Object

Representation ID: 8575

Received: 27/09/2021

Respondent: AW Group Limited

Agent: Arrow Planning Limited

2.1 Paragraph 16 states that Local Plans should be prepared with the objective of contributing to sustainable development and be prepared positively in a manner
that is aspirational as well as deliverable.
2.2 The NPPF also requires (para 23) that the Strategic Policies of the Plan should provide a clear strategy for bringing land forward to meet objectively assessed needs in line with the presumption in favour of sustainable development (para 11), and, in doing so, allocating sufficient sites to deliver the strategic priorities of the area.
2.3 National Policy therefore provides a clear, positive context with a clear requirement to meet identified needs in an aspirational but deliverable fashion. Importantly, the NPPF does not state that Plans should adopt a ‘do minimum’ approach; instead it promotes ambitious growth, where it is carried out in a sustainable fashion.
2.4 Bedford Borough sits in a key location within a national area of strategic importance, being at the heart of the Oxford-Cambridge Arc (‘the Arc’). Whilst the timetable for the Local Plan does not align with that of the Arc Spatial Framework, our client supports the approach being taken by BBC of progressing the Local Plan in advance of the Arc Spatial Framework and consider it is crucial that the Plan is adopted in a timely fashion.
2.5 Representations put forward by Cloud Wing provide a detailed explanation of the national, sub-regional and local context for employment needs. AWG, having reviewed those representations, fully support the case put forward by Cloud Wing in their representations and do not seek to replicate those arguments here.
2.6 The Cloud Wing submission is based upon up-to-date market evidence at all scales (national, sub-regional and local) and, crucially, demonstrate that the
targets for employment growth in the Local Plan significantly fall short of what is required to meet identified and future needs in the Borough.
2.7 AWG consider that the employment needs proposed in the Draft Local Plan 2040 do not fully capture recent economic trends nor consider the wider national and sub-regional context of significant economic growth planned within the region or the Arc.
2.8 Bedford Borough sits at the heart of the Arc, whilst the A421 and East-West Rail are key movement corridors through the Arc and wider sub-region. Whilst it is acknowledged that the Arc Spatial Framework is currently lagging behind the timetable for BBC’s Local Plan, sufficient knowledge and evidence for the ambition and scale of growth to be delivered in the Arc exists.
2.9 The current strategy of deferring decisions on housing and employment growth until the next Local Plan review is not a sound approach; it is not positively prepared planning for a spatial strategy that will cover some 20 years. Even with a review in 5 years’ time (as is suggested in the Local Plan), that would be close to the midpoint of the Local Plan on the basis that this Local Plan is not likely to be adopted until 2024 (if submission is in 2023). Moreover, the requirement is only that a Local Plan Review is commenced in 5 years’ time, not
completed, so any future review would not be completed until after 2030.
2.10 This approach contrasts the approach taken by other authorities within the Arc, including Oxfordshire who are currently consulting on a new Local Plan (Oxfordshire Plan 2050) which specifically sets out that part of its purpose is to influence and shape the emerging Arc Framework. Failure to positively plan for
the Arc now would reduce the Borough’s ability to influence the direction and vision for the Arc through the Borough.
2.11 As a result, the approach set out in the Draft Local Plan significantly underestimates the scale of economic development needed and envisaged within the wider sub-region. It also risks Bedford losing out on the substantial benefits associated with this growth to other parts of the Arc. The Council's evidence, therefore, needs to be updated including to reflect recent trends
and market signals and align with the wider ambitions for the sub-region.
2.12 Within this context any employment land requirement should clearly be set as a minimum rather than a ceiling on employment-generating development in
the Borough. BBC should adopt a similar approach to Central Bedfordshire Council (‘CBC’) in their recently adopted Local Plan. In the case of CBC, who share many similar characteristics with BBC in terms of employment market and needs, the Local Plan allocated a significant quantum of strategic employment land over and above the identified needs, as the Council (accepted by the Local Plan Inspectors) acknowledged that future employment growth is diverging from historic market trends, and that there is a chronic undersupply issue.
2.13 Whilst CBC had initially suggested this could be put to a future Local Plan Review, they took the positive approach of planning for these needs now, recognising the significant economic boost that will bring. It is crucial that BBC adopt a similarly positive approach in the Local Plan and do not progress a ‘do minimum’ strategy.
2.14 The Local Plan should also have regard to the changing nature of jobs within the employment market and the evidence base is presently misleading in this regard. The Employment Land Supply incorrectly asserts that the logistics sector does not generate highly skilled jobs. Whilst that may have been the case 10-15 years prior, modern logistics operations employ many highly skilled workers, and this is only set to increase in the future with further automation and robotics.
2.15 Furthermore, many logistics buildings now incorporate large areas of office within them, meaning that they also deliver E Class (former B1) jobs that would otherwise not come forward.
2.16 The Local Plan strategy fails to adequately recognise the difference in employment development and needs versus housing needs. Employment development is generally driven by demand from actual occupiers. It is important to note that there needs to be a range of unit sizes available to meet demand as it arises from occupiers who will have different requirements according to the nature and size of their businesses.
2.17 Occupiers’ need for new facilities is generally immediate because it arises from the demands of their businesses. Businesses are rarely able to plan accurately more than 12 months in advance, where delivery of new employment, even on allocated land, can take 18 months to deliver. Accordingly, there need to be employment sites identified well in advance which are capable of meeting need as it emerges. As a result, there needs to be a “surplus” of allocated land against identified needs to ensure there are sufficient sites available which can meet a range of demands quickly.
2.18 This in turn provides the opportunity to meet market demand in a sustainable, planned fashion, i.e. through a Local Plan, rather than through ad hoc planning applications on unallocated sites because the Local Plan has not provided sufficient employment land.
2.19 The Draft Local Plan recognises the strategic importance of the A421 rail-based growth corridor in unlocking and delivering growth in the area. However, it fails to recognise the unique opportunity presented by the Bedford Business Park in this location, instead contemplating the allocation of smaller, piecemeal business parks and other small employment sites. This approach does not appear to be soundly based and would not be capable of delivering the scale of investment or diversity of economic growth that could be delivered by Bedford Business Park.
2.20 The Bedford Business Park (and in particular the land at Broadmead) is considered in more detail in Section 5 of these representations.