Parish: Ward: North Mundham

NM/14/02300/FUL

Proposal Horticultural packhouse incorporating ancillary uses including changing rooms, hygiene areas, ancillary offices together with parking and loading areas and new balancing pond

Site Natures Way Food Limited Site Food Park Bognor Road Chichester West PO20 1NW

Map Ref (E) 488596 (N) 103355

Applicant Natures Way Foods Ltd

RECOMMENDATION TO DEFER FOR SECTION 106 THEN PERMIT

Note: Do not scale from map. For information only. Reproduced NOT TO from the Ordnance Survey Mapping with the permission of the SCALE controller of Her Majesty's Stationery Office, Crown Copyright. License No. 100018803 1.0 Reason for Committee Referral

Parish Objection: Officer recommends Permit

2.0 The Site and Surroundings

2.1 The application site comprises a broadly flat and rectangular 4 hectare parcel of Grade 1 agricultural land located within the designated Horticultural Development Area (HDA). The surrounding part of the HDA is known as the Chichester Food Park (CFP). The Food Park is accessed primarily from the A259 via a dedicated arm of its Merston roundabout, with access to the strategic road network (A27) only a further mile to the west.

2.2 The site occupies the western half of a large arable field which adjoins the HDA's northern boundary. The site's western boundary is flanked by a substantial range of commercial glasshouses which are accessed via Vinnetrow Row. The western part of the site's southern boundary borders a further agricultural field, with the remainder of this boundary flanking the site of an existing packhouse which was constructed by the applicant following the grant of planning permission in 2011 (NM/10/03529/FUL refers). This facility is known as the Merston packhouse. The applicant operates a further packhouse at Walnut Tree Farm which is located in the south-west corner of the Food Park; these premises are known as the Runcton packhouse.

2.3 The site's northern boundary consists of a mixed native species hedgerow of approximately 3.5m in height, beyond which arable fields extend northward up to the A259 Chichester-Bognor Road. The land to the east of the site currently comprises open and flat arable fields. Members will be aware, however, that there is a resolution to grant permission for a substantial glasshouse/packhouse/office building on land in the north-east corner of the HDA (NM/14/01721/FUL refers) and, further, that a grain store building permitted last year on land 200m to the south-east of the site is currently under construction (NM/13/02608/FUL refers).

2.4 The nearest residential properties are located approximately 200m to the north- east of the site on Green Lane. Green Lane is a public bridleway which runs broadly north-south through CFP providing a link from the A259 to the north with the B2166 (Chichester to Pagham Road) to the south. Part of this bridleway runs through the south-east corner of the site. This section is currently relatively poorly physically defined; it has no enclosing features to its sides and consists primarily of a dog-legged section of grassy track raised slightly above the surrounding field's surface. A spur off this bridleway also runs east-west along the southern side of the hedgerow which flanks the northern boundary of the site.

3.0 The Proposal

3.1 Permission is sought to erect a substantial horticultural packhouse facility on the site. The purpose of the facility is set out in various of the application's supporting documents and is also explained in the Agricultural Adviser's comments at paragraph 6.5 below. In summary, however, the facility is required due to the recent and substantial growth in the applicant's business which primarily involves the preparation of ready-to-eat, pre-packed salad and fruit bowls. According to the applicant this results from a rapidly growing, 365 days-per-year consumer demand for such products which has been driven by various factors including changing shopping and eating habits along with an increased preference for 'home grown' produce. The processes within the new facility would essentially be the same as those in the adjacent Merston facility which, despite being only 4 years old, is already operating at capacity.

3.2 The applicant confirms that 240 jobs would be created as a result of the proposal. These would comprise 60 support staff working normal office hours, along with 180 operational staff working in two shifts of 90. As with the Merston premises, the new facility would operate 24 hours per day, 365 days per year.

3.3 The building would be located in the north-east part of the site and would consist of two conjoined elements with an overall footprint measuring approximately 144m by 72m. The principal element would comprise the packhouse itself, accommodating the facility's production, packaging and despatch functions. This would measure 120m by 72m wide, comprising metal-sheeting-clad elevations beneath a single span, barrel-vaulted, standing seam metal roof of 11.9m in height. Attached to the southern elevation of this element would be what is described by the applicant as an 'ancillary facility' measuring approximately 70m by 23m. This would comprise cedar-clad elevations beneath a 6.5m high flat roof and would accommodate various supporting functions over two floors including; plant, engineering and changing rooms, a kitchen area and staff canteen, a reception area, hygiene facilities and, occupying the whole first floor, an office area incorporating a number of meeting rooms.

3.4 A service yard containing plant, equipment and goods in and out would adjoin the western side of the packhouse. To the south of this yard would be a car park for staff and visitors (147 spaces total) together with an area for temporarily storing packaging crates. The southeast corner of the site would contain a wetland area and surface water attenuation pond, with this area incorporating a footpath link from the site through to the applicant's Merston facility to the south.

3.5 The current alignment of the bridleway though the southeast corner of the site would not be affected by the proposal. However, the plans indicate the route of the bridleway within the site would be defined by new sections of flanking hedgerows with chain link security fencing on their outer sides. The surface of the bridleway would not be changed other than with the exception of a small area in the vicinity of the entrance to the ancillary building, where some hard surfacing is likely to be required where the proposed footpath between the applicant's new and existing facilities would cross its route. It should be noted that any changes to the surface of the bridleway will need to be the subject of separate consent from the Highway Authority.

3.6 The application includes relatively detailed landscaping proposals, the most significant elements of which comprise the formation of planted bunds to the majority of the site's eastern and northern boundaries.

3.7 Vehicular access to the site would be via an extension to an existing access road from a point in the north-west corner of the car park serving the Merston premises. The new section of access road would then wrap around the site's southern and western boundaries before linking to the above-mentioned service yard. 3.8 The application is supported by various statements and technical reports, a number of which have been amended during the course of the application. These include; a Planning and Design and Access Statement, a Transport Assessment, a Flood Risk Assessment and reports on ecological matters, noise generation, lighting, archaeology and surface water disposal. All of these documents are available for inspection on the application file.

4.0 History

None relevant

5.0 Constraints

Listed Building NO Conservation Area NO Rural Area YES AONB NO Strategic Gap YES Tree Preservation Order NO South Downs National Park No - Flood Zone 2 YES - Flood Zone 3 YES Historic Parks and Gardens NO

6.0 Representations and Consultations

6.1 Parish Council

North Mundham Parish Council has resolved to OBJECT to this application.

