Comment

Representation ID: 9706

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

Draft Policy DS4(S) proposes to make provision for up to 26,700 jobs to support the Council’s ambition to create a high-value, highly skilled economy, expanding on its current strengths and developing into a location where innovative business can thrive. The supporting text confirms that, in order to achieve this level of jobs growth, the Council’s Employment Land Study (2022) identifies a requirement for between 118Ha and 142Ha of employment land to be planned for, in addition to the existing available supply of employment sites.
3.2 Cloud Wing considers that the Council’s Employment Land Study and, therefore, the scale of employment growth set out in Policy DS4(S) significantly underestimates the scale of employment land needed in the Borough to cater for growing demand, particularly in the industrial and logistics sector. It, therefore, fails to identify and meet objectively assessed employment needs and is, therefore, unsound.
3.3 The starting point for understanding both the economic opportunity for growth, and the need to provide additional land to accommodate this, is to consider recent economic trends which are driving growth, and the existing and emerging policy context at a national, regional and local level.
3.4 This section sets out the national, regional and local context, highlighting the scale of ambition within the region for economic growth and prosperity. It also considers recent economic trends and why these suggest that there is a need for a more ambitious approach to planning for economic growth in the Borough.
National Context
3.5 At a national level, the NPPF (2021) provides a positive context for plans to proactively encourage investment and economic growth and provide new employment land which meets the locational requirements of different sectors.
3.6 Furthermore, the National Planning Policy Guidance (NPPG) requires policy-making authorities to prepare a robust evidence base to understand existing business needs. As part of this, the NPPG recognises that there are different characteristics for different sectors that need to be considered in formulating planning policies and it recognises the critical role of the logistics industry in enabling an efficient, sustainable and effective supply of goods for consumers and businesses, as well as contributing to local employment opportunities.
‘Better Delivery: The Challenge for Freight’ & ‘Future of Freight Plan’
3.7 The logistics sector is a major contributor to the UK economy, employing over 2.7 million people and contributing over £124bn of GVA -10% of the UK’s total economic output. It underpins how our economy and society functions – delivering component parts to businesses, stock to shops, supplies to hospitals and products directly to our homes. However, land supply has not kept pace with demand and now acts as a major barrier to growth and prosperity.
Recognising the critical role that logistics has in supporting the national economy, the Government asked the National Infrastructure Commission (NIC) for advice on how to tackle various industry issues whilst continuing to support UK growth. The result was NIC’s ‘Better Delivery: The Challenge for Freight’ report which was published in April 2019. The report states that whilst the availability of land for freight distribution centres and other infrastructure is crucial for the efficient operation of the sector, it is often a forgotten element of spatial planning, resulting in a system with insufficient, or sub optimally located space from which to run efficient and low congestion operations.
3.9 It states that locating depots and warehouses in places which minimise the distance from the distribution point to the first delivery address allows for the more intensive, optimised use of vehicles and confirms that the most effective way of managing freight’s impacts on congestion, while allowing efficient operations, is by planning for the needs of freight at an early stage of statutory planning processes.
3.10 The report made a number of recommendations which the Government responded to in August 2021 and largely endorsed recommendations that there is a need to look further into freight’s representation in the planning system through the development of the ‘Future of Freight’ Plan.
3.11 The Department for Transport published its ‘Future of Freight Plan: a long term plan’ in June 2022. This sets out a vision for a freight and logistics sector that is “cost-efficient, reliable, resilient, environmentally sustainable and valued by society.” It recognises the sector as a vital pillar of the UK economy and identifies a series of key priorities and proposals aimed at achieving a stronger logistics sector.
3.12 One of those priority areas is around planning and addressing existing challenges in bringing forward logistics development and the fact that demand for space is consistently outstripping supply. It seeks to achieve a planning system which “fully recognises the needs of freight and logistics sector now and in the future and empowers the relevant planning authority to plan for those needs” (Our emphasis). It proposes to deliver the following proposals:
• Work with the sector to support a programme of engagement with local planning authorities to provide an understanding of the wider economic benefits of freight infrastructure
• Review and amend Planning Practice Guidance to better support freight and logistics
• Publish a freight specific call for evidence to understand what is working well and not so well to identify appropriate interventions, including potential updates to national planning policy
• Consult on updated guidance for Local Transport Plans
• Engage with the review of National Networks National Policy Statement
• Engage with the Planning Reform programme informed by the call for evidence
3.13 The Plan states that it will succeed when there is:
“an increase in site allocations for freight and supply infrastructure being adopted in Local Plans to reflect the needs of the sector, alongside more robust and agile policies, where needed to meet specific needs”
and
“authorities are more aware of freight industry needs when devising planning policies … that pro-actively plan for and speak to the change needs of the sector”.
