Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10260

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

9. Employment
9.1 The Council generally supports the economic ambitions of Bedford Borough Council and recognises the desire to attract a variety of employment opportunities that span a range of sectors with jobs related to R&D, office and industrial, as well as strategic warehousing and distribution, which is in accordance with the plan vision and strategy to create a high-value, highly skilled, economy. It would have been helpful if individual maps had been included within the Submission consultation plan to clearly indicate the locations of the proposed allocations EMP1 to EMP8.
9.2 The Bedford Economic Growth Ambitions Topic Paper (April 2022) states that the allocation of employment land, and the attraction of non-B8 jobs as a result of policy intervention, would provide the opportunity for Bedford to develop a more balanced, productive and therefore higher value economy.
9.3 However, the proposals for 26,700 additional jobs on up to 142ha of land within the plan period, as set out within the Submission plan, is a significant increase from the 8,642 new jobs proposed in the Strategy Options and Draft Policies Consultation (Sept 2021). It is noted that the Borough Council have used the ORS employment growth forecast, derived from its population forecast and that the dwelling-led population growth scenario shows an increase in employment from about 87,800 in 2020 to about 114,500 in 2040, an increase of about 26,700 or 30%. Over the same period, the EEFM scenario shows an increase of only 15% to about 102,200 in 2040, some 12,300 fewer jobs.
9.4 Whilst CBC recognises the justification provided for the ambitious figure within the submission Local Plan and supporting technical documents, this is a substantial change which CBC had not been aware of until now. CBC may want to reflect on these figures further and through discussions with the Borough Council.
9.5 CBC would support the employment proposals set out within Policies EMP1 to EMP5 of the submission consultation plan, as they either make the best use of previously developed land or are immediately adjacent to existing employment and retail areas within the urban area of Bedford.

9.6 However, whilst it is understood why the Council would want to be ambitious in relation to economic growth, CBC considers that in relation to the proposed employment allocations outside of the main urban area, the Borough Council should more carefully consider the likely detrimental impacts on the strategic road network, as well as issues such as sustainable travel, accessibility of the location for future employers and employees, and out-commuting from areas such as Central Bedfordshire, especially given the close proximity of some of the proposed allocations to our administrative border.
9.7 The Council have significant concerns about the proposed employment allocations as set out within policies EMP6-EMP8 due to the likely impacts on the strategic road network as detailed at paragraphs 6.6 to 6.9 above in relation to the A1, Black Cat Junction and the A428, as well as the implications for Central Bedfordshire as noted above.
9.8 Central Bedfordshire therefore objects to Policies EMP6, EMP7 and EMP8 on the basis of our transport concerns as detailed above.
9.9 Further employment land is also identified to be allocated within the new settlements proposed at allocations HOU12 (South of Bedford) and HOU19 (Little Barford). Whilst CBC supports the delivery of mixed use sustainable developments, we do have some concerns about the proposed allocations, the impacts upon the strategic road network and the implications for Central Bedfordshire, as set out at paragraphs 6.1 to 6.9 above in relation to the A421 corridor, the A1, the Black Cat Junction and the A428.