Submission on the Modifications to the Aligned Core Strategy for Broxtowe Borough Council, Gedling Borough Council and Nottingham City Council in reference to Modification 8 (Mod8) On behalf of South Broxtowe 20/20 !Ref: Main Modification 8 (Mod8): Site Specific Consequence of Strategic Location for Growth in the Vicinity of the proposed HS2 station at Toton for minimum of 500 homes. !Introduction !This report was prepared on behalf of South Broxtowe 20/20, and should be read as our formal submission to the Modifications to the ACS in reference to Modification 8: site specific consequence of strategic location for growth in the Vicinity of the proposed HS2 station at Toton for a minimum of 500 homes. In addition, we have commissioned two independent reports via Ken Mafham Associates as detailed below. !• Comments on Modifications to the ACS for Broxtowe, Gedling and Nottingham City by Ken

Mafham Associates on behalf of Barton in Fabis, Calverton, Gotham, Thrumpton and Woodborough Parish Councils, Calverton Preservation and Historic Society, STRAG and South Broxtowe 20/20 !

• Comments on the Volterra Report by Ken Mafham Associates Town Planning Consultants on behalf of South Broxtowe 20/20 !

The “Comments on the Volterra Report” is attached to this submission, and should be considered part hereof. The “Comments on Modifications to the ACS Report”, will be submitted separately by Ken Mafham Associated, but should also be read in conjunction with and part of this submission. All other evidence mentioned in this submission, retained and available upon request. !1. Initial Inclusion of Toton as a Strategic Location for Growth !Broxtowe Borough Council (henceforth referred to as BBC) voted to put the land at Toton back into the Aligned Core Strategy as a Strategic location for growth, at a council meeting on the 20th May 2013. As can be evidenced from the minutes of that meeting, the focus was on 1

utilising the area for employment purposes with an emphasis on the protection and retention of open space and prevention of communities merging into one another. Moreover, the following salient points and suggestions were included from debate on the amendment (BBC, May 2013): !

• “ There was great potential in the borough for economic success and employers needed premises and a skilled workforce”.

• “The greenbelt should only be built on in exceptional circumstances which are not displayed here.”

• “HS2 on the doorstep will be beneficial although pressures on the locality will be considerable. The Core Strategy will defend the land.”

• “Village boundaries should be protected and not expect to be merged with other villages.” • “Permission for building on land had been given many years ago but still remained

undeveloped. This demonstrated the lack of need for new housing.” !Furthermore, the council resolved that it “will through the development plan document, seek to work with communities, developers, HS2 and other interested parties in order to ensure that we maximise employment opportunities and ensure that we protect and preserve as much open space as possible.” !

�1 Broxtowe Borough Council, Meeting Minutes, 20.05.20131

As can be evidenced from the above, there was no indication at this point that the land would be released for a large-scale housing development, the kind of which has been opposed strongly by local residents since 2011. Indeed, local residents were led to believe by this focus and, indeed by statements from councillors themselves, that there was no threat of this land being utilised for housing. !Councillors had publicly, as well as in meetings and correspondence with local residents and groups, repeatedly declared that there would “categorically” be no building on the land in Toton. For example, Councillor Watts stated (30th April, 2013, Battle of Broxtowe Blog), “I can absolutely guarantee that the council has no plans to allow building on the land opposite Bardills. Absolutely, unequivocally and completely”. !Councillors have asserted publicly, that they were forced to give a figure for housing at Toton by the Inspector, during the Inspection process for the ACS in November, 2013. At a public meeting, held in Toton on 7th December 2013, Steve Barber, Councillor for Beeston Rylands, stated that the decision to re-introduce Toton’s green belt into the Aligned Core Strategy (ACS) was made at a “panic” meeting, at which the inspector gave them no choice but to add Toton to the ACS, as the ACS was likely to fail if Toton didn’t go in. He stated that the controlling Labour/Liberal Democrat group were forced to vote on who was in favour of adding Toton back into the Aligned Core Strategy. !In the Nottingham Evening Post (9th of December 2013), Councillor David Watts, Councillor for Bramcote and Liberal Democrat leader for Broxtowe Borough Council stated that “this is not a U-turn because that would imply that we had a choice in the matter” and further that, “the planning inspector said that we had to give a figure and 500 was the minimum we could get away with – it’s about damage limitation.”

Councillor Watts reiterated this assertion during the extraordinary council meeting on Toton on 13th of January 2014. He stated that it had been a pleasure to take Toton out, but that the Inspector did not agree with them (he would have loved it if she had). He again stated that they had voted for 500 dwellings as it was the least they felt they could “get away with”. He stated that their arguments (to the Inspector) did not succeed and, that they had fought for Toton but lost.

Despite the fact that he was questioned on his assertions related to the role of the Inspector by Councillor Jackson and, despite his attention being drawn to a letter that had been sent by the Chief Planning Inspector to Anna Soubry MP about this issue, utterly refuting these statements, Councillor Watts took to his twitter account the following day to make further 2

comment on the issue. He stated, “We had no plans to build here, the Govt (sic) inspector said we were wrong. We had no choice.”

Whilst we accept, both from written evidence from other parties present at the hearing and, indeed from various letters written by the Inspectorate on the matter refuting the statements given by Councillors, the negative effect of these statements on the democratic process of the public consultation, can not be underestimated. This point will be discussed in more detail later in this submission.

Significantly, it seems clear that Councillors gave this figure at Toton, by their own admission, without being in possession of any relevant data as to the appropriateness of such a figure and, before any analysis of the site has been undertaken.

2. The Volterra Report

BBC commissioned a report by Volterra, claiming to assess maximising the economic benefits of HS2 at Toton. Since the publication of the Volterra report, it has been utilised by the council as their primary defence of the inclusion of the land at Toton and, their assertion of the appropriateness of the figure of a minimum of 500 homes.

�2 Watts D., Via Twitter, 14.01.2014.2

During a meeting with Steffan Saunders and South Broxtowe 20/20 (henceforth termed SB 20/20), he confirmed that Volterra was given the Peveril Planning Application, as background information for their report. This information is significant, because it serves to highlight the basic intrinsic problem with the Volterra report- it is not a comparative land-use analysis. SB 20/20 have commissioned an independent report via Ken Mafham Associates, which gives an analysis of the Volterra report. This analysis is included herewith, as part of this submission and is the basis of our submission in this regard.

However, we would also like to draw out several salient points. Upon analysis, Volterra appears to use the Peveril Housing application as a starting point and a basis for their report. Significantly, the report is not, and does not claim to be, an appraisal of the comparative benefits of different land use options around the HS2 station. It does not take into account the greenbelt designation of the land at Toton, does not fully consider the land needs around the station itself for associated infrastructure (not even HS2 themselves are currently able to fully ascertain the needs of associated infrastructure), nor does it allow for any firm aims with regard to job creation around the station. Indeed, BBC appear to be utilising one particular aspect of this report in order to justify bringing forward a large-scale housing development on this site, but choosing to ignore other points made by the Volterra report itself. !We have the following additional comments to make regarding points contained within the Volterra report: !

