SUPPLEMENTARY STATEMENT

Gedling Borough, Broxtowe Borough and City Submission Aligned Core Strategy

Representations: Matter 2 – The Spatial Strategy and Housing Policy

On behalf of Northern Trust Company Ltd

September 2013

1.1 Northern Trust Company Ltd (hereafter referred to as ‘Northern Trust’) submitted representations to the Gedling Borough, Broxtowe Borough and Nottingham City Publication Draft Aligned Core Strategy (ACS) dated 23rd July 2012. The Inspector has invited representors to submit supplementary statements on identified Matters and Issues ahead of the forthcoming Examination in Public (EiP) Hearings.

1.2 This statement responds to Matter 2 and expands upon Northern Trust’s representations insofar as they are considered relevant to this Matter.

1.3 A series of separate supplementary statements have been submitted on behalf of Northern Trust, by GVA, to address other identified Matters. Cross-reference is made to those statements where relevant below.

1.4 Northern Trust’s representations extend support to principles behind large parts of the Spatial Vision, Objectives, and the character of the area and Spatial Portraits. They are in large part considered to provide a sound basis for the Core Strategy, but it is considered that the vision and objectives have not been correctly applied. Northern Trust’s principal issue with the soundness of the ACS is that a major strategic site in a sustainable location at Teal Close, which in part benefits from an existing mixed use allocation in the Gedling Borough Local Plan Review (2005), has not been specifically recognised in the ACS. The absence of a strategic allocation for the site, means that the ACS does not represent the most appropriate strategy when considering alternatives, and does not possess the necessary level of certainty and flexibility to meet its stated aims. The Teal Close site is currently the subject of an outline planning application 2013/0546, details of which are included at Appendix A of this Supplementary Statement.

1.5 The remainder of this Statement seeks to respond to the Inspector’s questions, where applicable to Northern Trust’s representations.

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Overall Housing Provision Q5. Overall, does Policy 2 define the settlement hierarchy appropriately, and then identify sufficient and appropriate key sites which are critical to the delivery of the housing strategy over the plan period? (see Qs 23 onwards below)

1.6 The settlement hierarchy as identified in Policy 2 paragraphs 1 and 2, and justification paragraph 3.2.3 is considered to be appropriate, and in accordance with the principles of sustainable development.

1.7 However, insufficient Key Sites and Strategic Locations for development have been identified in Policy 2 of the ACS. The reasons for this are outlined in the response to questions 8 and 10 below.

1.8 To ensure development is appropriately located in accordance with the urban concentration and regeneration objectives of ACS Policy 2 a greater proportion of development should be located around the main urban area of Nottingham, additionally as necessary but certainly in preference to more remote locations. This would include the identification of a Key Site at Teal Close. This is justified further in response to question 6, below.

6 Is the distribution of sites consistent with the first paragraph in Policy 2 which places emphasis on urban concentration with regeneration, or has there been a relaxation of the Regional Plan-based policy (of concentration on sites in the Principal Urban Area with priority given to brownfield sites)? If so, has this change resulted in an unsustainable strategy?

1.9 The distribution of Key Sites identified in Gedling Borough as Key Sites is not considered to be compliant with the objectives of Policy 2.

1.10 Gedling Borough Council have not identified one Key Site in the PUA, albeit Policy 2 requires 2,840 dwellings to be built within or adjacent to the PUA over the plan period (Policy 2. 3a) ). The only site within or adjacent to the PUA in Gedling is the Gedling Colliery/Chase Farm, which it is acknowledged at paragraph 3.2.24 of the ACS will not come forward during the plan period.

1.11 The Key Sites for Gedling currently adjoin Sub-Regional Centre (Top Wighay Farm and Papplewick Lane). In accordance with the settlement hierarchy set out in Policy 2 these sites are in the second tier of the hierarchy. At the third tier of the settlement hierarchy, at the Key Settlements of Bestwood, Ravenshead and Calverton, Gedling Borough Council propose 2,543 dwellings.

