bunny appliance warehouse 1144879 agent dlp planning …...representations must be received by 5pm...

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From: Ian Long Sent: 28 June 2018 14:31To: LocaldevelopmentCc: Nottingham FilingSubject: 06.28.NTTS5078/1P.Representation to the Publication Draft Local Plan consultation - Bunny Trading Estate, BunnyAttachments: 06.28.NTTS5078.1P.Bunny Trading Estate.Publication draft LP rep.submission.pdf; RBC LP2 response form_autoform.pdf; Site Location

Plan.pdf

Dear�Sir/Madam��Please�find�enclosed�a�representation�to�the�Publication�Draft�Local�Plan�consultation�in�regards�to�Bunny�Trading�Estate,�Bunny.��Please�could�you�confirm�that�the�representation�has�been�successfully�received.��Kind�regards��Ian�Long�BA�(Hons)�MSc�Planner�www.dlpconsultants.co.uk�

�DLP�Planning�Limited�is�a�limited�company�registered�in�England�and�Wales.�Registered�number:�2604863,�Registered�office:�4�Abbey�Court,�Priory�Business�Park,�Bedford�MK44�3WH�and�is�part�of�DLP�(Consulting�Group)�Limited.�Registered�number:�3161011.��Please�note�that�the�DLP�(Consulting�Group)�Limited�and�its�operating�companies�may�monitor�email�traffic�data�and�also�the�content�of�emails�for�the�purposes�of�security.�This�email�is�confidential�and�may�contain�privileged�information.�It�is�intended�only�for�use�of�the�intended�recipient.�If�you�received�it�by�mistake,�please�notify�the�author�by�replying�to�this�email�or�telephone�(01234�832�740).�If�you�are�not�the�intended�recipient,�you�must�not�print,�copy,�amend,�distribute�or�disclose�it�to�anyone�else�or�rely�on�the�contents�of�this�email,�and�you�should�DELETE�it�from�your�system.�We�make�every�effort�to�keep�our�network�free�from�viruses,�but�you�should�check�this�email�and�any�attachments�for�viruses,�as�we�can�take�no�responsibility�for�any�virus�which�may�be�transferred�by�this�email.�Thank�you.��Please�be�aware�that�there�is�significant�risk,�due�to�the�increasing�use�of�cyber�fraud�by�criminals,�affecting�email�accounts�and�specifically�bank�account�details.�Please�note�that�our�Company’s�bank�account�details�will�never�change�via�email.�Please�be�extra�vigilant�and�recheck�our�bank�account�details�with�the�person�responsible�for�your�matter�before�sending�funds�to�us�if�you�are�in�any�doubt�whatsoever.�We�will�not�accept�any�responsibility�if�you�transfer�money�to�an�incorrect�bank�account.�

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Bunny Appliance Warehouse 1144879agent DLP Planning 1144880

Representations must be received by 5pm Thursday 28 June 2018. Representations received after this time will not be considered duly made.

RushcliffeBorough Council

Rushcliffe Local Plan Part 2: Land and Planning PoliciesPublication Version

Representation Form

OFFICE USE ONLY:

Representor no:

Representation no:

Plan ref:

Soundness test:

Please return by 5pm on Thursday 28 June 2018 to: Rushcliffe Borough CouncilRushcliffe Arena, Rugby RoadNottinghamNG2 7YG

This form has two parts: Part A – Personal details Part B – Your representation(s). Please fill in a separate part B for each issue/

representation you wish to make.

Please read the Representation Guidance Notes (available separately) and the Data Protection Notice (see below) before completing the form.

Part A (Please complete in full; in order for the Inspector to consider your representations you must provide your name and postal address).

1. Personal Details 2. Agent’s Details (if applicable)

Title Click here to enter text. Mr

First Name Click here to enter text. Chris

Last Name Click here to enter text. Dwan

Organisation(where relevant) Bunny Appliance Warehouse Ltd DLP Planning Ltd

Job title(where relevant) Click here to enter text. Director

Address – line 1 Click here to enter text.

Address – line 2 Click here to enter text.

Address – line 3 Click here to enter text. Click here to enter text.



Postcode Click here to enter text.

E-mail Address Click here to enter text.

Telephone Number Click here to enter text.


