire Joint Green Belt Study

8.6. A Joint Green Belt Study was commissioned by six local planning authorities in the West Midlands including Coventry City Council, North Warwickshire Borough Council, Nuneaton and Bedworth Borough Council, Rugby Borough Council, Stratford-on-Avon District Council and Warwick District Council. The study was undertaken by Land Use Consultants (LUC).

8.7. The study was split into two stages. During the first stage of the study, the Green Belt in four of the local planning authority areas (Coventry, Nuneaton and Bedworth, Rugby and Warwick District) was assessed against the five purposes of

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 32 Green Belts. The study findings were published in June 2015. The second stage of the study has considered the Green Belt in North Warwickshire and Stratford-on- Avon. The report findings were published in April 2016.

8.8. The Green Belt Assessment has divided each local authority area into smaller land parcels and broad areas and has then undertaken an assessment of these against the five purposes that Green Belts serve.

Study Findings

8.9. With regard to North Warwickshire, the Green Belt Assessment notes that the Borough contains high-performing and low-performing land parcels, with most parcels considered to be mid-performing against the five Green Belt purposes.

8.10. The application site has been included in Land Parcel CH1, which is defined by the Birmingham-Derby railway line to the north, the River Tame to the east and the existing Hams Hall Manufacturing and Distribution Park to the south and west. It includes the application site, as well as the adjoining playing fields and woodlands and the church, residential property and Hams Hall Environmental Studies Centre to the east of Church Lane.

8.11. Land Parcel CH1 is considered to be one of the low-performing Green Belt parcels, with the Green Belt Assessment giving it a score of 9 out of 20. The assessment considers that this land parcel makes no contribution towards two of the five purposes; it plays no role in safeguarding the countryside from encroachment or preserving the setting and special character of historic towns. The assessment, however, considers that this land parcel makes some limited contribution towards checking the unrestricted sprawl of large built-up areas. The land parcel is also considered to make a significant contribution towards preventing the neighbouring settlements of Coleshill/Hams Hall and Lea Marston merging into one another. All land parcels are given the maximum score with regard to the fifth purpose.

8.12. A summary of the Joint Green Belt Review assessment scores is provided below.

Green Belt Purpose Assessment Score 1. Check the unrestricted sprawl of large built-up areas 1 / 4 2. Prevent neighbouring towns merging into one another 4 / 4 3. Assist in safeguarding the countryside from 0 / 4 encroachment 4. Preserve the setting and special character of historic 0 / 4 towns 5. Assist in urban regeneration, by encouraging the 4 / 4 recycling of derelict and other urban land Total Score 9 / 20

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 33 Site-Specific Green Belt Assessment

8.13. The Joint Green Belt Study has included the application site in the same land parcel as adjoining land (playing fields, church and woodland area), which is very different in land use and character from the application site. It is therefore considered that a site specific assessment is required to fully assess the role the application site plays in preventing urban sprawl by keeping land permanently open (the principal purpose of the Green Belt).

8.14. The application site has been assessed against the five purposes Green Belt serve as set out below.

Purpose 1: To check the unrestricted sprawl of large built-up areas

8.15. The site is a previously developed site which is visually and physically connected to the existing Hams Hall Manufacturing and Distribution Park. It is bounded by existing employment developments to the south-east, south and west and a railway line to the north. Immediately to the east are playing fields, a church and a woodland area beyond which is the River Tame.

8.16. Although the former power station buildings have been demolished, substantial areas of hardstanding and the substructures remain. The site is also largely fenced and a number of light columns are clearly visible on the site. It therefore continues to appear ‘previously developed’ in character.

8.17. Given the above and the fact that the site and the adjoining Green Belt land are clearly contained by physical features (a river, railway line and the existing Hams Hall Manufacturing and Distribution Park), the development of the site would not constitute or risk the further urban sprawl of the built up area of Coleshill/Hams Hall into the open countryside to the north and east.

8.18. Contrary to the Joint Green Belt Study’s conclusion that the parcel has some sense of openness, it is considered that the previously developed nature of the application site and existing site characteristics substantially compromise its openness and that it therefore makes little contribution towards this Green Belt purpose.

Purpose 2: To prevent neighbouring towns merging into one another

8.19. The site lies outside the settlement boundary of the Green Belt Market Town of Coleshill and the adjoining existing industrial estate of Hams Hall (as defined on the North Warwickshire Local Plan Proposals Map), but immediately adjoins it to the north. It therefore plays no role in preventing the merging of Coleshill with Hams Hall.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 34 8.20. The other closest settlements to the site are the villages of Lea Marston and Whitacre Heath. At the closest point there is a gap of approximately 1km between the site and these settlements. Other parts of the existing Hams Hall Manufacturing and Distribution Park lie in closer proximity to Whitacre Heath. However, the whole of the employment park is separated from Whitacre Heath by the River Tame and from Lea Marston by the railway line and playing fields/woodland. The site therefore plays a very limited role in maintaining the boundaries between Hams Hall and Whitacre Heath/Lea Marston.