This Council is becoming increasingly concerned at the proliferation of large buildings within the Horticultural Development Area (HDA). In our response to the consultation for the emerging Local Plan, we suggested that it would be appropriate if the provision of packhouses on the HDA were limited to those required to process crops within the local District. It is apparent that this proposed guideline has already been exceeded.

Indeed, we note that the proposed development is categorised in the application form (section 18) as a mixed development for offices and light industrial use. This seems to be a significant departure from the concept of agricultural buildings to support horticulture. If the use of the building for the proposed purpose should cease for any reason, there would seem to be no bar to its being used as a factory for light industry and as offices for a business entirely unrelated to horticulture.

In our response to other applications on the HDA, we have expressed our concern about the size of the buildings and their effect on the landscape - the existing policy and proposed future policy state that developments are acceptable so long as "the height and bulk of development does not damage the character of the surrounding countryside". We have now reached the stage where the applicant can suggest that: "By grouping the buildings with the existing packhouse and adjoining glass houses (together with the recently approved grain store and submitted proposals for further glasshouses and another packhouse on adjoining land to the east) the additional visual bulk of the building will be reduced" (Design and Access Statement 6.4). If this argument continues to be applied, there appears to be no limit to the development of 'packhouses' on the HDA, entirely unrelated to its principal purpose of growing crops.

The application accepts that the proposed building will be a significant addition to the landscape (Landscape and Visual Impact Assessment 3.3). We would therefore wish to see a more robust landscaping proposal. Recognising that as any proposed indigenous planting will not provide effective screening of so large a building for several years, we suggest quick growing species such as bamboo or similar, capable of growing to 9 metres high or more in a year, are incorporated in the plans.

We note that the application includes a significant amount of office accommodation, with desk spaces identified for 60 workers and a lavish allocation of meeting rooms. Though we recognise that the day-to- day operation of the packhouse will require a small number of administrative staff, it is difficult to see how such a large office space can be justified. This seems to be an attempt to introduce office accommodation onto the HDA by stealth, and the provision of new general office accommodation onto the HDA is clearly inappropriate. This is particularly so since the planned move of the Free School from its Vinnetrow Road site will free up a significant amount of existing office accommodation.

In summary, we would ask the District Council to consider carefully whether further packhouse development on the HDA is appropriate. If it is decided nevertheless to grant consent to this application then we would ask that such consent is conditional on a more robust landscaping scheme. In any event we believe that the provision of any office space which is not directly connected with the day-to- day administration of the packhouse is an inappropriate use of the HDA and should be refused.

6.2 Environment Agency

No comments

6.3 Highways Agency

No objection

6.4 Southern Water Services

Applicant should satisfy himself that he is able to gain the necessary private permissions to connect his site to the nearest public sewer. Appropriate surface water disposal measures should be in place.

6.5 Agricultural Consultant (summarised)

This proposed development is to be adjacent to the applicant's current pack house facility at Merston. The applicant has another packhouse at Runcton which is also on the Chichester Food Park.

Natures Way is a leading British business preparing primarily ready-to-eat, pre- packed salads and salad bowls. Some 700 staff are currently employed by the company at their sites at Merston, Runcton and . The Company's published financial performance shows a turnover increase from £113 million to £121.5 million for the year ending March 2014.

Ease, speed and 'ready-to-eat' are important trends within a fast-changing food market. Big, bi-weekly or weekly shops have been replaced by buying for the next meal with ultra-fresh and easy-to-prepare products that can be ready to eat in minutes. The pre-packed ready to eat mixed leaf salad has quickly become a staple and ever present purchase in the consumer food basket.

About 60% of the products used by Natures Way originate from the UK based with the remaining imported from Europe by lorry. The bulk of the local product used by Natures Way consists of locally grown lettuce. Out of season this is replaced by Iceberg lettuce, from mainland Europe.

Salad leaves and other crops sourced locally are the preferred choice of the company. Local produce has a longer shelf life and is cheaper to produce with the lower transport costs. Further, produced crop has the advantage of meeting the increased consumer interest in local provenance.

The current pack house is working at full capacity with both day and night shifts. Some 160 people are employed at the existing premises and it is expected that this will increase to between 250 and 300 if this proposal is approved.

The salad crop would be delivered daily to the packhouse with a turnaround into prepared pre-packs ready for consumption within 24 hours. The product is then purchased by the general public within 24 hours, thereby enabling an average shelf life of 4-5 days.

The applicant's intention appears to be to create increased capacity to pack and deliver a greater range of pre-packed salad products rather than to establish a storage based unit in order to meet the business objective of ensuring a tasty fresh product available to buy 365 days of the year. This application appears to be one driven by growth and progression for the business rather than by any diversification plans into different enterprises e.g. storage.

The application includes additional office space. It is my understanding that all corporate functions will remain at the company's Selsey HQ. The applicant has stated that having office accommodation located next to the packhouse permits a more integrated approach between packhouse and administration staff who work in partnership. Having office facilities adjacent to the pack house will obviously assist the business to function efficiently.

In conclusion, Natures Way is an innovative and expanding local business using local products wherever possible. The packed salads and fresh leaves are sold to retailers and food outlets throughout the UK. The recent horse meat scandal has further highlighted the relevance of food provenance and traceability. This is much easier to guarantee from home grown food.

The Chichester area is quite unique in terms of its milder maritime climate and high solar units. Local growers and businesses have capitalised on these advantages making the area nationally significant in terms of glasshouse and field crop horticulture. CDC has acknowledged the importance of the industry by designating HDAs and this has given additional confidence to the industry. Consequently, the Chichester area continues to develop a reputation for excellence, skills and innovation in horticulture. Wherever possible, applications such as this one should be supported as businesses continue to develop new ideas, attracting skilled workers to the area, all of which is beneficial to the local economy.

6.6 WSCC Local Development Division (summarised)

There are no proposed changes to the adopted road network. The applicant should satisfy himself that the development's internal layout is suitable and fit for purpose including the provision of adequate site lines where the access road crosses the public footpath. The provision of 147 car parking spaces accords with adopted standards. The proposed level of cycle, motorcycle and HGV parking is acceptable and should be secured by condition.

