Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10311

Received: 29/07/2022

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

Representation Summary:

General Comments on EMP8
My client would like to note the following in relation to allocation EMP8 which they would welcome a
further review of:
- The Bedford Employment Land Study (May 2022) states that ‘the borough has in the last few years
had a number of high value business inward investments into larger industrial space for uses other
than warehousing and which would more suitably fit within a light industrial permission profile’. My
clients consider that in order to create flexibility in terms of what can come forward in allocation
EMP8, the policy should be amended to include ‘industrial’ as a potential end use alongside
‘warehousing and distribution’. It is noted that this provision is made in Allocation EMP7 and that
there is little to distinguish these sites in terms of nature and location.
- The Council could consider amending policy EMP8 and/or the proposals map in order to clarify the
site area that is proposed. The evidence base for this site (including the Call for Sites submission,
Site Assessment form and Regulation 18 representation) state that the site has an area of circa 22
hectares, however Policy EMP8 states that the site is 17 hectare employment site. It is noted that
difference is likely to reflect the fact that land on the eastern boundary of the site is being compulsory
purchased in order to facilitate improvements at the Black Cat roundabout and the surrounding
highway network. This leads to a discrepancy between the size of the site and the area identified for
the site on the proposals map. Whilst I do not think this affects the soundness of the plan, for clarity
and to allow comprehensive development of the site, it is best to retain the red line as currently
shown (i.e. around the full 22 hectare site) and clarify the position with appropriate wording in the
policy. If the Council are though to make any amendment to the red line, this should only remove the
area explicitly identified for CPO.
Given the location adjacent to two major highway routes, it is considered that there may be some
merit in the policy allowing roadside uses on the part of the site nearest the Black Cat roundabout. It
is noted that policy EMP7 makes reference to such a use and we consider that there is no material
reason why policy EMP8 could also not have this use built into the policy to allow flexibility for such a
use to come forward in the future if there is demand.
Conclusion
In conclusion, my client considers that the emerging Local Plan is sound, as per the tests of soundness
set out in paragraph 35 of the NPPF and would note that:
- There is a significant demand for and a need to create additional supply of warehouse and distribution
units in Bedford Borough and the surrounding area, justifying the allocation of land to meet this need.
- Bedford Borough have correctly sought to locate additional warehouse and distribution sites at key
road and infrastructure locations as part of their growth strategy, in keeping with national policy
expectations.
- Allocation EMP8 will help to meet identified warehouse and distribution needs and is located at a
strategically important location in the highways network in keeping with national policy.
- Allocation EMP8 represents a suitable site for warehouse and distribution uses, and remains
available for development.
- The Council should consider adding industrial and roadside uses to the allowed employment uses on
EMP8 to provide flexibility when developing this site, consistent with EMP7.