8.21. The Joint Green Belt Assessment considered that the development of all the countryside between Coleshill/Hams Hall and Lea Marston would give the appearance of merging at the landscape scale. The Study therefore concluded that the land parcel plays an important role in preventing the merging of these two settlements.

8.22. This application largely comprises previously developed land and does not contain any land that could be described as open countryside. Although the proposed development will result in a reduction in the gap between the built-up areas of Coleshill/Hams Hall and Lea Marston, the development will continue to be clearly separated from Lea Marston by woodlands and fields as the eastern part of Land Parcel CH1 will remain in the Green Belt.

Purpose 3: To assist in safeguarding the countryside from encroachment

8.23. The site is a previously developed site that still retains its urban character as large areas of hardstanding and the substructures of the now demolished power station buildings remain on the site.

8.24. The site is surrounded by urban development including the Hams Hall Manufacturing and Distribution Park to the south-east, south and west and a railway line to the north. In addition to these man-made features, the River Tame to the east severs any connections between the site and the wider countryside. The site therefore does not contain and is not well connected to land with the characteristics of open countryside. It is not well contained by permanent features and therefore plays no role in protecting the countryside from encroachment. This conclusion is also supported by the findings of the Joint Green Belt Study.

Purpose 4: To preserve the setting and special character of historic towns

8.25. As the site does not adjoin or lie in close proximity to a historic town, it plays no role in preserving the setting and special character of historic towns. This conclusion is also supported by the findings of the Joint Green Belt Study.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 35 Purpose 5: To assist in urban regeneration by encouraging the recycling of derelict and other urban land

8.26. North Warwickshire is a largely rural borough with limited derelict and other urban land available for development. As demonstrated in the Employment Land Assessment submitted in support of this application, there are no previously developed sites available within the Borough or immediately adjacent urban areas that could accommodate a development of this size. The site’s redevelopment will therefore not inhibit the recycling of derelict and other urban land.

8.27. It is also important to note that the site itself is a previously developed site which retains its urban character. Its redevelopment would secure the recycling of derelict land in an already urbanised location.

8.28. The Joint Green Belt Study has applied a blanket approach to this Green Belt purpose arguing that all parcels make an equally significant contribution by incentivising development on derelict and other urban land within settlements. We disagree with this conclusion for the reasons set out above and maintain that this site plays a very limited role in assisting urban regeneration.

Summary and Conclusions

8.29. The previously developed nature of the site together with the fact that there are very strong visual and physical links with the surrounding employment park wholly compromise the openness of this parcel of Green Belt land.

8.30. Given its previous use and the fact that it is well contained by clear and permanent boundaries, it is considered that the proposed development would not significantly conflict with the purposes of including land within Green Belts. The Green Belt harm is therefore considered to be extremely limited. Indeed the only harm on the Green Belt is, in accordance with Paragraph 87 of the NPPF, its definition as inappropriate development.

8.31. The conclusion that the site performs a limited role with regard to the five Green Belt purposes is supported by the findings of the Joint Green Belt Study.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 36 9. Assessment of Other Harm

9.1. In addition to assessing the proposal’s harm on the Green Belt by reason of its inappropriateness or conflict with the purposes of Green Belts, it is also necessary to assess whether the development would result in any other harm.

9.2. An Environmental Impact Assessment (EIA) has been undertaken to identify any potentially significant effects and to allow appropriate mitigation measures to be incorporated into the proposals. The scope of the Environmental Impact Assessment (EIA) was agreed with North Warwickshire Borough Council. An Environmental Statement (ES) has been prepared and submitted in support of the application. It clearly outlines what residual impacts the development would have following mitigation.

9.3. Based on the findings of the ES, the following section identifies any residual impacts or harm that would arise as a result of the proposed development.

Landscape and Visual Impacts

9.4. A Landscape and Visual Impact Assessment has been undertaken by BCA as part of the Environmental Impact Assessment. It has considered the impact of the proposed development, both during the construction and operational phase, on the landscape and key visual receptors including public rights of way and near-by residential properties.

9.5. The assessment shows that the site is identified as developed land in both the Regional Landscape Character Assessment and the North Warwickshire Landscape Character Area Assessment. Because the site is well contained, the impact of its redevelopment and changes to its landscape character are limited to the site itself and the local landscape.

9.6. The greatest effect on the landscape character will be experienced on the site itself where the presence of buildings, service areas, car parking, drainage attenuation and landscape infrastructure will replace areas of hardstanding, woodland and tree planting. With regard to local landscape areas, the most noteworthy effects will be experienced in close proximity to the assessment site (particularly to the rural landscape to the north around Lea Marston) where the proposals will have a direct effect on existing landscape features or the general character of the landscape.

9.7. The visual assessment shows that from the identified visual receptors, there is currently very limited visibility of the site given the topography of the area and existing vegetation and buildings at the Hams Hall Manufacturing and Distribution Park. The most noteworthy visual effects will be experienced in close proximity to the development to the north-west of the site from Hams Lane and from the existing playing fields directly east of the site.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 37 9.8. To mitigate the visual and landscape impacts of the proposed development, it is proposed to implement a landscape scheme comprising the following key elements:

 Structural landscaping areas to the northern and eastern boundaries including the retention of existing trees and landscaping (where possible) and provision of significant new tree planting;

 Retention of earth bunds along the northern and southern boundary, which will be planted with woodland;

 Landscaping areas on eastern part of the site to include water treatment ponds and drainage attenuation areas.

