Hearing Statement – Matter 7 Site Allocations Plan On behalf of Network Space

August 2017

Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

1. Introduction

1.1. This is a Hearing Statement prepared by Spawforths on behalf of Network Space in respect of:

• Matter 7: Selection of sites allocated for development

1.2. Network Space has significant land interests in the area and has made representations to earlier stages of the emerging Site Allocations Plan and is specifically interested in securing an employment allocation for their land at Warren Farm, Micklefield (Site 1269).

1.3. The Inspector’s Issues and Questions are included in bold for ease of reference. The following responses should be read in conjunction with Network Space’s comments upon the previous version of the Leeds Site Allocations Plan, dated September 2015 and March 2017.

1.4. Network Space has also expressed a desire to attend and participate in Matter 7 of the Examination in Public.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

2. Matter 6 – Selection of sites allocated for development

2.1. In addition to the general matters raised by Network Space in respect of Matter 2, the following individual sites are not considered “sound”:

• over 17ha of land in (Sites EG1-35 and EG1-36) which has significant ground condition issues, is constrained by the now safeguarded route of HS2 and the landowner is seeking residential uses on the site;

• 36.23ha of land at Leeds Bradford Airport (Site EG3) which is part of the long term plans for the airport;

• 5 hectares of employment land at the proposed new settlement at (MX2- 39) which is the subject of major objection; and

• 17.51ha at Thorp Arch Trading Estate which is the subject of a residential planning application.

2.2. These are now considered in more detail.

Sites EG1-35 and EG1-36 (Hawks Park North)

2.3. Network Space objected to the identification of these employment sites within the Site Allocation Plan. These sites form part of an existing UDPR employment allocation (E4:13) that has not come forward. Network Space is encouraged that these sites have been reduced to take into account some aspects of HS2 but do not consider that these changes are sufficient given the technical constraints to delivery, HS2 implications and the landowners own aspirations for the site.

2.4. In accordance with the Framework existing UDPR allocations “should be regularly reviewed” and should not be identified for employment use “where there is no reasonable prospect of a site being used for that purpose” (para 22). Whilst the area of land affected by HS2 has been removed from these allocations, the potential for additional land to be sterilized and the impact on viability or deliverability of the land to the north of HS2 which is landlocked between the HS2 railway and the M1 Motorway has not been taken into account. The affect being that following implementation of HS2 there is only feasibly circa 11ha of land that

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

could possibly accommodate employment development, which is a circa 12.8ha reduction from the original proposed allocation.

2.5. However, in addition to HS2 the site suffers from significant ground condition issues and the landowners own aspirations that the site should be developed for residential use. In response to the Publication Draft consultation the landowner states that the “employment scheme is not viable or deliverable”; that “the Council need to plan for the fact that Hawks Park may not come forward for its intended use”; that “the proposed construction of the HS2 Phase 2 line through the centre of the site further detracts from its deliverability for large floorplate employment development”; and that the Council should “consider the allocation of this site for a residential-led mixed-use scheme”. Given that the landowner states that the sites are unviable and will not come forward for employment purposes, the sites do not accord with the Framework and are not available, suitable or achievable. The sites (EG1-35 and EG1-36) should therefore not be allocated for employment and the Site Allocations Plan should be modified accordingly.

EG3: Land at Carlton Moor / Leeds Bradford Airport

2.6. Network Space considers that the allocation of 36.2ha of general employment land at Leeds Bradford Airport will not meet the short to medium term employment need in the area. The land is allocated for the future long term expansion of Leeds Bradford Airport and the creation of an employment hub. However, the scheme is dependent on the preparation of a Supplementary Planning Document and the delivery of strategic infrastructure which will guide how development will progress. The success of the allocation is dependent upon future transport infrastructure including new and improved links to the airport. The allocation is therefore for the long term and will not satisfy employment needs of the district in the short to medium term, especially those along the A1 / M1 corridor.

MX2-39: Parlington Estate

2.7. Network Space strongly objects to the draft allocation MX2-39 (Parlington estate) which identifies 5 ha of general employment land at the proposed new settlement at Parlington.

