Question 6
There should be clear environment and sustainability standards for commercial development including: Energy and water efficiency Renewable energy on site production Access by sustainable transport Quality layouts – landscaping, green space, biodiversity (resulting in net biodiversity and net environmental gain) Adequate water resources and water treatment facilities, Facilities to support electric vehicles
There would appear to be no areas to support significant employment or housing growth in or around LS
As stated in the opening paragraph we regard this as baseless aspiration given the fundamental changes to work patterns now clearly in train.
Focusing employment, alongside wider strategically important development has the potential to capture the economic benefits that will arise with the Oxford Cambridge Arc. However, it is also important to consider how more indigenous growth can increase the value of the economy in the Borough, not just at Bedford but also at other settlements, particularly in close proximity to Bedford on corridors between Bedford and other key settlements which are important to the economy of the Borough. This underscores the importance of decisions, not only for locating employment land but also for opportunities for home working and community focused co-working hubs.
6.1 The areas close to key transport corridors are the logical locations for additional employment growth in Bedford Borough. This includes the corridors along the A421 and A1 and close to new railway stations. 6.2 Land west of Wyboston is therefore ideally located to accommodate an element of employment land as part of a sustainable settlement. The type and amount of employment floorspace would need to be considered in more detail as part of the evolution of the settlement and the suitability and availability of opportunities elsewhere in the Borough, but there could be scope for a technology park, which we understand is a desire of the Council, or more locally orientated opportunities, possibly logistics benefiting from access to the A1. 6.3 The aspirations for the Arc are largely predicated on the economic potential of the area driven by the world class universities in Oxford and Cambridge. In this regard, it needs to be recognised that as well as creating employment opportunities in the Borough, the overall development strategy has to consider the fact that a large proportion of new residents will commute out of the area to work, particularly to Cambridge given its proximity. 6.4 Again, this supports residential development in the area west of Wyboston from where Cambridge will be accessible by both road and rail within the plan period.
Main employment areas should be located in vales – eg Marston Vale, where road network is good. Avoid major buildings on Manton Heights- where very intrusive. Scope for small specialist development close to the A421 eg at Renhold or at Willington and Cople. In villages barn conversions or use of brownfield land can be valuable for small scale businesses. Scope to expand employment in large villages such as Oakley, Sharnbrook re A6 and rail.
7.1 In relation to specific locations or requirements for employment growth, we reserve our position to consider specific policy proposals as part of subsequent stages of consultation. 7.2 In relation to the Plan’s strategic priorities and links with the wider sub-region it is, however, noted that the Council’s spatial options recognise the benefits of A421-based growth in terms of minimising journey times and facilitating sustainable access to a range of labour markets and opportunities for economic development, in particular our client’s site at High Barns Farm, Roxton.
Commercial development should be out of town, to bring life to the city centre
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth. The Council should also look for opportunities for existing employment sites to expand. This is an efficient way to increase economic growth and productivity and to provide more job opportunities and training. The Council should create planning policies which support the growth of existing businesses including those located within the rural area. These objectives are set out in Section 6 of the NPPF. Our client’s site at Land At Keysoe Road, Thurleigh which has been submitted through the Call For Sites process, is one such site which is available for expansion. This site is located in an established commercial area adjacent to Thurleigh Airfield and a demolition and reclamation yard. The site is previously developed, and can accommodate up to an additional 9ha of land for B1, B2, and B8 uses. The NPPF supports the use of previously developed land in the rural area for employment purposes and states that opportunities should be encouraged where they exist (Paragraph 84). Our clients site at Land South Of Goldington Road is also available for expansion. The site measures 14.3 ha and can accommodate mixed use development as well as a recreation and open space opportunity.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth. There should also be opportunities for existing employment sites to expand.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth.
It is considered that the location of new employment sites should correspond to the development strategy, ensuring that they are in accessible locations and well associated to the locations of growth.
The Issues and Options Paper identifies that new developments are coming to market at Wilstead Industrial estate in Wixams and Bedford link Logistics Park, west of Wixams on the A421. Building on these committed employment areas, the expansion of Wixams should be a key focal point for new residential development.
This depends on need, access to suitable markets, type of employment sites: distribution/logistics, service industry, high tech and the type of labour market required. Whilst it is suggested that the delivery of EWR will provide new opportunities for reversing current commuting flow, there may instead be significant out- commuting to Milton Keynes, Cambridge and other areas, with Bedford becoming a dormitory town. The provision of new sites would increase in-commuting but put further pressure on the highway network. New large scale employment sites should not be located in relatively isolated countryside and sensitive landscapes.