Point 1.37 of the report states: “The success of a HS2 station in the East Midlands will largely depend on the region’s ability to attract businesses and jobs, and the capacity that will be released for local transport infrastructure and commuter networks. The maintaining of the current service on the Midland Mainline to Nottingham is also crucial.” !Point 1.40 states: Accessibility to these job, from both a transport and skills perspective will enable the economic development and regeneration of large swathes of Nottinghamshire and Derbyshire. !Point 6.61 states: The analysis carried out by the Government showed that a station at Toton would generate an additional £500 million (60 year present value – PV) and revenues of £190 million over the Derby option. This is largely due to the fact that a HS2 station situated at Toton would serve a wider area and therefore a greater number of passengers would be attracted to the station. !Point 6.62 states that: “Indeed, based on existing models of passenger demand (which are likely to be conservative) it was estimated that a station at Toton would attract some 8,500 passengers daily – with 48% of these assumed to be new passengers; 31% would come from Nottingham, 17% from Derby and 4% from Leicester.” !Point 10.11 states that: “Overall while the shape of the local and regional infrastructure beyond HS2 is not clear, it is important that a coordinated and integrated strategy emerges at the local authority and LEP levels over the course of the consultation period. This would cement Toton as a regional transport hub that is capable of generating sufficient passenger numbers and thereby capable of boosting the economic prospectus of the region as a whole.” !

2.1. We find it astonishing that given such large passenger numbers quoted by the report as utilising the station daily and, the emphasis placed on the importance of inter-connectivity of modes of transport being one of the major determining factors in the success or failure of the scheme, priority would be given to pushing forward an existing large-scale housing development, which clearly limits any flexibility on the site, with regard to station infrastructure and, wider connectivity to the region as a whole. !Indeed, as the report itself points out, many workers do not live in the vicinity of the station, and would need to be able to access it in order to make use of it and, thus, for the benefits of HS2 to be disseminated throughout the region. Realistically, many passengers would need to

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utilise the car to access the station. In the absence of a Metro connection, as is found in many successful high speed railway stations internationally, there would surely also be the need for good bus links. Furthermore, the assertion that the tram would be utilised by people to gain access to the locality of Toton is entirely unproved. There is currently no way of knowing how many people are likely to utilise the tram facility, as it is not yet operational. !Clearly at this stage, it is impossible to determine, even by HS2 themselves, what will be required in the future with regard to associated infrastructure. At the very least, and for this reason alone, any development on the site should be delayed until such a time as the full needs of the station’s infrastructure and connectivity needs can be determined. Moreover, the points above illustrate that attracting business and jobs to the area is central in the success of this scheme. This would clearly be limited by the early development of a large-scale housing scheme. !

Point 7. states: “Evidence suggests that demand for office-space is likely to be low in the short to medium term, amidst all the uncertainty regarding HS2. Therefore, residential development is the wise choice to opt for in the near term, as is illustrated convincingly by certain European cities and towns. Planners should retain flexibility however so that commercial uses can be developed later on to complement the earlier residential investments. !

2.2. This position clearly ignores the strategic location of this site irrespective of HS2 (the proximity to the M1 and East Midlands Airport, centrality to Derby and Nottingham, proximity to several Universities, new Tram connection etc.), which has long been put forward by those seeking to develop on this site prior to the announcement of HS2. It is also surely more relevant to high speed railway stations which have little or no residential housing developments around them (and thus as Volterra claim no existing markets); clearly not the case with Toton as this location is surrounded by nothing but residential housing developments. !In addition, as will be discussed below, Volterra use very selective examples in the report, that it itself acknowledges, are not representative in location to Toton. Locations in cities close to local amenities, hospitality facilities and tourist attractions, as well as, with excellent transport links, such as bus stations and Metros, can not be seen to be indicative of the situation or locality of Toton. !Moreover, the current large-scale housing development would prevent this flexibility and limit the possibility of the development of commercial uses in proximity of the station; both factors seen by Volterra as decisive in the success of the scheme. The opinion posited by Volterra also ignores the statements by HS2 Ltd itself, which has frequently emphasised the view, that HS2 stations in and of themselves, will be attractive to investors, which will enable economic development. !Indeed, this statement surely, if anything, strengthens the argument that there should be no development on this land until such a time as not only the HS2 route is confirmed but, rather until the HS2 scheme as a whole is ratified, and a proper analysis can be undertaken as to the demand for and appropriate mix of uses, of this site. !It is noteworthy, that at the recent HS2 Working Group, where developers were invited to give evidence, representatives of Peveril confirmed, when questioned directly on this matter, that the only employment use that they were able to provide within the current scheme, was the very small B1 office space directly by the station itself which equates to only 2800 m2. The only other area that could be developed for employment according to Peveril, would be a small-scale area across the road on the East of Stapleford lane, in which an area approximately 17000m2 could be utilized. !Councillor Watts questioned as to whether this site was, in fact, too far away from the HS2 station to take advantage of it and, thus was in danger of becoming another location similar to the Chetwynd Business Park at Chilwell, a large percentage of which is empty at all times.

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Peveril’s representatives stated that business on this site East of the tram would not, be attracted by HS2, but rather through the proximity of the Tram. !This further strengthens the case that the current Peveril application is not in any way the specialised scheme that is needed to take advantage of the purported economic benefits and opportunities of HS2. Rather it is a standard housing scheme with some minor inclusion of Business space; no different to the kind that is evidenced at Chetwynd Business Park, with it’s accompanying housing scheme. Indeed, is useful to look at the comparative figures of the Chetwynd Buisness Park: !Chetwynd business park Total business space, 11.800 m2 with 377 dwellings = a ratio of m2 per dwelling 31.29 m2 !Toton Lane 17,000 m2 with 650 dwellings. = a ratio of 26.15 m2 !In using the Chetwynd Business Park ratio as a guide, there would need to be at least 20,000m2 of business space just for there to be a comparison on the Toton Lane site. This surely can not in any way be seen to be maximising the extraordinary opportunity of HS2. !

Point 1.29 states: Indeed experience form other countries where high speed rail has been in operation for some time shows that bringing forward residential development does not prevent commercial offers from emerging in the future. For example many of the intermediate Spanish cities, which lie on the high speed rail network, started with residential developments around the station. The success of these developments eventually acted as a catalyst for the commercial and hospitably offers that exist around bigh speed stations- Cordoba is a good example of this.” !

2.3. The Volterra report acknowledges that it utilises examples within it that are not indicative of the geographical location of Toton, for example, Cordoba. Cordoba is an inner-city train station which is serviced with good additional transport links, including a bus station across the road from the High Speed train station. Significantly, in it’s proximity were large swathes of industrial areas, which would have precluded investment in the area with regard to employment and hospitality opportunities. Thus the city was required to eliminate and develop the areas around the station in order to attract investors to it. This is clearly not the case here; Toton lies in an attractive suburban location and is already surrounded by housing developments. !Another international example used by Volterra is Lille, which again is an inner-city example and can not seen to correlate with that of Toton. The station at Lille is serviced by a bus station and significantly also the Metro. The site at Lille is in close proximity to the amenities of the city centre including museums, tourist attractions and the opera. Moreover, the site of Lille station is in no way comparable in size to the space available at Toton; it has a floorspace of over 100000 m2 for commercial, leisure and business uses. !Moreover, as stated in the Volterra Report itself, Lille station is considered to have become such a success as a high speed rail station, due to it becoming a prominent business centre in France. However, by land-locking the station at Toton with a large-scale housing development, it precludes this from occurring at Toton. Indeed, it arguably prevents this large-scale housing development from acting as a catalyst for commercial and hospitality offers, as would perhaps occur in other inner city or industrial localities, as world-class commercial and hospitality business is unlikely to be attracted to the location, if it has to be sited away from the station itself. !

Point 1.37 of the report states: “The success of a HS2 station in the East Midlands will largely depend on the region’s ability to attract businesses and jobs, and the capacity that will be released for local transport infrastructure and commuter networks. The maintaining of the current service on the Midland Mainline to Nottingham is also crucial.” !