Provision for pedestrians within the development is acceptable and a link to the Food Park's main footpath which provides access to the A259 should be provided. Employees would have access to bus services on the A259 and proposed shift patterns fit in reasonably well with these services. The applicant should, however, provide a new shelter for the southbound A259 stop which is close to the Food Park's entrance, and also real-time traffic information for both the north and southbound stops. A Travel Plan should be secured by condition.

The development should generate a combined daily traffic flow (i.e. walking, cycling, car and HGV) of about 640 trips including 34 HGV movements, with a peak of approximately 90 movements in the early morning period. A Road Safety Audit has been undertaken with no problems being identified. There are no objections from the Fire and Rescue Service.

The site is bisected by a bridleway. The WSCC Rights of Way Team has no objection in principle to the proposal subject to a condition being imposed that would safeguard the PRoW. Further work may need to be done in order to establish the precise width at which the bridleway should be maintained at, but this should be a minimum of 3m. The proposed hedge planting to each side of the bridleway must be properly maintained and should not reduce its effective width. Appropriate signage should be displayed where the access road crosses the bridleway. Consent must be sought if the bridleway is to be temporarily obstructed during the construction process.

There are no objections to the proposal from a highway point of view subject to various planning conditions and the provision of a TAD contribution of £244,768 towards a number of schemes aimed at improving sustainable travel infrastructure along the A259 Bognor-Chichester Corridor.

6.7 WSCC Landscape Architect (summarised)

During the course of the application further information has been submitted by the applicant's Landscape Architect in respect of various matters raised in earlier consultation responses. This includes additional photographic evidence, a further report giving consideration of landscape and visual impact, additional earthwork proposals and details of planting and maintenance regimes. No special landscape designations apply to the site. Although the site lies within the Rural Area and Strategic Gap, existing and emerging HDA planning policies accept that commercial horticultural development will take place within them.

The proposed development site is very low-lying, open and exposed to numerous views from publically accessible viewpoints in the nearby surrounding landscape. In particular, users of Bridleway 2792 (passing within the site in its south-eastern corner, and adjacent to the site's northern boundary) would experience clear and sustained visual changes as a result of any development on the site. Visual receptors passing along the A259 at the Merston roundabout (to the north-east of the site) would also experience a clear view of the site, albeit it comparatively briefly where the access road into Chichester Food Park forms a break in the roadside vegetation. Similarly, clear views of the site are available from a section of the A259 due north of the site, where the roadside vegetation is a gappy hedgerow, and low-growing, allowing a clear, over-sailing line of sight.

The applicant's rationale for the layout of the development is accepted. This is appropriate in relation to the A259 and Bridleway 2792 to its east, placing the service yard behind the built form. This would have the effect of limiting the visual and audible disturbance of vehicle movements. It should be noted however, that the shorter section of Bridleway 2792, running adjacent to the northern boundary of the site, would still experience some exposure to visual and audible intrusion from the service yard. Although views of the proposal in the wider landscape will be available - for example from the Trundle - it is accepted that the impact of these will be limited due to the fact that the building will be seen in the immediate context of other large structures on and adjacent to the Food Park.

There is some concern over the impact of external lighting given that a lighting scheme has not yet been fully worked-up, but an appropriate scheme could be reserved by condition. There is also some concern about the details of some of the planting that is proposed - as specified this may fail - and for this reason only there is a HOLDING OBJECTION to the proposal.

6.8 CDC: Environmental Health Officer

The access road onto the site is over 2km of concrete road which carries all traffic onto the Food Park from the A259. It is limited to 20mph and is fitted with speed bumps to ensure that cars and lorries are reminded of this restriction. The access road serves several business sites. I note from the comments of residents within 250m of the access road that they use expressions such as 'noise 24 hours a day', 'hell' and 'unbearable'. This causes me to have significant concern about noise of vehicle movements on the access road; it is necessary to consider the cumulative impact of additional movements, particularly at night.

The originally submitted acoustic report did not address the issue of cumulative noise on the communal access road which has been the subject of concern expressed by residents. Further comments were subsequently submitted by the applicant's noise consultants and these do demonstrate that, in isolation, the traffic generated by the proposal is unlikely to result in harm. However, this approach fails to address concerns about cumulative impact - i.e. it is likely that there will be exceedance of noise target levels if the applicant's HGVs happen to depart at night around the same time as some of those of the Food Park's various other operators. Given that there remains a degree of uncertainty about the impact of noise from the access road, a precautionary approach should be taken. I recommend that a noise mitigation scheme is considered as a condition requiring ongoing measures, both physical and management, intended to mitigate against the noise from the site and the cumulative growth of traffic-related noise. Measures such as speed control, road narrowing, surface treatment, bunding and barriers could be provided and maintained, to ensure that slow steady progress is made by vehicles and noise controlled at source. A condition specifying a maximum noise level at nearby residential properties should also be imposed.

Revised Noise Assessment

Further to previous comments that I have made with reference to this site and the two applications referred to above, this response is with particular reference to the recently submitted Site Access Road Noise Assessment prepared by Applied Acoustic Design and dated 30th June 2015.

The report explains the results of detailed survey work carried out to investigate the concern about existing and potential future noise of vehicles travelling on the food park access road. Residents had specifically raised this as a concern and it was felt that previous acoustic reports did not fully address this.

The methodology for the noise survey work was discussed and agreed in advance. Five noise monitoring locations were used in total, including automated monitoring over several days and attended monitoring periods adjacent to residential locations. Sound level meters were specifically programmed with a trigger noise level such that short term events of noise could be assessed in addition to average levels. The automated monitoring was situated close to noise sources and the residential impact assessed by calculation.

The main outcome of the noise assessment is that at the residential properties in Green Lane, the ambient noise environment is dominated by the traffic on the A259. The average noise from the food park access road was measured and calculated as 10 - 15dB lower than the average noise from the A259. Short term events of noise were also considered and discounted in terms of amplitude and frequency (the number of events from the access road was dwarfed by those generated on the A259). In order for the noise of vehicles from the access road to equal that of the main highway, it would have to increase by at least tenfold. This scenario is sufficiently unlikely to provide reassurance about future noise levels.

The consultant commented that during the attended measurements in Green Lane there were no audible noise events from the food park or access road, but that road traffic noise was dominant.

The report provides objective evidence that noise from traffic on the food park does not and should not impact negatively upon local residents and clearly this is not consistent with the objections raised. A possible explanation for this is that although noise is measured and predicted in objective and cold scientific terms, it is experienced by individuals who may respond differently to the notional average person or who may have reasons to notice and be annoyed by a specific noise source. It is possible that the headlights of vehicles moving on the food park access road are drawing attention to noise from this direction and it is therefore very positive that a mitigation scheme is being considered.