9.9. In landscape terms, the development will have a minor beneficial impact on the site itself as this derelict land is replaced with a more structured designed landscape and the inclusion of waterbodies will complement the wetland areas further to the east. The main residual impact will be on the rural landscape to the north around Lea Marston, which is considered to be a minor adverse impact following the implementation and maturing of the proposed landscaping scheme.

9.10. As the landscape mitigation proposals and the existing vegetation mature, and the development becomes a more familiar feature in the landscape, the presence of the development will become less prominent in visual terms.

9.11. The resulting visual effect is generally predicted to be negligible from public footpaths. From residential properties in the vicinity of the site very little visibility is available and the residual visual effect is assessed to be negligible. The main impact will be on views from the playing fields immediately to the east of the site and from Hams Lane to the north, which will experience minor/moderate adverse effects at worst.

9.12. Given the limited impact of the proposals and the retention/inclusion of significant areas of landscaping, which will provide a substantial element of mitigation, it is considered that the proposed development complies with Core Strategy Policy NW12 and Local Plan Policy ENV4. There is very limited harm caused by way of landscape and visual impact.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 38 Ecology

9.13. An Ecological Appraisal has been carried out by FPCR as part of the Environmental Impact Assessment.

9.14. It shows that the majority of the site is covered by hardstanding areas associated with the former power station use of the site including the remaining concrete foundations and basements of the former ‘B Station’ and cooling towers, a disused car park and areas formerly occupied by the switch houses and electricity sub- station.

9.15. The majority of the habitats within the application site are considered to be of low ecological value, and the site is not covered by any habitat designations.

9.16. A series of surveys have been carried out to assess the presence/absence of a number of protected species including:

 Bats;

 Great Crested Newts; and

 Reptiles.

9.17. Although a bat roost is present in the Roundhouse (outside the application site boundary), the bat surveys recorded relatively low levels of bat activity across the site. Despite some historic records of Great Crested Newts within the area, none were recorded on the site or the surrounding area during the surveys. Grass snakes were recorded on the site.

9.18. The development will not affect any designated ecology sites and mitigation measures will be put in place with regard to protected species on the site and existing limited features of nature conservation value to ensure they will be protected and enhanced as part of the wider landscaping strategy. Accordingly it is submitted that the proposed development accords with Core Strategy Policy NW10, NW12 and NW15 and saved Policy ENV4 of the North Warwickshire Local Plan, and there is very limited harm to ecology and nature conservation.

Traffic and Transportation

9.19. A Transport Assessment (TA) has been prepared by White Young Green (WYG) in consultation with the local highways authority and Highways England and an assessment of the transport impacts has been carried out as part of the Environmental Impact Assessment.

9.20. The TA demonstrates that the application site lies in an accessible location, which forms part of a wider employment area, and can be reached by sustainable transport modes.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 39 9.21. It is proposed that individual development plots will be accessed from Faraday Avenue via an upgraded estate road or from Canton Lane. The TA shows that the vehicular and pedestrian access proposals are appropriate to serve the proposed development.

9.22. With regard to traffic generation, the TA demonstrates that the proposed development will lead to an increase in traffic using the local and strategic road network, particularly along the estate roads at the Hams Hall Manufacturing and Distribution Park and the Hams Hall roundabout. Mitigation will be required in the form of a third lane to Lichfield Road (A446) southbound approach to the Hams Hall roundabout in order to accommodate the development’s traffic flows. As shown by the transport assessment in the Environmental Statement, the provision of this third lane will reduce the traffic impacts of the proposed development to minor adverse at worst.

9.23. A Framework Travel Plan has been submitted with the application. The purpose of the Framework Travel Plan is to encourage the use of sustainable travel modes including walking, cycling and public transport and thereby reduce traffic generated by the development over time. The Framework Travel Plan requires future occupiers of the proposed employment buildings to appoint a Travel Plan Coordinator, to prepare a detailed Travel Plan and to implement and monitor the agreed provisions.

9.24. The TA and transport assessment in the ES demonstrate that the proposed development will maximise opportunities for sustainable travel, suitable and safe provision can be made for vehicular and pedestrian access and mitigation measures can be put in place to accommodate the traffic generated by the proposed development. It is therefore concluded that the proposal accords with Core Strategy Policy NW10 and NW21 and saved Local Plan Policies ENV14, TPT1, TPT2, TPT3, TPT5 and TPT6, and that the harm caused by traffic flows associated with the development is limited, and not severe.

Noise and Vibration

9.25. The impacts of potential noise and vibration from the development during the construction and operation of the proposed development has been assessed in detail within the Environmental Statement.

9.26. The assessment has considered the potential impact arising from the development on key receptors in the area, specifically near-by residential properties and also the adjacent BMW plant (with regard to vibration).