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Point 7.22 The main implication for the proposed development at Toton is that the commencement of residential development in the vicinity of the HS2 station does not mean that other mixed uses will not be built in the future. After all, NET Phase 2 makes residential development viable in the near term, bringing the benefits forward. These economic benefits will be more valuable than those that will accrue in the medium to long term. !

2.4. The report clearly states that the success of the station at Toton is related to attracting business and employment and, even goes so far as to conclude that, “the most appropriate way to maximise benefits at Toton will be to promote housing uses initially but not to the detriment of future commercial uses.” (point 10.20). !As discussed previously in this submission, the current proposals of a large-scale housing development, would not allow for the necessary flexibility of the site, with regard to infrastructure and in order to attract business. It is these factors, which Volterra themselves conclude, are necessary for the success of the scheme at Toton. !2.5 In addition, Table 5 of the report is seriously flawed. Out of the 15 sites listed on the table, 12 of the sites are already complete, some of which have been for as long as 10 years. Furthermore, some of these clearly can not be seen to be in close proximity to any tram stop and, thus are arguably non-applicable. Errors such as this, call into question the accuracy and validity of the entire report. !3. Planning Rules in relation to Toton !We object to BBC prioritising building on Green Belt land over bringing forward brownfield sites. We find that BBC has been incompetent and negligent with regard to fully assessing all Brownfield capacity in the Borough. In addition, we object to the fact that there has been no full and comprehensive Green Belt review undertaken of all Green Belt land in the Broxtowe. Furthermore, we object to the overall housing figures as agreed in the ACS and, believe that the so-called Hunston Ruling (Tesco vs Dundee), should have been applied in the case of Broxtowe to challenge the overall housing figures and, reduce the numbers based upon the constraints of Green Belt policies. The Hunston ruling clearly also reaffirms the responsibility of local planning authorities to conform to the requirements of the National Planning Policy Framework (NPPF) , in particular with Green Belt land, as will be discussed below. 3!We have commissioned a submission from Ken Mafham Associates (in conjunction with Barton in Fabis, Calverton, Gotham, Thrumpton and Woodborough Parish Councils, Calverton Preservation and Historic Society), which forms the basis of our objections, and should be seen as a part of our submission, in this regard. Further, we find that BBC has been negligent in their duty of care with regard to protecting the Green Belt land as is required by the NPPF. !The following paragraphs from the National Planning Policy Framework (NPPF) on the protection of Green Belt land are applicable to the Green belt land at Toton. 4!

79: The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

80: Green Belt serves five purposes:

• to check the unrestricted sprawl of large built-up areas;

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National Policy Planning Framework, 27.03.2012, Department for Communities and Local 3

Government.

National Policy Planning Framework, 27.03.2012, Department for Communities and Local 4

Government.

• to prevent neighbouring towns merging into one another;

• to assist in safeguarding the countryside from encroachment;

• to preserve the setting and special character of historic towns; and

• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

82: Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

!In the case of Toton, it’s Green Belt land fulfils purposes 1-3 and 5, as set out by paragraph 80 of the NPPF. No exceptional circumstances, as required by paragraph 82, exist in the case of Toton. This was in fact recognised by the Council on May 2013 when they voted to include Toton in the ACS, during which they confirmed their commitment to the land at Toton’s Green belt status by stating that, “The greenbelt should only be built on in exceptional circumstances which are not displayed here”. Moreover, the Council resolved to, ”… ensure that we protect and preserve as much open space as possible.” 5!No exceptional circumstances exist for development at Toton, as HS2 itself has not been confirmed, nor has the route been finalised or the station confirmed at Toton. Indeed, it now seems unlikely that the HS2 bill will get onto the statue book by May 2015, which is likely to make it a contentious election issue between the parties, putting the whole project in doubt. When asked whether HS2 will gain the Royal Assent by the time of the next election, Patrick McLoughlin stated that: “I think one has to accept that perhaps through all it’s stages within the next 12 months is slightly ambitious (sic).” Even, if and when, Stage 1 is 6

confirmed, it seems unlikely that at that stage, it will be known for certain, whether Stage 2 will also go ahead. !Significantly, the importance of protecting Green Belt land and the necessity of demonstrating exceptional circumstances was recently reconfirmed by Nick Boles MP, in his letter to Sir 7

Michael Pitt, Chief Executive of the Planning Inspectorate in March 2014, in which he stated that: !

“Fundamental to the National Planning Policy Framework and to this Government’s planning reforms is the idea that local authorities, and the communities who elect them, are in charge of planning for their own areas. That is why we abolished the top down regional strategies, why we have emphasised the primacy of the Local Plan and why we gave communities the powers to create neighbourhood plans. !Alongside these reforms we were always very clear that we would maintain key protections for the countryside and, in particular, for the Green Belt. The National Planning Policy Framework met this commitment in full. The Framework makes clear that a Green Belt boundary may be altered only in exceptional circumstances and reiterates the importance and permanence of the Green Belt.” !

The Hunston ruling, as mentioned previously, also reaffirmed that the importance of the Green Belt and, the commitment to current Green Belt boundaries. The recent revision of the Planning Practice Guidance (2014) goes further by stating that:

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Broxtowe Borough Council, 20.05.2013, Council Meeting Minutes.5

BBC News, 6.03.2014, High Speed Rail Bill Delayed.6

Boles N., Letter to Sir Michael Pitt, 3.3.2014, Inspectors’ Reports on Local Plans7

!“Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt”. (2014) 8!

In the case of Toton, this paragraph is particularly relevant, as during the Extraordinary Council Meeting related to the land at Toton in January 2014 (where councillors voted to include the modification of the ACS to include a minimum of 500 homes), the focus of this modification was not in fact HS2, but rather unmet housing need. Councillors arguing for the inclusion of this land for housing, argued on the basis that Broxtowe needed to utilise the land at Toton for housing due to a housing shortage. !The only Councillors making representations in relation to HS2 were those that were arguing to prevent the current planned development and the figure of 500 homes. Rather, they were calling to save the site until HS2 was confirmed and for HS2 related development. It was clear to those in attendance at the meeting, that far from the initial purported rationally of HS2 for including the land in the ACS (as was voted on by the Council in their meeting in May 2013), the Council voted upon the rationale of a so-called housing crisis and a lack of a 5 year land supply within the ACS. !This rationale is clearly contrary to the extraordinary circumstances that are required by the Planning Practice Guidance as detailed above and, can be clearly evidenced by the minutes of the meeting (included below in full in relation to Councillor representations for the purposes of clarity) : 9!!

• it was understandable that members of the public were concerned about development, however Broxtowe needed to be clear about its vision during the housing crisis

• the added text would make improvements to the Core Strategy and working groups would be able to liaise with concerned groups and individuals

• if Broxtowe does not have a workable plan, the borough would be overrun by developers rather than have the Council decide which land is built on

• there is not enough brownfield land to satisfy the number of houses that are required

• a minimum of 500 houses could leave Broxtowe open to having to build many more properties

• the Council should wait until decisions have been made on the location of HS2 • the residents of Toton have been treated with contempt and have been deceived • Borough Councillors have to represent the borough and it was a myth that central

government policy could be denied. The Council had little option and now had to take a decision.

• Toton had become a large traffic jam which affected the quality of life for residents. The Council should work with residents to seek improvements to the transport infrastructure.

• the Council had failed and the people of Toton had suffered. Councillors did not have to accept the comments of the Inspector.

• if the Council stipulated a celling, the Inspector Inspector had not instructed the Council to build in Toton and had not accepted the figure of 6,150 properties. Broxtowe is in a unique position. A minimum of 500 houses would result in many more houses being built and the amendment did not improve the proposals.