2.8. The Core Strategy sets a framework for identifying allocations. Policy SP1 states that development will be focused towards the Main Urban Area, Major Settlements and Smaller Settlements. Policy SP1 also states that the identification of land should be towards previously developed sites within the settlement, followed by other suitable infill sites and

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

sustainable extensions to settlements. Furthermore, the policy states that a selective Green Belt review will occur to “direct development consistent with the overall strategy”.

2.9. The Core Strategy through Policies SP8 and SP9 identifies the priorities and level of employment growth required, including providing employment land in accordance with the settlement hierarchy. Policy SP8 also specifically supports employment development in existing locations / sites for general industry and warehousing to take advantage of existing services, accessibility and infrastructure (including rail infrastructure). Furthermore, Policy SP10 indicates the priority order for the review of the Green Belt, which is first the Main Urban Area, followed by the Major Settlements and Smaller Settlements. Only exceptionally will sites be considered outside of the settlement hierarchy, where they will be in sustainable locations and are able to provide a full range of services and facilities and are more appropriate in meeting the spatial objectives of the Plan than the alternatives within the settlement hierarchy. Within this context, “sustainability” is of paramount importance given Spatial Objective 7 to “deliver economic development which makes the best use of land and premises across the district in sustainable locations, accessible to the community and wider labour market”.

2.10. In relation to locating development, the national policy through the Framework is specific in stating that planning should “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” (para 17).

2.11. In order to be “sound” the Site Allocations Plan must follow the principles of the Framework and the Spatial Approach established through the Core Strategy. For the Parlington Estate Mixed Use allocation to be found “sound” in employment terms it must be more appropriate than the alternatives within the settlement hierarchy to accord with Policy SP10. It is clear that the Warren Farm, Micklefield site is an extension to an existing modern employment site (Peckfield Business Park) within walking distance to a train station (in accord with SP8) which forms an extension to a “Smaller settlement” (in accord with SP1 and SP10). The Parlington Estate Mixed Use proposal is a free standing new settlement that does not extend an existing employment site (contrary to SP8); does not lie adjacent to an existing public transport node (contrary to SP8) and does not form an extension to an existing settlement within the Settlement Hierarchy (contrary to SP10). In accordance with the Framework and Core Strategy, sites that are located within or adjacent to the settlement hierarchy (i.e

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

Micklefield) should be allocated before a greenfield new settlement that is poorly related to the settlement hierarchy and with poor accessibility credentials. As such, the Parlington Estate site should have been sieved out and should be removed from the Site Allocations Plan.

2.12. The creation of a new settlement in this location is not in accordance with the Core Strategy and would significantly harm the openness and purposes of the Green Belt in this location. It is apparent that there are significant environmental, heritage and technical constraints to the delivery of the Partington site and that detailed assessments should be undertaken and made available to demonstrate that the site is deliverable in accordance with the Framework. Furthermore, the site assessment notes that the site “fails all accessibility criteria” and scores 1 out of 5 for accessibility. Exceptional circumstances have therefore not been demonstrated and the site should be sieved out. The site therefore fails to accord with the principles of the Framework and should be deleted.

Thorpe Arch

2.13. Approx. 17.5ha of current employment land at the Thorp Arch Trading Estate in the Outer North East area is the subject of a residential planning application and now an appeal against non-determination. Whilst the Council has previously been supportive of the principle of housing on the site, the City Plans Panel Report (20th July 2017) confirms that the Council do not support the planning application and will be contesting the appeal. The appeal site covers mostly white land but also includes two saved UDP allocations for employment (E3B:21 and E3B:22). The saved UDP allocations are retained in the SAP (reference EG1-63 and EG1-65) and total 12.4ha. The City Plans Panel Report notes that this equates to 58% of the total employment land identified in the Outer North East area. The same Report notes that if these two sites are released for residential then “this would inevitably weaken what has been a well-considered, intended clustering of general employment allocations (encompassing all 6 sites), as to severely prejudice the other four sites”. The other four sites are reference EG1-8, EG1-9, EG21-64 and EG1-68. Whilst the outcome of the appeal is not known, it is clear that the landowner is seeking to bring the land forward for an alternative use and hence that it is not “available” for employment uses even though the Council confirm its critical importance to the wider employment land delivery.