We consider land around Little Barford as a suitable site to accommodate employment growth. The proposals on drawings 068-001-004 (AL1), 068-001-005 (AL2), 068-001-006 (AL3) and 60830-PP-005 show an area to the north of Little Barford as an area for employment use filtering into an area of mixed-use development. This area to the north adjoins the existing Little Barford employment site designated by Policy 70 of the Local Plan 2030 as a key employment site. The policy explains, “The role and function of key employment sites which contribute to the economic function of the borough will be protected and further extension of employment uses and investment in premises will be supported.” The recently adopted local plan does not allocate new sites for employment because there was already enough land available that had not been occupied. However, that situation will change over this plan period up to 2040 and additional employment land will be required. As an extension to an existing employment area there is an opportunity for businesses similar to those currently operating from the site to cluster together. The site also benefits from access to St Neots and over the plan period will be benefit from the “potential EWR station St Neots/Sandy area” south of Little Barford which will provide access to both the north-south and east-west destination on the rail network. Page 27 of the Issues and Options consultation states, “Demand for buildings in Bedford with its excellent and growing transport links and proximity to other towns, including the capital within short journey times, will continue.” The site at Little Barford would deliver a site with immediate access to services in St Neots and any future development on the AL1, AL2, AL3 sites put forward as part of the call for sites process. Beyond the local context employment growth at Little Barford benefits from the improvements to transport links to neighbouring towns and further to Cambridge, London and Oxford.
On brown field sites close to town and out of town, and close to road network south of Bedford with sustainable transport options, developing existing businesses and new residential development along Western bypass. It really depends on the nature of the new employment, office, warehousing, logistics etc. In light of Covid 19 and the fact that more and more people are choosing to work from home, some town centre offices will soon be redundant and these should be developed first.
6.1 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations, should these form part of the future development strategy. 6.2 Development at Cotton End could provide additional employment land to support and compliment the existing businesses in the area, it is proposed that smaller units are provided to support the large businesses, in particular the Cardington Hangers and their use for film, TV, media, etc.. This employment area could be expanded on within close proximity to new homes and help facilitate growth in this sector. A smaller scale employment area would also provide variety in the market and encourage fledgling businesses to grow within the district. 6.3 It is important to ensure that a range of business units are provided within Bedford Borough to encourage a range of businesses. Employment areas should be well located to the existing road network as well as near high quality housing.
7.1 Employment land must be allocated alongside housing growth. This will promote sustainable growth. Bedford Borough is well located with a central position in close proximity to the major road and rail arteries of the country. Furthermore, it is close to a number of mayor cities and towns including London and is located in the centre of the Arc. It is therefore ideally placed for many businesses. In order to attract business, it is important that the employment premises are fit for purpose, but also that there is appropriate infrastructure including transport links, services and facilities that support the workforce. 7.2 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations, should these form part of the future development strategy. 7.3 Development at Roxton is ideally located to the existing and proposed transport infrastructure. It is particularly suited to Storage and Distribution (Use Class B8) given the location. Furthermore, supporting services and facilities could be located within the site.
Ideally new employment sites should be located within cycling and even walking distance of housing developments to avoid the need for travel by car.
Offices should be in the town centre, ideally using brown-field sites; industrial/warehousing should be out of town (preferably not farmland) or on brown-field sites.
