Mclaren CAMPUS WOKING WOKING BOROUGH COUNCIL SITE ALLOCATIONS DPD REGULATION 19 CONSULTATION RESPONSE Mclaren TECHNOLOGY GROUP LTD DECEMBER 2018

McLAREN CAMPUS WOKING WOKING BOROUGH COUNCIL SITE ALLOCATIONS DPD REGULATION 19 CONSULTATION RESPONSE McLAREN TECHNOLOGY GROUP LTD DECEMBER 2018

Issue / revision FINAL Prepared by Thomas Southgate

Reference 135727 Signature

This document is issued for Date December 2018

[ ] Information [ ] Approval Checked by Tim Hancock

[ ] Comment [ X ] Submission Signature

Comments Date December 2018

Authorised by Tim Hancock

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Date December 2018

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All figures (unless otherwise stated) © Terence O’Rourke Ltd 2018. Based upon the Ordnance Survey mapping with the permission of the Ordnance Survey on behalf of Her Majesty’s Stationery Office © Crown Copyright Terence O’Rourke Ltd Licence number 100019980.

Contents

Response to Regulation 19 consultation question 5 4 Response to Regulation 19 consultation question 6 17 Response to Regulation 19 consultation question 8 18

Regulation 19 consultation question 5

Please give details of why you consider the Site Allocations DPD is / is not legally compliant or is sound / unsound, or has met / not met the requirements of the Duty to Cooperate. Please be as precise as possible. Include any references to relevant legislation, policies and/or regulations

1. Introduction

1.1 McLaren Technology Group Ltd (McLaren) wishes to outline its overall support for Woking Borough Council’s Site Allocations DPD. However, it considers that the plan in its current form is unsound when tested against paragraph 182 of the National Planning Policy Framework 2012 (paragraph 35 in 2018 version), as it does not consider it to be positively prepared, justified or consistent with national policy. Principally, McLaren considers that there is a clear justification and benefit to its campus being removed from the Green Belt and allocated within the DPD as a strategic employment site or explicitly identified as a strategic employment site in the Green Belt.

1.2 Principally, McLaren considers that there is a clear justification and benefit to its campus being allocated within the DPD as a strategic employment site in the Green Belt.

2. About McLaren

2.1 For over 50 years McLaren has operated at the forefront of British automotive engineering and design from its base in Woking, and it is renowned as one of the world’s most prominent high-technology brands. Its Formula 1 success has led to its automotive components being incorporated into other race team cars, to the success of the McLaren Formula 1 road car, the Mercedes-Benz SLR McLaren road car, and to the Group’s confidence in its expanding range of McLaren Automotive road cars, the most recent being the McLaren Senna and McLaren Speedtail.

2.2 McLaren’s success in the motor racing industry has in part resulted from the continued excellence in engineering and design achieved at its campus in Woking, and the skills and associations built up within the local population. McLaren is a global brand, a major part of the national motorsport cluster, and a nationally significant exporter. McLaren therefore is a significant contributor to the local, regional and national economy.

2.3 McLaren’s racing success is the principal driver behind all other activities, and has in turn fed through to the rapid growth of McLaren Applied Technologies in delivering creative and technological solutions to many divergent sectors of British industry, such as UK sport, energy, healthcare, pharmaceuticals, transportation and consumer brands. The transfer of technology, skills and know-how within Formula 1 to developing a McLaren branded high-performance sports car is not surprising. What is astounding, and much less visible, is how McLaren is using the cutting-edge technology and expertise in data monitoring and human performance from its Formula 1 experience to help develop products and processes across a whole range of sectors as diverse as:

• A computer model and drilling simulator to improve North Sea oil and gas drilling operations • A biotelemetry system for use in pharmaceutical trials to better assess and understand the trial results more accurately • A Decision Insight system that allows air traffic control to optimise traffic flow • A lightweight leg brace support commissioned by the US Marines

• A baby incubation carrier to transport seriously ill babies • A super light-weight carbon fibre road racing bicycle with an electronic gearshift and weighing less than 1kg • Improving the efficiency of handover processes and surgery techniques within Great Ormond Street Children’s Hospital • A software scenario modelling tool to allow companies to forecast outcomes of corporate strategies spanning a variety of market conditions • Creating a not-for-profit partnership with UK Sport, English Institute for Sport, Scottish Institute for Sport and key GB medal winning sports, to supply cutting- edge electronic technology to British coaches and athletes in their quest for medals at World and European Championships as well as future Summer and Winter Olympic and Paralympic Games.

