Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6187

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Representation Summary:

Policy E1S (Amount and Distribution of Employment Development) – Comment
2.1 The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended Plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
2.2 However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in Key Service Centres and Rural Service Centres. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
2.3 Our client’s site at Highfield Road, Oakley, would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters (including access, ecology, and landscape). these parameters would be satisfied.
2.4 Additionally, and should our client’s land not be allocated, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the expansion and intensification of existing safeguarded employment uses within suitably located adjacent sites.
2.5 Paragraph 6.12 of the Council’s consultation document is also noted with regards recent changes to the Use Classes Order. As well as amending policies within the existing LP2030 it is necessary that criteria (i) and (ii) of proposed Policy E1S also recognise that support for economic development in accordance with the strategy, and on unallocated sites, extends across Use Classes B2, B8 and Class E. Criteria (ii), as drafted, refers only to ‘B-uses’. It is not considered necessary for suitable opportunities to be limited only to ‘business’ uses within Class E as suggested by the Council’s paragraph 6.12.
2.6 This is contrary to the flexibility sought by the changes to the Use Classes Order. This approach is also ineffective, as it would not apply to existing lawful former B1 uses within existing employment areas would in most cases benefit from opportunities to provide a wider range of commercial uses under Permitted Development Rights. This could, for example, in principle allow a more diverse range of occupiers at the existing Highfield Park site, commensurate with its location well-related to the settlement of Oakley and wider transport network. The same flexibility should be applied to the Council’s policy criteria when assessing new development proposals.