Part B (please use a separate Part B form for each representation)

Name/Organisation:

Bunny Appliance Warehouse Ltd c/o DLP Planning Ltd

3a. To which document does your response relate? (please tick one)

Local Plan Part 2 Publication Version

� Local Plan Part 2 Policies Map �

Other supporting document � please state which:

Click here to enter text.

3b. To which part of the document does this representation relate? (complete all that apply)

Page no. 93-94 Paragraph no.


Policy ref.

Policy 23: Redevelopment of Bunny Brickworks

Site ref. Policy 23: Redevelopment of Bunny Brickworks

Policies Map


4. Do you consider the Local Plan Part 2:

4(1) Legally compliant Yes � No �

4(2) Sound Yes � No �

4(3) Complies with the Duty to Yes Co-operate � No �

→ If you have selected No to Question 4(2), please continue to Question 5. → In all other circumstances, please go to Question 6.

What makes a Local Plan “sound”?

Positively prepared - the plan should be prepared in a way that meets the need for housing and other development, including infrastructure and business development.


Justified – the plan should be based on evidence, and be the most appropriate strategy for the district when considered against other reasonable alternatives.

Effective – the plan should be deliverable; the housing and other development should be capable of being carried out.

Consistent with national policy – the plan should enable sustainable development and be consistent with the policies in the National Planning Policy Framework (NPPF).

Positively Prepared � Justified �

Effective � Consistent with national policy �

6. Please give reasons for you answer to Questions 4(1), 4(2), 4(3) and 5, where applicable.

You may also use this box if you wish to make representations on one of the Local Plan Part 2’s supporting documents (e.g. Sustainability Appraisal, Habitat Regulations Assessment or Equalities Impact Assessment). You can attach additional information but please make sure it is securely attached and clearly referenced.

Please see supporting Statement

7. Please set out what change(s) you consider necessary to make the Local Plan Part 2

legally compliant or sound, having regard to your responses to Questions 5 and 6. You will need to say why this change will make the Local Plan Part 2 legally compliant or sound. It will be helpful if you could put forward your suggested revised wording of any policy or text. Please be as precise as possible.

(If you are suggesting that the Local Plan Part 2 is legally compliant or sound please write

“Not applicable”).

Please see supporting Statement

8. If your representation is seeking a change, do you consider it necessary to participate at

the hearing sessions of the Public Examination? (please tick one box only)

No, I do not wish to participate at the hearing � Yes, I wish to appear at

the examination �

5. If you consider the Development Plan is UNSOUND, do you consider this to be because

it is NOT: (please tick all that apply)


session at the examination. I would like my representation to be dealt with by written representation

If you have selected No, your representation(s) will still be considered by the independent Planning Inspector by way of written representations.

9. If you wish to participate at the hearing sessions of Public Examination, please

outline why you consider this to be necessary: It is important that we are able to participate in the Hearing Sessions. We would welcome the opportunity to discuss the merits of the site subject to this representation in relation to including the site within the proposed allocation under emerging Policy 23 'Redevelopment of Bunny Brickworks'. We are not satisfied with the verbal response from the Council in omitting/discounting the Trading Estate at the previous consultation stage and would greatly appreciate the opportunity to discuss the merits of the site at Public Examination.

Please note: the Planning Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to participate at the hearing session of the examination.

The Local Plan Part 2 has been submitted for independent examination.

�

The recommendations of the Planning Inspector appointed to carry out the independent examination have been published.

�

The Local Plan Part 2 has been adopted

�

Date form completed

28/06/2018

Please return the completed form by no later than 5pm on Thursday 28 June 2018 to:

[email protected]; or Planning Policy Rushcliffe Borough Council Rushcliffe Arena Rugby Road, Nottingham NG2 7YG

10. Please indicate if you wish to be notified that: (please tick all that apply)


(Electronic copies of this form are available to download at www.rushcliffe.gov.uk/planningpolicy). If you have any questions, please contact the Planning Policy team by telephone on 0115 981 9911, or email at [email protected]

Data Protection Notice

The personal information you provide will only be used by Rushcliffe Borough Council, the Data Controller, in accordance with General Data Protection Regulation 2016/Data Protection Act 2018 to undertake a statutory function (also known as a ‘public task’) Your personal information will be shared with the Planning Inspectorate in connection with the above purpose. Your personal data will be kept in accordance with the Council’s retention policy and schedule. Details of which can be found on the Council’s website at http://www.rushcliffe.gov.uk/retention_schedule/ Your data protection rights are not absolute and in most cases are subject to the Council demonstrating compliance with other statutory legislation, for further information see http://www.rushcliffe.gov.uk/privacy/ Representations will be available to view on the Borough Council’s website, but any signatures, addresses, email addresses or telephone numbers will not be included. However, as copies of representations must be made available for public inspection, comments cannot be treated as confidential and will be available for inspection in full.