3.14 In terms of people and skills it talks about a need to improve training and employment options across the sector, address awareness and negative perceptions of the industry and promote the availability of attractive, fulfilling jobs at all levels. It also proposes a series of actions to support the aim to achieve net zero carbon freight system by 2050.
Building Back Better
3.15 At a national level, the Government has recently set out its national strategy for how to ‘Build Back Better’7 in response to the COVID-19 pandemic and recent challenges that the economy has faced. This sets out plans to support economic growth through significant investment in infrastructure, skills and innovation and support for high growth businesses, including in research and development, that make a significant contribution to employment and allow technology and best practice to diffuse through the economy to the benefit of all.
3.16 The Build Back Better agenda also makes reference to a number of high-profile “pathfinder projects” which will be central to delivering the economic growth envisaged.
3.17 In addition to the Government’s ambitions to ‘build back better’ and for the UK to become a hub of innovation, as a business ecosystem that supports the creation and growth of businesses, there have been major economic shifts in the UK in recent years which should be central to planning for future employment needs. These are considered further in the following sections. Linked to this, the UK Innovation Strategy8 talks about the critical importance of manufacturing and logistics are critical elements of an R&D ecosystem, particularly for supply chain efficiency and resilience.
3.18 Furthermore, recent planning decisions issued by the Secretary of State confirm that the Government considers that very substantial weight may be afforded to the need for employment land and economic benefits of logistics development in terms of their job creation and other economic benefits, including addressing local needs and specific locational requirements in the logistics sector9.
7 Build Back Better: our plan for growth. HM Treasury Policy Paper (March 2021) https://www.gov.uk/government/publications/build-back-better-our-plan-for-growth/build-back-better-ourplan-for-growth-html
8 Department for Business, Energy and Industrial Strategy, UK Innovation Strategy (July 2021)
9 Various see: Wingates, Bolton (APP/N4205/V/20/3253244), Junction 25, Bolton (APP/V4250/V/20/3253242) & Parkside, Newton Le Willows (APP/
V4250/V/20/3253242)
Covid-19
3.19 The Covid-19 pandemic has fundamentally changed the way that the UK population and economy operates and has rapidly accelerated trends that have been slowly shifting business and consumer behaviour over the last few years.
3.20 The pandemic has, for example, driven a significant change in shopping habits. The UK already had the highest proportion of online sales in the world and the lockdowns associated with Covid-19 have accelerated this trend with a rapid increase in online sales. According to the ONS, internet sales as a percentage of total retail sales rose to 28% in 2020 peaking at 36.5% in February 2021. Whilst online sales dropped to 25.3% in January 2022, this is still higher than prior to the pandemic (19.8% in Feb 2020) and some are forecasting that online sales could continue to grow to 37% by 202510.
3.21 On the basis that for every extra £1bn spent online, a further 775,000 sq ft of warehouse space is needed to meet the new demand11, based on market advice from Cloud Wing’s agents Savills in June 2021, by 2025 there could be a need for an additional 63.9m sq ft of warehouse space across the UK. As such, the occupier profile of warehouses has significantly changed in recent years, with online retailers increasing their warehouse occupancy by 614% from 201512.
3.22 Other recent research by Turley suggests that at least 73 sq ft of warehouse floorspace is needed per home in the UK to meet even pre-pandemic levels of consumer demand13. It is noted that this figure does not account for geographical differences or more recent economic trends since 2019 and is, therefore, likely to be an underestimation of real demand, particularly in the strategic location of Bedford when taking into account the growth ambitions for the wider region.