7.0 QUESTION 6 – LOCATIONS FOR EMPLOYMENT GROWTH 7.1 We consider that the Review of the Local Plan 2030 should be positively prepared in terms of assessing a range of opportunities to support economic development that are compatible with the different spatial options being assessed and capable of addressing requirements for future growth. 7.2 To ensure sufficient employment land is available to support housing growth, we would emphasise that when evaluating potential options for allocation and existing land use designations, consideration should be given to potential sites that could provide optimize opportunities for economic development in rural areas as well as potential infrastructure that would improve the delivery of employment sites. This would be in accord with national policy to support a prosperous rural economy (NPPF2019 paragraph 83) and consistent with opportunities for sustainable development as part of a ‘Dispersed’ spatial strategy. 7.3 As part of sustaining and enhancing the role of Key Service Centres and Rural Service Centres as well as meeting needs across the wider rural area it is important that existing and future opportunities for economic development are supported by the Plan’s policies. Increasing opportunities for economic development would further provide opportunities to reduce the need for travel and facilitate job creation alongside housing growth. 7.4 We would invite the Council’s Planning Policy Team to consider the previous site assessment findings for land within our client’s control when considering locations where job creation may be supported. In the case of our client’s Land adjacent to Highfield Road, Oakley and Land off Rushen Road, Milton Ernest both sites were considered favourably in the Council’s assessment of sites. The Council’s 2018 SHELAA records both sites as having the potential for employment as its primary use and would be suitable, available, and achievable for development. 7.5 These conclusions remain entirely valid in the context of the role of Oakley and Milton Ernest and specific planning considerations regarding our client’s land that provide opportunities to accommodate the Borough’s growth 7.6 In relation to our client’s land adjacent to Highfield Road, Oakley, the site is considered suitable for a high calibre employment site (across the B1/B2/B8 Use Classes at a scale appropriate to the local area). The site offers an opportunity for the consolidation of the existing employment development on Highfield Road, which was purpose built and offers arrange of ‘mid-size’ units for a range of ‘B’ type uses. Policy BE1 of the Oakley Neighbourhood Plan provides support for a range of B1/B2/B8 uses within the existing Highfield Park. 7.7 The site is contained by existing development comprising the Midland Main Railway Line, existing housing, employment uses and the A6 Clapham Bypass. This contained setting would result in development appearing as a logical extension to Oakley and can also benefit from appropriate landscaping to mitigate impacts upon rural character and separation with Clapham to the south and east. The site has the capacity to accommodate approximately 3ha of employment development and offers an opportunity for innovative design and job creation. 7.8 Our client’s Land at Rushden Road, Milton Ernest comprises a part-previously developed site that is well-related to the existing settlement area and with part of the site area in existing commercial use. Allocation of this area for employment uses together with an opportunity to increase opportunities for additional floorspace and job creation and would complement the existing role of the site. It is therefore requested that based on the above examples the Review of the Local Plan 2030 provides an enhanced range of policies and allocations to support economic development in the rural area.
7.1 We consider that the Review of the Local Plan 2030 should be positively prepared in terms of assessing a range of opportunities to support economic development that are compatible with the different spatial options being assessed and capable of addressing requirements for future growth. 7.2 To ensure sufficient employment land is available to support housing growth, we would emphasise that when evaluating potential options for allocation and existing land use designations, consideration should be given to potential sites that could provide optimize opportunities for economic development in rural areas as well as potential infrastructure that would improve the delivery of employment sites. This would be in accord with national policy to support a prosperous rural economy (NPPF2019 paragraph 83) and consistent with opportunities for sustainable development as part of a ‘Dispersed’ spatial strategy. 7.3 As part of sustaining and enhancing the role of Key Service Centres and Rural Service Centres as well as meeting needs across the wider rural area it is important that existing and future opportunities for economic development are supported by the Plan’s policies. Increasing opportunities for economic development would further provide opportunities to reduce the need for travel and facilitate job creation alongside housing growth. 7.4 We would invite the Council’s Planning Policy Team to consider the previous site assessment findings for land within our client’s control when considering locations where job creation may be supported. In the case of our client’s Land adjacent to Highfield Road, Oakley and Land off Rushen Road, Milton Ernest both sites were considered favourably in the Council’s assessment of sites. The Council’s 2018 SHELAA records both sites as having the potential for employment as its primary use and would be suitable, available, and achievable for development. 7.5 These conclusions remain entirely valid in the context of the role of Oakley and Milton Ernest and specific planning considerations regarding our client’s land that provide opportunities to accommodate the Borough’s growth 7.6 In relation to our client’s land adjacent to Highfield Road, Oakley, the site is considered suitable for a high calibre employment site (across the B1/B2/B8 Use Classes at a scale appropriate to the local area). The site offers an opportunity for the consolidation of the existing employment development on Highfield Road, which was purpose built and offers arrange of ‘mid-size’ units for a range of ‘B’ type uses. Policy BE1 of the Oakley Neighbourhood Plan provides support for a range of B1/B2/B8 uses within the existing Highfield Park. 7.7 The site is contained by existing development comprising the Midland Main Railway Line, existing housing, employment uses and the A6 Clapham Bypass. This contained setting would result in development appearing as a logical extension to Oakley and can also benefit from appropriate landscaping to mitigate impacts upon rural character and separation with Clapham to the south and east. The site has the capacity to accommodate approximately 3ha of employment development and offers an opportunity for innovative design and job creation. 7.8 Our client’s Land at Rushden Road, Milton Ernest comprises a part-previously developed site that is well-related to the existing settlement area and with part of the site area in existing commercial use. Allocation of this area for employment uses together with an opportunity to increase opportunities for additional floorspace and job creation and would complement the existing role of the site. It is therefore requested that based on the above examples the Review of the Local Plan 2030 provides an enhanced range of policies and allocations to support economic development in the rural area. BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 31 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission 8.0 QUESTION 7 – ROLE OF THE OXFORD-CAMBRIDGE ARC 8.1 The response to this question should be read alongside or overall observations regarding the spatial options identified by the Council under Question 4. The role of the Oxford-Cambridge Arc is supported in terms of identifying and delivering the priorities for plan-making. However, the Arc itself is not specifically referred to in the text of Policy 1 and does not appear to be identified as part of the assessment criteria for the emerging Plan’s Sustainability Objectives. This reflects the continued uncertainties regarding delivery of growth across the wider sub-region and features such as the Expressway. 8.2 In this respect there has been only limited progress compared to the Council’s conclusions when preparing the Local Plan 2030. This acknowledged the uncertainty of planning for the wider corridor and while it was anticipated that future decisions would align with the timescales for this Review this cannot be guaranteed. Testing of options to meet full development needs should not be further constrained by these outstanding uncertainties. 8.3 It is appropriate that the strategy for the Review of the Local Plan 2030 capitalises on those existing commitments for infrastructure improvements (including the A421 corridor) as well as meeting the needs of individual settlements and enhancing the role of Bedford. This would ensure that the Plans priorities are delivered rather than deferred (as is the case in the Local Plan 2030) while remaining consistent with longer-term objectives for the corridor.