For and on behalf of Bunny Appliance Warehouse Ltd

REPRESENTATION TO THE RUSHCLIFFE BOROUGH COUNCIL: LOCAL PLAN

PUBLICATION DRAFT

Bunny Trading Estate, Gotham Lane, Bunny, NG12 6QJ

Prepared by DLP Planning Ltd

Nottingham

June 2018

NTTS5078/1P Bunny Trading Estate, BunnyJune 2018

Publication Draft Local Plan consultation – Bunny Appliance Warehouse Ltd

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DLP Consulting Group disclaims any responsibility to the client and others in respect of matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence. This report is confidential to the client and DLP Planning Ltd accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the

report at their own risk.

Prepared by: …………………………………….. Ian LongBA (Hons) MSc

Planner

Approved by: ……………………………………. Chris DwanBSc Assoc.RTPI

Director

Date: June 2018

DLP Planning Ltd

NTTS5078/1P Bunny Trading Estate, Bunny June 2018


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Contents Page 1.0 INTRODUCTION 4

2.0 WHY THE LOCAL PLAN IS UNSOUND 5

3.0 THE CHANGES WE CONSIDER NECESSARY IN ORDER TO MAKE THE PLAN SOUND 13

4.0 SITE SPECIFIC ASSESSMENT 14

5.0 CONCLUSION 24



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1.0 INTRODUCTION

1.1 This representation has been prepared for and on behalf of Bunny Appliance Warehouse

Ltd in response to the consultation on the Rushcliffe Borough Council, Local Plan

Publication Draft. The consultation (17 May 2018 – 28 June 2018) forms part of the

process for the preparation of the new Local Plan.

1.2 This representation seeks the inclusion of the Bunny Trading Estate within the boundary

of the proposed allocation under emerging Policy 23 ‘Redevelopment of Bunny

Brickworks’. The site is entirely brownfield land and hosts the highly successful Bunny

Trading Estate. In order to remain competitive within the market there will be a need in

the near future for moderate upgrading and expansion of the existing built form on site.

If the Trading Estate cannot be upgraded and continue to grow it is possible that the

proprietors will be forced to consider alternative sites for future operation, with the likely

outcome that the businesses would leave Rushcliffe Borough.

1.3 This representation will confirm that the Bunny Trading Estate is available, suitable and

achievable to achieve the necessary upgrading and expansion to accommodate the

growth of the successful business. Accordingly, the representation objects to the Local

Plan Publication Draft, due to the omission of the subject site from being included within

the proposed allocation under emerging Policy 23 ‘Redevelopment of Bunny

Brickworks’. The emerging Local Plan is not considered to be positively prepared,

justified, effective or consistent with national policy and so the Plan is considered

unsound.

1.4 This Representation is submitted alongside the ‘Representation Form’ and is structured

as follows:

� Section 2 provides a response to Question 6 of the Representation Form;

� Section 3 provides a response to Question 7 of the ‘Representation Form’ and outlines the changes we consider necessary in order to make the plan sound;

� Section 4 will provide a site-specific assessment of the Bunny Trading Estate, Bunny in order to demonstrate that it is suitable for inclusion with the proposed allocation under Policy 23 and is available, developable and deliverable; and

� Section 5 will summarise the representation and provide our conclusions.



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2.0 WHY THE LOCAL PLAN IS UNSOUND

2.1 This section of the representation relates to the Bunny Trading Estate, Bunny and

queries its omission from the inclusion of the site within the boundary of the proposed

mixed-use allocation under emerging Policy 23 ‘Redevelopment of Bunny Brickworks’.

2.2 The Local Plan will be assessed by an Independent Inspector whose role is to evaluate

whether the plan has been prepared in accordance with the Duty to Cooperate, legal

and procedural requirements and whether it is sound.