10 The size and make-up of the UK warehousing sector – 2021. Savills (June 2021) https://pdf.euro.savills.co.uk/uk/commercial---other/uk-warehousing-sector---2021.pdf
11 The size and make-up of the UK warehousing sector – 2021. Savills (June 2021) https://pdf.euro.savills.co.uk/uk/commercial---other/uk-warehousing-sector---2021.pdf
12 The size and make-up of the UK warehousing sector – 2021. Savills (June 2021) https://pdf.euro.savills.co.uk/uk/commercial---other/uk-warehousing-sector---2021.pdf
13 Playing to Our Strengths Turley (2021)
Brexit
3.23 In addition to an acceleration in e-commerce activity, the demand for logistics space has also been driven partly by Brexit which has resulted in increased needs in the food, third party (3PL), pharmaceutical and healthcare sectors – all of which require additional capacity for storage and distribution of inventory.
3.24 Brexit has also driven demand from new occupiers. European distributers and retailers, who pre-Brexit serviced the UK market from the continent, are now actively seeking warehouse premises to create a UK hub.
3.25 There was also unprecedented disruption in global supply chains in 2020 / 2021. As a result, logistics companies, retailers and manufacturers have been mitigating for this by increasing inventory levels closer to home. A recent survey in December 2021 found that 46% of occupier respondents expected to take more warehouse space over the next two years, partly as a result of Brexit and other supply chain disruption14.
14 2021 Logistics Census Results: The Sector’s Highest Ever Recorded Take-Up. Tritax Symmetry (December 2020)
https://tritaxsymmetry.com/wp-content/uploads/2020/12/Property-Week-Logistics-Census-Results-2020-04-Dec-
20.pdf
3.26 More widely, even low performing sectors have seen a need to continue to demand space. All elements of the industrial / logistics market have been challenged by the need to operate within social distance guidelines (making space less productive) and also increased stock storage requirements – either
through mounting backlogs or a desire to hold more contingency stock.
3.27 Whilst the UK is now returning to normal, it is expected that the demand for space will remain and continue to grow in the coming years. As such, more fulfilment and distribution facilities will be needed to support this shift and continue to serve consumer demand for home delivery15.
3.28 These changes have resulted in a significant increase in demand for warehouse space in key locations. As such, in the first half of 2022, despite the economic uncertainties, rising inflation and the war in Ukraine, the UK has still seen the highest levels of transactions for warehousing space on record of 28.6m sq ft16 with exceeds the H1 long-term average by 90% (see Figure 5). Demand is therefore outstripping supply.
3.29 In addition to the quantum, the type of warehousing unit sought is also changing. The trend now is largely towards bigger warehousing units, with a 242% rise in demand for units over 1m sq ft17 since 2015.
3.30 Furthermore, of the space transacted in the first half of 2022, 54% was build-to-suit, 24% was speculatively developed space, and 21% was second hand, which demonstrates a growing preference towards newly developed, higher quality space with better ESG credentials and lower running costs18.
15 The size and make-up of the UK warehousing sector – 2021. Savills (June 2021)
https://pdf.euro.savills.co.uk/uk/commercial---other/uk-warehousing-sector---2021.pdf
16 Spotlight: Big Shed Briefing. Savills (July 2022)
17 The size and make-up of the UK warehousing sector – 2021. Savills (June 2021) https://pdf.euro.savills.co.uk/uk/commercial---other/uk-warehousing-sector---2021.pdf
18 Spotlight: Big Shed Briefing. Savills (July 2022)
3.31 The demand for space is diverse, with 18% of take-up in H2 2022 by online retailers, 25% by third-party logistics (3PLs) and approx. 24% by the manufacturing and automotive sector19.
3.32 Given the rise in demand and high level of take-up, applying the overall annual take-up from 2021 (55.1m sq ft)20 to the existing supply at the end of H2 2022 (18.4m sq ft)21, there would only be c. 4 months supply left within the whole of the UK.
New Growth Sectors & Changing Demands
3.33 In addition to e-commerce, a range of manufacturers and production businesses rely on 3PLs to deliver goods to business customers or supply component parts to themselves. The growth of 3PLs is a reflection of how those businesses produce goods and it is important that the logistics industry is recognised for its value as an enabler, facilitator and catalyst of growth.