2.4 It is through this growing diversification that McLaren is looking to excel beyond the automotive industry and meet the challenges of a rapidly shifting world economy; creating and shaping new markets, working with external partners to transfer and re- apply technologies from other industries to produce solutions, and continually adapting and innovating to be able to grow and progress as a world-leading company. This is all led from its headquarters and campus in Woking.

2.5 McLaren is a major part of the national motorsport cluster, and is one of Woking Borough’s largest employers, with in excess of 3,000 staff working at the campus on a day-to-day basis. McLaren provides a major contribution to diversifying the economic offer of Woking, making the borough’s economy and jobs profile more balanced and more competitive, and therefore more resilient.

2.6 The Motorsport Cluster, which extends in a crescent from Norwich through Northampton and Oxford to Surrey, is one of the UK’s few success stories in the area of high value manufacturing. It is hugely valuable to the economy, in its contribution to GDP, to export performance, to jobs and to the UK’s international reputation as a location for innovative, technology-led businesses. The cluster includes around 4,500 firms with an annual turnover of around £6bn, of which circa £3.6bn is exported.

3 The history of the McLaren Campus

3.1 The McLaren Campus is located just under 3km (as the crow flies) north east of Woking town centre, and is accessed off the A320 at the Paragon Roundabout. The site comprises of the McLaren Technology Centre (MTC) and McLaren Production Centre (MPC), and benefits from an extant permission for the McLaren Applied Technology Centre (MATC). The campus also contains formal landscaped areas, parking and open parkland. The open parkland consists of a man-made landscape located west of the main development, which is publicly accessible. A public right of way (PROW footpath 1) also runs through the site in a north-south direction.

3.2 The planning history of the campus dates back to the mid 1990’s, when planning permission PLAN/1995/0641 was granted for an c. 37,160sq m corporate headquarters with research, development and automotive production (MTC). The MTC has been open and operational since 2003 (15 years). Following this, McLaren then established its own road-going sports car range (McLaren Automotive) which required a bespoke production facility. Planning permission PLAN/2009/0440 for the MPC, comprising 37,838sq m of floor space was subsequently granted in September 2009. McLaren’s continued growth and success, including within divergent sectors through McLaren Applied Technologies,

meant that further floor space and facilities were required, which resulted in planning permission PLAN/2014/1297 being granted in March 2016 for the MATC, comprising 52,000sq m for an aerodynamic research facility, workshops, research and development space, offices, meeting rooms, teaching and training space, and vehicle preparation and assembly space.

3.3 The plans set out below show the ‘as built’ and ‘as permitted’ development at the campus. As is clear from these plans, and from the floor areas summarised within the table below (figure 3), the site benefits from a significant level of development, all of which has demonstrated on multiple occasions and across varying national and local planning policy contexts, that very special circumstances exist to justify development within the Green Belt.

Figure 1: Site plan as built

Figure 2: Site plan as approved

Figure 3: Summary of extent of development Campus Floor area (GIA) Sq m development MTC c. 37,160 MPC c. 37,838 MATC c. 52,000 Total c. 126,998

4 Justification for allocating the McLaren Campus

4.1 McLaren considers that given the site’s long and established development history, including the continued demonstration of very special circumstances, the unique nature of the group of companies and McLaren’s local, regional and national significance, that there is a clear and demonstrable rationale for the campus to now be formally recognised in the Local Plan.

4.2 In fact, the very special circumstances that were tested and accepted by the Secretary of State in granting permission for the MTC in 1996 still prevail, and in some respects can be considered stronger and more pertinent today. These relate to:

• The unique nature of McLaren and its operational needs • The track-record and reliability of McLaren • The quality and excellence McLaren promotes in all its products and operations • The important symbiotic relationship between McLaren and Woking whereby they depend upon each other for economic investment and a skilled workforce.

4.3 This was clearly explained in the Inquiry Inspector’s conclusions which stated:

“This important proposal arises from unique circumstances, which would bring a range of positive benefits which significantly outweigh any degree of harm which may be caused by inappropriate development in the Green Belt.

