Object

Site Assessment Pro Formas

Representation ID: 6508

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Representation Summary:

Introduction to Site and Proposals
3.1 The site was previously submitted to the Council for consideration as part of the Council’s ‘call for sites’ exercise in August 2020. The land area being promoted is shown below. [site plan inserted here]
3.2 The site, as submitted, extends to 1.4ha and is located immediately adjacent the northern edge of the built settlement.
3.3 The site comprises an active and successful existing employment use, assessed as such and identified for protection as part of the Council’s Part 2 Employment Land Topic Paper (Site BE20).
3.4 The Council’s assessment relates only to a smaller portion of the site (0.63ha) occupied by an existing industrial unit and office facility comprising for vehicle repairs and fleet logistics. Demand for uses at the site has and continues to intensify, with the Council’s own assessment noting - having regard to temporary extensions to workspace and vehicle parking – “the site may not be large enough to fully accommodate the uses, or may require built development to accommodate this.”
3.5 These representations seek to ensure that the emerging Local Plan 2040 supports the sustainable growth of the site in to maintain and increase opportunities for economic development in this location. This can be achieved through an extension in the area proposed for designation/allocation and policies to support the future expansion of floorspace at the site, in accordance with the Strategy’s settlement hierarchy and objectives for jobs growth.
3.6 The site is suitable served by an existing access from the A6 (Rushden Road). The site has no known environmental, ecological, or archaeological constraints that would inhibit development.
Response to Borough Council’s Site Assessment Pro-Forma (Site ID: 852)
Site Assessment Criteria
3.7 We have reviewed the Council’s assessment of the site and wish to make a number of comments below.
Within or adjoining the urban area or a defined settlement policy area boundary
3.8 The site adjoins the urban area or a settlement policy area (SPA), it therefore should be considered for development and predominantly comprises previously developed land in existing employment uses (or temporary uses associated with these). The land is well-related to the existing settlement and its expansion would be contained by the presence of further commercial floorspace lying to the north (at Protech Stainless Steel) beyond the existing settlement boundary. Designation of the full site area submitted in respect of our client’s interests is therefore appropriate and would proportionate to the scale of the settlement and would not extend beyond existing development.
Impact on designated or non-designated heritage assets or their setting
3.9 The Call for Site assessment found that the proposal has the potential to cause harm to heritage assets, which may range from low to high. This is a standard response that the Council has applied to a large number of the assessment pro-forma.
3.10 In this case our client’s land at Rushden Road there are no designated heritage assets within or in close proximity to the site.
3.11 There will be options to avoid, reduce or mitigate this harm and where sites have not been ruled out altogether for other reasons. In the case of our client’s land further assessment will be undertaken to more fully explore impacts on significance (including the contribution made by the setting of any affected assets) and to ensure that any impact would represent less than substantial harm in terms of Paragraph 202 of the NPPF, which is the expected outcome given the context described above.
Impact on Highways
3.12 No access or capacity issues are identified, reflective of the site’s location and existing use. The findings of the site assessment proforma are endorsed, including the potential to extend pedestrian footway connections, if required.
Protected Species and Ecological Value
3.13 The Council’s assessment records a potential uncertain impact but recognises that the land is not within or adjacent areas of nature conservation importance. The proforma does not reflect that the majority of the site area comprises previously developed land.
3.14 As part of future development of the site it would be appropriate to seek preparation of an Ecological Impact Assessment comprising a Phase 1 Habitat Survey and assessment of potential site features supporting the presence of protected species.
3.15 This would be an appropriate basis assess the impact of the development proposal and set out mitigation measures required to ensure there is no net harm to ecological features and where possible identify any opportunities available for integrating ecological features within the development. It is anticipated that a number of ecological enhancements could be provided as part of proposals, such as habitat piles, hedgehog tunnels, bat boxes, bird boxes and native planting and that delivery of these enhancements would lead to an overall Neutral to Minor Beneficial impact.
[Site plan inserted here]