2.3 We consider that the plan fails to meet the tests of soundness and this section of the

representation will outline the reasons why. Namely, the focus of the representation is

that the Council has:

� Failed to achieve sound planning in not including the Bunny Trading Estate as

part of the adjacent proposed allocation under emerging Policy 23

‘Redevelopment of Bunny Brickworks’.

Question 6: Please give reasons for your answer to Questions 4(1), 4(2), 4(3) and 5, where applicable.

2.4 For the Rushcliffe Borough Local Plan Publication Version to be found sound under the

four tests of soundness as defined by the Framework (paragraph 182), the Plan should

be positively prepared, justified, effective and consistent with National Policy. It is

considered that the Local Plan Publication Draft Local Plan fails to meet all four of the

tests of soundness as summarised overleaf.

2.5 Historically the Bunny Trading Estate formed part of the Bunny Brickworks factory, the

site of which is proposed for mixed-use allocation comprising around 100 homes and

employment uses (B1, B2 and B8 use classes) under emerging Policy 23


2.6 The Bunny Trading Estate would serve as a complimentary and logical extension to the

proposed allocation and not including the Bunny Trading Estate within the boundary of

emerging Policy 23 represents an unsound, poorly prepared Local Plan.

2.7 Prior to Bunny Appliance Warehouse Ltd owning the Bunny Trading Estate the previous



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owner had used the site as a waste ground (see figs 1 and 2) and sold the premises

without undertaking any site clearance. The site had been polluting the surrounding area,

including allowing plastic to leak into the nearby waterways. The current landowner

made a significant financial investment in clearing the site and upgrading the facilities to

a high standard wherein several businesses offering skilled and semi-skilled

employment now occupy units in the Bunny Trading Estate.

Fig 1: Photo of the site in c2010 showing the extent of waste left on the site by the previous owner

Fig 2: Example of the waste material stored on site



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2.8 Since taking over the site in 2010, the current landowner has successfully implemented

a business strategy which has resulted in considerable success and consistent growth.

The current landowner is also the main tenant of the site, occupying 85% of the Trading

Estate.

2.9 This growth has collectively enabled the tenants of the Trading Estate to employ 75

people in skilled and semi-skilled roles, many of whom are local to the area. Staffing

levels have grown by 20% in this year alone and it is anticipated that a further 25 full-

time positions would be created through an extension to the existing Trading Estate.

2.10 There is ongoing concern amongst the tenants of the Trading Estate that without the

upgrading works and additional space and capacity, which a renovative extension could

provide, that they could be forced to relocate away from Bunny and potentially outside

of the Borough.

2.11 Despite the investment that has been made to date and the commitment of the

landowner to grow and develop the Trading Estate, the site is currently located within

the Green Belt, which severely restricts development opportunities on the site. Indeed,

the Framework highlights that the Government attaches great importance to the Green

Belt. Inappropriate development, is by definition, harmful to the Green Belt and should

not be approved except in very special circumstances. The Framework is explicit that

the construction of new buildings should be considered as inappropriate in the Green

Belt, subject to a number of exceptions.

2.12 Whilst the extension or alteration of a building (subject to it not resulting in

disproportionate additions over and above the size of the original dwelling) or the limited

infilling of previously developed land are considered to be ‘exceptions’ it would not allow

Bunny Trading Estate to grow to its potential. In particular, it is economically challenging

for the landowner to invest further into the employment site without being able to deliver

new floorspace. If this is unable to take place due to the fundamental restriction of

existing Green Belt policy, further investment is unlikely to take place and the landowner

will be forced to look for alternative employment sites, which would realistically be

outside of the Borough.

2.13 The reality is, certainly in the short term, the renovation and extension works being

considered are relatively moderate and entirely appropriate in the context of the site



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location, especially given how the site looked when the landowner first took responsibility

for the Trading Estate. Figs 4 and 5 provide proposed images that the landlord has had

prepared for the modernization, renovation and extension of the existing main unit. As

can be seen, the primary driver is to improve the operational shape of the building to

allow more efficient, internal use, whilst also providing a smarter, more contemporary

façade. At present, such works would be restricted by policy, regardless of the fact that

the site is entirely brownfield and will improve the general environment of the locality.