The unique circumstances include the nature of TM’s [Tag McLaren] business activities and their markets and the very special requirements for the relocation of the HQ, the form of the building required, the essential need for security and privacy, and the need to retain the workforce.

A cursory reading of other Green Belt applications which have been permitted show the TM proposal to be the strongest of them all, in the combination of the support the proposal has from the strategic and local planning authorities; in the needs of the applicant for its future survival; in the particular importance the applicant has to the local economy and, more fundamentally, to the image of the area.”

4.4 McLaren has therefore been actively seeking to promote the site through the plan-making process, submitting representations at each consultation stage held to date. Options have been presented to Woking Borough Council that would either allow the allocation and removal of the campus from the Green Belt, or simply recognise the significance of the site through allocation as a strategic site in the Green Belt. These options are outlined clearly in the February 2017 Martyrs Lane consultation representation, which is appended to this submission to avoid unnecessary duplication.

4.5 McLaren’s business needs and investment decisions often far outpace the planning process. This is exacerbated by the campus’ Green Belt location, which requires each application to demonstrate the presence of very special circumstances, despite it being clear that the nature of McLaren’s operations and its global significance means that these will always be present. In addition to this, the majority of applications will also need to be referred to the Secretary of State (SoS) for potential call-in the application for determination on account of divergence from Green Belt policy. This generates significant additional uncertainty and risk, not to mention time delays. In the event an application is called in, then the risk and costs associated with any subsequent public inquiry would increase exponentially.

4.6 This process therefore creates a great deal of uncertainty and risk surrounding what should be straightforward investment decisions in the campus. This hampers the expansion potential of the site, hindering further growth and leading to wider economic implications for Woking and the surrounding region.

4.7 McLaren strongly believes that local planning policy should recognise and encourage the further sustainable development of important economic drivers. Woking Borough Council’s support of development proposals at the campus to date highlights its support and understanding of McLaren’s significance. Recognition of the campus within the Local Plan, through supportive policy, therefore, represents the next logical step and would provide the certainty that McLaren requires to make long-term investment decisions in response to market opportunities.

4.8 McLaren’s ability to continue to sustainably grow within Woking is vital to the ongoing and future success of the Group. The campus’ location within the Green Belt fundamentally frustrates and threatens the potential for sustainable expansion, and with it McLaren’s growth potential. Allocation would clearly support the future sustainable growth of the company.

4.9 McLaren is aware of a number of similar circumstances within local authority areas where the local plan-making process has considered similar cases and deemed that it would be justified and supportive to either allocate sites in the Green Belt, or remove them from the designation entirely.

4.10 One such example is revision to Green Belt boundaries to accommodate the Warner Bros. site at Leavesden (Three Rivers District Council), which contains not just the Warner Bros. UK studio complex but the Harry Potter visitor experience. The site was proposed for Green Belt removal as main modifications by the local planning authority in order to ensure the plan was sound.

4.11 In his conclusions on the Three Rivers Site Allocations Local Development Document (SALDD), the Planning Inspector, Mr Keith Manning, stated in his report dated 15th September 2014 that (paragraphs 36, 38 and 42):

“… given the importance of the Leavesden Studios site in the context of Framework intensions to build a strong, competitive, economy, that the relevant areas should be removed from the Green Belt.

The needs of WBSL… are evidently real and pressing as the Leavesden Studios develop as a major force in the local economy with significant implications for the British film industry… the SALDD not only fails to allocate it as such but retains key areas in the Green Belt where demonstration of very special circumstances would arguably be likely for the Studios operation but would nevertheless represent an unduly onerous impediment to expansion… In the interests of soundness the Council proposed during the examination that the long term pattern of development at the Studios should be provided for now, complemented by the necessary adjustment to the Green Belt to reflect… what is expected and apparently supported in the way of developing the Studios operation. The current ambiguity in the SALDD in respect of the studios anticipated expansion is a failing that undermines soundness…

… The Leavesden Studios sites and expansion land… should not only be removed from the Green Belt but positively allocated for their purpose…”

4.12 Another relevant example relates to Cambridge City Council’s Local Plan Review, and the removal of land from the Green Belt and allocation at Peterhouse Technology Park. In her report dated 29 August 2018, the examining Inspector, Laura Graham, concluded (paragraphs 61-63):

“The Plan allocated sites a Fulbourn Road for employment purposes, referred to as GB3 and GB4. These sites adjoin the existing Peterhour Technology Park… We agree with the Council’s assessment that the development of these sites would have a limited impact on the purposes of the Green Belt.