9.27. The assessment shows that during the construction the most notable impacts will arise during earthworks and the construction of site infrastructure. During the operation of the development, noise sources include building services, deliveries and development traffic including cars and HGVs.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 40 9.28. The assessment demonstrates that the proposed development will lead to a minimal increase in noise and vibration levels at the sensitive receptors both during the construction and operation of the development. Although the potential for impacts are not considered to be significant, a number of mitigation measures are nevertheless recommended including the careful selection of equipment, working methods, monitoring and programme. Specifically with regard to noise, the inclusion of a 2.4 metre high noise barrier along the eastern boundary of the development zone is recommended in circumstances where HGV docking facilities are located along this boundary.

9.29. Given that the proposed development will not give rise to any unacceptable impacts in terms of noise or vibration, it is considered that the proposals comply with Core Strategy Policy NW10 and saved Policy ENV9 of the North Warwickshire Local Plan. There is very limited harm caused in terms of noise and vibration.

Air Quality

9.30. An Air Quality Assessment has been undertaken by WYG as part of the Environmental Impact Assessment.

9.31. The assessment considers the impact of the proposed development on local air quality on a number of sensitive receptors in the area.

9.32. The main impact on air quality during the construction phase of the development relates to dust and particulate emissions arising from on-site activities including demolition, earthworks, construction and associated vehicles movements.

9.33. During the operational phase of the development, local air quality effects would arise from changes in traffic flows associated with the completed development.

9.34. No significant air quality impacts are expected from the construction or operation of the proposed development, and the proposal therefore complies with Core Strategy Policy NW10 and saved Policy ENV9 of the North Warwickshire Local Plan, and accordingly no significant harm is caused in terms of air quality.

Flood Risk and Drainage

9.35. Issues relating to flooding and surface water drainage are also dealt with in detail in the Environmental Statement and accompanying Flood Risk Assessment and Drainage Strategy prepared by RPS.

9.36. The FRA shows that the nearest watercourse to the site is the River Tame, approximately 300 metres east of the site at its nearest point. The site is located in Flood Zone 1 with a low risk of flooding from rivers. Small areas of the site are currently at risk of surface water flooding.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 41 9.37. During the construction of the proposed development surface water run-off from the site could potentially increase due to stockpiled materials on the site with consequential impacts on the water quality of the River Tame. However, through the implementation of a Construction Environmental Management Plan appropriate controls can be put in place to protect the water environment.

9.38. Once the development is operational, there is a risk that silt-laden run-off from hardstanding areas and oil/chemical contamination enters the surface water drainage system and ultimately the River Tame. A concept drainage strategy has been developed which includes a large attenuation basin, which will limit run-off from the site to greenfield run-off rates, thereby providing an improvement on the current situation, and also water quality benefits.

9.39. It is therefore considered that from a flood risk and drainage perspective, the proposals comply with Policy NW10 of the Core Spatial Strategy and will not result in any harm.

Ground Conditions

9.40. Site Investigations have been undertaken by WSP and an assessment of the impacts on ground conditions has been carried out as part of the Environmental Impact Assessment.

9.41. The site surface is generally a mix of hardstanding and grass over topsoil. Areas of hardstanding correspond with former footprints of the turbine hall and cooling towers. Beneath the areas of hardstanding, Made Ground comprising concrete and demolition-fill of bricks and concrete was recorded up to 8m deep. Localised deposits of pulverised fuel ash were found in the south of the site. Superficial River Terrace Deposits comprising gravelly sand were encountered up to 3.0m bgl, across the site, overlying the Mercia Mudstone comprising bedrock of weathered clay and mudstone. There were no visual or olfactory evidence of contamination on site.

9.42. Preliminary observations during the fieldwork did not indicate the presence of gross contamination on site. Detailed chemical analysis of soil and groundwater samples recorded asbestos fibres in Made Ground across the site. It also showed that shallow groundwater is impacted by PAH and TPH in the east of the site, which could indicate a localised soil impact or a point source. The Site Investigation concluded that potentially localised contamination can be found elsewhere on the site within shallow soils, particularly where below ground infrastructure remains in situ.

9.43. It is expected that a remediation strategy will need to be put in place and implemented to ensure that any contamination present on the site is adequately addressed to fulfil the requirements of Core Strategy Policy NW10 and saved Policy ENV6 of the North Warwickshire Local Plan. It is anticipated that there will

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 42 be no harm caused to local ground conditions and indeed the remediation of the site will provide positive benefits to ground water quality.

Summary and Conclusions

9.44. An Environmental Impact Assessment has been carried out, which considers the potential impacts of the proposed development on landscape, ecology, transport, noise/vibration, air quality, flood risk/drainage and ground conditions. The submitted Environmental Statement shows that the proposed development would not have any significant detrimental impacts on the site and its surrounding area. It would therefore result in very limited harm.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 43 10. Need for Employment Land and Benefits of the Proposed Development

10.1. Paragraph 88 of the NPPF stresses that ‘very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

10.2. This section outlines the factors that weigh in the proposals favour looking at the following four considerations:

 There is a significant demand for employment land in the market area. Satisfying such demand is a key aim of the economic growth aspirations of the area.