Site EG1-43 Unit 3 Peckfield Business Park, Micklefield

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

2.14. Site EG1-43 for 1.54ha is already constructed at Peckfield Business Park and therefore does not contribute to the future employment supply of the SAP.

Site EG1-44 Peckfield Business Park, Micklefield

2.15. Site EG1-44 could be expanded by the extraction from the Green Belt and the allocation of the Warren Farm, Micklefield replacement employment site. The Network Space site at Warren Farm, Micklefield can replace the employment elements of the above sites which will not come forward. This would be in accordance with the Framework and spatial approach established in the Core Strategy, as the Warren Farm site is in a sustainable location; on the edge of a defined Smaller Settlement; within walking distance of the train station; with excellent accessibility to the Motorway network; and includes previously developed land. The Warren Farm site represents an excellent opportunity for future employment development as it would be an extension to the existing Peckfield Employment Park and within walking distance of Micklefield train station. This site would allow employment uses to be delivered within an area that is attractive to the employment market but which can also offer alternative modes of transport for workers. The site is located within a sustainable location on the edge of Micklefield. The site is in close proximity to existing and proposed housing at Micklefield and Garforth and therefore has the opportunity to provide new employment in a sustainable location. The site also benefits from being close to the M1 motorway and the A1(M) which makes it attractive for B2 and B8 (logistics) uses. A fuller explanation of the merits of the Warren Farm site is included as Appendix 1.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

Appendix 1

Site 1269: Warren Farm, Micklefield

Overview of Proposals

The site at Warren Farm forms part of a former colliery portfolio purchased by Network Space (formally Langtree Group PLC) from British Coal circa 20 years ago. The attached illustrative masterplan shows that the site can deliver a range of size and type of uses from B8 storage and distribution, B2 Manufacturing, through to smaller B1(b) and (c) Hi-Tec and start up uses. The overall site is approximately 39 hectares.

The green infrastructure shown consists of existing extensive vegetation surrounding and enclosing several boundaries of the site, which can be reinforced. This approach will soften the edges of the site and ease the transition to the countryside beyond. The illustrative masterplan shows that the main road that runs between the two settlements of Garforth and Micklefield would act as a strong defensible boundary (the A656) in line with the Council’s conclusion for the Stourton Grange Farm, Garforth site (HG2-124; SHLAA ref 1232). In line with the proposed housing allocation at Stourton Grange Farm, Garforth, the Warren Farm site could include substantial landscaping/planting along the western boundary of the site. Network Space would be happy to accept a criterion based policy to emphasise that the substantial planting along the western boundary will be delivered and that this is appropriate to maintain the gap between Garforth and Micklefield.

Deliverability

The site is an available, suitable and achievable employment site which is eminently deliverable in accordance with the NPPF and represents a sustainable employment opportunity adjacent to an established Employment Park. If allocated for employment uses, Network Space would be committed to deliver employment development on the site themselves which further demonstrates the site’s deliverability.

Availability

Network Space owns and controls the whole site and therefore the site is available for development now.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

Suitability

The proposed development can make an efficient and attractive use of land. Although currently Green Belt land, the site does represent an excellent opportunity for future employment development as it would be an extension to an existing Employment Park and within walking distance of Micklefield train station. This site would allow employment uses to be delivered within an area that is attractive to the employment market but also which can offer alternative modes of transport for workers. The site is located within a sustainable location on the edge of Micklefield. The site also benefits from being close to the M1 motorway and the A1(M) which makes it attractive for B2 and B8 (logistics) uses. The attached wider context plan demonstrates the suitable and sustainable location of the site.