Inclusion of the site in the emerging allocation would allow for greater flexibility in order

to ensure the improvement and expansion works could be undertaken.

Fig 3: Existing and Proposed floor plans showing the moderate proposed extensions

Fig 4: Proposed west-facing elevation



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Fig 5: Extension to the Bunny Trading Estate

2.14 We understand from officers that the Bunny Trading Estate was omitted from inclusion

within the proposed former Bunny Brickworks allocation at the previous Local Plan

consultation stage due to over-encroachment into the Green Belt and through being

incongruous with the forthcoming mixed-use development of Bunny Brickworks. These

arguments do not hold any planning merit for the reasons contained in this

representation.

Positively prepared? 2.15 Incorporating the Bunny Trading Estate within the proposed allocation under emerging

Policy 23 ‘Redevelopment of Bunny Brickworks’ would inset the site from the Green Belt.

The removal of the Trading Estate alongside the Brickworks from the Green Belt would

allow the landowner to more easily invest in the site and so increase employment

floorspace within the existing brownfield footprint of the Trading Estate. Its continued

employment use would be consistent with the adjacent proposed mixed-use allocation.

2.16 The continued growth and success of the Bunny Trading Estate will, in turn, aid the

regeneration of the wider Bunny Brickworks site. As such, the Trading Estate would

make a logical and congruent extension to the Brickworks allocation, complimenting the

proposed forthcoming mixed-use development. The tenants of the Trading Estate, who

provide a number of skilled and semi-skilled employment opportunities, do not undertake

polluting works on the site.

2.17 Overall it is considered that the inclusion of the Bunny Trading Estate within the

boundary of emerging Policy 23 ‘Redevelopment of Bunny Brickworks’ is wholly logical



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and would allow the Trading Estate to sustainably grow whilst being a harmonious

neighbour to the proposed forthcoming mixed-use development. Having failed to include

the Trading Estate as part of the emerging allocation represents a poorly prepared and

ineffective Local Plan which does not accord with the aspirations of the National Planning

Policy Framework.

Justified? 2.18 Excluding the Trading Estate from the proposed allocation, thus maintaining the site as

Green Belt land, represents a poorly prepared and ineffective Local Plan. When

considering the justifications for continuing to keep the Trading Estate washed over by

the Green Belt it is correct to assess the site against the five purposes of the Green Belt

as set out in Paragraph 80 of the Framework.

� To check the unrestricted sprawl of large built-up areas;

The site, due to its industrial history, is set away from existing built form of Bunny

or other nearby settlements, namely Gotham, Bradmore, Costock and East

Leake. The site is a brownfield site with existing buildings present. Development

of the site would not significantly encroach into the Green Belt or result in

unrestricted sprawl of large built-up areas. It would simply allow the opportunity

to invest and redevelop the existing brownfield site to deliver additional jobs.

� To prevent neighbouring towns merging into one another;

The site is well contained with strong defensible boundaries. As no new

development is proposed beyond the existing boundary of the employment site

the redevelopment of the site will not result in towns merging.

� To assist in safeguarding the countryside from encroachment;

The site is entirely brownfield land. The allocation of the entire employment site

allows the opportunity of a comprehensive redevelopment of the site to make the

most efficient use of the land and so reduce pressure on other potential

greenfield sites in the Borough.

� To preserve the setting and special character of historic towns; and



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There are no listed buildings or heritage assets in close proximity to the site and

so the sensitive redevelopment of the site will have a positive impact on the local

environment and landscape.

� To assist in urban regeneration, by encouraging the recycling of derelict and

other urban land.

It is necessary to remove the entire site not just the Brickworks from the Green

Belt to allow the landowner a more flexible planning policy context to invest and

redevelop the site to maximise the potential development opportunity of this

brownfield site.

2.19 As can be seen, the site does not fulfil any of the five purposes of the Green Belt. The

site is entirely brownfield land with a number of existing buildings on-site.

Effective 2.20 The Bunny Trading Estate has achieved considerable and sustained success and

growth since the current landowner took over the site in 2010. In this regard, the Trading

Estate have maximised their existing built assets and are at capacity. In order to continue

the sustainable growth of the Trading Estate an expansion of facilities is required.