6.9 CDC: Archaeological Officer

The applicant's archaeologist's initial assessment of the site establishes that a programme of trial trenching would be justified - no objection subject to a condition securing the same.

6.10 CDC: Drainage Engineer

Details of the surface water disposal scheme should be secured prior to commencement of the development. If discharging to a ditch then this should be at no higher than greenfield rates and, further, the relevant Land Drainage consent for such discharges will need to be obtained in addition to planning requirements.

6.11 CDC: Environmental Strategy

No objections subject to consideration of ecology, including ecological enhancements, forming part of the details of the development's landscaping proposals.

6.12 CDC: Economic Development Service

The Economic Development Service strongly supports this application. The development will support the expansion of a well-established and successful business within the District, creating 240 new jobs. This business is expanding rapidly, having already outgrown the site that it built in 2011. In order to meet its customers' needs and expectations the business needs to provide facilities for the future of the business, not just the business as it stands currently. The NPPF, the emerging Local Plan and the Council's Economic Development Strategy support this.

To support the development needs of a horticultural business, it is vital to understand the changes that the horticultural industry has seen in the last 20 years; there are now many more office-based processes due to the automation of many of the methods within the packhouse, which are essential for the running of the modern and successful horticultural business.

The Economic Development Strategy identifies that there is a shortage of higher skilled jobs within the District. We need more working age people to settle within the District, by creating higher-paid job opportunities, enabling them to afford the cost of living. This development will improve the economy of the District by supporting a high-growth business that makes best use of its natural assets; this is fully supported by the EDS.

6.13 Third Party Objections - 4 Inappropriate industrial scale development on agricultural land; increased noise, traffic and light pollution, particularly at night; will cause on-going disturbance to nearby occupiers; too much development on Food Park ; enough is enough; noise and light pollution already disrupts nearby residents' lives and any increase will be unbearable; increased litter; developments of this nature should be in a more suitable location; unpleasant odours from existing Food Park operators at times; use of bridleway detrimentally affected by noise, obstacles etc. on Food Park.

6.14 Third Party Support - 1

Chichester Chamber of Commerce supports the application. Natures Way is a major employer in the region having a significant beneficial impact on the local economy. The business provides an essential link between growers, farmers and retailers producing fresh, healthy ready to eat produce. The company needs flexible and efficient ancillary space and the Food Park is an appropriate and sensible location for a variety of practical and business-efficiency-related reasons. It is vital that the District Council works hard to retain large employers in the district.

6.15 Applicant/Agent's Supporting Information

In May 2011 Council granted planning permission for a Horticultural Packhouse as an annexe facility to the existing facility at Walnut Tree Farm and it was explained at that time that the business had been so successful, that more floorspace was required to satisfy demand for new product lines and increased requirements from clients. Only a few years later and Natures Way Foods finds itself in a similar position requiring greater demand to supply freshly prepared, healthy salads and fruits to retailers across the UK. The business has evolved into a major national enterprise supplying many of the top supermarkets, supporting local growers who wish to reach markets quickly and cost effectively. The purpose of this application is to consolidate the business at Chichester, benefiting from the central location in the main growing area of the south east.

Natures Way Foods is now a multi million pound business employing over 1,000 people and is increasingly important to the local Chichester and regional economy. The current planning application will create 11,470sqm of new floorspace requiring 240 jobs representing a major new investment in Chichester.

Planning policy continues to support the growth of the horticultural industry with the site lying wholly within the HDA. The previously approved centres at Runcton and Merston are consistent with the activities proposed at Drayton (current application) and all three outlets will provide a synergy, complementing the HQ based at Selsey.

The emerging Local Plan (2014-2029) strives for economic development supporting education and skills relevant to national and international competition, encouraging and attracting higher paid technical jobs and retaining talented young people. The opportunity at Natures Way Foods will be to focus on those technological jobs as mechanisation will inevitably become more prominent in the future meaning that jobs will become increasingly technical requiring higher order skills attracting higher salaries.

During the course of the planning process much consideration has been given to the environmental effects of a new building within the HDA looking closely at the impact of the building within the landscape setting, the transport links, potential noise creation and impacts of artificial lighting as per Policy 32. There are no objections from any of the statutory consultees and any fine tuning can be accommodated by way of suitably applied planning conditions.

In terms of the National Planning Policy Framework the current proposal is highly sustainable achieving a good balance of economic, social and environmental roles which is also consistent with local planning policy.

7.0 Planning Policy

The Development Plan

7.1 The Development Plan for Chichester District comprises the saved policies of the Chichester District Local Plan First Review 1999 and all adopted neighbourhood plans. There is no adopted neighbourhood plan for North Mundham parish at this time

7.2 The principal planning policies relevant to the consideration of this application are as follows: Chichester District Local Plan First Review 1999:

BE11 New Development BE14 Wildlife Habitat, Trees, Hedges and Other Landscape Features RE1 Rural Area Generally RE6 Strategic Gaps RE8 Nature Conservation (Non-designated Areas) RE11A Horticultural Development: Areas for Horticultural Development RE12 Rural Diversification RE14 Conversions in the Rural Area TR6 Highway Safety B5 Rural Area : New Build and Extension R4 Public Rights of Way and Other Paths

7.3 The Chichester Local Plan: Key Policies and modifications has been submitted to the Secretary of State and has already been the subject of Examination hearings. The emerging Local Plan is a material consideration and following Submission it gains increasing weight for decision making purposes. As it progresses through the Local Plan process to adoption it will gain more weight, paragraph 216 of the NPPF is therefore relevant.

Chichester Local Plan (Pre-Submission) Draft 2013

Policy 1: Presumption in Favour of Sustainable Development Policy 3: The Economy and Employment Provision Policy 8: Transport and Accessibility Policy 9: Development and Infrastructure Provision Policy 32: Horticultural Development Policy 39: Transport, Accessibility and Parking Policy 40: Sustainable Design and Construction Policy 42: Flood Risk Policy 45: Development in the Countryside Policy 48: Natural Environment Policy 49: Biodiversity National Policy and Guidance

7.4 Government planning policy now comprises the National Planning Policy Framework (NPPF), paragraph 14 of which states: At the heart of the NPPF is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking: For decision-taking this means unless material considerations indicate otherwise: - Approving development proposals that accord with the development plan without delay; and - Where the development plan is absent, silent or relevant policies are out-of-date, granting planning permission unless any adverse impacts of doing so would significantly or demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or specific policies in (the) Framework indicate development should be restricted.