• a long-term vision would see the borough benefit from the growth provided by HS2. It would be a tragedy to be hamstrung should there be a lack of available

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Planning Portal, 6.03.2014, Guidance: Housing and Eoconomic Land Availability Assessment, 8

Methodology-Stage 5 Final Evidence, Paragraph 034 Reference ID: 3-034-20140306

Broxtowe Borough Council, 13.01.2014, Council Meeting Minutes.9

land around the HS2 station. The final route for HS2 has not been set and building houses in Toton would jeopardise this.

• there had been countless objections from the residents of Toton and the strength of public feeling should not be underestimated

• Toton Environment Protection Society, along with some other pressure groups had acted well, however councillors were not in control of this situation. The Core Strategy was necessary for the wellbeing of the borough.

• the Council had given a unanimous decision to the people of Toton but the Council now wanted to renege on the agreement

• if the Inspector declares the Core Strategy unsound the Council will have lost control. Councillors had a wider responsibility to address the desperate housing shortage.

• new housing is necessary as people are living longer. Officers had looked into the subject in great detail and alternative sites to Toton had not been suggested.

• Broxtowe had failed to deliver a five year plan for many years. This is just the first stage of destroying the green belt. The Council has not fought against these figures. The numbers should be changed because of HS2.

• councillors have a responsibility to listen to the views of the people. If the housing crisis is so desperate then land that already has planning permission should be built on.

• the houses have to go somewhere and they should go into a conurbation of the city. There are benefits to putting them in Toton.

• there is a defeatist attitude amongst councillors. We should fight developers for the people of Broxtowe.

• the site could not be defended by rejecting these proposals. Alternative sites had not been put forward. It was accepted that there will be major traffic implications which needed to be reviewed. This is a great opportunity for growth and business development and the only chance to protect the green belt is to accept the HS2 agenda. !

It is striking that the large-scale housing development as currently being considered for this site has not significantly changed (apart from an extremely minor addition of some standard B1 office space), since the original Peveril housing application. It is in no way a specialised scheme to maximise the benefits of HS2. We consider this further proof that the initially stated rationale for opening this land up for development, has not in fact since been considered as a factor in the planning thereof. !Indeed, when questioned about this during a meeting on the 28th of February between Steffan Saunders and SB 20/20, the response was perhaps telling. SB 20/20 asked whether the land had been included because of the announcement of HS2, which Mr Saunders duly confirmed. When asked if that meant if HS2 did not come to Toton, the council would not be pursuing building on this Green Belt land, Mr Saunders stated that they would continue with plans on the site irrespective of HS2. This surely further confirms, that the site was, and is, up for development not because of HS2, but rather, (as was also confirmed by councillors statements during the extraordinary council meeting), due to the need to meet housing numbers. !We would like to point out, that contrary to statements made at the ‘Greater Nottingham- Alligned Core Strategies Examination Hearing Session (7.11.2013), as can be evidenced through the written notes of the assistant to the Inspector, there has always been and is still, 10

widespread opposition to the kind of large-scale housing development that is being proposed on this site. This was clearly evidenced and documented during the public consultation of 2011, the result of which was that Toton unanimously removed from the ACS by vote. As has been mentioned previously, Councillors had led people to believe that the land was ‘safe’ and that there was no risk of this kind of development at Toton. !

�9 Gray J., 7.11.13, Greater Nottingham ACS Examination (Notes)10

We have also obtained evidence that the inspector was not provided with the very large 11

petition with regard to the Peveril housing application from 2011. We understand that it was not compulsory at that time to provide this information to the Inspector, as it was not the issue being consulted upon. However, we believe that, due to the exclusion of this information, as well as the fact that, those opposing the inclusion of the land at Toton were not (or no longer) present at the hearing session, the reality of the public opinion with regard to Toton was unrepresented. !In the event that the HS2 station is not sited at Toton, we oppose all development on the Green Belt land. We believe that there should be no development on the site at Toton until such a time as HS2 is ratified. Until then, we believe that the Green Belt status of the land should retained. !If HS2 is ratified and the station confirmed at Toton then, and only then, do we believe plans for this site should be revisited. In the initial phase of this, we are calling for a proper comparative assessment of the land to be carried out, as well as a review of how to minimise the environmental impact of development on this land. !4. Economic growth and Toton !The NPPF provides clear guidance on proactively planning to support the economy and the importance of planning for economic growth. The following paragraphs establish the importance of building a strong competitive economy as outlined in the NPPF. !18. The Government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meeting the twin challenges of global competition and of a low carbon future.

19. The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.

20. To help achieve economic growth, local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century.

!Moreover, Broxtowe’s ACS itself states that: 12

2.4.1 iii Economic prosperity for all: to ensure economic growth is as equitable as possible, and that a more knowledge based economy is supported, in line with the aims of Science City, and enhancing the Core City role of the Nottingham conurbation. Supporting, developing and enhancing the City Centre by providing for new office, commercial, residential and other uses especially through the development of the Regeneration Zones and within the Sustainable Urban Extension of Top Wighay. Maximising the opportunities associated with the Enterprise Zone at Boots campus, Beeston Business Park, MediPark and Nottingham Science Park and development in the vicinity of the proposed HS2 hub station at Toton. Creating the conditions for all people to participate in the economy, by providing new and protecting existing local employment opportunities, encouraging rural enterprise, improving access to training opportunities and supporting educational developments at all levels. !

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Email from Steffan Saunders, can be available upon request.11

Broxtowe, Gedling, Nottingham City Borough Councils, June 2013, Document Showing the 12

Proposed Changes to the Broxtowe Borough, Gedling Borough and Nottingham City Aligned Core Strategies Publication Version, CD/REG/03

3.4.1 New employment development is vital to the growth of the area’s economy, which supports a working population of 311,00032 (363,000 for the Greater Nottingham). Over the plan period, an increase of approximately 37,000 jobs in Greater Nottingham is anticipated, of which around 27,900 are expected to be in the plan area. These new jobs are required not only to support increased numbers of workers, but to facilitate the shift from manufacturing sectors, where employment is expected to fall, to a more knowledge based economy. Nottingham’s role as a Science City is an important part of facilitating this process. The area also experiences significant problems of unemployment and low economic activity amongst its population when compared to the national average, together with a relatively low skill base. Addressing these issues by providing employment and training opportunities is a key priority. More jobs may also facilitate less out-commuting from the area, providing sustainability benefits.

If the proposed large-scale housing development is given preference to developing the site for suitable business development, economic growth is only achieved for the lifetime of the build of the housing. Given that HS2 is likely to displace 600 jobs in the locality and the opportunity of developing possibly more than 1500 long-term 13

employment opportunities in this location, as well as bolstering the local economy through supportive industries, we find it extraordinary that the BBC is not planning positively to take advantage of such an opportunity.

It is also noteworthy, that the housing development at Toton as currently proposed, has publicly been aimed at attracting commuter homes for people working on the HS2 line. This would also seem to also be contrary to the stated aims of the ACS, that more jobs would facilitate less out-commuting.

We find that this plan is counter to building a strong competitive economy and, is lacking the positive proactive planning to maximise the purported benefits of HS2. Moreover, we find that by pursuing the current proposals, BBC is not fulfilling it’s own stated aims for a prosperous economy and, the development of new employment opportunities as set out in the ACS.