2.21 By excluding the Trading Estate from being within the boundary of Policy 23 the

emerging Local Plan is considered to be ineffective at meeting the needs of a successful

rural enterprise.

Consistent with national policy? 2.22 The aspiration to maintain and create investment and new employment opportunities is

wholly consistent with national planning policy, specifically Paragraph 18 of the

Framework which states that the Government is committed to securing economic growth

in order to create jobs and prosperity. Likewise, the Core Strategy, at Policy 5 seeks to

strengthen and diversify the economy and provide new floorspace across all

employment sectors to meet restructuring, modernisation and inward investment needs.

Allowing Bunny Trading Estate to grow and modernise by insetting it from the Green Belt

will help meet the aspirations of Policy 5.

2.23 As such, it is not considered that the Local Plan Publication Draft is consistent with the

aspirations of the National Planning Policy Framework.



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2.24 The Framework (paragraph 19) states that the Government is committed to ensuring

that the planning system does everything it can to support sustainable economic growth.

2.25 The emerging Local Plan fails to accord with Paragraph 20, which states:

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.

The Bunny Trading Estate has a clear identified need to renovate and expand within the

confines of the land under their ownership and the Council should respond proactively

and provide support in the emerging Local Plan.

2.26 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.

2.27 The Framework (paragraph 21) states that Local Planning Authorities should support

existing business sectors, taking account of whether they are expanding or contracting

and, where possible, identify and plan for new or emerging sectors likely to locate in their

areas. Policies should be flexible enough to accommodate needs not anticipated in the

plan and to allow a rapid response to changes in economic circumstances.



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3.0 THE CHANGES WE CONSIDER NECESSARY IN ORDER TO MAKE THE PLAN SOUND

3.1 This section of the supporting Statement responds to Question 7 of the Representation

Form by stating what changes we consider necessary to make the Local Plan legally

compliant and / or sound.

3.2 In order to make the Plan sound we believe that the Council should integrate the Bunny

Trading Estate within the boundary of the proposed allocation under emerging Policy 23


3.3 This will allow the Trading Estate to sustainably expand in line with the growth and

ongoing success of the business since the current landowner occupied the site in 2010.

The Trading Estate would serve as a logical extension to the proposed allocation and

would be congruous with the mixed-use development of the site.

3.4 It is considered wholly logical to extend the proposed allocation under emerging Policy

23 to incorporate Bunny Trading Estate, in order to widen employment opportunities on

the site and maximise the development opportunities on the brownfield site.

3.5 The Trading Estate does not serve any of the 5 purposes of the Green Belt. In particular,

no new development would extend beyond the established, permanent and defensible

boundary of the Trading Estate. It is not necessary to keep the Trading Estate ‘open’.

3.6 The landowner is willing to continue to invest in the site which would be extremely

beneficial to the proposed redevelopment of Bunny Brickworks so that the neighbouring

land uses are compatible and result in a satisfactory residential environment for future

residents and employees.

3.7 The Site Location Plan (fig 4) on page 13 in the Site-Specific Assessment section of this

supporting Statement shows the existing boundary and the boundary as proposed

inclusive of the Bunny Trading Estate.

3.8 The Council’s verbal justification in respect to ‘extending into the Green Belt’ does not

make sense from a planning perspective. The Trading Estate in question is already in

operation as a brownfield site. Future development allows for opportunities to improve

the quality of the built form on the brownfield site.



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4.0 SITE SPECIFIC ASSESSMENT

Site Context 4.1 Bunny is located approximately 10km to the south of Nottingham, approximately 3.8km

north-east of East Leake and approximately 14km east of East Midlands Airport.

4.2 The representation site comprises approximately 2.3ha of entirely brownfield land to the

south of Gotham Lane to the south of the village of Bunny (see fig 6 below for site

location in the wider Bunny context).

Fig 6: Site location in the wider Bunny context (site edged in red, proposed allocation edged in blue)

4.3 Whilst Bunny has not been considered as one of the ‘other villages’ identified as

potentially suitable for a limited level of new housing development, it is acknowledged in

the emerging Local Plan that in order to support the regeneration of the former Bunny

Brickworks site the inclusion of housing and employment is considered sustainable.