Achievable

Network Space is an experienced Employment Developer and has assembled an experienced Development Team to progress the site. Part of the site has colliery spoil upon it but the rest is agricultural land. The Peckfield Landfill Site lies to the east of the site. Based upon the assessments undertaken to date, there are no known constraints that would preclude it coming forward, though there would be a need for further assessments to address development considerations as part of any planning application.

Accessibility

The site is located adjacent to the current Peckfield Business Park, which forms part of a current UDPR employment allocation. The site would be accessed from the A656 Roman Road and will also have good pedestrian and cycle linkages to Micklefield railway station which is located to the east of the site, and which provides links to Leeds, , Bradford, Huddersfield and , as well as to Blackpool and Hull. Bus stops are also located on the Great North Road with access to Leeds, Selby, Wakefield and Wetherby. The site is also 1.5 miles from Junction 47 of the M1 motorway and has good accessibility to the A1(M) via the A63. The site is therefore in a sustainable and accessible location.

Environmental Matters

Initial observations have been undertaken which show that development of the site would have little impact on the landscape character of the area, as some hedgerows and tree belts can be retained and reinforced. The site is visually “contained” by the large Peckfield Landfill Site. More detailed assessments would need to be undertaken in respect of Ecology and

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

Ground Conditions at the relevant time, but initial observations indicate that there are no known constraints that would preclude development.

Green Belt Assessment

Due to the aspirations for economic and housing growth in the District, the Core Strategy confirms that there is a requirement for a strategic review of the Green Belt to deliver sustainable economic growth. Due to the significant need for employment land to meet the aspirations for economic growth, this strategic review of the Green Belt needs to accommodate new employment sites. In line with paragraph 84 of the Framework, the development of the site would comprise a “sustainable pattern of development” as it would form part of a review of the development limits of Micklefield to meet the employment land needs of the future.

The Green Belt Assessment undertaken by the Council in relation to the Warren Farm site is inaccurate in a number of respects. It considers that the site would lead to isolated development as it does not connect to existing boundaries, although the site physically adjoins the urban edge of Micklefield. The Assessment does not reflect the poor urban edge to Peckfield Business Park which is defined by a 2m high metal palisade fence. The existing vegetation in this location is on the former spoil heap. The Assessment does not reflect the contained setting of the site and strong physical features and boundaries surrounding the site. The main body of the site is not crossed by footpaths and bridleways, but one is located within the site but along the northern boundary. As such the Council’s Assessment concludes incorrectly that the site is isolated and does not relate to a settlement.

Network Space therefore commissioned Spawforths to undertake its own Green Belt Assessment. The full Spawforth Green Belt assessment is submitted with the SAP objections and the conclusions are summarised below:

The Framework explains that there are five purposes of including land within the Green Belt, which are:

1. To check the unrestricted sprawl of large built up areas; 2. To prevent neighbouring towns merging into one another; 3. assist in safeguarding the countryside from encroachment; 4. To preserve the setting and special character of historic towns; and 5. To assist in urban regeneration by encouraging the recycling of derelict and other urban land.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

Part of the site accommodates a colliery spoil mound which urbanises its character in this location. Contextually, the site is “contained” by development and activity being adjacent to residential properties, Peckfield Business Park and Peckfield Landfill Site. Within this context the release of the site from the Green Belt has limited impact on “openness” and redevelopment of the site would not have a material impact on the purposes of including land within the Green Belt.

Paragraph 85 of the Framework states that Green Belt boundaries should be drawn so as not to include land which it is unnecessary to keep permanently open. The site lies on the edge of Micklefield with residential development and Peckfield Landfill Site located to the east and Peckfield Business Park to the north, to the west lies the A656 with Garforth beyond and to the south lies the access road to the landfill site.

Warren Farm, Micklefield is therefore “contained” and will not lead to unrestricted sprawl or encroachment. The site is located on the edge of Micklefield and would not extend the built form of Micklefield further to the west than that already established by Peckfield Business Park. The site would not therefore lead to the coalescence of towns. Whilst the development would result in development of some countryside, part of the site is Colliery spoil and hence the degree of encroachment into the countryside would be minimised. The site has no impact upon the setting of a historic town. It would however assist in urban regeneration by facilitating the recycling of the Colliery spoil mound.