7.5 Consideration should also be given to paragraph 17 (Core Planning Principles), Section 1 (Building a strong, competitive economy), paragraphs 24-27 concerning the sequential approach to town centre uses, Section 3 (Supporting a prosperous rural economy), Section 4(Promoting sustainable transport), Section 7 (Requiring good design), Section 11 (Conserving and enhancing the natural environment) and paragraphs 2-15-216 concerning the weight to be given to existing and emerging development plan policies.

7.6 The National Planning Practice Guidance (NPPG) was published 6th March 2014 and provides guidance aimed at aiding the interpretation of national planning policy. The Guidance is both detailed and wide ranging and, whilst it is not considered necessary to list all of its relevant paragraphs and sections here, its contents have been taken into account in the preparation of this report.

Other Local Policy and Guidance

7.7 The following Supplementary Planning Guidance and Interim Statements are material to the determination of this planning application:

- The Provision of Service Infrastructure Related to New Development in Chichester District (Parts 1 and 2)

7.8 The aims and objectives of the Council's Sustainable Community Strategy are material to the determination of this planning application. These are:

A1: A strong local economy where businesses can thrive and grow

A2: Employees with good skills relevant to local employers, prepared for national and international competition and with well-paid and secure jobs

A4: The district to be known as a centre for creative and innovative industries building on our rich arts and heritage base

B1: Managing a changing environment

B2: Greener living B3: Environmental Resources

E1: Traffic management in the district will improve so as to reduce congestion

E2: There will be improved cycling networks and strong links to public transport to ensure that cycling is a viable alternative to using the car.

8.0 Planning Comments

8.1 The main issues arising from this proposal are: (i) Planning policy context (ii) Principle of the development (iii) Character and appearance (iv) Highways and parking (v) Residential amenity (vi) Surface water

Assessment

(i) Planning policy context

8.2 The site is located within countryside forming part of the designated Rural Area where, in general terms, existing and emerging development plan policies seek to carefully control development. ELP policy 45 (Development in the Countryside) states 'development will be granted where it requires a countryside location and meets the essential, small scale and local need which cannot be met within or immediately adjacent to existing settlements'. Other policies, for example ELP policy 39, seek to ensure that development is sustainably located and that journeys are minimised.

8.3 Agriculture, which includes horticulture, is clearly one such activity that requires a countryside location and in recognition of this the District Council designated four Horticultural Development Areas (HDA) in the 1999 Local Plan. The site is located within the Runcton HDA.

8.4 The creation of HDAs resulted from recognition of the favourable growing conditions on the coastal plain (in terms of climate, soil and topography), the area's good transport links and the substantial contribution that commercial horticulture makes to the local economy. The use of such a designation was intended as a positive development tool to encourage such development and inward investment, but also to focus it in appropriate locations where environmental impacts could be minimised and access to the strategic road network maximised.

8.5 The policy can be considered to have thus far achieved a significant level of success, particularly in respect of the and Runcton HDAs which are capable of accommodating large-scale enterprises and which have good access to the strategic road network. As referred to above, the Runcton HDA (of which the site is part) has been the subject of a number of substantial proposals in recent years including the development of several packhouses, large areas of glass and a substantial grain storage and distribution facility. 8.6 Local Plan policy RE11A relates specifically to development within HDAs. RE11A is criteria-based policy which, in summary, establishes that commercial horticultural development will be permitted in HDAs subject to them not resulting in unacceptable impacts in respect of a number of issues such as noise, light and air pollution, residential amenity, the character and appearance of the landscape and highway safety. Proposals must be accompanied by suitable measures in terms of landscaping and surface water disposal.

8.7 The emerging Local Plan (ELP) brings forward the HDA designation. ELP Policy 32 (Horticultural Development) was the subject of detailed discussion at the recent Hearings into the draft Local Plan; it is proposed to contain a range of criteria similar to those of RE11A.

8.8 The development must also be considered in the context of national planning policies set out in the National Planning Policy Framework (NPPF) - see paragraph 7.5 above. The NPPF does not contain policies relating specifically to large scale horticultural development of the type proposed in this case, but it is underpinned by policies that recognise the importance of securing sustainable economic growth in both the rural and wider economy. The Framework does, however, set out the various economic, social and environmental dimensions of sustainable development, recognising the need to balance the economically beneficial aspects of development against, for example, the need to protect the character of the countryside and the vitality and viability of existing centres.

(ii)The principle of the development

The packhouse

8.9 The proposed development's packhouse element extends to about 0.9 hectares comprising a metal-clad structure with a barrel-vaulted roof of 11.9m in height. The building has been designed to closely match the applicant's Merston premises immediately to the south, and is sited and orientated to facilitate interaction between the two.

8.10 As set out in the Agricultural Adviser's response the purpose of the facility is to replicate what already happens at the Merston premises. This essentially involves the production and distribution of a variety of fresh, ready-to-eat salad and fruit- based products to various customers including a number of national supermarket and restaurant chains. The processes carried out at the facility would primarily involve the washing, chopping and mixing of fresh produce, although a small amount of ancillary products such as chicken, fish or salad dressings may be added to some dishes. No cooking would take place at the premises.

8.11 The applicant has confirmed that the majority of produce processed at the facility would originate from the UK, with as much as possible being sourced from the surrounding coastal plain area. Using local produce is cheaper (due to lower transportation costs), has longer shelf life (due to shorter transport times) and meets customers' increasing demands in respect of local provenance. However, at some times of the year, for example during the UK winter months and especially around the Christmas period, the facility would primarily process produce imported from mainland Europe. 8.12 Given that a primary purpose of HDA planning policies is to recognise and support horticultural activity within Chichester District, the issue of processing imported produce is a matter that requires careful consideration. However, whilst acknowledging that, it is accepted that given both the commercial realities of a development of this nature and scale and the year-round character of consumer demand for fresh produce, an element of such activity is inevitable. The Agricultural Adviser considers the likely proportion of imported produce to be generally acceptable; it would strike an appropriate balance between supporting local producers (and reducing 'food miles') and meeting customers' demand for convenient, healthy food products 365 days per year. Furthermore, it is noted that the Council has accepted the principle of other recent packhouse developments within the HDAs on a similar basis.