1.12 The focus of urban concentration for new development in Gedling is therefore diluted, with Key Sites and locations in tiers 2 and 3 of the settlement hierarchy. In addition, an almost equal amount of development is proposed in the key settlements, as proposed in PUA locations. The most sustainable strategy for development over the Plan area is therefore is not currently outlined for Gedling in the ACS. Page 3 of 7

1.13 The Teal Close site adjoins the Principal Urban Area (PUA) of Nottingham and has excellent links with the City. It therefore meets the objectives of ACS Policy 2.

1.14 Gedling Borough Council has acknowledged that the Teal Close site can provide 400 dwellings in the Strategic Housing Land Availability Assessment (SHLAA) Background Paper, June 2013 (core document CD/BACK/16). This is purely reflective of the present allocations that apply to part of the site in the adopted Gedling Borough Replacement Local Plan and does not take in to account the potential to re-consider the adopted employment allocation on the wider site nor the need to release Safeguarded Land on the wider site. The Council’s position does not take account of the site’s full development potential, the landowners intentions and aspirations, and the firm and justified proposals set out in the current planning application referenced above.

1.15 In evidence supplied to the Council in advance of the Submission of the ACS, and within the current planning application, it is demonstrated that the wider Teal Close site is well-related to the PUA, and is otherwise suitable, available and deliverable for a mixed use development, comprising up to 830 residential dwellings, up to 18,000 sq m of business floorspace and a range of complementary uses. This overall proposal would incorporate the housing and employment allocations on the site in the adopted Gedling Borough Replacement Local Plan, but also Safeguarded Land immediately to the east. It would not interfere with Green Belt land, which would be used purely for uses appropriate to the Green Belt (e.g. recreational open space and ecological mitigation).

1.16 The wider, deliverable and justified proposition for the Teal Close Site is of strategic significance, of a comparable scale as those sites that are specifically identified in the ACS.

1.17 The site is sustainably located and aligns directly with the Spatial Strategy, to a much greater extent than many of the selected sites / locations. Beyond its accessibility to and relationship with the PUA, it also aligns with the regeneration requirements of Policy 2. The site is adjacent to the Netherfield and Colwick areas, are identified as being within 20% of the UK’s most deprived areas (ACS, paragraph 2.2.20). The regeneration benefits associated with the development of the Teal Close site through employment opportunities and increasing housing choice would have major beneficial impacts on the area.

1.18 Teal Close site should be identified as a ‘Key Site’ in the ACS. By increasing the number of dwellings to be provided at the site from 400 to 830, the number of dwellings to be provided in the PUA could increase to 3,270, ensuring focus for development in Gedling remains in and adjacent to the the PUA, and maximising potential for regeneration, consistent with its own stated Strategy. It would convey certainty on deliverability, which is not afforded by leaving such matters to an Allocations DPD, particularly in view of the present Safeguarded Land designation that applies to the site. Page 4 of 7

1.19 Gedling Borough Council has not provided a sound basis for discounting the strategic allocation of the Teal Close site, citing only a deficiency in evidence at the time of preparation. It is for the Council to meet the NPPF requirements and tests of soundness by ensuring the Plan is ‘positively prepared’ and ‘justified’, including that it represents the most appropriate of reasonable alternatives. The site is well known to the Council (not least given its present allocations), and evidence has been available to the Council to demonstrate the site’s suitability for some time. The absence of the site from the ACS, in view of the identified needs and stated spatial strategy, means that the ACS fails the tests of soundness, and is not consistent with national planning policy.

8 Do the table in Policy 2, new paragraph 3.2.8a and footnote 31 on Page 52 of the modified plan [CD/REG/03], imply a shortfall against housing requirements in the five year supply of specific, deliverable housing sites? If so, how can this be remedied; do results from the 2013 Strategic Housing Land Availability Assessment (SHLAA) help?