3.34 Demand for large scale industrial and logistics space is also being generated by other emerging growth sectors, which are competing for space but which are not necessarily reflected when forecasting future needs based on past trends. Those emerging growth sectors include:
• battery storage;
• data centres;
• vertical farming;
• modular construction factories;
• film, TV & media production;
• green technologies; and
• giga-factories.
3.35 Consumer expectations for same-day or next-day delivery are also reshaping the operating models of logistics companies and are generating requirements for more regional and local storage space to meet demands, including increasing space in suitable locations for the ‘last mile’ to the end point delivery.
3.36 The logistics sector is also rapidly becoming conscious of their environmental and social impacts and is actively seeking space with higher energy performance standards, that supports their businesses’ sustainability ambitions and, in the case of 3PLs and manufacturers, those of the clients that they serve. This is further driving demand for new space to allow businesses to re-locate to more efficient buildings.
19 Spotlight: Big Shed Briefing. Savills (July 2022)
20 Spotlight: Big Shed Briefing. Savills (January 2022)
21 Spotlight: Big Shed Briefing. Savills (July 2022)
Summary
3.37 In line with national planning guidance and the strategies to build back better from Covid-19, it is increasingly important that spatial planning at a regional and local level takes into account both the changing requirements of industrial and logistics developers and occupiers in terms of the type, size, quality and location of facilities needed to meet a growing demand within this sector, whilst also factoring in the emphasis nationally on innovation and research and development to the future prosperity of the UK and delivering cohesive business ecosystems that support the creation and growth of businesses and a variety of employment.
Regional Context
Ox-Cam Arc
3.38 At a regional level, Bedford is located at the heart of the Golden Triangle and within the Oxford-Cambridge Arc (‘the Arc’). The Arc is being promoted as the World’s Premier Growth Corridor as well as an exemplar of sustainability and the approach for the Arc is to be bold, visionary, pro-development and action-orientated.
3.39 The National Infrastructure Committee (‘NIC’)’s ‘Partnering for Prosperity’ Report (2017) sets out the overriding vision for the Arc and, in terms of employment growth, states:
“the area could support around 335,000 new jobs to 2050, increasing economic output by around £85bn per annum (2011 prices). However, by meeting future needs and removing the constraints to growth arising from the area’s housing shortage, the area could sustain a transformational level of growth, supporting around 1.1m new jobs and increasing economic output by £163bn per annum”. (Our emphasis)
3.40 To achieve this scale of employment growth, the report identifies a series of opportunities for growth particularly centred around the proposed East - West Rail improvements and Expressway schemes22. Such opportunities include unlocking growth in and around Bedford and focusing development on a small number of key nodes in the Marston Vale.
3.41 The ambition for the Oxford-Cambridge Arc is well documented and is focused on unlocking investment, driving economic growth and promoting world class research, innovation and technology assets, as set out in the Oxford-Cambridge Arc Economic Prospectus (2020).
3.42 In 2021, the MHCLG set out plans to prepare a Spatial Framework for the Arc to cover the five counties of Oxfordshire, Northamptonshire, Buckinghamshire, Bedfordshire and Cambridgeshire. As set out in the ‘Planning for Sustainable Growth in the Oxford-Cambridge Arc’ (2021) the new
22 It is noted that Oxford to Cambridge expressway has been cancelled but that alternative plans
for improving transport in the region are in discussion:
Framework will plan for growth in the Arc area, setting policies on the economy, the environment, transport, infrastructure and housing. The intention is that the Framework will have the status of national planning and transport policy.
3.43 Following this, the ‘Creating a Vision for the Oxford-Cambridge Arc’ document was published for public consultation in July 2021. This is the first stage in preparing the Spatial Framework for the Arc and seeks to obtain views to help create the vision and guide the future of growth of the area to 2050. Two further rounds of consultation were due to take place in Spring and Autumn 2022, with publication and implementation of the Spatial Framework targeted for 2023.
3.44 It is understood that BBC is advancing its Local Plan 2040 ahead of the Arc Spatial Framework to avoid a scenario whereby Bedford has an out-of-date Local Plan. As a result, the Council is focused on meeting its own growth requirements in the absence of the Arc Spatial Strategy being finalised. However, by not considering the wider regional growth ambitions, there is a risk that Bedford fails to positively plan for the level of growth required within the Borough to meet strategic needs and contribute towards meeting the wider goals of the Oxford-Cambridge Arc.