8.13 In view of the preceding considerations, and subject to the restrictions (via planning conditions) on certain activities, such as cooking and the introduction of anything other than an ancillary proportion of non-horticultural food-stuffs, no objection is raised in terms of the principle of erecting a packhouse of the nature and scale proposed.

The ancillary facility

8.14 As set out at paragraph 3.5 above the ancillary facility would be attached to the southern elevation of the packhouse and would accommodate a range of accommodation over two floors.

8.15 It is acknowledged that a substantial packhouse with up to 150 staff on site at any one time will require a range of supporting facilities, and the inclusion of a canteen facility along with changing rooms, various hygiene areas and plant and engineering rooms of the scale proposed is considered acceptable.

8.16 The principle of including a substantial (approx. 1500m2) element of office accommodation does, though, require careful consideration; it is acknowledged that this is an issue that forms part of the Parish Council's objection.

8.17 There is no in-principle objection to the inclusion of office accommodation that can be justified by the operational requirements of the packhouse. However, accommodation for office staff who do not strictly need to be located at the site to enable the facility to function may involve a degree of conflict with central Government planning policies which aim to steer such uses to more sequentially preferable locations i.e. within or close to existing settlements. Members will recall that this issue was central to consideration of a separate, unrelated glasshouse/packhouse/office proposal at the November 2014 Planning Committee meeting where the committee concluded that a similar quantum of office accommodation could be justified (NM/14/01721/FUL refers).

8.18 The applicant has provided further information to justify the scale of proposed office accommodation. It is stated that the majority of positions would indeed be required to service the day-to-day operational needs of the facility - for example those involved in managing deliveries and despatch, production planning, health and safety, food quality and safety and personnel management. Whilst the justification for these positions is broadly accepted, the need for a relatively small number of other roles to be accommodated on site - for example those involved in buying, marketing and packaging design - is perhaps less clear cut. The applicant has, however, explained that his business relies to a large extent on the ability to react quickly to customer's expectations - for example with large orders from national retailers being received for despatch within 24 hours. Given the nature of this business, together with the short shelf-life of the produce involved, there is a need for all of those involved in all parts of the production process to work as a close team in one location.

8.19 Furthermore, in order to justify this element of his proposal the applicant has confirmed the following: - the office accommodation is in part required to make good a shortfall in the very modest and cramped office accommodation provided at the adjacent Merston facility. The applicant confirms that there is a shortfall of approximately 200m2 of office floorspace at Merston, and that approximately 13 office staff would transfer from here to the new building. - Natures Way's Selsey premises will remain the company's HQ, with all over- arching corporate functions being accommodated there - the applicant would accept planning conditions requiring the office accommodation (i) to be limited to the area defined on the plans; and (ii) not to be occupied unless and until the packhouse had first been constructed and was ready for use; and (iii) to only be occupied for purposes in connection with the applicant's horticultural business activities being carried on within the Food Park

8.20 In conclusion on this matter, it is considered that, subject to the imposition of planning conditions in respect of the matters referred to above, the scale of office accommodation proposed can be justified by the particular circumstances of this case and would not materially undermine the aim of planning policies which aim to locate 'town centre' uses in geographically sustainable locations.

(iii) Character and appearance

8.21 The site lies in the Rural Area where local and national planning policies require the careful control of development in order to protect the essentially rural and undeveloped character and appearance of the countryside. Further, the site lies within the Chichester and Bognor Regis Strategic Gap (Local Plan policy RE6) which seeks to preserve the separate identity of those settlements by preventing coalescence.

8.22 Whilst the broadly restrictive backdrop of these policies is noted, by allocating Horticultural Development Areas there is a clear acknowledgement that large scale commercial horticultural development may take place within them. Although such developments will inevitably have some impact on the appearance of the locality, by concentrating such proposals is a few areas of countryside (which are not the subject of restrictive landscape designations) and by making best use of landscaping, the overall impact on the District's wider landscape can be minimised.

8.23 With a footprint of about 1 hectare and at nearly 12m in height the proposed building will comprise a substantial element of built form and, along with its various external parking, storage and service areas, will clearly result in a noticeable change to the character and appearance of the surrounding area. Furthermore, given its predominantly metal-clad elevations and general scale and form, the proposed building will have a generally utilitarian, industrial appearance. However, it must be noted that it would not be dissimilar in character to other recently constructed and permitted buildings on the Runcton HDA.

8.24 Given the scale of the development, views of the proposal are likely to be available from elevated locations within the National Park. However, the wider landscape impact of the development should not be significant given the distance from which such views are available and the fact that the development will be seen in the context of other packhouse and glasshouse development in the immediate vicinity of the site.

8.25 Various close to medium range public views of the proposal will be available. These are principally (i) from the A259, approximately 500m due north of the site and (ii) from the bridleway (2972) running through the south-eastern part of the site and along its northern boundary.

8.26 When viewed from the direction of the A259, the proposal will essentially result in the existing view of the applicant's Merston facility being brought approximately 275m closer to the observer. This change will be noticeable, but the impact of the proposal will to an extent be mitigated by the use of muted facing materials, a gently curving roof and the formation of a 3.5m high bund, fronted by a hedge and topped by tree planting, which would obscure both the lower part of the building's northern elevation and also the proposed parking and service yard areas. Given also that the building will be seen in the immediate context of other substantial structures with the HDA, there should be no significant degradation in terms of the character of the locality when viewed from this direction.

8.27 With regard to bridleway 2972, the proposal will clearly result in a substantial change to the experience of those using its two sections that would pass close the building and its ancillary areas, and it is acknowledged that this impact will to an extent be detrimental. However, whilst accepting that some harm would be caused, it is noted that only a relatively short section of bridleway would be affected and, further, that landscaping - which includes the formation of a planted bund adjacent to the eastern elevation together with a proposal to reinstate hedgerows to a 200m section of the bridleway to the east of the proposed building - will serve to soften and filter views to a degree. It is also noted that, in general terms, users of this bridleway already experience close views of other substantial structures on the Food Park; the site is not located within pristine countryside and, in that regard, the proposal should not be perceived as being particularly incongruous or 'suprising'.

8.28 The Highway Authority has confirmed that its Rights of Way Section raised no objection to the proposal subject to details of the treatment of the bridleway and its boundaries being reserved and to appropriate measures being put in place during the construction process; it is noted that any changes to the bridleway will need to be the subject of a separate consenting regime administered by the Highway Authority.