5. HS2 at Toton !HS2 has been described as an “engine for growth” by the government and is seen as a vital part of national measures to stimulate economic growth. Indeed, Patrick McLaughlin (Minister of Transport) stated that: “It’s a once in a lifetime opportunity and I think we should seize it for the national benefit.” 14!As one of only two stations between Birmingham and Leeds, the HS2 station at Toton is if significant importance to the wider region as a whole. We believe that HS2 is, in fact, an extraordinary international opportunity, that is in danger of being under-sold or, worse still, squandered by the current proposals for the site around the station. !According to government estimates, HS2 could generate an estimated 1,500 direct jobs around the station at Toton. According to HS2 Ltd: “Station environs will be attractive sites for investment and new development, bringing new jobs to the area as well as new services and amenities for local communities.” !Moreover, further economic growth to the area as a whole would be supported by a specialised economic development around the station; through the use of supportive industries and staff from the surrounding area (eg. maintenance staff, support staff, catering services, tradesmen etc.). In addition, economic growth would be disseminated throughout the area by those working at the site, utilising local businesses and facilities (eg. pubs, restaurants, local shops,

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http://www.bbc.co.uk/news/uk-england-nottinghamshire-2612449413

McLaughlin P., High Speed Rail: Investing in Britain’s Future, Department of Transport, January 14

2013

hairdressers etc). However, significantly, such an economic development would not burden local services and infrastructure that are already stretched and oversubscribed, for example, local medical services and schools. !As a group, we advocate a development in line with the initial government assessment. We believe that any development on that site should be economic and in line with HS2, maximising the long-term growth that HS2 is purported to bring with it. In consideration of the fact that we believe this to be an enormous international opportunity, we advocate a world-class Science, Research and Development and Business Park. !To fully take advantage of this opportunity, this would be a flagship development that should be high tech, high-quality, bespoke and architecturally designed and, of a world-leading international standard; world-class design for a world-class opportunity. !In recognition of the Green Belt status of the land, we envisage that this purpose-built design would be landscaped to maximise open space and minimise environmental impacts. We envisage sympathetic landscaping, protecting and enhancing the local environment and taking into account its’ status as a wildlife corridor. A development that would ensure, through sympathetic design, that existing local residents would benefit from the use thereof. !There are many national and international examples, where such high-quality developments, merging principles of good design with an an environmental and ecological aims, have been successfully achieved, for example, Granta Park in Cambridge. 15!The kind of high-quality development envisaged also would be in line with the aims of the NPPF which states (63.): “In determining applications, great weight should be given to outstanding or innovative designs which help raise the standard of design more generally in the area.” This kind of development would be also be in line with the aims of the ACS and further Nottingham’s status as a Science City. !In addition, a world-class business development would inevitably attract other business; attracted to the proximity of the station and each other, thus, further boosting economic growth and development. However, it seems likely that such economic growth will only occur, if there is land is available for it with close proximity to the station. !The current proposals for a large-scale housing development, not only land-lock the station, stymying flexibility of the site but, also preclude the likelihood that business will be attracted to the site for investment. We would go so far as to argue, there is surely a very real danger that the current plans result in another small-scale failed commercial development similar in size and scale to that of Chetwynd Business Park in Chilwell (in close proximity to the site at Toton), which is permanently largely empty. We feel that the opportunity of HS2 deserves a development, which is bigger in size, scope and vision than the average mixed use development, such as Chetwynd Business Park and it’s surrounding housing development. !Further, given the world-class opportunity of HS2, we also find that the current plans are arguably counter to the aims of the NPPF with regard to the emphasis on innovative design; Point 64 appears to apply: “Permission should be refused for development of design that fails to take the opportunities available for improving the character and quality of an area and the way it functions.” !6. HS2 Working group !During the Inquiry, it was confirmed by BBC that, a HS2 Working Group would be established to fully ascertain the best use of the land at Toton. This was billed as a forum in which all parties, including resident groups, would be able to work together to find common ground and, as stated in BBC literature, analyse the land to establish an appropriate mix use and retention of open land. We object to the current configuration of this working group on several levels. !

�12 Further details of Granta Park Science Park can be found at www.grantapark.co.uk15

Firstly, this is not a true working group, as groups representing residents do not make up a permanent part of the group. They were not invited to make representations at the first 3 meetings of this group and, whilst they have been invited to attend an upcoming meeting to be part of the discussions, this can not be seen as a fully inclusive working group, as was proposed in the inquiry and, during the initial council meeting to include the land at Toton in the ACS (May, 2013). As mentioned previously, during this meeting in May 2013, the council resolved that they would “seek to work with communities, developers, HS2 and other interested parties in order to ensure that we maximise employment opportunities and ensure that we protect and preserve as much open space as possible.” !Moreover, this appears to be counter to point 66 of the NPPF which states that, “Applicants will be expected to work closely with those directly affected by their proposals to evolve designs and to take account of the views of the community.” As mentioned previously the large-scale opposition to the current housing scheme that has been proposed on the site, is well documented and has been widely reported. !Secondly, BBC purportedly set up the Working Group in order to complete a comprehensive analysis of the site and determine the optimum mix of uses of the site. The council stated 16

that the Toton site,“…does require a comprehensive analysis of how employment development, housing, open space provision and transport connections both to/from the new station and beyond can be integrated to best enhance the immediate area and also provide the optimum mix of uses for the economic benefit of the housing market area as a whole… The best way of undertaking this comprehensive approach is through the already established Working Group with final decisions as to precise mix and quantum of development and removal of land from the green belt to be taken as part of the Broxtowe Part 2 Allocations Local Plan.” !However, during a meeting with Steffan Saunders on the 28th of Febrary 2014 and SB 20/20, we questioned the status of the Peveril application and, the relevance of the HS2 working group in this regard. Steffan Saunders stated that he believed that, should the Inspector find the ACS sound, Peveril would immediately progress with their application and the council would then see fit to approve this application. When questioned as to what the purpose of the working group was if the approval of the Peveril application was a foregone conclusion, Mr Saunders stated that the Council would not appeal the Peveril application, because they would probably lose on appeal. !SB 20/20 made the point that HS2 makes this situation extraordinary and unique, surely meaning that developers winning on appeal was not a foregone conclusion. That, in fact, surely, BBC was justified in asking any judge presiding over the case to take into account the special circumstances of HS2 and ask at least for a delay, until the proper use of the land could be determined by the working group. However, Mr Saunders stated that BBC would not be inclined to do this. !In addition, in the “Report on Proposing Modifications to the draft Broxtowe Core Strategy” (p. 54), the report states, “A planning application has been submitted for the land on the West side of Toton Lane and is under consideration and negations have reached an advanced stage. No irresolvable constraints have been identified.” The statement in the Council’s Report, as well as the statements by Mr Saunders, lead us to conclude that the BBC have every intention of permitting the Peveril application if it is submitted. !Moreover, the Working Group has published it’s agenda for it’s upcoming meeting, in which it states that it is constrained by only being able to consider options for this land, in line with the figure of a minimum of 500 homes on that land as stated in the ACS. By constraining the full remits of the Working Group, it can not be seen to be a group enabled to fully analyse and properly assess the appropriate use of the land in proximity to the HS2 station. !

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BBC, 13 January 2014, Report of the Chief Executive: Report on the Proposing Modifications to 16

the Draft Broxtowe Core Strategy.