1.20 Gedling Borough Council’s five year housing land supply requirement as set out in Policy 2 of the ACS is 2,217 (2750 - 533 completions during 2011 to 2013, as outlined in the housing trajectory in Appendix C of the ACS).

1.21 Gedling should have a 20% buffer in accordance with the National Planning Policy Framework (NPPF) as they have only met their housing requirements twice in the past 11 years:

• 2003/04 where completions were 355 dwellings in relation to a 250 dwelling pa requirement as set out in the Joint Structure Plan;

• 2007/08 where completions were 447 dwellings in relation to a 400 dwelling pa requirement as set out in the East Midlands Regional Plan.

1.22 This clearly equates to a persistent under delivery. Gedling’s five year supply requirement based on the proposed ACS figures, with the appropriate 20% buffer, is therefore:

Housing requirement up to 2018 2,750

Minus completions (as outlined in housing trajectory in 533 Appendix C of the ACS)

5 year Requirement up to 2018 2,217

20% buffer (based on above Requirement) 2,328

Revised 5 year Requirement with 20% buffer 2,661

1.23 The housing supply identified in the ‘Five Year Housing Land Supply Assessment as at 31 March 2012’ (updated February 2013) is 2,198 dwellings. This falls short of the Page 5 of 7

requirements. The Five Year Housing Land Supply Assessment goes on to suggest at page 14, that the housing trajectory identifies all suitable sites available for development across the plan period. As such the larger theoretical capacity figure of these sites is actually 2,426 dwellings. However, this still falls short of the requirement with the appropriate buffer.

1.24 It is therefore at best marginal as to whether Gedling have a 5 year supply of housing land and there is clearly no flexibility in land supply. Should any of the sites not come forward for development, at the anticipated densities, or are delayed, Gedling will certainly not have the requisite supply of housing land.

1.25 In accordance with the NPPF the Local Plan should be clear on sites required to meet the development needs of the area going forward, and provide for choice and competition in the market to ensure development needs are met. In order to ensure an appropriate 5 year supply more Key Sites should be identified in Policy 2 of the ACS.

1.26 It is accepted that part of the 5 year supply identified by the Council comprises the Teal Close site (based on the site’s existing allocations), but it is anticipated that a greater contribution could be made to the 5 year supply through the wider development of the site for a greater amount of housing (up to 830 residential units). The strategic allocation of the site, conveying greater certainty, would facilitate this.

9 What should be the appropriate buffer, based on the NPPF’s thresholds and past housing delivery for the three authorities?

1.27 A 20% buffer is considered to be appropriate for Gedling Borough Council as outlined in paragraphs 1.21 – 1.22 above.

10 Do the housing trajectory and schedule of strategic sites in Appendices C and A demonstrate that there is an adequate supply of specific, developable sites or broad locations for growth for the years 6-10 and 11-15?

1.28 The overall housing requirement as set out in Policy 2 of ACS for Gedling is 7,250. The housing trajectory in Appendix C identifies sites for up to 8,134 dwellings (with footnote to the table stating this is a ‘theoretical maximum’ for all suitable sites). This provides limited flexibility in housing land supply in Gedling during the plan period.

1.29 Of the Key Sites proposed there is a lot of reliance on historically allocated sites. Top Wighay Farm benefitted from a residential and employment land allocations in the 2005 Local Plan, together with areas of safeguarded land. Papplewick Lane was allocated as entirely safeguarded land in the 2005 Local Plan. Neither sites have come forward for development to date.

1.30 Of the strategic locations identified both Calverton and Ravenshead have constraints identified in the ACS paragraph 3.2.15, due to their proximity to the Sherwood Forest prospective Special Protection Area. The housing trajectory proposed over 500 dwellings more than allocated in Policy 2 for Calverton and Ravenshead, presumably Page 6 of 7

to reflect the theoretical maximum dwellings that can be provided. Given the constraints of these strategic locations it is questionable that the trajectory maximums can be reached.