8.29 In conclusion on this issue, it is accepted that the proposal will inevitably impact upon the rural character of the locality. However, in view the preceding considerations and given that the justification for the packhouse is accepted it is considered that, subject to conditions securing robust and comprehensive landscaping, the impact of the packhouse on the character and appearance of the locality is acceptable. (iii) Highways and Parking

8.30 A facility of the scale proposed will clearly generate a significant level of traffic movements. The submitted information indicates up to 34 daily HGV movements with a daily total of approximately 640 movements generated by all modes of transport.

8.31 It can be seen from the Highway Authority's consultation response above that it accepts the A259 roundabout is capable of safely accommodating the likely range of additional movements. Although the site is located some distance from the nearest settlements, access by alternative modes of transport - by bus and via the Chichester to Bognor cycleway - is reasonable. The Highways Agency has raised no objections in respect of the proposal's likely impact on the wider strategic road network.

8.32 The proposed level of car (147), HGV, cycle and motorcycle parking provision is considered acceptable.

8.33 Further details of the safety measures to be employed at the point where the bridleway crosses the proposed access road are required and these will be reserved by condition. However, bridleway and road users should benefit from good levels of mutual visibility and no safety problems are anticipated.

8.34 In view of the above, and subject to conditions and financial contributions relating to improvements to sustainable transport measures at and near the site (see para 8.41 below), the proposal is considered acceptable in terms of transport, highway safety and parking matters.

(v) Residential amenity

8.35 In terms of potential visual intrusion, it is unlikely that views of any element of the proposal will be available from the nearest properties to the site on Green Lane.

8.36 Turning to the issue of potential noise disturbance, the initial approach taken by the applicant was to volunteer to adhere to maximum noise level planning conditions imposed on other recent Food Park planning permissions. As set out in the EHO's consultation response above, there is at least some evidence that might indicate that these noise levels are currently being breached and that residents (on Green Lane) are already suffering disturbance from both the premises on the northern part of the Food Park and from traffic using the access road that serves them.

8.37 Further information has been submitted by the applicant which demonstrates that, when taken in isolation, the proposal is unlikely to result in harm. However, whilst the EHO accepts that noise emanating from plant and general activity with the servicing and parking areas (both of which would be screened from the above dwellings by the packhouse itself) is unlikely to be problematic, concerns remain that the potential cumulative impact of traffic on the Food Park's access road has not been fully addressed. 8.38 Discussions with the applicant concerning a rigorous assessment of noise associated with use of the access road are on-going. However, given that, at the time of writing, a degree of uncertainty in this respect remains the EHO recommends a precautionary approach based on planning conditions requiring the submission of a comprehensive scheme of noise mitigation for the access road together with adherence to a maximum noise level at the nearest residential properties. Such a condition forms part of the recommendation below.

(vi) Surface water

8.39 The site lies within Flood Zone 1 which indicates a low level of flood risk. However, given the scale of the proposal it has been necessary for the applicant to submit a Flood Risk Assessment. This clarifies that the majority of water from the building's roofs and from adjacent hard surfaces would be captured and stored in the proposed reservoir in the south-east corner of the site from where it would drain at a restricted rate into the adjacent ditch network. Subject to the detail of the drainage measures and storage reservoir being reserved by planning condition, no objections are raised in this regard.

Significant Conditions

8.40 The recommendation below is subject to, amongst others, conditions in respect of the following matters:  Processes within packhouse - processing of horticultural produce only, with no cooking  Office use restriction - only to be used in connection with the applicants Merston and (proposed) Drayton premises.  Office accommodation not to be brought into use unless and until packhouse has been constructed and is ready for use  Top soil retention on site  External lighting scheme  Green Travel Plan  Details of treatment of bridleway and provisions for access road crossing point  Noise : mitigation and management plans and maximum noise levels  Construction management plan and construction hours  Comprehensive landscaping scheme including formation of planted bunds to flank the building's northern and eastern boundaries, hedge planting to all boundaries and reinstatement of native species hedgerow to 200m section of bridleway located on the eastern part of the site.

Section 106 agreement

8.41 As referred to in paragraph 6.5 above the Highway Authority has requested a TAD contribution of £244,768 towards sustainable transport infrastructure schemes in the vicinity of the site including the enhancement of bus stops close to the Food Park entrance, improvements to the A259 cycle route, the widening of the A259's approach to the Bognor Road A27 roundabout in order to introduce bus priority and enhanced pedestrians links into the Food Park from both the Vinnetrow and Lagness Roads. Conclusion

8.42 The principle of erecting a horticultural packhouse of the nature and scale proposed accords with both national and local planning policies relating to horticultural development. The proposal would involve significant investment in an important sector of the District's economy, would allow a successful local company to expand, would create a large number of jobs and would help meet rapidly growing consumer demand for ready to eat, locally sourced healthy food.

8.43 As with other recent developments within the HDA, the development would have some impact on the character of the locality. However, subject to the careful future consideration of detailed matters such as external materials, landscaping, external lighting and a noise mitigation and management scheme, the development can be achieved without causing significant detriment to the appearance of the locality, highway safety or residential amenity.

8.44 Consequently, when balancing the various economic, social and environmental considerations in this case the proposal can be considered to constitute a sustainable form of development which is capable of receiving strong support. It is therefore recommended that, subject to the conditions set out below and the completion of a Section 106 legal agreement to secure the infrastructure contributions referred to above, permission is granted.

Post deferral matters

Residential amenity

8.45 At the Planning Committee meeting held on 1 April 2015 Members heard from a number of residents of Green Lane (to the north-east of the site) who raised concerns about existing noise and light pollution issues which in their view resulted from activities at the Food Park. Following the debate, the Committee resolved to defer determination of the application in order for further information to be sought in respect of potential noise and light mitigation measures.

8.46 Discussions were held with the applicant who subsequently commissioned a new noise assessment. This primarily focussed on assessing noise associated with existing vehicular movements on the Food Park access road, comparing this to background noise levels and then predicting the impact of the proposed development.

8.47 The assessment was carried out over a 5 day period using automated noise monitors sited at three different locations close to the Food Park's access road. During these 5 days there were also two periods of attended monitoring which, in order to verify the automated results, involved surveyors separately monitoring noise at two locations on Green Lane.