The main occupier of the Peterhouse Technology Park is ARM, an internationally recognised technology company. The company has plans to expand and there are clear advantages to being able to do so at their existing site. In view of the importance of research and development to the Cambridge economy and, in turn, to the national economy, we consider that the benefits of allocating these sites for employment development outweighs the limited impact on the purposes of the Green Belt thereby constituting the exceptional circumstances necessary to justify the alteration to the boundary of the Green Belt.

Some representors raised concerns about the development of these sites, unrelated to the Green Belt issue. These include impact on adjoining residential development, biodiversity and transport infrastructure. We agree with the Council that these matters are capable of resolution through the development management process.”

5 Woking Borough Council’s position

5.1 The most recent stage of the plan-making process has considered the suitability of Green Belt sites for safeguarding beyond the current plan period (2027) for the delivery of housing. Woking Borough Council held a consultation during early 2017 to consider the potential of a number of Green Belt sites south of Woking, as well as a single strategic site east of Martyrs Lane to the north of Woking. As part of this process, McLaren submitted a detailed consultation response dated February 2017 (appended to this submission) that set out a number of potential options for how the site could be treated.

5.2 Specifically, the proposal sought to include the entire campus, including the parkland, as well as land owned by McLaren to the east of the A320, which benefits from extant permission and was proposed as part of the Martyr’s Lane safeguarding proposal (denoted in figure 4).

Figure 4: Proposed McLaren Campus allocation boundary (consultation response dated February 2017)

5.3 Three options were proposed for consideration, namely:

• The removal of the campus and land east of the A320 from the Green Belt and allocation as a strategic employment site • The removal of the eastern land holding from the Green Belt as part of the Martyrs Lane safeguarding proposal, and removal and allocation of the western site as a strategic employment site • Allocation of the campus and land east of the A320 as a strategic employment site in the Green Belt.

5.4 A draft policy was also proposed that sought to ensure the council would maintain control of development, fully in accordance with the existing design parameters and constraints employed on the site.

5.5 The council has considered these options, and set out its response to it as part of its Regulation 19 documentation. The council’s current position is summarised as follows (contributor reference: 03027/1/001):

• Policy C15 of the Core Strategy provides the framework for meeting the economic needs of the area over the plan period, and is clear that the need for economic development will not necessitate the allocation of greenfield land for employment. Existing business estates are protected and capable of meeting future need. The policy also reinforces the overall spatial strategy (Policy CS1) not to allocate employment uses in the Green Belt. Such an allocation would therefore risk that the Site Allocations DPD would be found to not be in conformity with the Core Strategy, or the NPPF which states Green Belt boundaries should only be altered in exception circumstances. • As there is no requirement to release Green Belt land for employment purposes the Council can continue to respond to development needs on a case-by-case basis, in line with the supportive stance taken throughout the development history of the site. • NPPF paragraphs 89 and 90 clearly defines what development is appropriate in Green Belt locations. It is reasonable to expect McLaren to continue to justify each proposal in terms of the demonstration of very special circumstances in line with Green Belt policy. • Including McLaren’s land ownership east of the A320, as proposed, would not meet the Core Strategy’s definition of a Major Developed Site in the Green Belt. Whilst the site benefits from an extant permission, as McLaren’s preference remains to build within the existing campus, the lack of allocating this site would not compromise the certainty of their short to medium term growth aspirations. • The McLaren Campus is sensitively located and washed over by Green Belt, adjacent to the Thames Basin Heaths Special Protection Area, with the surrounding landscape contributing to the setting of the Borough. As such it is important that any future development proposals receive the same level of scrutiny and assessment of special circumstances. There remains a need to balance the need to protect the Green Belt whilst also supporting sustainable development. • It is not considered that the lack of allocation has significantly constrained the growth of the company to date.

6 The policy context

6.1 McLaren believes that both the national and local policy supports the allocation of the campus, which was clearly outlined in the February 2017 Martyrs Lane consultation submission. This is appended to the current consultation response, so only key policy references are set out below as well as reference to updates in the 2018 NPPF. It is noted that paragraph 214 of the 2018 NPPF applies, which states that the 2012 NPPF policies apply when examining plans submitted prior to 24 January 2019.