 There is a critical shortage of high quality land for manufacturing and distribution uses in the market area and a lack of strategic sites that can meet needs in the short term.

 The site is highly suitable for the proposed uses given its location, site characteristics and the existing infrastructure already in place at Hams Hall such that it would constitute sustainable development.

 The site would bring significant economic benefits in terms of employment generation and capital investment in the local area.

Need for Employment Land

10.3. An Employment Land and Market Assessment has been prepared by Cushman & Wakefield and submitted in support of this planning application.

10.4. It shows that there is significant market demand for new industrial and distribution buildings in the West Midlands, particularly within the area within which the application site is located. The demand is fuelled by a resurgent manufacturing industry, led by the automotive sector, and the requirements of retailers and third party logistics providers for additional distribution space. Given the high occupier demand, the West Midlands market has seen high take-up rates of industrial and distribution floorspace over recent years and an increase in rents.

10.5. The application site lies within two overlapping market areas, the Birmingham M42 corridor and the Coventry and Warwickshire market area, and is covered by three employment land studies that have been carried out to assess the demand and supply of employment land within the respective study areas as follows:

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 44  North Warwickshire Employment Land Review (GL Hearn, September 2013). This is currently being updated.

 Coventry and Warwickshire Employment Land Use Study (CBRE, August 2015); and

 West Midlands Strategic Employment Sites Study (PBA/JLL, September 2015.

10.6. All three of these recent studies conclude that there is a substantial need for additional employment land and specifically for strategic sites. They constitute the most up to date evidence base for employment land in the area.

10.7. The North Warwickshire Employment Land Review identifies demand for between 212 hectares (economic forecasts model) and 410 hectares (past trends) of employment land. It concludes at Paragraph 8.5 that “The evidence identifies that there is likely to be relatively significant demand for employment land in the borough; driven particularly by demand for B8 distribution space” and goes on to state at Paragraph 8.6 that “forecasts demonstrate that the land would be required not only by local business growth but also the continuing desire for national companies to locate within the ‘Golden Triangle’”.

10.8. The Coventry and Warwickshire Employment Land Use Study identifies an employment land requirement of 353 to 660 hectares (using different Government recommended methodologies) and concludes that “In particularly there is a need for additional strategic sites that are capable of accommodating the largest B8 requirements, as well as sites for development as R&D sites”.

10.9. The West Midlands Strategic Employment Sites Study identifies the M42 belt as one of the areas of highest demand. It notes at Paragraph 4.87 that “this area is experiencing strong levels of demand from both distribution specialists and a resurgent manufacturing sector”.

10.10. One of the key priorities for North Warwickshire Borough Council and the two Local Enterprise Partnerships (Greater Birmingham and Solihull LEP; Coventry and Warwickshire LEP) covering the market area is to retain, grow and attract businesses to this area. It is widely recognised that failing to provide sufficient sites of the right quality and in the right location will restrict the economic growth potential of North Warwickshire and the wider West Midlands region.

10.11. In its Strategic Economic Plan, the Coventry and Warwickshire LEP acknowledges that the availability of employment sites is fundamental to attracting new investors, retaining local businesses and reshoring of manufacturing. The Coventry and Warwickshire Employment Land Use Study concludes that “Not only is a significant level of employment land required over the plan period, but this has to be of a suitable quality to meet sectoral needs, and be in the right location within

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 45 the LEP area to respond to demographic and market driven demand”. Similarly, the West Midlands Strategic Employment Sites Study highlights that unlocking supply in the areas of highest demand will support economic growth and employment in the manufacturing and distribution industries in the West Midlands by attracting inward investment, encouraging firms already based in the region to grow, expand and diversify in the region, thereby also supporting the suppliers that serve both sectors.

10.12. Increasing pressures are being placed on North Warwickshire to assist neighbouring authorities to meet their local employment land needs. Both Tamworth Borough Council and Coventry City Council do not have sufficient capacity within their own administrative boundaries to meet their local employment land needs and have therefore asked North Warwickshire Borough Council to deliver part of their requirements within the Borough (a total of 43 hectares) as outlined in the report to the North Warwickshire LDF Sub-Committee on 25 April 2016. It is also clear that Birmingham will not be able to accommodate all its development requirements within the City’s boundaries and will therefore be looking to adjoining authorities including North Warwickshire to meet some of its needs. The level and distribution of this growth will be subject to further discussions and negotiations between Birmingham and the adjoining authorities.

10.13. In summary, the employment evidence base for North Warwickshire and the wider sub-region identifies significant demand for new industrial and distribution space, particularly within the market area within which the application site is located.

Shortage of Supply and Lack of Strategic Sites

10.14. The two sub-regional/regional studies that have recently been completed identify a severe lack of immediately available sites to meet the identified demand for new industrial and distribution space.

