The South Swindon Protection Group, representing over 600 Swindon residents, submits its formal objection to the Inlands Farm development. John Warr says "we are pleased that over 500 residents and 23 statutory consultees have already sent in objections to the proposed Science Park. Our objection, will provide extra weight in dismantling the economic case for this development and exposing this application for what it is. A speculative application on a site that didn’t even qualify for consideration in Swindon’s local plan and on planning grounds alone should be dismissed out of hand". The SSPG is supportive of economic growth in Swindon and wish Wasdell all success in growing its business on one of the plethora of suitable sites already earmarked for development in the 2036 local plan.
Below is full text our objection submitted today on behalf of its 600 resident members.
The South Swindon Protection Group, which represents the views of over 600 Swindon residents, provided a lengthy objection letter on the first application dated 31st January 2019. The objections raised then still stand, together with some additional concerns the revised proposal has raised.
We will therefore focus this further objection letter to cover the additional points arising from the revised submission. Please take it as read that SSPG fully supports the reasons for objection raised by our consultants Andy Rollinson and Dr Malcolm Parry.
SSPG Position Overview
In essence, the site remains outside the development boundaries of the Local Plan to 2036, which provides ample land for industrial and commercial purposes in the Swindon area.
We would remind you that the SHELAA process reviewed and expressly excluded this site from possible inclusion within the Local Plan as it was unviable and contravenes core planning policies. Granting approval to this application now would call into question the purpose of having any planning process, and usher in open season on similarly flawed applications throughout the Swindon area.
This proposed site contravenes your planning policies for non-coalescence and developments in the setting of an Area of Outstanding Natural Beauty. We find it something of a planning trojan horse, an opportunistic, speculative development from an applicant who will not even put their name as primary occupiers of the proposed development.
We were frankly askance to note in their letter to you dated 24th April 2020, from Turley, acting for the applicant, fully accepted that the development contravenes planning policy, but nevertheless urged that this application be considered on the grounds of “planning balance”, with supposed (but unspecified) economic benefits “demonstrably” outweighing any harm. This strikes the SSPG as an astonishing basis for a development proposal that undermines the validity of the entire planning process.
You will appreciate our natural concern that the economic benefits claimed are not able to receive the same level of scrutiny and would urge that simply taking the applicant at their word that they are “demonstrable” should not be accepted.
We have full confidence that your planning team will look closely at this scheme and consider all aspects of the development in terms of its adherence to policy and impact it may have on the heritage, landscape, traffic and other standard criteria and make sound observations and recommendations.
We urge you to apply the same rigour is addressing the applicant’s claims on benefit so that a properly informed decision can be made. To assist here are some pointers that we feel should be fully investigated and have been highlighted in other submissions.
Claim1: The Science Park will provide a direct wage expenditure that equates to £22.4 million p.a.
SSPG: Wasdell does not have the capacity, capability, commitment, funding or gravitas to set up a Science Park. We urge that before considering this application a full assessment should be undertaken on the viability of a Swindon Science Park, as per the criteria laid out by Dr Parry in his report under section 39.
It is by no means a given that granting permission for this development will deliver a fully operational Science Park, let alone that it will generate consequential direct wage expenditure of £22.4 million per annum (equivalent to around 350 highly skilled jobholders).
As Dr Parry explains in his review of the CamSci Report, on which these claims are based, state that to be a successful Science Park, you need a “critical mass and collaboration benefits alongside dedicated infrastructure”. So building a Science Park in itself is not a recipe for success. Dr Parry goes on to illustrate that to achieve the “critical mass” you need a locally established, world class major research institution and/or a large science-based university or government research facility to act as the host company that wishes to collaborate and share knowledge with locally based “R&D” focussed start-ups. Analysis of UK based Science Parks by UKSPA indicates that for Swindon to have a successful Science Park on the scale proposed, it needs to successfully attract collaboration with around 51 R&D-focussed companies located within 5 miles of Swindon, or 104 from within 30 miles.