We do not believe that BBC has the expertise that is required to make the most of such an enormous international opportunity as HS2. In line with the calls of Lord Michael Heseltine MP, it should perhaps be considered for control to be passed to an Urban Development Corporation, to take charge of the planning around the station to reduce costs and maximise economic growth of the project. !In addition, we advocate that groups representing residents should be properly involved in the plans for that land, perhaps through the use of a Neighbourhood Plan. Certainly neighbourhood groups and some key residents, have been very heavily involved in this process thus far and have expressed the commitment, and possess the drive, that would be required for this to occur. !7. The Flawed Consultation Process !We object to the public consultation process for several reasons. We find it inappropriate that the boundary of the land at Toton has not been defined, nor the number of possible houses to be sited there, specified. By stating a ‘minimum’ of 500 homes, no one involved in the process, neither developers, politicians nor the public, has any clarity about what is actually meant by the plans. !Numbers used about the site are equally misleading, as at times during the process even at the inquiry, talk was of 42 hectares, but also of 73 hectares. Indeed, developers themselves, during the additional hearing days of the inquiry, repeatedly stated that the lack of definition of the site was confusing and misleading. It begs the question as to how anyone is able to properly consult on something that they have no full details or knowledge of. !Furthermore, we find the consultation process itself severely flawed. Firstly, the council was meant to write to everyone who had previously commented on the ACS, to inform them of the start of the public consultation process, so that the public would be enabled to make representation. This did not occur. Even members of SB 20/20, who have been heavily involved in the process, did not receive the relevant information, that the public consultation process had in fact started. Having consulted with many members of the general public, who had also responded to the initial consultation on the ACS, they, too, received no such information. !If not even members of the public that have been involved in the process are kept fully informed of it, it can not be expected that members of the public who are not, are aware of their rights to make a submission. As such, the process can not be seen to be fully inclusive of everyone, who has the right to be a part thereof. !Accessing the consultation documentation via the internet was also particularly difficult. Even when people wanted to respond to the modifications, the documentation was difficult to find; even for someone with prior knowledge of what one is looking for, it is very difficult to find. Throughout the process, documentation and online forms, have been unclear, difficult to find and in no way user-friendly. As such, it is very difficult to determine that the process is fully inclusive of everyone who has the right to be involved in it. !Additionally, throughout the process of this site being included in the ACS and the consultation thereof, councillors have given misinformation to the public, both publicly and in private emails, about the nature of the situation of Toton. As can be evidenced above, councillors repeatedly publicly and in the press, stated that the inspector had instructed for there to be housing at Toton and that 500 homes was the least they could “get away with”. In emails 17

sent by councillors to local campaigners, they restated this position. For example, in an email sent by Councillor Barber, at the start of January, he states that, “The Inspector has as good as told us that zero is not an option and she wants a number. If we don’t appease here and her interpretation of the National Planning Policy Framework (as voted for by our MP) then we can expect the strategy to fail and 100% of Toton’s Green Belt to be built upon.” !

�14 All emails retained for evidence and full emails available on request. 17

At a council meeting on the 18th December 2013, Councillor Watts also stated that the Inspector was pushing for housing and that the Labour/Lib Dem group (that had voted to include Toton) were fearful that if they did not to so, they would fail the core strategy, which they felt was untenable. This position and the threat that, failing the ACS would mean that all the Green Belt was under threat, the developers would have free reign and Toton and Broxtowe as a whole, could expect thousands of new homes, was reiterated as evidenced above not only at the extraordinary council meeting on the 13th of January 2014, by various Councillors, but also in the press on other occasions. !For example, in his own newsletter, when speaking about Rushcliffe and, according to Watts 18

their failure with regard to the ACS he stated: !“Where does this leave people as a result? Well for Rushcliffe Borough Council they are firmly up the creek without a paddle. They have no current plan and now no future plan. As a result it will be open season for developers there. All their undeveloped land is now fair game for developers to try and build on. It does raise very serious questions about the ability and judgement of their political leaders. This isn't just scare mongering on my part, the same thing is happening in Castle Point council in Essex, in Bude council in Cornwall and in Stratford Council in Warwickshire where a new housing estate is being developed right next to Anne Hatthaway's cottage. Here in Broxtowe Anna Soubry is left with significant amounts of egg on her face. If we had taken the path that she was advocating, which she has been telling people for at least the past year was the right thing to do, then we would be in the same mess as Rushcliffe. No-one wants to build on the green belt but those of us running the council found ourselves in a position where we had no choice. To then have our MP launch an extremely nasty and vindictive campaign against us was extremely galling, and I do now feel completely vindicated. By being willing to consider sacrificing a small part of Broxtowe's green belt we have saved the rest of it from development.” !

In a public meeting held by SB 20/20 on the 26th January 2014, Councillor Barber reiterated this point stating that, if Councillors had not accepted the figure of 500 homes, the developers would get free reign and it was more likely to be thousands. He then also stated that, in fact, Toton no longer had any Green Belt, promoting significant reaction of distress from the many members of the public present at the meeting. Indeed, at the recent HS2 Working Group 19

meeting, at which the developers were able to give representation, Councillor Barber, again restated his assertion that Toton no longer had any Green Belt land. !We find that the statements with regard to the status of the Green Belt land at Toton, the process of the inclusion of Toton and the inevitability of the outcome of the process (the frequent assertions that housing was essentially a foregone conclusion, that the Inspector was pushing for it and that the least that the minimum that would be acceptable would be 500 homes), as well as the threatening nature of the outcome if Toton was not included (the developer having a free reign and thousands of homes having to be built), to be at best misleading, and at worst a blatant subversion of the democratic nature of the process. !The outcome of these actions is very clear, not only from public meetings held, social media sites and other internet writings, but also from speaking to many members of the general public during our campaign; not only are members of the public largely unaware that they are still able to respond to the process but, perhaps more importantly, that such statements have led residents to believe that the outcome of the process is in fact inevitable. Many people have termed this “a done deal” and, residents have felt apathetic about the process, believing that there is no point in responding a process, the result of which is a foregone conclusion. We strongly believe that this means that the process can not possibly be considered to be inclusive, fair or democratic. Moreover we believe that through the series of public misrepresentations by Councillors, the public consultation process is surely seriously flawed and can not be seen to be legally compliant.

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Watts D., Newsletter: Housing Numbers, 11th December 201218

HS2 Working Group19

!!!Conclusion !In the event that the HS2 station is not sited at Toton, we oppose all development on this Green Belt land. We believe that, without HS2 no extraordinary circumstance exists to permit building on this green belt land; the permanence and the protection of the greenbelt has been reaffirmed by recent legislation and planning guidelines. Moreover, the need to meeting housing targets in itself does not constitute the extraordinary circumstance required to build on Green Belt land. !In light of this, we believe that there should be no development on the site at Toton until such a time as HS2 is ratified. Until then, the Green Belt status of the land should remain. If HS2 is ratified and the station confirmed at Toton then, and only then, do we believe plans for this site should be revisited. !We believe that HS2 is an extraordinary opportunity for the whole of this region, that will only come once in a generation. Arguably, the largest opportunity Broxtowe has had to this date or is likely to have in the future. We believe that any development on that site should be economic and in line with HS2, maximising long-term economic growth. !The current proposals for a large-scale housing development, can not possibly be seen to encompass the vision or flexibility that is needed maximise the long-term economic growth that HS2 is purported to bring with it. We also believe that failing to maximise the benefits of HS2 is counter to the aims as set out by the NPPF and, indeed, the ACS to plan positively to seize this opportunity and ensure economic growth. !Further we object to the validity of the public consultation process and the HS2 working group. !For all the reasons as detailed in this submission, we do not believe the current plans for this site as set out by the ACS can possibly be seen to be positively prepared, justified, effective or consistent with National Policy. !!!Sources !BBC News, 10.01.2014, http://www.bbc.co.uk/news/uk-england-nottinghamshire-26124494 !BBC News, High Speed Rail Bill Delayed, 6.03.2014,http://www.nottinghampost.com/High-speed-rail-delayed/story-20772602-detail/story.html?ito=email_newsletter_nottinghampost#ixzz2vC1yBU6h !Boles N. MP, Letter to Sir Michael Pitt, 3.3.2014, Inspectors’ Reports on Local Plans https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/292648/Scan-to-Me_from_ela-mfd-f6-zc1.link.local_2014-03-03_180547.pdf !Broxtowe, Gedling, Nottingham City Borough Councils, June 2013, Document Showing the Proposed Changes to the Broxtowe Borough, Gedling Borough and Nottingham City Aligned Core Strategies Publication Version, CD/REG/03, http://www.nottinghamcity.gov.uk/CHttpHandler.ashx?id=43346&p=0!!Broxtowe Borough Council, 20.05.2013, Council Meeting Minutes!!Broxtowe Borough Council, 13.01.2014, Report of the Chief Executive: Report on the Proposing Modifications to the Draft Broxtowe Core Strategy, !http://www.broxtowe.gov.uk/CHttpHandler.ashx?id=29217&p=0!!Broxtowe Borough Council, 13.01.2014, Council Meeting Minutes,

