Response to the Further Draft Local Plan University of Lincoln Response to the Central Lincolnshire Local Plan Proposed Submission University of Lincoln Contents 1. Introduction and Background 2 Local Enterprise Partnership 3 2. The Test of Soundness 5 3. Response to the Submission Local Plan 7 Appendices 17 Appendix A 18 Un iversity of Lincoln May 2016 1 Response to the Further Draft Local Plan University of Lincoln 1. Introduction and Background 1.1. This report has been prepared as part of the University’s response to the Central Lincolnshire Local Plan (Proposed Submission) and follows previous submissions to both the Joint Planning Unit and Central Lincolnshire Joint Strategic Planning Team dating back to September 2010, the most recent being November 2015. 1.2. The purpose of this report is to make representations to the Central Lincolnshire Local Plan Team, in respect of a number of policies to be submitted for Examination in Public later this year. The University has since November 2015 engaged with local stakeholders positively. Whilst the importance of the University has been verbally acknowledged, the institution feels the Submission Draft Local Plan (“the Submission Draft”) as it stands, does not reflect this importance, nor has it taken on board the University’s written representations adequately. Instead of incorporating the University’s suggested amendments to the consultation draft plan in the Submission Draft, the Council has indicated to the University that the Inspector will be asked to address the issues raised in the University’s representations. We do not believe that this approach is appropriate. In light of the approach adopted by the Local Plan Team, these submissions develop the points made on the University’s behalf in November 2015. The two documents should be read together. 1.3. The Submission Draft continues to recognise the importance of the University as a key driver in economic growth in the region but the institution feels that it fails to support the University in the delivery of its Estate and academic investment Strategy – this, in the University’s view is a flaw which goes to the soundness of the Local Plan in its failure to be plan positive, particularly where the University is concerned. 1.4. The University of Lincoln is estimated to be worth more than £300 million to the local economy, doubling local economic growth rates, and creating more than 3,000 new jobs. The National Centre for Food Manufacturing at the University’s Holbeach campus is a state-of-the-art training facility, sponsored and updated by the multi-billion pound food industry. The University is leading the transformation of the agri- tech and agri-food industry in the county and supporting the STEM (science technology engineering and maths) and health agenda; industries recognised in the Submission Draft as a key area of economic growth. 1.5. The University needs a robust and supportive policy framework if it is to continue to grow over the 15 year plan period and increase its contribution to the Central Lincoln's economy. Local Plan policy support is key to attracting further investment to enable the University to deliver its long term growth strategies and in the short term, deliver a Centre of Excellence, in the guise of the new Lincoln Institute of Agri-Food Technology (LIAT), at its Riseholme Campus. University of Lincoln May 2016 2 Response to the Further Draft Local Plan University of Lincoln Local Enterprise Partnership 1.6. The Greater Lincolnshire Local Enterprise Partnership (“GLLEP”) Strategic Economic Plan - is a strategic business investment programme across Lincolnshire, North Lincolnshire and North East Lincolnshire which aims to help create 13,000 new jobs, support the building of 100,000 new homes,help 22,000 businesses grow and increase the size of the economy by £3.2Bn. Lincolnshire has also been successful in securing One public sector Estate programme finance. The University and its Brayford and Riseholme site are key components of GLLEP’s Economic Plan (see 1.7 below). 1.7. A core theme of the Strategic Economic Plan is the important role the University of Lincoln will play in driving economic growth noting that ‘the University is at the forefront of supporting innovation in the local business community, growing its research capacity and performance and driving transformational change’.1 1.8. The Submission Draft refers to the GLLEP Economic Strategy, in particular in section 2.4.1 (“Our Vision”) and at section 2.5.3 where it is stated that: “The Local Plan objectives have evolved from the review of relevant plans and programmes undertaken for the Sustainability Appraisal process. They reflect the aims and objectives of other important strategies that affect Central Lincolnshire’s future. This is to ensure that the Local Plan and other plans are as closely aligned as possible and that strategies support each other. Examples include: • Greater Lincolnshire Enterprise Partnership Strategic Economic Plan • Growth Strategy for Lincoln • Lincolnshire Joint Health and Wellbeing Strategy Lincolnshire Joint Strategic Needs Assessment • Corporate Plans for City of Lincoln, • North Kesteven and West Lindsey Lincolnshire Biodiversity Action Plan • Lincolnshire Local Transport Plan and local transport strategies • Joint Lincolnshire Flood Risk and Drainage Management Strategy” 1 The Greater Lincolnshire Local Enterprise Partnership Strategic Economic Plan, March 2014, page 31. University of Lincoln May 2016 3 Response to the Further Draft Local Plan University of Lincoln 1.9. The University feels that the Submission Draft does not reflect the supportive policies of the Strategic Economic Plan. In the GLLEP, support for the University’s continued long-term growth and development is recognised as being fundamental to delivering a strong and stable economic future for Central Lincolnshire. However, there is no equivalent economic support in the Local Plan. 1.10. In the short term, the lack of policy support for investment at the University’s Riseholme Campus continues to conflict with the next phase of development by the University at Riseholme and across the county. Since November 2015, the University, working closely with the Local Enterprise Partnership has sought to develop plans for development of agri-tech and agri-food. The University is now proposing development of the new Lincoln Institute of Agri-Food Technology (LIAT) which will be based in a new, state of the art centre at Riseholme complementing the already established National Centre for Food Manufacturing at Holbeach and the Food Refrigeration and Process Research at Grimsby (creating a ‘food corridor’ through the LEP region). 1.11. The University intends for the LIAT to be hosted at the University’s Riseholme Campus and to form part of the mixed-use redevelopment of the campus. The project’s location combines agricultural land with buildings in a model farm which will host laboratories, seminar rooms, a modern glasshouse and workshop space to allow both field trials and events and workshops to be held, bringing together scientists, technology companies and end users. It will also provide a specialist Avian research facility and laboratories in support of West Lindsey’s proposed Food Enterprise Development Zones. 1.12. Riseholme is the appropriate location for the development. The campus forms part of West Lindsey District Council’s Agri-tech corridor Local Development Order (LDO) which runs along the A15 from Grimsby to Lincoln. 1.13. The University is currently preparing a planning application for submission to West Lindsey District Council on this basis which will include an element of sustainable high quality housing to part fund these critical developments. Whilst both West Lindsey District Council and Lincoln City Council have been supportive of the principles of the investment at Riseholme and understand the need to create a capital receipt from some of the land to fund the investment, this support has failed to materialise in draft policy. The Submission Draft, if adopted as drafted, could prevent meaningful development at Riseholme and prevent development of the LIAT Centre. The authorities have encouraged the University to seek changes to the Submission Draft at Examination in Public and/or to advance a case in a planning application that the LIAT is justified by exceptional circumstances. The Institution feels that this puts development at Riseholme in a precarious position and this uncertainty is likely to have funding implications for the development. The authorities’ approach is therefore inconsistent with the clear support for growth at the University in the GLLEP’s Economic Strategy and the Submission Plan’s strategic aim of encouraging and supporting a competitive economy. University of Lincoln May 2016 4 Response to the Further Draft Local Plan University of Lincoln 2. The Test of Soundness 2.1. The allocations and supporting policies in the Draft Local Plan will be subject to the tests of soundness under independent examination under Section 20 of the 2004 Act, as set out in the National Planning Policy Framework at paragraph 182. 2.2. The mis-match between the Local Plan's economic objectives and the absence of specific policy support for the University's growth undermines the soundness of the Local Plan, in the context of positive and effective plan making. Again building on the University’s previous submission in November 2015 we comment on each of the four tests as follows: § Positively Prepared: The University considers that whilst the Local Plan sets out clear strategies for growth which are embedded in sound evidence and to an extent reflect the objectives of the Local Enterprise Partnership, failure to provide policy support for the University’s continued growth undermines those objectives. Further, the University does not consider the Plan is sound on the basis of the deliverability of some of the sites identified in Lincoln and therefore the ability to deliver a five year housing land supply is flawed.