10.15. The Coventry and Warwickshire Employment Land Use Study concludes that even if all deliverable sites (sites with immediate capacity for B2/B8), secondary potential sites (sites with infrastructure requirements or other constraints restricting deliverability) and potential new strategic sites (sites capable of meeting large scale needs across all employment uses) are taken into account, at 307 hectares the employment land supply is still insufficient to meet the ‘objectively identified need’ in the LEP area and less than half the required land to meet the ‘take-up’ based assessment.

10.16. The West Midlands Strategic Employment Sites Study shows that the Hams Hall ‘B Station’ site is located within the area of highest demand (Area A: M42 Belt) where land supply is particularly tight with only 3.7 years of supply identified.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 46 10.17. The findings of these two studies have been updated by Cushman & Wakefield and an up-to-date analysis of employment land supply is provided in the submitted Employment Land and Market Assessment. This shows that there has been significant activity in the market since the West Midlands Strategic Employment Sites Study was completed and that the supply of immediately available land has further reduced. Cushman & Wakefield consider that there is now only 1.4 years of supply of immediately available land (over 8 hectares/20 acres). There is therefore an urgent need to release further land that can meet employment land needs in the short term.

10.18. The longer term supply looks healthier with Cushman & Wakefield estimating that there are 11.5 years of potential development land available in Area A (Birmingham M42 Belt). This ‘supply’ assumes the ‘B Station’ site at Hams Hall is brought forward. A further 11.1 years of potential supply can be found in Area B which includes Coventry, Rugby and large parts of Warwickshire (outside the M42 Belt).

10.19. Apart from Hams Hall, none of the other potential strategic development sites within Area A can be brought forward quickly as Cushman & Wakefield’s analysis shows:

 Peddimore – This 72 hectare Green Belt site is allocated in the emerging Birmingham Development Plan, which was recently found sound by an Inspector and is likely to be adopted in summer 2016. This development will require significant infrastructure improvements including a new junction off the A38.

 Birmingham International Gateway – This Green Belt site adjoins the allocation at Peddimore. It has no current development plan status and no planning applications have been submitted for this site. The infrastructure requirements are currently unknown.

 Land east of M42 Junction 10 – This 25 hectare greenfield site is located in the ‘Meaningful Gap’ between Tamworth and Polesworth with Dordon/Birch Coppice. A planning application for an employment development on the site was refused in August 2015. An appeal against the decision by North Warwickshire Borough Council to refuse planning permission will be considered at a Public Inquiry in September 2016. 10.20. There is a significant shortage of sites that are immediately available for development and the potential future supply is largely constrained and cannot be brought forward quickly to address demands in the short term. This is recognised by the West Midlands Strategic Employment Sites Study, which notes that “the immediately available component of land supply is inadequate and the potential component is risky, being concentrated in two very large Green Belt sites [Peddimore and Birmingham International Gateway]”.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 47 10.21. Only one site within Area B, Redditch Gateway, could meet some of the short term demand for employment land within this market area. However, the site’s development will do little to meet the demand for new industrial and distribution space along the Birmingham M42 Belt as it serves a different market area. All the other sites within Area B identified by Cushman & Wakefield as potential development land in the Employment Land and Market Assessment are constrained by policy designations (Green Belt), physical or locational characteristics or infrastructure requirements.

10.22. The Coventry and Warwickshire Employment Land Use Study and the West Midlands Strategic Employment Sites Study identify a significant shortage of supply in the short term. The Cushman & Wakefield Employment Land and Market Assessment shows that this situation has already got worse since these studies were published and there is now only 1.4 years of immediately available supply left in the market area (sites of at least 8 hectares/20 acres).

10.23. The supply is critically low and there is therefore an urgent need to bring forward additional sites. It is considered that the ‘B Station’ site at Hams Hall is the only identified strategic site within the market area that can be brought forward quickly helping to address demands for new industrial and distribution floorspace in Area A in the short term.

10.24. In summary, there is a clear recognition that sites of the right quality and in the right location are urgently needed to meet market demand and support the economic growth objectives of the area. Failing to unlock further supply will hold the West Midlands region back from achieving its economic potential.

Suitability of Site

10.25. The ‘B Station’ site is located immediately adjacent to the existing Hams Hall business park, an established manufacturing and logistics location with excellent connections to the strategic road network via the M6, M42, M6(Toll), A38, A446, A5 and A45. Hams Hall benefits from access to a rail freight terminal located at the southern end of the park, which provides daily freight services and currently has capacity to accommodate additional rail freight. The site also lies in close proximity to passenger rail facilities at Coleshill Parkway. Access to the site can be taken off the existing highway infrastructure within Hams Hall.

10.26. The submitted Employment Land and Market Assessment highlights that the site’s excellent accessibility by road and rail and its location at the eastern edge of the West Midlands conurbation make it particularly attractive to potential industrial and/or logistics occupiers seeking to locate or expand their operations in this market area.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 48 10.27. The ‘B Station’ site is a large regularly shaped site that could accommodate a large industrial/distribution building of up to 85,000 square metres, but it could also be brought forward for a number of smaller buildings (perhaps 2 or 3) to respond to market demands. As the Employment Land and Market Assessment shows there are very few sites that can satisfy market requirements for large buildings and none of the other strategic sites can meet demands in the short term.