3.45 This may also impact Bedford’s ability to influence the direction and shape the vision for the Oxford-Cambridge Arc. This is in contrast to the approach taken by other authorities within the Arc, including Oxfordshire who have previously consulted on a new Local Plan (Oxfordshire Plan 2050) which specifically set out that part of its purpose is to influence and shape the future of the Arc.
South East Midlands Local Enterprise Partnership
3.46 In addition to the above, BBC also forms part of the South East Midlands Local Enterprise Partnership (SEMLEP) which is a multi-authority group that covers Bedford, Central Bedfordshire, Luton, Milton Keynes and Northamptonshire. This area is a rapidly-growing £50bn economy at the nexus of London, Birmingham, Oxford and Cambridge.
3.47 SEMLEP works closely with the other Local Enterprise Partnerships across the Oxford-Cambridge Arc.
3.48 The South East Midlands Local Industrial Strategy (‘LIS’) was published in July 2019. This predates the recent and rapid economic shifts in and changing face of the industrial and logistics sector. This emphasises the opportunities in this area to fuse productivity-led growth with sustainability by enhancing renewable energy use, connected transport solutions and greener vehicles, buildings and design principles. It also notes the need to develop a pipeline of quality employment land and premises. It acknowledges the strength of the area as an “unrivalled location” for logistics and sets out measures to increase productivity within the sector.
3.49 SEMLEP has also published an Economic Recovery Strategy for the South East Midlands which sets out the actions being taken by way of a response to ensure the ambitions within the LIS can still be met. This highlights that the national trend towards online retail (discussed in further detail below), has been reflected in strong demand in the SEM for logistics premises over 2020 and in early 2021. As such, one of the key goals of the SEM is to work with local partners to expand the innovation capabilities, sustainability and productivity of the local logistics and manufacturing sectors.
3.50 It is understood that SEMLEP has recently commissioned its own ‘Logistics Study’ that is currently being carried out by Iceni. The aim of this study is understanding the future demand for and supply of logistics premises and strategic warehousing across the South East Midlands and allowing SEMLEP and authorities partners to proactively plan for the needs of the sector to 2050, alongside the needs of other sectors.
Market Context
3.51 Take up in the South East (which includes Bedford) in 2021 reached 7.34m sq ft, whilst slightly down on the record levels in 2020, 2021 was the fourth year in a row where take up has exceeded 7m sq ft (Figure 523) and reflects a greater number of transactions for smaller units. Savills’ view is that the shift to smaller units and fewer ‘build-to-suit’ units over the last 12 months is linked to immediate requirements from occupiers seeking to mitigate supply chain issues by increasing their inventory levels quickly. 3.52 This trend may also reflect the relatively high proportion of space that is available in smaller units compared to larger units. In particular, it was notes that MH Star, a Chinese e-commerce company, took the entirety of G Park Bedford which totals 534,000 sq ft across three units, such is the lack of supply in the larger size bands in the area24.
3.53 Savills suggest that demand is from a range of occupiers including retailers, 3PLs, parcel delivery companies, data centres and film studios with the preference being for good quality space.
3.54 Savills confirmed that the level of supply within the region has remained broadly stable but has fallen to 3.94m sq ft across only 25 units, with 43% of this supply being located within London25. Vacancy rates are low at 2.89%. Based on the 2021 take-up levels, this equates to just 6.5 months’ worth of supply. Furthermore, only approximately half of the space available is Grade A. There are only 22 units under
23 Savills (2022) The logistics market in London and the South East https://www.savills.co.uk/research_articles/229130/323883-0
24 Savills (2022) The logistics market in London and the South East https://www.savills.co.uk/research_articles/229130/323883-0
25 Savills (2022) The logistics market in London and the South East https://www.savills.co.uk/research_articles/229130/330511-0
construction in the region totalling 3.57m sq ft (a further 6 months’ of supply), most of which are under 200,000 sq ft26. This lack of available space can stifle demand, particularly given the preference of occupiers towards higher quality units.
