Object

Representation ID: 7470

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

6.55 It is understood that as part of the Bedford Local Plan 2040, the Council will identify site’s to be allocated for employment land and these will be identified at the Regulation 19 Consultation Stage.
6.56 The methodology for this site selection process is set out in the Site Selection Methodology (2021). This sets out that each site is to be assessed against 15 sustainability objectives to test the social, economic and environmental impacts of development in response to key issues in the local area.
6.57 Sites are rated based upon how well they perform against each of the questions contained within the 15 objectives, from ‘major positive effect’ to ‘major negative effect’.
6.58 The initial assessment for all sites submitted as part of the 2020 Call for Sites process has also been published as part of the Reg 18 Local Plan. The Bedford Business Park is included within this as site reference 809.
6.59 Whilst we consider the Site Selection Methodology is a useful tool for considering sites suitable for residential development, we do not consider that all of the criteria are relevant when assessing sites for employment land allocations. For example, a number of the assessment criteria concern a site’s proximity to primary schools, food stores and sports facilities. We consider this is more important when considering the location of new housing developments and that there are different priorities when considering locations appropriate for employment uses, such as proximity to the strategic road network. In addition a number of these criteria are repeated under a number of the sustainability objectives which risks applying an inappropriate weighting to those criteria in the site assessment process.
6.60 Furthermore, the Site Selection Methodology is weighted towards housing development in terms of assessing flood risk. Sites which are located within flood zones 2 or 3a are automatically rated as having a negative or major negative effect on this basis. However, this does not take into account that the NPPF guidance sets out that less vulnerable uses (such as employment uses) may be suitable within flood zones 2 and 3. This therefore leads to such sites being scored negatively against this criterion despite policy not precluding such uses.
6.61 We also consider that the Methodology is unable to capture that large scale developments may be able to provide additional facilities as part of future development which would support the uses to be created. For example, the Bedford Business Park proposals include an element of retail uses, green infrastructure and other amenities in order to support future employees and complement the business offer. This therefore seeks to create a sustainable employment community in its own right and should therefore score highly against sustainability criteria.
6.62 The Methodology also fails to take into account the fact that some potential constraints can be mitigated against as part of future development to ensure there is no unacceptable impact. For example, whilst the Bedford Business Park site is located in an area where protected species are likely to exist, the proposals put forward an extensive series of mitigation measures to such species are protected along with enhancement measures to deliver net gains for biodiversity. We consider any assessment of the site should take the proposed mitigation measures into account and rated accordingly.
6.63 We therefore consider that it may be more appropriate to consider sites against the NPPF criteria concerning deliverability when considering allocations for employment land. As set out above, the site fully accords with the criteria and is demonstrated to be suitable, available and achievable for development.
6.64 Notwithstanding this, a full appraisal of the site has been undertaken in line with the site selection methodology criteria and is included in Appendix 2 This demonstrates that the proposals meet all the relevant criteria and should therefore be taken forward as a site allocation in the emerging Local Plan.
– We request that the site is formally allocated for economic development within the emerging Local Plan and that the Site Selection Methodology be amended to better reflect the range of factors and key characteristics that are relevant for assessing the merits of employment land.
See 59 page attachment relating to Bedford Business Park.