10.28. The application is accompanied by a Parameters Plan, which sets out the key principles for the future development of the site. A Design and Access Statement has also been submitted which demonstrates that based on the principles established by the Parameters Plan, a high quality employment development can be brought forward on the site with strong visual and physical links to the existing manufacturing and distribution park, but well screened from the more rural surroundings to the north and east.

10.29. The site does not immediately adjoin any residential areas and, as shown in the Environmental Statement, the proposal will not give rise to any amenity issues. A development that operates on a 24/7 basis, a requirement by industrial/distribution occupiers, could therefore be brought forward on the site without raising any significant amenity concerns.

10.30. In terms of the site infrastructure constraints, there is nothing that cannot be dealt with as part of the site redevelopment process. As a previously developed site, some remediation will be required to deal with historic contamination. Appropriate drainage infrastructure will also have to be delivered as part of the development and additional planting will be put in place to reinforce existing landscaping, particularly along the northern and eastern site boundary. Mitigation will also be required to address the traffic impacts of the proposed development. It is however considered that these infrastructure requirements can be satisfactorily addressed as part of the development proposal. There are therefore no significant infrastructure constraints which would hold up the redevelopment of the site.

10.31. The ‘B Station’ site is a previously developed site immediately adjacent to an established manufacturing and distribution location and within easy reach of a large potential workforce drawn both from within the Borough and the wider West Midlands region. As evidenced by the Environmental Statement, the development of this site will not result in any significant residual adverse impacts, but bring substantial economic benefits by helping to meet the pressing demand for strategic employment sites and by providing significant investment and job opportunities as further outlined below.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 49 Economic Benefits

10.32. The socio-economic impacts of the proposed development have been assessed in detail at Chapter 12 of the Environmental Statement. The assessment shows that the proposal will result in significant economic benefits both during the construction and operational phase of the development.

10.33. During the construction phase, it is estimated that the proposed development would generate the following socio-economic benefits:

 Support for significant numbers of jobs in the construction industry with a large proportion of the construction jobs likely to be taken up by the local workforce;

 An estimated £70 million of direct expenditure on the construction of the proposed industrial/distribution development;

 Wider economic benefits and jobs through the impact on the supply chain including for example manufacturing, real estate, transport, planning and survey services;

 Total economic output of £198.8 million.

10.34. Once the development is fully operational, it will create a significant number of new job opportunities. The estimates presented in the Environmental Statement suggest that at least 1,000 jobs could be created at the site. The proposed development will also indirectly support further jobs through the additional local income, expenditure and local supplier purchases.

10.35. Although no end occupier(s) have at this stage been identified for the ‘B Station’ site, a strategic site of this nature is likely to attract large manufacturing companies or logistics providers. Such companies often have well established employee development schemes and offer opportunities for job related training and career progression. Opportunities also exist to work with education providers in the area to improve and extend skills and enable future occupier(s) to recruit appropriately skilled employees in North Warwickshire.

10.36. In addition to creating job opportunities at the site itself and the proposal’s indirect effects on the local economy (its multiplier effect), the proposed development will bring other benefits. It will result in additional business rate income, which the local authority will be able to spend on local people and services. It will also help to reduce crime as it will lead to improvements in the economic activity rate and by making the area more prosperous.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 50 10.37. The application proposals will support the local and regional economic growth agenda by making a previously developed site in a sustainable location available to the market thereby helping to attract new investors to the area and/or enabling local businesses to grow and expand.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 51 11. Planning Balance – The Case for Very Special Circumstances

11.1. As set out in the NPPF the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

11.2. The proposed development is inappropriate development in the Green Belt and, by definition, is therefore considered to be harmful to the Green Belt.

11.3. However, as demonstrated in this Planning Statement, it is considered that the redevelopment of this site would not be in conflict with any of the five purposes for including land in the Green Belt and the harm to the Green Belt is very limited. The site is clearly contained by permanent physical features (the Hams Hall Manufacturing and Distribution Park and the railway line) that prevent any sprawl of the built-up area of Coleshill/Hams Hall into the open countryside to the north and east. Given its location and well contained nature, the site also plays no role in maintaining the boundaries between neighbouring settlements or protecting the countryside from encroachment. As the site does not adjoin or lie in close proximity to a historic town, it plays no role in preserving the setting and special character of historic towns. There are no previously developed sites available within the Borough or immediately adjacent urban areas that could accommodate a development of this size in the short term. The site’s redevelopment will therefore not inhibit the recycling of derelict and other urban land, but would secure the recycling of a previously developed site on the edge of an existing industrial location. The low value of the site to the Green Belt has also been independently verified through the Council’s own Green Belt Study. In conclusion, the proposed development would result in very limited Green Belt harm.

11.4. In terms of ‘any other harm’, an Environmental Impact Assessment has been carried out to identify any significant effects that would arise as a result of the proposed development looking at potential visual and landscape impacts, ecology, transport, air quality, noise, flood risk/drainage and ground conditions. The Environmental Statement shows that the proposed development would not give rise to any significant residual adverse impacts.