Summary
3.55 Therefore, at the regional scale there are ambitious plans for significant economic growth and development within the South East Midlands and across the Oxford-Cambridge Arc, across a range of sectors to meet these goals. There is also a recognition at a regional level of the need to understand the future demand for and supply of logistics premises and strategic warehousing across the South East Midlands to ensure this can be appropriately planned for, alongside the needs of other sectors. This should be taken into consideration alongside the particularly strong market demand for logistics space, the lack of existing supply that is suitable to cater for occupier’s requirements and limited development opportunities in the pipeline.
Local Context
3.56 Bedford’s current Local Plan was adopted in January 2020 and sets out a plan for Bedford up to 2030. The adopted Local Plan does not plan for an increase in the existing employment land supply as the supporting evidence, at the time, suggested that the existing supply was sufficient to meet future needs. This amounted to a minimum of 6,900 net additional jobs to be provided up to 2030, with the main focus around the urban area of Bedford and Kempston and on the employment sites that were already allocated.
3.57 Notwithstanding this, Policy 72S of the adopted Local Plan recognised that there may be unanticipated demand for additional employment land and therefore supported new high quality windfall development subject to meeting a number of criteria, including being close to the strategic transport network. The limited supply of available employment land for development indicates employment land has been taken up at a faster rate than anticipated at the time the adopted Plan was prepared. This is the context in which Cloud Wing’s outline planning application has been prepared and submitted.
3.58 To support the emerging Bedford Local Plan 2040, the Council has undertaken a study to consider Bedford’s position in the wider area, the pattern of employment in the Borough and the need for additional employment land. This is contained within the Bedford Employment Land Study (2022) which forms an evidence base document to the draft Local Plan 2040 and sits alongside its Economic Growth Ambitions Paper (2022).
Employment Land Evidence
3.59 Our previous representations to the Local Plan process highlighted the strength of the logistics and distribution market within Bedford and the wider South East Midlands sub-region and the lack of recognition/weight placed on this in the draft Local Plan and its evidence base. In summary those representations set out the following:
26 Savills (2022) The logistics market in London and the South East https://www.savills.co.uk/research_articles/229130/330511-0
• The draft Local Plan and its evidence base failed to consider the strategic market trends in the logistics sector and take them into account appropriately when forecasting future needs.
• The approach to market analysis contained misunderstanding of the data that led to a series of inaccurate conclusions being drawn on the strength of the office, industrial and logistics markets locally.
• Floorspace requirement projects suffered from a number of technical issues that undermined their robustness and ability to produce a sound Plan for economic growth in terms of defining land requirements.
• The data used is considerably out of date and fails to capture recent fundamental shifts in the local, regional and UK economy that are reshaping the nature of work, employment space needs and sectoral growth prospects meaning the Plan sets a direction of travel that is outdated and therefore not ‘sound’.
• The land provided does not take into account both quantitative and qualitative needs of the logistics sector satisfactorily and therefore leaves the borough woefully under provided for in terms of future land availability.
3.60 Unfortunately, the updated evidence and draft Local Plan have not addressed these, meaning there remain issues with how demand is understood and planned for over the Plan Period. Critically much of the underlying evidence remains out of date and not reflective of current conditions or future growth prospects, undermining the robustness of the plan.
3.61 Critically, we do not believe that the current assessment of future needs presented in the ELR to support the draft Local Plan fully takes into account the economic growth needs of the borough. Critically the NPPF recommends three mechanisms for assessing future employment needs, namely:
– Employment forecasts
– Past trends
– Market signals
3.62 To a greater or lesser degree the ELR relies on each of these to inform future needs, however we do not believe this has been done in a robust, consistent or appropriate manner to allow the draft Local Plan to be considered to meet the tests of the NPPF.
Demand Forecasts
3.63 Whilst the ELR was updated in the first part of 2022, with a number of new or revised elements included, these extend to:
– Additional commentary explaining the market engagement undertaken and its findings – which reinforces the identified demand for large logistics space and also the emerging market for innovation based activity, which indicates even this activity requires industrial land and premises.
– An updated review of employment land supply – which revises the scale and status of all existing and proposed sites
– Introduction of new forecast scenario and sensitivity tests – albeit with the base forecast data remaining consistent with the previous ELR which we have previously commented on in terms of its appropriateness and consider again in more detail below.
– Additionally commentary relating to the economic strategy for the borough and how it will meet future economic needs.