7.1 We have no comments at this time in relation to specific locations or requirements for employment growth but reserve our position to consider specific policy proposals as part of subsequent stages of consultation. 7.2 In relation to the Plan’s strategic priorities and links with the wider sub-region it is, however, noted that the Council’s spatial options recognise the benefits of A421-based growth in terms of minimising journey times and facilitating sustainable access to a range of labour markets and opportunities for economic development.
7.1 The A421 corridor is the logical location for additional employment growth in Bedford Borough, as well as close to new rail stations, should these form part of the future development strategy. 7.2 The Local Plan Review should though recognise that many residents of Bedford Borough travel outside of the Borough for work, especially given the proximity to major employment centres such as Cambridge and Milton Keynes and the ability to reach London via train. It is therefore important that the overall development strategy recognises that many residents will travel for work and that the allocation of residential development land needs to reflect this. 7.3 Therefore, sites such as that at Bedford Police HQ, with good access to the A421 and also good public transport into Bedford rail station, are ideal for allocation with regards to access to employment opportunities not only locally but outside Bedford.
9.1 Paragraph 20 of the NPPF recognises that planning measures to address climate change are a strategic matter and should therefore be at the heart of decisions made in relation to the development strategy. 9.2 It is further added in paragraph 149 of the NPPF that a proactive approach to mitigating and adapting to climate change, taking into account the implications for matters such as flood risk and biodiversity, should be taken in Local Plans. 9.3 In line with the above, development should avoid areas which are more vulnerable to the impacts of climate change such as flood plain. Adaption measures should also be built into plans i.e. new blue and green infrastructure. New development should be located in close proximity to public transport infrastructure, whilst ensuring that there are opportunities for existing rural settlements to remain functioning with a range of services and facilities for residents. 9.4 Policy standards which are too specific, stating what is to be achieved by new development, should be avoided, unless they relate to the application of the Government’s technical standards as required by paragraph 150 of the NPPF. This because climate change policy and good practice is constantly changing. Climate change scenarios predict extensive changes by the end of the earliest plan period of 2040, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. As a result, Bedford Borough need to be able to adapt to innovation and changing legislation and have the flexibility to accommodate these changes within the lifetime of any planning documentation. 9.5 Also, allowing for changing technologies and approaches has the potential to help with viability as these areas develop and improve and are more widely adopted reducing costs.
7.1 As already noted, the A421 corridor is the logical location for additional employment growth in Bedford Borough. There may also be opportunities for employment growth close to new rail stations, should these form part of the future development strategy. 7.2 Recognition should be given that the many residents of Bedford Borough travel outside of the Borough for work, especially given the proximity to major employment centres such as Cambridge and Milton Keynes and the ability to reach London via train. 7.3 It is therefore important to ensure that not only are employment sites located in sustainable locations within the Borough, but that the overall development strategy, particularly the allocation of residential development land, recognises that many residents will travel for work. This means it is important the new homes are located in areas such as Willington and Wilstead, with good highway access and in close proximity to rail stations
On brown field sites close to town and out of town, and close to road network south of Bedford with sustainable transport options, developing existing businesses and new residential development along Western bypass. It really depends on the nature of the new employment, office, warehousing, logistics etc. In light of Covid 19 and the fact that more and more people are choosing to work from home, some town centre offices will soon be redundant and these should be developed first.