The current location of the Green Belt boundary around Micklefield is not robust and does not accord with the Framework where boundaries should be clearly defined using readily recognisable features to ensure permanency. In this area the Green Belt boundary is drawn around the edge of the employment allocation, which is now Peckfield Business Park. The boundary in this location is defined by a 2m high metal palisade fence along the boundary of the employment site.

The built form surrounding the site suggests that the existing Green Belt boundary is not one that is logical. The proposed new boundary would be defined by roads (A656 Roman Road and the access road to Peckfield Landfill site which are both well-defined and bordered by existing strong vegetation buffers) and tracks (Pit Lane bridleway which is clear and well defined by hedgerows and fences) which would accord with the Framework and ensure that the Green Belt is clearly defined using readily recognisable features to ensure permanency reinforcing the urban context whilst providing a robust boundary for the future.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

All the boundaries have the potential to be further reinforced within the site through additional planting to ensure an effective transition between the development and the countryside beyond. If the proposal for the Garforth housing site (HG2-124) is supported by the Examiners of the Site Allocations Plan any development on the Warren Farm, Micklefield site can retain a green infrastructure buffer along its eastern boundary through reinforcing the existing extensive vegetation.

All the boundaries have the potential to be further reinforced within the site through additional planting to ensure an effective transition between the development and the countryside beyond.

Effective Use of Land

Although parts of the site are greenfield, it does include the former Colliery spoil mound which is in need of regeneration. The existing Peckfield Business Park has established services and infrastructure and is well located within walking distance of Micklefield Train Station. The Warren Farm site would benefit from these services and facilities and hence would utilise and enhance existing infrastructure. The site is easily accessible and the proposed main access is off the A656 Roman Road. The scheme is therefore making an efficient and effective use of land and infrastructure.

A Positive Response to the Key Objectives of the National Planning Policy Framework (The Framework)

The Framework sets out that the Governments key economic policy goal is to secure economic growth in order to create jobs and prosperity and proactively drive and support sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the Country needs. The Framework explains that the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth and that significant weight should be ascribed to economic growth through the planning system. The proposal responds positively towards this national guidance, in that:

• The site helps to meet the employment needs and addresses the potential shortfall in employment land. • The site is appropriate for accommodating employment development and economic growth, being an expansion of an existing settlement and employment area.

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Hearing Statement: Matter 7 – Leeds SAP Network Space, August 2017

• The proposed site is accessible to existing local community facilities, national and local infrastructure and services, including public transport. • The site has been assessed and is available, suitable and achievable for development. • The site is in part previously developed land which will be regenerated. • The site can be developed without adverse impact upon the Green Belt openness and purposes.

Benefits of Warren Farm, Micklefield

The development of the site would provide significant benefits. The site would provide 39 hectares of general employment land which would address the current anticipated employment shortfall and help to meet both the quantitative and qualitative needs for employment land in the District. The site is in part previously developed and provides a unique opportunity in a sustainable location (within walking distance to a train station) without compromising its Green Belt function and purpose.

In accordance with the Framework, it is concluded that:

• The site is suitable for employment. • The proposal will deliver 39ha of high quality employment. • The proposal can provide a good mix of employment plots commensurate to the demand and need in the area. • The scheme uses land efficiently and effectively and helps to recycle derelict land. • The proposal is in line with planning for employment objectives. • The site is within a sustainable location situated in close proximity to facilities and services and also to Micklefield train station and bus stops.

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Suggested Settlement Boundary

Housing Allocations

Employment Allocations

EAST A1(M) GARFORTH

A656

MICKLEFIELD

A656

A1(M)

PECKFIELD M1

A1 (M)

A642 & A656

A63

TRAINLINE

H62-124

SITE

PECKFIELD BUSINESS PARK

LOCATION

GREEN BUFFER

MICKLEFIELD HS2

GARFORTH