6.2 At the national level, paragraph 80 of the NPPF (2018) is explicit in stating that (our emphasis added):

“Planning policies… should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development... This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.”

6.3 Sections c) and d) of paragraph 81 are also fundamental as they require planning policies to address potential barriers to investment as well as requiring flexibility to ensure needs not anticipated in plans can be accommodated, enabling rapid responses to changing economic circumstances.

6.4 In terms of local policy, the Woking Borough Council Core Strategy (2012) sets out the development needs, spatial strategy and development objectives for the borough to 2027. Supporting the economy is identified as being one of the key issues and challenges over the plan period, with paragraph 5.130 establishing the council’s commitment to supporting sustainable economic growth over the plan period. Paragraphs 2.16 and 2.18 identify that Woking’s economy is mainly made up of the service sector, and that manufacturing is under-represented in the borough, reflecting the wider position within the south east region.

6.5 Policy CS1 establishes the overarching spatial strategy for the borough over the plan period, with policy CS15 setting out the economic needs and approach to delivering these. Policy CS6 relates to Green Belt, and is consistent with the NPPF in terms of assessing development proposals. However, the policy also identifies and allows for the allocation of Major Developed Sites in the Green Belt, stating that such allocations would allow for limited infilling and redevelopment of sites, without compromising the integrity of the Green Belt. The glossary to the Core Strategy defines these as:

“Green Belts contain some Major Developed sites such as factories… and research and education establishments…

These sites remain subject to development control policies for Green Belts, and the Green Belt notation should be carried across them, however, infilling or redevelopment is not inappropriate development in sites allocated as Major Developed Sites in DPD’s.”

6.6 McLaren considers that the Core Strategy does, therefore provide a framework for the identification and supportive allocation of key strategic sites in Green Belt locations.

6.7 The Regulation 19 draft of the Site Allocations DPD is clear that its purpose is to deliver the spatial vision, development requirement and objectives of the Core Strategy.

Supporting economic growth and increasing the level of manufacturing are such key objectives. The introduction to the DPD states that its purpose is to provide a clear framework for clear and consistent decision making, giving greater certainty to both the local community and developers. It also states that development proposals submitted in line with the DPD, would carry more weight in the planning and decision-making process.

6.8 The DPD proposes to allocate a number of Green Belt sites, including supporting important employment sites. However, it is explicitly clear that such allocations will not lead to a loss of control regarding the development management of these sites:

“…allocation of a site does not replace the need for planning permission; developers will still need to submit a planning application for an allocated site, allowing the local community and other interested parties the opportunity to comment on the detailed proposals and the Local Planning Authority to ensure the development is in accordance with all relevant planning policy requirements.”

6.9 Instead, the allocation simply removes the need to assess Green Belt harm, and demonstrates the presence of very special circumstances when there is obviously no benefit or need to do so.

7 Considering the tests of soundness

7.1 McLaren believes that it has a clear and justified case for seeking the allocation of its campus within the Site Allocations DPD. For this reason, it does not believe the current draft of the plan meets the NPPF’s tests of soundness in terms of being positively prepared, justified or consistent with national policy. Each point is addressed in further detail below.

Positively prepared

7.2 In Woking Borough Council’s assessment of McLaren’s allocation proposals, it concludes that the Core Strategy (Policy CS15) makes sufficient provision for employment within the borough over the plan period without having to identify any greenfield or Green Belt sites to provide for employment uses. This is also consistent with the overall spatial strategy set out in Policy CS1. As a result, any such allocation of the campus would be contrary to the Core Strategy.

7.3 McLaren does not seek to challenge this assessment of employment need within the Borough over the plan period, and the associated land required. Instead, McLaren considers that its campus represents an exceptional and unique circumstance, as clearly set out above, that would benefit from supportive policy within the Local Plan. The campus has never formed part of the overall assessment of employment need / provision within Woking, so to suggest as much in resisting any allocation on the basis of policies CS1 and CS15 is considered to be somewhat inappropriate. The campus represents a unique circumstance relating to an already significantly developed Green Belt site. It should not be forgotten that Policy CS6 identifies Major Developed Sites in the Green Belt, which allows for limited infilling and redevelopment, without compromising the Green Belt’s integrity.