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http://www.broxtowe.gov.uk/CHttpHandler.ashx?id=29410&p=0 !Broxtowe Borough Council, REPORT Report on Proposing Modifications to the draft Broxtowe Core Strategy, Appendix 17, Land in the vicinity of the proposed HS2 station at Toton (Broxtowe) Gray J., 7.11.13, Greater Nottingham ACS Examination (Notes) !Ken Mafham Associates Town Planning Consultants, 20.1.2014, Comments on the Volterra Report (report included in this submission) !Ken Mafham Associates, Comments on Modifications to the ACS for Broxtowe, Gedling and Nottingham City by Ken Mafham Associates on behalf of Barton in Fabis, Calverton, Gotham, Thrumpton and Woodborough Parish Councils, Calverton Preservation and Historic Society, STRAG and South Broxtowe 20/20 !McLoughlin P., January 2013, High Speed Rail: Investing in Britain’s Future, Department of Transport. !National Policy Planning Framework, 27.03.2012, Department for Communities and Local Government, http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/9-protecting-green-belt-land/ !Nottingham Post, 6.1.2014, The HS2 stop is not far away and we have to view that positively. http://www.nottinghampost.com/HS2-stop-far-away-view-positively-ndash-Prof/story-20404439-detail/story.html !Planning Portal, 6.03.2014, Guidance: Housing and Eoconomic Land Availability Assessment, Methodology-Stage 5 Final Evidence, Paragraph 034 Reference ID: 3-034-20140306 http://planningguidance.planningportal.gov.uk/blog/guidance/housing-and-economic-land-availability-assessment/stage-5-final-evidence-base/ Watts D., Newsletter: Housing Numbers, 11th December 2012, http://cllrdavidwatts.blogspot.co.uk/2012_12_01_archive.html !Watts D., Battle of Broxtowe, 30th April 2013, http://beestoniabattleofbroxtowe.wordpress.com/2013/04/29/radio-wrong/ !Watts D., Nottingham Evening Post, 9th Dec 2013, http://www.nottinghampost.com/homes-earmarked-green-belt-Toton/story-20296040-detail/story.html#ixzz2zhPboPs5 !!!!

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Comments on the Volterra Report by Ken Mafham Associates Town Planning Consultants in association with South Broxtowe 20/20 !1. Introduction !1.1 The first thing to say is that the Report deals with the broad benefits over a wide area. It is not and, does not claim, to be an appraisal of the comparative benefits of different land use options around the HS2 Station itself. It reads as though the consultants were asked at a late stage to comment on that issue. !1.2 Our critique of the report concentrates on two aspects ! • Whether the assessment of the overall job benefits form HS2 and, the assessment of

what is a reasonable amount of business space within the Toton Growth Zone as identified in the Broxtowe Aligned Core Strategy, are compatible with one another. !

• Whether the report justifies the claim that housing needs are to come first and, that a figure of around 500 dws is correct. !

2 Jobs !2.1 The section of the report dealing with jobs is summarised in the sections below;

“1.18 Based on the current distribution of relevant employment sectors across the UK, we estimate that around 15% of the 89,000 jobs could be workers within the East Midlands. This implies the East Midlands as a whole could benefit from 13,350 additional jobs as a result of HS2.

1.19 These employment activities could be worth an estimated £575 million in annual economic benefits, which, even using conservative assumptions about phasing, would result in a 60 year NPV of over £7 billion.

1.20 The most notable type of employment that the region, and specifically Derby, could benefit from, is the manufacturing of rolling stock. Over half of national employment in this sector is located in the East Midlands, and two thirds of this is within Derby. This means that around 2,500 workers in Derby could be involved in the manufacturing of rolling stock related to HS2. This of course has no bearing on the location of the HS2 station. But the point is that Derby will be boosted by the overall HSR programme due to the relative strength of its transport engineering industry.

1.21 This could have a huge bearing on the East Midlands economy, as the direct effects from manufacturing the rolling stock reverberate to the wider region through supply-chains and additional household spend. !!1.22 Another specific job creation site linked to HS2 that the area could benefit from is the Staveley Infrastructure Maintenance Depot. Although no detail is available at this stage, initial estimates suggest that this could create around 80 FTE construction jobs and around 500 FTE operational jobs. It should be noted that the site is currently earmarked for residential development so it will be important to ensure that the specific location of the depot is compatible with wider regeneration aims for the area.”

2.2 The 13500 figure, is clearly an educated guess but we have alternative to offer, so we are happy to work with that estimate. !The first point to note, is that the two key sectors identified by Volterra, 2500 jobs estimated to through the manufacture of rolling stock and around 500 jobs at the maintenance depot, only make up 20% or so of the total forecast job increase. If the rolling stock contract does not come to Derby then only 4 % of jobs are in these sectors. !

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2.3 The obvious question is where would the other jobs come from. The answer has to be in growth sectors that would benefit form the increase competitive advantage that HS2 brings to the Region and, these are largely in the service sector. !When it comes to the employment space at Toton the Report says: ! “For example, in the vicinity of the Toton site, there are currently plans for a

mixed-use housing and commercial development that could result in around 650 to 875 residential dwellings, and 2,800 sq m to 19,800 sq m of commercial office space – other uses are planned too. This could result in the creation of 200 to 1,500 office-based jobs once the development enters its operational phase. Meanwhile, since the total capital investment is expected to be in the region of £120 million, this could lead to some 200 full-time jobs generated during its 5 year construction phase.”

2.4 We find it extraordinary that consultants will quote a range of 200 to 1500 without comment, given that the basic brief is to advise on how to maximise the benefits of HS2. At 200 jobs only 1.5% of the additional jobs estimated to be created are at Toton. The 1500 figure is closer to 10%. The planning application from Peveril homes, shows a employment area of 2800 sq ms which we would assess as having the job creation potential of 200. !2.5 There are two existing business parks in the Greater Nottingham Area; the Nottingham Business Park and the Ruddington Business Park . It is a useful exercise to compare the area covered by those two employment centres, in comparison with the total area the subject of the Peveril Homes application. If the whole of the Peveril site were developed for employment, the scale of space and jobs created would be no greater than either of those two development individually. !2.6 Nottingham City Council have recently permitted housing on some 10 hectares of the Nottingham Business Park. At the Hearing they explained this on the grounds that the Nottingham Business Park was not a success due to the poor public transport access. We would agree with that analysis to some extent, but would add, that the poor design and layout of the scheme has contributed. !2.7 The Ruddington Business Park has been a success, but is now fully developed and, any further expansion is constrained by the Ruddington Country Park and Transport Heritage Centre. !2.8 In our view, based on many years experience carrying out employment studies for the private and public sectors, Toton with the NET terminus and, access to the M1 and A52, is one of the best locations for a business park in the Greater Nottingham area. With the HS2 it ranks as the best location. Taking a 30 hectare site and assuming 80% developable area and a plot ratio of 0.7 to 1.0 then the total business floor area would be 170000 sq ms. With an employment density of one worker per 10ms squared, the Peveril site in business park use, would allow up to 1700 jobs. This is a sensible proportion of the 13500 total extra jobs, in that the location is convenient for Nottingham and Derby, has good public transport connections and is close to the HS2 station. !2.9 The Volterra Report also refers to another site in an undisclosed area on the East side of Toton Lane and there appear to be three options as outlined below: !