Even if the host hub and the talent pool needed to make it successful existed, the setting up of a Science Park requires a huge investment that cannot be delivered without considerable regional or national support. Just to kit a Science Park on this scale, with the appropriate level of laboratory research facilities is estimated to cost between £30m - £50m. This is before taking into account direct operational costs, rental subsidies and grants to help start-ups get established. Setting up a Science Park is a high risk strategy to achieve economic success.
The CamSci report is careful to apply a disclaimer that it does not endorse Wasdell as a suitable anchor tenant; it simply takes Wasdell’s word for it. Wasdell is a packaging and distribution company for pharmaceutical products, it cannot remotely boast the necessary level of R&D as its primary business that this designation would demand; it does not possess more than the most basic of research facilities.
The Science Park is unable to be realised, and in any event would be subject to unproven demand.
WebbPaton was commissioned to find a suitable site for a Science Park, as confirmed in its opening statements of its submitted report. Any Science Park location had to meet all mandatory requirements; these requirements simply do not stand up to any scrutiny in this proposal.
The analysis by Dr Parry shows that close proximity to a town centre or major road network is not part of any “critical mass” criteria and in fact most UK Science Parks are more than 15 minutes from their local town centre or major road network. There is no requirement that a Science Park has to be within 15 minutes of a town centre or a major road network as claimed.
Similarly the insistence that it must be operational by 2021 is absurd. As Dr Parry has demonstrated it can take 30 years to establish a Science Park and even with critical mass conditions in place the minimum is 5 years.
We urge the analysis by WebbPaton be disregarded as neither credible nor relevant to this application.
We further urge your team to note a nearby model, in complete contrast: Porton Science Park, sponsored by Wiltshire Council and with Porton Down and PHE as its anchor tenants, has the ability to attract a talent pool; with the benefit of over £20m of public investment and after 5 years, it now boasts the creation of 100 new jobs.
Claim 2: Moving Wasdell to a single site will deliver huge economic benefits, including job creation.
SSPG: We urge that you take into account a full economic benefit analysis on a relocation of Wasdell’s Swindon operation before considering this application further.
There is no “planning balance” to be considered and the scheme should be judged purely in terms of planning policy.
Another strand of the economic benefits of this development is the assertion that relocating Wasdell to a single site will deliver huge economic benefits for Swindon. Turley and the applicant they represent avoid direct claims on employment gains in Phase 1 and major more on benefits from a Science Park in Phase 2, which are tougher to quantify beyond mere speculation.
However full planning application is being sought for Phase 1, whilst the ‘Science Park’ is an outline application and is “subject to demand”. So any decision to override planning policy using the “balance” of economic gain needs to be proven for “phase 1”.
The applicant’s media release of 21st April 2020 clearly states that it is “looking to locate all our Swindon business on one site”. This suggests they have no plans to relocate their Burnley manufacturing operation or close their International Warehousing and Distribution centre set up in Dublin. So any economic benefits would need to be realised purely through the relocation of their three Swindon sites.
As you will have noted from the supporting comments submitted from existing employees, the workforce largely lives in Central and West Swindon. Published accounts confirm that the majority of the workforce (83%) are classified “Labour” and the remainder “Admin”, with an average salary of £22,500: i.e. the majority of their workforce is unskilled.
The Phase 1 development is clearly designed as a modern Warehouse and Distribution centre, consistent with the company’s operations. In closing the three Swindon sites and relocating to a site in North Swindon, with poor public transport, the jobs of low skilled workers must be deemed at risk.
The applicant is a highly successful commercial operator and has grown by investing in technology, whilst reducing their staffing costs. A modern, state-of-the-art Warehousing and Distribution facility is highly automated, making full use of robotics.
Taken together it is clear that this relocation to one site would be used as an opportunity for Wasdell to consolidate their operation and lead to a net loss of jobs.
This would be worsened by the impact on local employment close to the proposed development. The Ridgeway villages support jobs in the equestrian, hospitality and leisure industries. Many have indicated that the siting of this development so close to these rural communities will force some of the businesses to close, potentially causing the loss of 100 further jobs.