7.4 The council’s responsibility to deliver the identified employment requirement established in the Core Strategy is not challenged. However, this simply reflects a ‘minimum’ requirement for plan-making, and the failure to not respond to wider exceptional

circumstances to further support economic growth within the borough means that the DPD in its current form cannot be considered to have been positively prepared. As the case studies have highlighted, there is a clear precedent for such exceptional sites to be identified and allocated in order to ensure the planning system is doing all it can to support economic growth and development. The long-term growth and importance of the campus to McLaren is further highlighted by the council’s proposed allocation of the Broadoaks site (draft policy GB11), in which it is highlighted that there is a lack of high- quality office and research and development facilities within the borough. Should McLaren therefore wish to progress future growth, there are extremely limited opportunities to do so within Woking other than at the existing campus.

7.5 The site’s planning history clearly demonstrates that very special circumstances have and do continue to exist, and therefore the logical progression is for this significant and important employment site to be formally recognised in local policy. McLaren considers such an approach to represent a positive approach to the preparation of Local Plans.

Justified

7.6 In responding to McLaren’s February 2017 Martyrs Lane consultation response, Woking Borough Council concluded that the campus is sensitively located, washed over by Green Belt, with the surrounding landscape contributing to the setting of the borough. Specifically, the council refers to its Green Belt assessment, stating (Contributor Reference: 03027/1/001) that it has undertaken a Green Belt review, with the outcome forming part of the evidence base used to inform the DPD.

7.7 McLaren does not consider this position to be justified for a number of reasons, principally because the council’s studies have not appropriately assessed the campus in terms of strategic and exceptional employment purposes.

7.8 McLaren has commissioned a robust landscape and visual impact assessment of the campus (submitted as part of the Martyrs Lane consultation response). Recognising that the campus already represents a significant developed site, the study sought to establish the baseline conditions prior to assessing the potential for the campus to accommodate future growth. The assessment concluded that the areas surrounding the existing development could accommodate further development, as well as an area within the parkland located to the west. The assessment identified that the effects of such development on landscape character and visual amenity were limited to within 1km of the campus, with the only significant landscape and visual effects being felt at site level, where you already experience the existing developments. The assessment also highlighted the ability for future development to include appropriate landscape mitigation to further reduce visual impacts.

7.9 McLaren also commissioned a Green Belt review, which was based on the methodology used by Peter Brett Associates (PBA) who undertook the council’s review of potential safeguarding sites in 2014. The review identified a number of issues in terms of how the campus was assessed. This is largely the result of the site (Assessment Parcel 1) being assessed on the basis of housing suitability. In fact, as figure 5 below highlights, in the case of the residential exclusion zone around the Thames Basin heathland, only a very small area of the campus was assessed. Woking Borough Council’s response to the proposed allocation also refers to the proximity of designated landscapes, though it should be noted that such exclusion zones do not apply to the uses at the McLaren Campus.

7.10 Of the five purposes of the Green Belt, McLaren’s review identified that future development would only have the potential to affect one of these, namely encroachment into the countryside, and that any such impact would only be moderate to less than moderate.

Figure 5: area of campus assessed as part of PBA’s Green Belt Review (extract from Figure 3 of 2014 report)

7.11 Given the rationale presented, including case study examples, the level of development already present and positive policy framework (discussed above under ‘positively prepared’), McLaren considers that the council is not justified in its position regarding the allocation of the campus. This is further evidenced by the contradictory approach the council takes with regard to the proposed allocation of Brookwood Cemetery under draft policy GB3 (grade I listed park and garden). The draft policy seeks to support the continued use as a cemetery whilst also seeking to conserve an important heritage asset. This site is described within the reasoned justification to the policy as being washed over by the Green Belt, and despite its proposed allocation has not been assessed in any of the supporting Green Belt reviews, despite the policy being clear that future development is proposed within the site.

