Drivers Jonas Deloitte Four Brindleyplace Birmingham B1 2HZ Tel: +44 (0) 121 695 5500 Fax: +44 (0) 121 695 5678 www.djdeloitte.co.uk

Direct: +44 (0) 121 695 5738 Site Specific DPD Consultation Direct Fax: +44 (0) 121 695 5678 [email protected] Planning Policy Borough Council of Wellingborough Swanspool House Wellingborough NN8 1BP

31 December 2010 Our Ref: C-0154687 Client Ref:

Dear Sir / Madam

Site Specific Development Plan Document – Preferred Options Consultation

Drivers Jonas Deloitte write on behalf of Aberdeen Property Investors Limited (API) to submit representations in relation to the current Site Specific Development Plan Document (DPD) consultation (hereafter referred to as ‘the Plan’). API understand that the Plan will set out policies and proposals that relate to particular sites and areas within the Borough for the period from 2001 to 2021. Whilst the ‘preferred options’ stage is no longer a formal requirement of the plan preparation process, API welcome the opportunity to comment on this document in adva nce of the proposed submission consultation. Site Information

Within the Borough of Wellingborough, API manage the Minton Distribution Centre. The extent of the site is shown on the attached plan, and the site address is as a detailed below:

Minton Distribution Centre Sywell Northamptonshire NN6 0BN.

The Minton Distribution Centre is an existing employment site, currently in class B8 use. The site extends to 6.17 hectares (15.25 acres) and comprises a warehouse facility arranged as two separate multi-bay buildings. It is located in close proximity to the Sywell Aerodrome site, but is under separate ownership and has no functional links with the Aerodrome itself, or the existing employment uses around it. The site is included within the Sywell Limits of Development Area (Local Plan Saved Policy SY1).

The buildings on the Minton site date predominantly from the 1950s and are in a dilapidated condition reflecting the age of the structures. As a result, there are increasing viability problems in keeping the structures wind and water tight.

Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 2 New Street Square, London EC4A 3BZ, United Kingdom.

Drivers Jonas Deloitte is a trading name of Deloitte LLP, which is the United Kingdom member firm of Deloitte Touche Tohmatsu Limited (‘DTTL’), a UK private company limited by guarantee, whose member firms are legally separate and independent entities. Please see www.deloitte.co.uk/about for a detailed description of the legal structure of DTT and its member firms. Drivers Jonas Deloitte is regulated by RICS.

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Drivers Jonas Deloitte (then “Drivers Jonas LLP”) has previously written to the Council and has attended two meetings with Planning Officers in respect of the future of the site, and its suitability for redevelopment. The Minton Distribution Centre represents a significant brownfield site which is currently failing to attract occupiers due to higher quality and more strategically located distribution sites elsewhere in the county. It is our client’s intention to pursue redevelopment opportunities.

Below, I set out our client’s key considerations in respect of the current consultation.

Approach to the Site Specific Proposals DPD

Paragraph 11.1.1 of the Preferred Options Plan states:

A major function of the Plan is to identify sites to accommodate the scale of growth envisaged in the Core Spatial Strategy. Provision therefore needs to be made for approximately 11,590 new homes in the town of Wellingborough and 1,210 in the rural area of the Borough between 2001 and 2021. [Emphasis added].

Following the North Northamptonshire Joint Committee Meeting of 7 December 2010, it is understood that the Council intend to extend the period over which housing targets will be delivered. In Wellingborough it is proposed that an additional 10 year period, to 2031 should be considered. It was recommended at the meeting that the planning authority should regard this as a “material consideration for the purposes of calculating a 5 year housing supply and bringing forward site specific documents pending the JCS review” (extract from Item 4, report for of the North Northamptonshire Joint Committee, 7 December 2010).

This approach is not in accordance with the phasing set out within the adopted Core Strategy. In particular Policy 10: Distribution of Housing including the associated figures within Table 5. In addition, there has been no public consultation, assessment of future housing needs / commensurate assessment of the implications for the delivery of employment uses, or strategic environmental assessment to justify such a departure from adopted policy. If this approach was to be carried through to the Site Allocations DPD then it would not withstand scrutiny under Examination by a Planning Inspector. However, we note that the approach currently being promoted by the Joint Committee is not reflected within the Site Allocations Preferred Options DPD, the draft of which was published in advance of the 7 December committee and we welcome consistency with the Core Strategy. Should this position change at submission stage to reflect the Joint Committee’s request then we wish to state now that objections will be lodged at that time.

It is understood that a forthcoming Joint Core Strategy Review will assess Options for differing levels of housing development to 2031, and its distribution between settlements and Consultation on Options is believed to be scheduled to take place in early 2011. This does, in our view, bring into question the effectiveness of the current consultation on the site specific proposals DPD when the strategic context surrounding the decisions to be made within the document is uncertain. Notwithstanding this, below I set out our response to the content of the Preferred Options draft.