This development risks undermining the viability of the NEV with consequential economic impacts.
In conclusion we urge the council to carry out a full economic benefits analysis, looking at the impact on jobs through a relocation, on the local economy and viability of the NEV.
We are assuming of course that the claimed “economic benefits” would come about if Wasdell were to occupy the proposed site. However Wasdell have again in their letter to you of the 24th April re-affirmed this is not a personal application and Wasdell are not even committing to this site. In addition to the above economic flaws in the proposal, this alone negates as irrelevant any economic benefit that may be attributed to their relocation. They cannot have it both ways.
Claim 3: The planned use of this development is designated as B8 class.
SSPG: We urge you to consider rejecting this application on that mis-definition of class usage or insist the applicant reconsiders its design.
We note that the design for Phase 1 has not materially changed in the re-submission. The changes are cosmetic, and no amount of landscaping or colours schemes can hide a 14.5m high 33,500 m2 building abutting an Area of Outstanding Natural Beauty.
The layout still includes 12m high racking and storage over 85% of its floor space and includes 6 loading bays and lorry facilities and is designed to operate 24x7.
We note in the submission that the applicant maintains that the Phase 1 building will be consistent with B1C light industrial use and will not be used as is clearly designed and consistent with their business model, as a Warehouse and Distribution centre, which is a B8 class use.
B8 class use is prohibited in close proximity to residential properties. We urge your team considers rejecting this application or suggests that the applicant reconsiders its design. Otherwise you would become obliged to raise the financial risk to SBC of enforcement action and potential legal challenges if the building were to be used as designed and operated by the occupier as a warehouse and distribution centre.
Claim 4: The applicant maintains there are no other suitable sites for its operation.
SSPG: The 2036 Local Plan includes provision of 77.5 hectares of employment land, which makes ample provision for the commercial/industrial needs of the Swindon area, and already includes several other suitable sites.
We congratulate and fully endorse the Council’s effort to try and accommodate the needs of this employer, including helping them with a possible location to a new site at Wichelstowe, close to the M4.
As we have already highlighted, the Science Park is unable to be realised, and in any event is subject to demand. This analysis by WebbPaton should be disregarded and is not relevant to this application.
This proposal makes a lengthy list of requirements tailored to the applicant’s own needs, even though the applicant has not put itself forward as the likely lead occupier of this development, which renders their specific requirements irrelevant.
Extending them the courtesy of addressing its stated requirements nevertheless, all of these are able to be satisfied by the alternative sites available bar one: Wasdell’s desire for it to be freehold. The SSPG is utterly dismissive of the aspiration to make this nothing more than a speculative investment; financial gain of that sort should not feature in the planning considerations for a development of this type.
Claim 5: The applicant maintains this location is the only one to meet their requirements.
SSPG: As established in the foregoing, the applicant’s requirement is for a single Warehousing and Distribution centre. The application should be considered on planning merits for Phase 1 alone.
Given the bizarre situation where there is no guarantee that the occupier will be the applicant, any balancing economic benefit cannot be considered as part of this application and should be rejected. The proposal should be referred to the economic panel for consideration as part of the new Local Plan, where the economic benefits around this application can receive proper scrutiny.
Even Turley, acting on behalf of the applicant, has acknowledged that this proposal falls outside the normal planning requirements.
For our detailed position on the suitability of this application in Phase I, we refer you to all our previously documented objections which are echoed in the hundreds of other public and statutory consultees’ comments. Again we remind you that there are several alternative sites already provisioned for in the new local plan, including Wichelstowe, Symmetry park and in the near future the Honda site.
The changes made to this revamped application are merely cosmetic; it remains a deeply flawed case for development:
For all these myriad reasons, in conclusion the SSPG respectfully urges the Planning Team to reject this unnecessary, deeply flawed and potentially damaging proposal.
Chair, South Swindon Protection Group
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Action Group opposed to the development of land in the non coalescent area or joining the AONB in the South Swindon Area
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