7.11 The developer of the scheme is also planning to submit an application for the associated land to the east of Toton Lane, which is likely to include either 225 residential dwellings, or 17,000 sq m of commercial office (B1), or a mix of 5,000 sq m of commercial office (B1) and 175 residential dwellings.

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2.10 Once again it is astounding that the consultants offer no advice on which of these might be the best option. We have to conclude that they do see themselves as having a responsibility to appraise land use options at Toton.

2.11 Section 2.6.1 of the HS2 route consultation estimates 1500 to 1600 jobs in the vicinity of the station. This is entirely consistent with the assumption we have made that around 30 hectares gross are developed for business. !2.12 We understand that the Nottinghamshire Chamber of Commerce also back an option that maximises business space at the expense of housing. !!3.Housing as a pump primer !3.1 The bottom line on this issue in the Volterra Report is ! 7.24 “Accordingly, the immediate concern of Broxtowe council is to accelerate the

development of the residential component of the proposed scheme, such as the one proposed in the plans that were already submitted. This will bring forward development and economic benefits for the borough and wider region.”

3.2 The only justification we find for this conclusion is that housing was a key component in the spin off developments at Cordoba in Spain. The report implies that this was not he case the case of the HSR network in France, nor indeed in Zaragosa in Spain. We do not understand the reference to Ebbsfleet. The granting of permission for housing is not the way to ensure flexibility. !3.3 We would suggest that it might perhaps be more relevant to look at the demand for commercial space in a location at Toton itself and, to carry out some preliminary viability studies. It could well be that there are grounds for including some housing as a pump primer on the Peveril site, so as to allow early implementation of infrastructure. In our view, a housing component up to 150 dwellings would have the following advantages: ! • It would improve viability in the early stages of the scheme. ! • It would tie in the developer to a high standard of design on the Business Park

component, since the business park would be part of the setting for the housing and, good design would add a premium to house prices. !

• The housing would relieve pressure on other parts of the greenbelt and, would in itself, not withstanding any justification based on brownfield resources, allow a reduction in the scale of Field Farm so as to delete the housing proposals on the eastern section. !

• The residents of the housing would have a good choice of employment nearby and, the sustainability advantages of mixed use schemes, so often claimed but rarely realised, could actually apply in this case.

3.4 The effect of including such a housing component would be to reduce the number of potential jobs form around 1600 to around 1200. It could well be, that the shortfall could be made up by stand alone commercial developments in and around the Bardills site and the NET Park and ride. !3.5. It is of relevance that the housing figures in the ACS are based on a jobs ambition of 72000 additional in Greater Nottingham over the plan period. If it proves to be the case that commercial development well related to the NET terminus, Junction 25 and possible an HS2 station is non viable, then the realism of the 72000 jobs ambition is thrown into doubt and the ACS would run foul of the requirement in para 154 of the NPPF that “154. Local Plans should be aspirational but realistic.” !3.6 There is also a simple fact of planning, that argues for the majority of the site to be

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employment rather than housing and that is, that whilst housing can be very successfully provided on small brownfield sites, a top class business cannot. There is evidence that housing schemes suffer from dis-economies of scale and, are harder to market than an equivalent number of houses on a number of small sites. The opposite is true of first class business accommodation. !3.7 There has been talk of a corridor of commercial growth from the NET terminus into Beeston and, the Volterra Report at paras s 7.25 and 7.26 purports to provide some justification for this view. We have the following comments: ! • Table 5, which details planned development along the tram route in Broxtowe, contains

serious inaccuracies in that 12 out of 15 of the proposals, have actually been implemented or were planned, before the tram route was confirmed. Similar issues affect Table Six. The Boots proposals are of long standing and do not depend on the tram route. The Nottingham Science Park is a proposal that goes back some fifteen or twenty years when the NET was just a bad idea. !

• The point we make in para 3.5 is relevant. Many of the potential site s along the tram route are small brownfield sites, highly suitable for residential development. What Broxtowe BC should be doing, is re-assessing the SHLAA resource along the tram route and, looking at ways and means of bringing these forward. Tables five and six include many residential proposals, and can in fact be used as an argument against residential development at Toton. !!

4.Greenbelt Issues !4.1 Reading the Volterra Report one might be forgiven for thinking that the land at Toton is all brownfield or, at the very least is open land, but not in the greenbelt. The fact of the matter is that, the two sites mentioned above, are designated greenbelt. The NPPF clearly requires exceptional circumstances to be put forward as a justification for the release. Non whatsoever is provided, to justify support for a range of options which includes almost 800 dwellings and business space only sufficient to accommodate 200 jobs. No case has been made for the release of areas of the greenbelt at Toton for housing. The National Planning Policy Framework lists five purposes for the greenbelt. ● to check the unrestricted sprawl of large built-up areas; ● to prevent neighbouring towns merging into one another; ● to assist in safeguarding the countryside from encroachment; ● to preserve the setting and special character of historic towns; and ● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. The greenbelt at Toton fulfils purposes 1-3 and 5. 4.2 Paragraph 81 of the National Planning Policy Framework says .” Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and\ biodiversity”. The greenbelt at Toton has great potential for this kind of positive use. !4.3 The original Aligned Core Strategy did not propose any housing for Toton and things have not changed since then. There has been no change of circumstances since then. If HS2 does happens and, if this is the site of the station for Nottingham and Derby, then it could have a special value for a narrow range of uses that would truly benefit from the special advantages such as a world class class business/ science park. !!!!

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4.4 Criteria: ! • Accommodation of the operational needs and means of access for the HS2 station, as

a top priority • Exceptional economic benefits ! • Minimum visual impact ! • Not adding to peak flow congestion ! • Net gains in terms of environment and bio diversity !!4.5 It is crucial the local community is involved. This might might be by means of a Neighbourhood Plan. The key point is, that there is no need for any rush because the station is unlikely to be built before 2030. The right policy is to retain the greenbelt at Toton in the present Local Development Framework and, to plan for any future economic development as plans for HS2 are firmed up. !4.6 There is a need for a comprehensive review of the Greenbelt, before any housing sites are released. No exceptional circumstances exist for release of land from the Greenbelt at the present time. There is adequate brownfield within the main urban area of Broxtowe and in Nottingham City, which is in n the same Housing Market Area. 5. Conclusions on the Volterra Report !The Volterra Report is perfectly adequate as a desk study that pulls together information from a variety of sources in order to broadly outline the benefits of HS2 to Greater Nottingham and Derby. It is not an adequate appraisal of the land use options around the HS2 station and, in particular, does not take the greenbelt designation of most of the undeveloped land. At Toton, it does not fully consider the land needs of the station itself and is without any firm objectives so far as job creation around the station is concerned . It give an importance to a single current application, which is disproportionate in view of the long-term perspective of the Study being undertaken. !We are also concerned about some seemingly inaccurate data that has been included about developments taking place as a result of the NET extension, quoted as a precedent. !!Ken Mafham Associates Jan 30th, 2014 !!! !!!!!

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