11.5. In its favour, the proposed development would help to meet the significant identified demand for new industrial and distribution space thereby supporting the economic growth objectives of the area. As there is a severe shortage of supply to meet market demands and a clear lack of alternative strategic sites in the market area that can be brought forward in the short term, substantial weight should be attached to the proposal’s ability to satisfy the need for high quality employment land.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 52 11.6. Furthermore, the development will result in significant socio-economic benefits in terms of capital investment and job creation both during the construction and operational phase of the development. These benefits are also of significant weight.

11.7. The proposed development is also considered to meet the environmental dimension to sustainable development outlined at Paragraph 7 of the NPPF. It is a previously developed site immediately adjacent to an established manufacturing and distribution location and within easy reach of a large potential workforce drawn both from within the Borough and the wider West Midlands region. A high quality sustainable employment development can be delivered on the site based on the principles established by the submitted Parameters Plan and Design and Access Statement. Full account has been taken of environmental issues through the preparation of an Environmental Impact Assessment. The implementation of mitigation measures identified as part of the application will ensure that an environmentally sustainable development is brought forward.

11.8. The NPPF states at Paragraph 83 that Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. Although a review of the North Warwickshire Local Plan has commenced this is still at a very early stage with consultation on a draft Local Plan likely to be undertaken later this year. As demonstrated in this Planning Statement there is an urgent need for additional strategic employment sites to be delivered in the short term to address a severe lack of supply.

11.9. It is considered that the benefits of the proposal clearly outweigh the very limited harm to the Green Belt and any other harm and as such amount to very special circumstances sufficient to justify a grant of planning permission in advance of the Local Plan Review.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 53 12. Summary and Conclusions

12.1. This Statement accompanies an outline planning application for the redevelopment of the former ‘B Station’ site for industrial/distribution uses (Use Class B2/B8) including ancillary offices and associated parking, highway infrastructure, ground engineering works, drainage and landscaping.

12.2. The application is submitted in outline. It is accompanied by a Parameters Plan which sets out key development principles including the maximum floorspace proposed (85,000 square metres) and maximum building height (22 metres to ridge).

12.3. The application site extends to approximately 20 hectares and is the last remaining part of the former Hams Hall Power Station that has not been redeveloped. It comprises the remaining concrete foundations and basements of the former ‘B Station’ and cooling towers which have been left in situ, a disused tarmac car park and a number of other hardstanding areas associated with the former power station use of the site.

12.4. Whilst the remainder of the Hams Hall Power Station was removed from the Green Belt in the 1990s and subsequently redeveloped for employment uses, the ‘B Station’ site was not removed as at that time PowerGen (now E.ON) wished to reserve the land for future power generation use. For some time, however, E.ON have considered the site to be surplus to requirements and have promoted it for alternative employment uses through the development plan. It has now been sold to Prologis to promote the site for employment uses.

12.5. The ‘B Station’ site remains in the Green Belt and its redevelopment for employment would therefore constitute inappropriate development. This Planning Statement has therefore sought to demonstrate that ‘very special circumstances’ exist to justify the proposed development.

12.6. It has been shown that the proposed development would result in extremely limited Green Belt harm. The site’s openness is already compromised by its previously developed nature together with the fact that there are very strong visual and physical links with the surrounding employment park. Given the site’s previous use and the fact that it is well contained by clear and permanent boundaries, the proposed development would not significantly conflict with the purposes of including land within Green Belts. The low value of the site to the Green Belt has been independently verified by the Council’s own Green Belt Study.

12.7. Based on an assessment of the proposal’s environmental impacts, it is considered that the proposed development would also result in very limited other harm. An Environmental Statement has been prepared, which shows that a high quality and sustainable employment development can be delivered and that the proposed

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 54 development will not have any significant long term detrimental impacts on the site and its surrounding area.

12.8. The Planning Statement also shows that the proposed development would help to meet the significant identified need for new industrial and distribution space thereby supporting the economic growth objectives of the area. As there is a severe shortage of supply to meet market demands and a clear lack of alternative strategic sites in the market area that can be brought forward in the short term, substantial weight should be attached to the proposal’s ability to satisfy the need for high quality employment land.

12.9. Moreover, the proposed development performs well against all three dimensions to sustainable development outlined at Paragraph 7 of the NPPF. It will:

 Provide substantial economic benefits in terms of capital investment and job creation both during the construction and operational phase of the development.

 Make an important contribution towards the well-being of the Borough’s community through investment in the local economy and provision of employment opportunities.

 Protect and enhance the local environment by focusing development in a sustainable location, adjoining the existing Hams Hall Manufacturing and Distribution Park, and delivering a sustainable employment development in line with local and national sustainability priorities.

12.10. The Planning Statement considers that, taken together, the benefits of the proposal clearly outweigh the very limited harm to the Green Belt and any other harm and as such amount to very special circumstances sufficient to justify a grant of planning permission.

Prologis and E.ON, ‘B Station’ site, Hams Hall Planning Statement Page 55