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Economic Prosperity

Drivers Jonas Deloitte has previously written to the Council in respect of Saved Local Plan Policy SY1, which we considered to be overly restrictive and inconsistent with the factual circumstances of our client’s site. As set out above, the Minton Distribution Centre has no functional links with the activities of the aerodrome and the allocation of the site within the Sywell Aerodrome Limits of Development Area (as shown on the proposals map) unnecessarily constrains the range of uses considered acceptable on site.

We therefore consider the allocation of the Sywell Aerodrome Employment Area as an Existing Employment Area, under Preferred Option 42, which will be safeguarded for B1 (Business), B2 (General Industry) and B8 (Storage and Distribution) purposes to be more acceptable and would support this aspiration if our assessment of the policy objectives are as stated. Under Preferred Option 42 it is understood that redevelopment or refurbishment of areas or properties will be encouraged in order to ensure that the Employment Areas remain fit for purpose. We would suggest however that quasi- employment uses should also be allowed due to the provisions of PPS4.

We accept that the title ‘Sywell Aerodrome’ may be used in the context of Preferred Option 42 to differentiate this employment area from employment areas elsewhere in the Borough. However, we wish to strongly re-emphasise that not all uses within this area relate to the aerodrome, more specifically the Minton Distribution centre which is physically separate and also functionally separate in terms of ownership.

This point is particularly relevant in respect of Preferred Option 47 which relates to modest expansion of the site at ‘Sywell Aerodrome’. We consider that this policy should only relate to aviation related uses to the northwest of Wellingborough Road, and we therefore seek clarification that any other proposed expansion within the allocated Existing Employment Area for the Minton Distribution Centre Site would not be tested against this policy. For example, should the Minton Distribution site come forward for redevelopment in accordance with Preferred Option 42, we would not expect any increase in floorspace on the site to be considered ‘expansion’ under Preferred Option 47. If this is not the case then we object to the current wording of the policy.

We would wish to propose that a criteria based policy is progressed in place of Preferred Option 47 that would direct aviation related expansion to the most sustainable locations within the overall Sywell Aerodrome Employment Area. The policy should set out that expansion plans should be subject to a sequential test approach, whereby expansion should only be permitted on greenfield sites outside of the allocated Existing Employment Area if there are no brownfield sites within the allocated Existing Employment Area that could accommodate the expansion at the time it is proposed. This would therefore mean that if the aviation element of the Sywell Aerodrome to the northwest of Wellingborough Road seeks to expand then the first stage in this process should be to identify whether there is an opportunity at that time to redevelop the Minton Distribution Centre. If there is not then greenfield expansion would be permissible.

However, as stated above the redevelopment or expansion of the Minton Distribution Centre for alternative employment uses should not be subject to the constraints of ‘aviation uses’ as potentially captured by Preferred Option 47 under expansion requirements should our client wish to redevelop or marginally expand the site for B1, B2 or B8 uses.

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In addition, the policy should also set out that in cases where no economically viable employment development can be sustained on safeguarded employment sites then alternative uses can be sought subject to meeting the criteria of Preferred Option 45 or a derivative thereof. While safeguarding land for employment uses is understood there needs to be recognition that in some cases continuing employment use may not be achievable and therefore there needs to be a suitable fall back position to ensure scarce brownfield land resources are used efficiently and sustainably.

Delivering Housing

Our response to the Council’s approach to housing numbers and delivery of targets has been set out previously within this letter. At the time of writing, we are unable to robustly assess the Council’s five year housing land supply position due to a lack of up-to-date information. We therefore seek to reserve the right to make further representations in respect of this issue once the necessary information and evidence becomes available and also should the Joint Committee’s wishes surface within the Submission Version of the Site Allocation DPD.

We note that section 11.2 of the Plan refers to the managed release of housing sites, and the acknowledgement that Wellingborough has a limited supply of previously development land. Preferred Option 31 states that

Priority will be given to the identification of previously developed land in determining preferred sites for allocation…

We wish to reiterate our previous correspondence to the Council, that the Minton Distribution Centre site in Sywell provides a sustainable brownfield opportunity which would be suitable for residential redevelopment.

Summary

On behalf of Aberdeen Property Investors, we request that we be kept informed of progress with this and future LDF documents, and wish to reserve our client’s position to submit further representations on this, and subsequent, documents.

We welcome the opportunity to meet to discuss any aspect of these representations with you, please do not hesitate to contact me if you require further information regarding this matter.

Yours sincerely

Matthew Williams for Deloitte LLP (trading as Drivers Jonas Deloitte)

Enc: Site Plan

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