Portfolio Holdings and Gleeson Homes/GVA Grimley (Reference 484)
Matters 4/6
May 2004
342A
Representation Reference: 342/001
Document Reference: P/GVAG - WEP/HS1
West of England Partnership
Joint Waste Core Strategy
Hearing Sessions
Recovery Facilities
Location and Sites
October 2010
Hearing Statement
submitted on behalf of
Goodman
by
Tim Gent BA(Hons) BPl MRTPI
GVA Grimley Limited
One Kingsway
Cardiff
CF10 3AN
Report author: Tim Gent
Direct Line: 029 2024 8916
e-mail:
Wiltshire and Swindon Structure plan 2016
Examination in Public
Goodman (Reference 342)
Recovery Facilities, Location and Sites
Foreword
GVA Grimley Limited provides planning advice to Goodman which owns the Merebank site in Avonmouth to the north of Bristol. This brief statement has been prepared to support representations submitted in March this year to the West of England Partnership on its Joint Waste Core Strategy. These representations welcomed the general concept of waste related development at Merebank, but questioned the Strategy’s approach which appeared to prevent other forms of economic development coming forward.
To reflect the clear instructions to participants, the statement starts by providing a very brief overview of our representations and the current position on the site, before providing some further evidence on the importance of retaining the scope for various forms of economic development to come forward on the Merebank site.
1.0Goodman’s Representations to the Strategy
1.1Our representations welcomed the recognition of the Merebank site’s favourable position and significant potential. However, they argued that a more flexible approach was required that would allow the site to be developed for alternative uses should the option of developing a waste treatment facility become unviable or undeliverable.
1.2The representations requested that Merebank should either be removed from the list of sites allocated under policy 5, or that changes should be made to Policy 13 to provide a more flexible approach at Merebank which responds to the sites planning history and potential. This reflects the planning position at Merebank where permission exists for both industrial and warehouse development and the waste recovery facility or resource park.
2.0The Current Position at Merebank
2.1The Merebank site comprises previously developed land with planning permission for a mixture of B2 and B8 development and a resource park. Goodman acquired the site in 2006 and has made significant progress with its comprehensive redevelopment – Merebank is already home to the regionally important Constellation Logistics facility, Superdrug and VOSA.
2.2Proposals for the last undeveloped part of the site – which is known as M2 – include the development of a resource park by an organisation called Cyclamax. These proposals are very well advanced – full planning permission and the necessary environmental permit have been secured and it is expected that the project will proceed to a start on site very quickly. Progress with these proposals has in no small way triggered the identification and allocation of the site in the core strategy.
2.3However, until this project is finally and formally secured, it is essential that the scope for alternative, more conventional, forms of economic development is retained.
2.4This remains our sole but key concern with the plan and whilst we are slightly comforted with the response to our representations, we remain worried that the plan could, inadvertently or not, frustrate other forms of economic development that would clearly support (and be supported by) other planning strategy and policy. In particular, the test referred to in the response by WSP to our comments (that it be “demonstrated that the necessary waste management infrastructure has been provided in the Avonmouth Zone” before alternative uses would be allowed) is very onerous and potentially very difficult to achieve.
3.0The importance of retaining flexibility
3.1Our representations identified two reasons why it was important to retain flexibility at Merebank. The first was because it reflected the planning history of the site. This comprises planning permission for B2 and B8 development as well as for the resource park. These uses can come forward and little more needs to be added on this point.
3.2The second reason concerns the need to ensure that the site is available for other forms of economic development should the resource park concept fail.
3.3 Goodman is committed to the concept but it is being promoted by other specialist organisations. This means that its ultimate success cannot be guaranteed despite the progress that has been made. Because of this progress and the time and resources that have been spent both in securing the necessary approvals (the scheme can be no more “oven ready”) and in developing the business case, if the concept is not delivered at this time then it is unlikely that the site will ever be suitable or necessary for waste related development during the plan period.
3.4In this context then, the site should then become available for other forms of equally valuable economic activity for which there is clear need and equal strategic importance.
3.5Since submission of the representations, the need for this type of site for economic development in Avonmouth has been discussed as part of the Examination associated with the Bristol Core Strategy. At a session held on the 24th June, the topic “is adequate provision made to support economic development having regard to the emerging RSS local evidence and the overall strategy (to include consideration of development at Avonmouth)” was discussed.
3.6In the Inspectors Preliminary comments prior to the hearing he questioned Bristol City Council’s reliance on the Employment Land Study (the ELS). Specific attention was given to the ELS’ projections in relation to Avonmouth, highlighting the fact that the level of completions increased after the study was completed in 2007 (and demonstrated in the 2009 Bristol Business Development Survey Report). This meant that there could well be less developable land remaining than had been assumed.
3.7The Inspector’s note goes on to state that he is or was unclear on the assessment and conclusions of the ELS in relation to the adequacy of supply for large format premises at Avonmouth (and whether subsequent developments may have altered the situation).
3.8The importance of these concerns is clear: it is possible that there has been an exaggeration of the supply of land for conventional economic development following a period when this sector was strong and during a time when land availability is essential to capture local, regional and national projects and to deliver them on fundamentally sustainable sites.
3.9At the hearing session some time was also spent on the following issues:
a)on making sure that the range and choice of sites that are available was appropriate (that were able to accommodate projects of varying sizes and types
b)the scope and need for further greenfield land release in the face of the perceived shortage of previously developed land,
c)the overall soundness of policy for Avonmouth and the impact on the Core Strategy if policy there were not sound
d)the impact of constraints including nature conservation and the need for appropriate assessment, together with flood risk and highway infrastructure and capacity limitations
e)the extent of previously developed land and land with planning permission for development
3.10The Inspector’s conclusions on Avonmouth and his recommendations are of course not yet known. However, it is reasonably clear that concerns were raised about land availability (and land deliverability) in the area for conventional forms of economic development. The Merebank site forms an important part of that supply: it is previously developed, is demonstrably capable of accommodating single large users, and has the necessary approvals in place to capture mobile and valuable schemes. If it was to be taken out of the supply (because it was reserved solely for waste purposes) it could further threaten the very limited supply of land or lead to a more unsustainable release of other land elsewhere.
3.11This goes to the heart of our concerns with the Waste Core Strategy – as currently drafted, and if the resource park concept is not delivered, it could effectively sterilise the site for needed and necessary development (which would support wider local development framework strategy and allocations).
Summary
Goodman remain committed to the concept of developing a “resource park” on the site that will respond to this potential and there is clear support from potential operators and detailed discussions have reached a very advanced stage). Nevertheless, until the scheme is on site, its delivery cannot be guaranteed. It is therefore vital to ensure that the site is able to fulfil its clear economic potential (for Avonmouth, Bristol and the south west). The JWCS therefore needs to provide the owners with the flexibility to develop the site for alternative uses should the need or scope to do so arise. At the moment it does not.
In this context we retain our request for the Merebank site to be deleted from the schedule of sites under Policy 5. This will in no way jeopardise the current position with the resource park (which has triggered the approach to the site recorded in the Strategy). However, it will provide (or allow) a much more accurate and sustainable approach to the site’s history, position and potential should the resource park not be delivered.
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West of England Partnership
Joint Waste Core Strategy
October 2010