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Fig 7: Site Location Plan (Site edged in red, proposed allocation under emerging Policy 23 edged in blue)

4.4 The site subject to this representation (edged in red on figure 7) is an operating and

successful Trading Estate. In this regard, there are currently 4 businesses operating

from the site. They are as follows:

� Bridgford Pressing – Specialist engineering works, employing skilled and semi-

skilled engineers;

� Fine Finish Furniture – Employing designers, skilled wood machinists, fitters and

wood polishers;

� Hawton Civils – Specialist ground workers;

� Bunny Appliance Warehouse (main tenants of the Trading Estate) – Mixture of



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skilled and semi-skilled workers, currently employing 28 drivers for the delivery

of goods around the country.

4.5 There are a several services and facilities in Bunny including a Primary School, a

Church, a Village Hall, a pub and several bus stops which are located along the A60

Loughborough Road, which leads on from Gotham Lane. These bus stops are served

by buses which run approximately half-hourly between Nottingham and Loughborough.

Bunny is well placed to take advantage of the wider strategic highway network through

access to the M1 approximately 10.5km to the west. The nearest train station is the East

Midlands Parkway, located some 7.9km to the west of the representation site, with

regular services south to London St Pancras and Leicester, and north to Derby,

Nottingham and Sheffield.

4.6 The drivers who are employed by the Bunny Appliance Warehouse utilise the existing

arterial route to the M1 along the main British Gypsum route

Site Specifics 4.7 The site adjoins the western boundary of the proposed allocation under emerging Policy

23 ‘Redevelopment of Bunny Brickworks’.

4.8 The following photographs illustrate the nature of the current site, and show the

significant visual improvement made by the site clearance undertaken by the landowner

(refer to figs 1 and 2 for context):

Fig 8: Bunny Trading Estate looking south-west from the proposed allocation site



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Fig 9: Bunny Trading Estate pic 2




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Access 4.9 Access to the site is currently taken at two separate points off Gotham Lane.

4.10 The site currently receives 25 plus large vehicle (at least 18 tons) movements a day.

These vehicles use the access roads created for British Gypsum at East Leake in order

to avoid other nearby settlements.

4.11 Gotham Lane is defined as a National Trail/Long Distance Route (Midshires Way). The

inclusion of the site within the proposed allocation under emerging Policy 23 would not

detrimentally impact this Public Right of Way.

4.12 There are no PRoWs which traverse the site itself.

Proximity to Local Facilities 4.13 The distance people need to travel in order to reach employment, facilities and services

will inevitably affect the mode of travel and subsequently the sustainability of a location.

Paragraph 30 of the Framework states that Local Planning Authorities should support a



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pattern of development which, where reasonable to do so, facilitates the use of

sustainable modes of transport. The number 863 bus runs two-hourly to nearby East

Leake providing access to the services and facilities of the settlement.

4.14 In this regard, the site is located within close distance to bus stops with services to

Loughborough, Keyworth, Ruddington and Nottingham, enabling sustainable methods

of connection to wider transport links. The settlement of Bunny is also within walking

distance of the Trading Estate. As such the site is accessible by public transport and

people working at the Estate will have sustainable travel options.

4.15 A number of staff who work at the Trading Estate live in neighbouring villages and elect

to travel to work by public transport, with others choosing to cycle or walk and utilise the

pavement opposite the main entrance to the site in order to access the Trading Estate.

Topography 4.16 The site is largely flat. It is therefore considered development of the site is not

constrained by topography.

Heritage/Archaeological Impact 4.17 The site is not within a Conservation Area. There are no listed buildings or other defined

heritage assets within the boundary or in close proximity to the site.

Landscape/Visual Impact 4.18 In July 2017, Rushcliffe Borough Council appointed AECOM to undertake a Landscape

and Visual Analysis (‘LVA’) of potential development sites. Each site was assessed for

both its impact on the landscape and its visual impact; reflected in a score for each which

is combined to give an overall score of sensitivity.

4.19 The adjacent allocation under emerging Policy 23 is referenced as RBC/BUN/001 in the

LVA. The analysis concluded that:

‘The site is situated on the southern edge of the village of Bunny, adjacent to a landfill

site and Bunny Trading Estate, as well as a line of housing. The site includes an area of

TPO and slopes gently up towards the south. Within the study area, there is a low

landscape value due to the degraded and industrial character of the site's immediate

surroundings. The landscape susceptibility is medium as the site would form a block of

development and have a perceived increase in density on the sparsely populated village



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edge. Overall the landscape sensitivity is low. There is very limited visual value

associated with the site, as well as a low visual susceptibility arising from the dense

vegetation on the site boundaries, which currently screens it from view. The visual

sensitivity is overall low.’