1.31 The Local Planning Authorities appear to have doubts about the deliverability of the sites identified in Policy 2, in paragraph 3.2.37. This allows for other sites in the SHLAAs to come forward to meet any shortfall during the plan period, or identify other Sustainable Urban Extensions if necessary. As a last resort if no sites can be found it suggests a review of the ACS itself. This is approach not considered to be in accordance with the NPPF which requires LPAs to plan positively for development and infrastructure requirements over a 15 year period.

11 Are the sites listed in Policy 2 capable of delivering the required housing within the plan period, given that paragraph 3.2.13 suggests several of them were identified in earlier Local Plans and some representors question the ability to delivering brownfield sites?

1.32 Please refer to the response to question 10 above.

13 Is the ACS sufficiently flexible overall allowing some headroom for the currently unpredictable delay or non-delivery of some sites?

1.33 Given the housing requirements and identified limited supply, as outlined above it is not considered that there is sufficient flexibility for delay or non-delivery of any of the Key Sites or Strategic Locations. Please refer to paragraph 1.29 above.

Sites and Settlements for New Housing Development 23 Are the sites named in Policy 2 (and see Appendix A for Strategic Sites Schedules and Plans) the best options for growth? Have they been selected following objective assessments of all reasonable alternatives through sustainability appraisal [see CD/REG/06]? If not, where specifically did the process fail?

1.34 The Gedling sites identified in Policy 2 are not considered to be the best options for growth. As outlined above the sites do not meet the PUA concentration policy objective of Policy 2 of the ACS, nor are there sufficient sites identified to meet a 5 year supply requirement, or should delivery be less than anticipated during the plan period.

1.35 Inclusion of the strategic allocation of land at Teal Close will address both issues of distribution of sites and provide flexibility in delivery of them.

1.36 The Teal Close was discounted from the Sustainability Appraisal process due to concerns of floodplain limiting the site’s development potential. This issue is dealt with in full below.

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25 If you consider that the sites should be replaced with other sites or that additional sites should be included in the policy, have those (new) sites been subject to sustainability appraisal? What did the appraisal conclude? And, has public consultation been carried out for those sites?

1.37 As noted throughout this statement the full development potential of the site at Teal Close should be realised in the ACS to meet the development needs of the Borough.

1.38 The Site was discounted from further consideration at the initial stages of the Sustainability Appraisal process (refer to table 13 of the Sustainability Appraisal Core Document reference CD/REG/06). The ‘Appraisal of Sustainable Urban Extensions’ (June 2008) by Tribal Studios discounted any growth outside the existing allocations for development in the Trent Corridor East area due to floodplain constraints limiting development (paragraphs 2.7.1 and 2.7.2).

1.39 This was also recognised by Officers in the ‘Summary of the Main Issues Raised by Representations on the Publication Version Aligned Core Strategies’ (May 2013) document. In direct response to representations promoting Teal Close as a strategic site Officers stated that the sustainability of the Site has long been established and led to the current allocation of the site, however further evidence would be required to address issues of flooding and highways.

1.40 Such evidence could have been generated by the Council, or indeed specifically requested from the landowners at the appropriate time. The site was discounted too readily despite its clear accordance with the spatial objectives of the Plan. This evidence has now been assembled in the context of the current planning application, and it has been proven that the site is capable of delivery and accommodating the scale and composition of uses proposed within that application. Given the wider credentials of the site, we would fully expect that the re-running of the Sustainability Appraisal to reflect the additional evidence, would find that the site performs well and represents a more sustainable alternative than a number of those selected for allocation.

1.41 The inclusion of the Teal Close site as a strategic allocation would necessitate the Sustainability Appraisal being updated, but without it, the ACS is not sound. It would also likely necessitate formal consultation on such a change (notwithstanding the extensive consultation undertaken on the planning application), given that the Plan has discounted the site’s inclusion in all previous drafts of the ACS, but again this is deemed necessary in order to ensure the Plan is sound.