7.12 Whilst the context is different in terms of land use McLaren cannot see how, based on the council’s position on the campus, there is a justification to allocate this site within the DPD, when there is no policy framework for doing so set out in the Core Strategy, the site is washed over by the Green Belt and an important part of the surrounding landscape, and is affected by the same environmental designations. It also does not appear that any landscape or Green Belt assessment has been undertaken to inform and provide any evidence base to support this policy, which, given its historic importance and heritage significance, you could argue should require such considerations to continue to be fully assessed as part of any development proposal. McLaren wishes to make clear

that it is in no way objecting to the proposed allocation of Brookwood Cemetery, but simply wishes to highlight the unjustified position relating to the treatment of the McLaren Campus, which has equally compelling reasons for being allocated.

7.13 Given the council’s reasoning, and the evidence presented within this and previous representations, McLaren considers that it is clear that the DPD’s omission of the campus is not justified, and therefore the proposed allocations and plan as a whole cannot be deemed to be sound.

Consistent with national policy

7.14 As has already been clearly demonstrated, the national policy position is inherently clear that the planning system should look to do all it can to support sustainable economic growth. The importance of supporting and encouraging economic development, growth and innovation within the UK economy is also reflected in government reports, budgets and ministerial statements made over a significant number of years. Further to this, the extreme economic uncertainty surrounding the UK’s withdrawal from the European Union, means that such economic support is more imperative than ever.

7.15 In this context McLaren does not believe that the DPD in its current format is consistent with national policy, and cannot therefore be considered to be sound.

Regulation consultation question 6

Please set out what modification(s) you consider necessary to make the Site Allocations DPD legally complaint and/or to strengthen its compliance; or to make the DPD sound and/or strengthen its soundness, having regard to the Matter(s) you have identified at 5 above where this relates to compliance or soundness. (NB. Please note that any non-compliance with the duty to co-operate is incapable of modification at examination).

You will need to say why this modification will make the DPD legally compliant / strengthen its legal compliance; or make the DPD sound / strengthen its soundness. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

1.1 Whilst McLaren strongly believes that there is justification for the allocation of the campus, it also recognises the council’s position and concerns on a number of matters, particularly relating to McLaren’s land immediately adjacent to the campus, east of the A320.

1.2 As such, in order to address McLaren’s concerns relating to the tests of soundness set out in Question 5, McLaren would support the removal of its campus from the Green Belt or allocation in line with that proposed for Brookwood Cemetery (draft policy GB3), recognising the site as either a Major Developed Site or a Strategic Employment Site in the Green Belt. Any policy for the campus would be able to set out clear development parameters and requirements for any future development. McLaren considers that this would overcome the council’s key concerns, whilst also providing greater certainty for McLaren relating to future growth of the campus, and avoiding the need to continue to justify the presence of very special circumstance, along with the risks associated with Secretary of State referral.

1.3 McLaren accepts the council’s position relating to the land east of the A320, in that its context and site history differ from that of the campus. Therefore, McLaren would be prepared to accept this land being excluded from any allocation. With regard to the campus itself, based on the clear and justified evidence presented in the landscape assessment and Green Belt Review, McLaren believes that any proposal should comprise the entire campus inclusive of the parkland, as it has been demonstrated that further development can be accommodated within this area without causing any significant harm to the surrounding landscape and visual character or to the Green Belt.

1.4 McLaren would very much welcome the opportunity to work proactively with the council to determine the allocation boundary and policy wording should the council be minded to review their position in respect to the campus.

Regulation 19 consultation question 8

If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:

Please note attendance at the examination in public is at the discretion of the appointed Inspector.

1.1 As noted previously, McLaren has engaged in every stage of the plan preparation process to date, and given its current concerns, believes it will be vital to participate in the forthcoming hearing sessions in order to present its evidence to the Planning Inspector for consideration. McLaren considers its evidence base and rationale for allocating its campus to be robust, and does not consider that due consideration has been given to this. McLaren’s local, regional and national importance justifies a wider discussion relating to the campus and its inclusion / omission from the Site Allocations DPD.

1.2 National Planning Practice Guidance (ref: Paragraph 023 Reference ID: 12-023- 20140306) also states clearly that:

“Anyone who has made representations seeking to change a published Local Plan must, if they request, be given the opportunity of attending a hearing (section 20(6) of the Planning and Compulsory Purchase Act 2004). The local planning authority will liaise with those who have asked to appear at the hearing to arrange attendance, including whether interested groups wish to nominate a representative to put forward their views.”

1.3 As such, given that McLaren continues to have concerns relating to the soundness of the DPD, it is only appropriate for these concerns to be tested fully at the examination stage.