4.20 Considering the assessments conclusion that the overall visual sensitivity of the site

immediately adjacent is low, it is considered that any further development of the site

would not result in a significant detrimental landscape and visual impacts.

Flood Risk/Drainage 4.21 The site is located in Flood Zone 1 (low risk) as illustrated in the Environment Agency’s

online flood map records (see fig 14). There are no known drainage constraints which

would form insurmountable barriers to the delivery of this site subject to detailed design

and consideration of infrastructure capacity.

Fig 14: Environment Agency Flood Map results

Ecology/Trees 4.22 There are no known natural environment constraints which is reflective of the site being

in active use as a Trading Estate.

Material Planning Policy Considerations 4.23 The site is currently located within Green Belt. However, as noted above it is not



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considered that the land serves any of the five purposes of the Green Belt as defined in

the National Planning Policy Framework.

Capacity 4.24 The representation site area is approximately 2.3 hectares. The landowner would like to

invest in the site to renovate and create additional floorspace and create new jobs but is

restricted by current Green Belt policy.

Fig 15: Proposed built form at the Bunny Trading Estate

4.25 The site area of Bunny Trading Estate is currently underutilised and there is the

opportunity to construct new buildings to the west and south of the existing main building,

within the curtilage of the existing Trading Estate. It is critical to the ongoing success of

the Trading Estate that additional space is provided so tenants currently onsite have

expansion space to rent as their businesses grow. If additional space is not provided

there is the risk that existing tenants could be forced to relocate potentially outside of the

Borough.

4.26 Accordingly, the site should be included within the wider proposed allocation under

emerging Policy 23, so a comprehensive redevelopment of the site can come forward

which is sympathetic to existing and future residents and businesses.



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Suitability, Availability, Achievability

Suitability 4.27 This section of the representation has demonstrated that the site is not known to be

unduly constrained in terms of topography, ecology, flood risk, or heritage.

4.28 The Trading Estate would make a logical and congruent extension to the proposed

allocation under emerging Policy 23.

Availability 4.29 The site is available for development now with funding in place to invest in the site

immediately.

Achievability 4.30 The site is a brownfield site which has historically been associated with the now-cleared

Bunny Brickworks site (proposed site allocation under emerging Policy 23)

4.31 The site is not known to be unduly constrained in terms of topography, ecology, flood

risk, or heritage.

4.32 There are no known development constraints requiring extensive mitigation. The site is

therefore considered to be achievable in terms of viability.

4.33 The site is in single ownership and so not constrained by any ownership issues and as

such is deliverable.



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5.0 CONCLUSION

5.1 This supporting Statement provides a representation submitted to the Rushcliffe

Borough Council Publication Version draft consultation on behalf of Bunny Appliance

Warehouse Ltd in respect of the Bunny Trading Estate, Bunny.

5.2 The Council have failed to prepare the Plan in a sound fashion by not including the

Bunny Trading Estate within the boundary of the proposed mixed-use allocation under

emerging Policy 23 ‘Redevelopment of Bunny Brickworks’.

5.3 The Bunny Trading Estate is a successful business which has experienced consistent

growth since the current landowner occupied the site in 2010. Previous to that, the site

had been left in a visually undesirable state by the previous owner, requiring a significant

investment to clear the site.

5.4 Renovation and expansion is now required to enable the business to continue to operate

and grow, and there is concern amongst the landowner and the current tenants alike

that without being able to expand within the confines of the site (as defined in the Site

Location Plan) that they will be forced to leave Bunny, and quite possibly leave the

Borough too.

5.5 The Trading Estate would make a logical and congruent extension to the proposed

allocation under emerging Policy 23 and would be harmonious with the forthcoming

mixed-use development of the former Bunny Brickworks site.

5.6 As such, this representation therefore seeks to:

� Include the Bunny Trading Estate, as outlined in the Site Location Plan, within the boundary of the proposed mixed-use allocation under emerging Policy 23 ‘Redevelopment of Bunny Brickworks’.

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