1.42 It should be taken into consideration that the Council has indicated local and corporate political support for the principles, as have senior planning officers. We are presently seeking to firm up the terms of prospective S106 obligations, before moving to an early Committee. SUPPLEMENTARY STATEMENT

Appendix A

Teal Close Planning Application Details

The Teal Close site is currently the subject of an outline planning application, reference 2013/0546.

This appendix contains the following documents which identify the site location and outline the development proposals:

• Site location Plan reference DE076_016;

• Proposed Parameters Plan reference DE076_014 revision B;

• Development Schedule.

Land off Teal Close, Gedling Borough Schedule of Development

Use Use Class Floorspace (gross floor area m 2) / Units / Land Area

Employment Use B1/B2/B8 Up to 18,000 m 2 *

Local Centre comprising of: A1/A2/A3/A4/A5/B1/D2 Up to 2,800 m 2 * Retail / Financial and Professional Services / Food and Drink / Takeaway / Non-Residential Institutions / Leisure

Residential C3 Up to 830 Units

Hotel C1 Up to 150 beds

Care Home C2 Up to 60 beds

Single Form Primary School D1 1.1 Ha

Community Building D1/D2 Up to 500 m2

Sports Pitches - 4.2 Ha minimum

Ecology Park - 10 Ha minimum

General Open Space (including - Refer to Parameters landscaping, children’s play areas Plan and allotments)

*: The employment uses and local centre will comprise of no more than 4,500 m2 of B1 office I

T H LC Mast FLORENCE Sewage ROAD E C Works N Football E

F ROAD R L O Ground O L R F 22m E

N A6211D C Pav R E LEGEND N C Drain Drain O R 22m T R Site boundary U B

Residential (to include children's play, 2 No. LEAPs, landscaping Pipeliine and drainage and highways infrastructure requirements EMERYS Recreation Water Reclamation Ground Residential zone of height limitation (predominently 2 RD storeys & maximum 2.5 storeys) Works ROAD D G New Employment/commercial B class uses W A Works H S WILLIAM Cottages Local centre A1-A5, B1, C1 & D1 24m EMERYS 22m Allot

AMBLESIDE Gdns

21m Community D1-2 CL Works 30 WY m m Primary school

30

A V E Landscape buffer/development offset (see dimensions T for minimum requirements from site boundary) N E LOUISE STREET C S 20 Landscape buffer/development offset (see dimensions E S m R for minimum requirements from site boundary to include a minimum O D STOKE of 10m woodland/buffer planting) N A H Allotments (to include buffer/offset to allow for C M footpaths/cycleways) ID AV Allot L 22m LANE A N Gdns Recreation ground (to include a minimum 4.2ha sports D CHANDOS pitches & 1 No. NEAP) COLWICK GR Parkland (to include a minimum 10ha Ecology Park & drainage Top Row

Rail infrastructure requirements)

Sch Track 10 BELVOIR m Retained woodland/tree groups (loss limited to access requirements) way

L Retained hedgerow RD AVE O O C Drain GN P STREETL Playing U M B Field Retained tree E R A ROAD V disused Principal points of access * LEY (refer to drawings 90372_001C, 002 & 003B for details) 20 A m 6 S 2 Football T Retained public right of way R 1 ST E 1 Ground E T LILY Drain Minimum 10m building offset (from hedgerow/woodland - ASPER AVE may include minor roads) BP ST

STREET Pavilion 22m E INDICATIVE ROUTES U 20 STREET DN m E R 21m V U A M Primary vehicular route (indicative only) ST M O CROSS N R D Emergency access link (indicative only) CURZON GN E A ST T V DUNSTAN S

BRIERLEY E H

C A612 Cycleway (indicative only) D E O N N R ST IS 21m Footpath (indicative only) WAY E STOKE BARDOLPH CP STREET IV D R Y * Principal access on Stoke Lane to serve employment (B class) uses only, L E S other than in an emergency. STREET Hall G