8.48 The assessment comprises a comprehensive piece of technical work which can be viewed on the application file. However, its findings can be broadly summarised as follows: - the noise environment in the vicinity of the properties on Green Lane is currently dominated by noise generated by traffic on the A259 - the average noise generated by vehicles using the Food Park access road would, if taken in isolation, equate to less than half that currently created by traffic on the A259 - in order for traffic noise from the Food Park to be perceptible above the noise levels experienced from the A259 there would have to be a tenfold increase in HGV traffic using the Food Park access road - with regard to existing sudden noise events - such as those resulting from vehicles crossing the access road's speed bumps - the assessment concludes that (i) due to the distance between these sources and the Green Lane properties and the nature of the intervening terrain, noise is currently reduced so as to be within acceptable parameters; and (ii) measurements demonstrate that the frequency of such events already generated by traffic activity associated with the A259 is of an order of magnitude greater than those created within the Food Park. - during the attended survey periods there was no audible noise activity associated with either the Food Park premises or vehicles on the access road

8.49 As will be noted from his additional comments at Section 6.8 above, the EHO accepts the assessment's methodology and its primary conclusions that (i) there is no evidence to suggest that activity associated with the Food Park is currently resulting in material harm to nearby residential amenity and (ii) that any additional activity associated with the currently proposed and recently permitted developments at the Food Park will not change this situation. Clearly, the assessment's conclusions conflict with the concerns expressed by residents at the April meeting and possible reasons for this contradiction are referred to in the EHO's response.

8.50 Whilst the applicant is keen to reiterate the assessment's finding that no demonstrable harm to amenity is being or will be caused, he has nevertheless noted the neighbours' concerns and has undertaken to attempt to minimise any potential future impact on these residents through the following mitigation and management measures which would be secured via planning conditions (see proposed conditions 13 and 15 in the event that permission is granted): - removal of an existing speed bump at a point on the access road 200m to the south of the properties on Green Lane and its replacement with a chicane/road narrowing arrangement (detail to be agreed) - the provision of two belts of planting (including evergreen species) to the north of the part of the access road closest to Green Lane to prevent light intrusion from vehicle headlights. These would supplement both existing planting and planting required to be carried out under the terms of the grain store permission which is currently being implemented. - an agreement to a period of post-development noise monitoring in order to ensure compliance with the proposed condition requiring adherence to maximum noise levels (condition 21) - the provision of and adherence to a Noise Management Plan which would include a number of 'soft' measures such as regular staff briefings where the need for neighbourly behaviour within the Food Park and its environs would be reiterated and the provision of information to HGV operators in respect of driving behaviour and the use of potentially noise chiller units - an agreement to a 10 year replanting period in respect of new planting as opposed to the normal 5 year period 8.51 The applicant has, in conjunction with the manager of the Food Park's common areas (which include the access road), also undertaken to set up a Neighbourhood Liaison Group in order to provide a forum for facilitating ongoing discussion with nearby residents. Outside of this application process, the applicant also proposes to reduce the height of lighting columns within the parking area that serves the existing packhouse located immediately to the south of the site, and to also enhance planting to the bund which flanks this area's northern side. It should be noted that whilst the applicant has committed to carry out these works, it would not be reasonable to require them under the terms of the current application.

8.52 In summary on this issue, the findings of the latest noise assessment that demonstrable harm to residential amenity is not being caused by activity associated with the Food Park and that this will remain the case following this development, is accepted by the Council's EHO and your officers. However, notwithstanding the assessment's conclusion, the applicant has sought to demonstrate that the concerns of the residents are being taken seriously by suggesting a number of physical mitigation and on-going management measures which aim to ensure that the likelihood of disturbance being caused is reduced further. These measures, together with adherence to a maximum level of noise that can be emitted from the site and access road, would be secured by the conditions included in the recommendation below.

8.53 In terms of potential light nuisance, the two proposed belts of planting to the north of the access road should serve to screen the properties on Green Lane from the headlights of vehicles using the access road. A lighting scheme relating to the building itself and its attendant external areas is required under the terms of proposed condition 16.

8.54 In view of the preceding considerations no objections are raised to the proposal on the grounds of residential amenity.

Chichester Local Plan

8.55 Having recently been found sound by the Local Plan Inspector, the policies of the new Local Plan now attract significantly more weight than they did at the time the application was originally considered by the Planning Committee. Whilst the change in the status of these policies should be taken into account, the site is located within an HDA and the proposal is considered to meet the criteria of the HDA-specific policy in the new Plan (Policy 32). Consequently, the policy considerations set out in the report above are not materially affected and there remain no policy-based objections to the proposal.

Conclusion

8.56 For the reasons set out in the preceding paragraphs it is considered that the applicant has adequately addressed the concerns raised by Members at the April meeting. Furthermore, since that time neither planning policy nor on- site circumstances have changed in a manner that would justify a conclusion on the planning merits of the application that differs from that which is set out in paragraphs 8.42-8.45 above. Accordingly, it is recommended that, subject to the conditions set out below and the completion of the Section 106 agreement referred to above, permission is granted.

Human Rights

8.57 In reaching this conclusion the Human Rights of the applicants and nearby occupiers have been taken into account when reaching this recommendation and it is concluded that the recommendation to permit is justified and proportionate.

RECOMMENDATION DEFER FOR SECTION 106 THEN PERMIT

1 U92350 - Time limit 2 U92351 - Decision plans 3 U92352 - materials 4 U92354 - service yard details 5 U92355 - screen walls/fences 6 U92356 - archaeological investigation 7 U92357 - foul/surface water 8 U92358 - access details 9 U92359 - PRoW safeguarding 10 U92360 - Construction Method Statement 11 U92361 - construction hours 12 U92362 - topsoil retention 13 U92363 - Noise Mit and Man Plan + monitoring 14 U92364 - landscaping scheme 15 U92365 - landscaping implementation - 10 years 16 U92366 - lighting scheme 17 U92367 - parking/turning etc provision 18 U92368 - Travel Plan 19 U92369 - ancillary accommodation 20 U92370 - packhouse use 21 U92371 - noise levels 22 U92372 - access from A259 only 23 U94845 - Siting - clarification

INFORMATIVES

1 U92373 - Ecology 2 U92374 - noise mitigation plan 3 U92375 - surface water drainage 4 U92376 - PRoW 5 U92377 - landscaping 6 U92378 - s106 7 U92379 - S59 agreement 8 U92381 - EA consent 9 U92383 - proactive approach to determination

For further information on this application please contact Steve Harris on 01243 534734