IN HENLEY TEAL K A 5m +/- tolerance may be applied to the land use boundaries, except where DUNSTAN 22m CL development/building offsets are defined. Ind Est DENNIS LC Residential, recreation ground and parkland zones together are to NORTHERN PW accommodate a minimum of 4.77ha of play area/sports facilities, inclusive of Netherfield 1 no. NEAP and 2 no. LEAPs, and a minimum of 4.2ha of playing pitches. Govt CLOSE STREET STREET V IC T 21m Office O R IA

COOPER GREAT Rev Description Date R O A D VICTORIA ST E HODGKINSON R PARK U Path T ARTHUR B Rev S WY

ST A

P Development Schedule ROAD NORMAN R O E N H Land Use Max units/GFAT Max Ridge Height DE076_014 Drg No STREET STREET N E VICTORIA STREETST E

R LOOP U 1. Residential 830T dwellings 3 storey 11m (see plan for restrictions) S K A IC Northern Trust Client P 2. Employment/commercialDEABILL Business: W R L O FB E C H P T up to 18,000m2 B1-B2 & B8 2 storey 12m A E R GODFREY N Local centre/commercial: K Land off Teal Close, Stoke Bardolph Project WAY up to 2,800m2 A1-A5, B1 & D1 2 storey 9m Victoria hotel C1 150 beds 3 storey 12m Parameters Plan Title Park residential care home 60 bed 3 storey 12m

20m (total B1 within the business and/or local centre/commercial areas comprising not more than 4,500m2) 1:5,000 Scale PINTAIL 0 50 75 100 m 3. Community up to 500m2 D1-D2 1 storey 9m MALLARD Track ROAD 4. School 1 form entry 2 storey 10m Petrol and Oil

C Rail Terminal L ROAD

DRAKE FLORENCE Sewage ROAD E C Works N Football E

F ROAD R L Ground O O L R F 22m E

N A6211D C R Pav E N C Drain Drain O R 22m T R U B

Pipeliine EMERYS LEGEND Recreation Water Reclamation Ground RD Site boundary 62.88 ha Works ROAD D G New W A Works H S WILLIAM Cottages EMERYS 22m Allot

AMBLESIDE Gdns 21m CL Works WY

A

V E T N E LOUISE STREET C

S O D STOKE N A H C M ID AV Allot L 22m LANE A N Gdns D CHANDOS COLWICK GR

Top Row

Rail

BELVOIR Track

way

L RD AVE O O Drain C GN P STREETL Playing U M B Field E R A

V ROAD

disused LEY A 6 S 2 Football T R 1 E 1 Ground E T LILY Drain ASPER AVE ST BP

STREET Pavilion 22m E U STREET DN E R 21m V U A M ST M O CROSS N R D

CURZON GN E A ST T V DUNSTAN S

BRIERLEY E H

C A612 D E O N N R ST IS 21m

WAY E STOKE BARDOLPH CP STREET IV D R Y L E S STREET Hall G

IN HENLEY TEAL K

DUNSTAN 22m CL Ind Est DENNIS LC NORTHERN PW Netherfield

Govt CLOSE STREET V IC T 21m Office O R IA

COOPER GREAT R O A D VICTORIA ST E HODGKINSON R

U PARK Path T

S WY

ST A

P

ROAD NORMAN R E H T STREET STREET N E VICTORIA STREETST E R LOOP U T S K A IC P DEABILL W R L Rev Description Date O FB E C H P T A E R Rev GODFREY N K

WAY DE076_016 Drg No

Victoria Northern Trust Client Park Land off Teal Close, Stoke Bardolph Project

20m Site Location Plan Title

PINTAIL 0 50 75 100 m MALLARD Track ROAD 1:2,500 @ A1 Scale

Petrol and Oil