Technical Concerns
3.64 Our previous representations to the Local Plan process, whilst accepting the overall approach to the base forecasts, did highlight some areas where the assumptions used in the model could lead to future needs being over or under estimated. Unfortunately, a number of these concerns still remain, in short they relate to:
– The Use of the EEFM:
• The EEFM data was published in July 2019 and has since been cancelled as an ongoing source of economic forecasts for the region. Whilst published in 2019 the EEFM 2019 Technical Report confirms that much of the data used to develop the projections is considerably older, with BRES the most ‘up to date’ input, but still dating from 2018. As previously noted, the use of a forecast that predates the COVID-19 pandemic and before the UK’s deal to exit the EU had been agreed. Both events have had major impacts on the scale and nature of the UK economy, driving different forms of demand in different locations than have been experienced pre-2020. Using a 2019 economic model means that none of these impacts are understood or built into the ELS. The chart below highlights the potential scale of the difference (albeit using Experian forecasts given they have been run post-2019).
As shown, historic forecasts dating from around the time of the EEFM (2018 and 2020) significantly under-estimate the scale of growth in the Land Transport, Storage and Post category sector over the period they covered, with figures from the end of 2021 clearly showing national prospects for the sector have increased compared to all other years considered . This is a critical point when considering land supply in Bedford as it directly shows that the basis on which land needs have been determined fail to capture the new dynamics and needs of the sector.
• The potential limitations of the EEFM base data stemming from its year of publication are not solely related to the logistics sector. As previously identified, it also provides the basis for how the ELR splits employment between (former) B and non-B class uses – maintaining a high proportion of the borough’s employment in ‘non-B class’ activities. It is considered the non-B class share of jobs will represent 61% of all jobs in the short term and increase to 64% in the future. Given uncertainty in the retail, leisure and many other sectors, the confidence which can be placed in this projected growth needs to be carefully managed and, in order to achieve its desired employment outcomes, the borough should be considering alternate approaches to growth to offset any underperformance in non-B class activity.
• Again, as previously noted, the EEFM uses a lower density assumption than would be usually assumed based on the nature of demand for logistics space. The previous ELR gave no explanation for why this assumption was used, however additional text now provides the following explanation “Whereas the Employment Density Guide suggests a range from 70 sqm per employee for ‘final mile’ distribution to 77 sqm for regional distribution centres and 95 sqm for national distribution centres, the East of England model uses a single figure of 67 sqm per employee. This is equivalent to the Density Guide’s ‘final mile’ distribution figure (after conversion from gross external area to gross internal area).” Whilst this explains what has been done, it doesn’t provide a justification for either the assumption that all logistics activity will be ‘final mile’ or why, if that is the case, the density assumption is still lower than the Density Guide recommends.
• Critically, the use of a ‘final mile’ density is undermined by the Council’s own market evidence, which highlights the growth in take up of space for businesses that play a regional role – referencing the B+M Distribution Centre for example at paragraph 4.13 – and also the wider demand that is acknowledged to exist for similar activities. To be appropriate, the use of a density within a forecast model should reflect the likely nature of demand going forward based on the market and occupier evidence or, at least, should reflect an ‘average’ that represents the potential range of uses that may happen. Unfortunately the assumption used does neither of these things and seems to have been selected in order to reduce the floorspace/land requirement.
– The ORS Model
• The second basis for forecasting is the ORS population projects, which have been translated into estimates of floorspace need. There is no detailed methodology paper provided in the ELR to describe the ORS model so it is difficult to understand how robust the approach is or what data
sources it relies on. Given this, it may well suffer from the same time-lag limitations as the EEFM and, therefore, present the same challenges in reliably forecasting future need.
• The ORS model also draws on the EEFM for key inputs around the split of jobs better use classes and employment densities. As such it suffers from the same limitations as the EEFM explained above, calling into question the robustness of the recommendations that are based on it.
• One big difference between the EEFM and the ORS model is the basis on which floorspace need is calculated.
 Firstly, the model appears to ‘constrain’ employment growth within the borough to “the same level of ‘self-containment’ of employment within the borough as currently experienced” (paragraph 7.27) – inherently this doesn’t allow for the true economic potential of the borough to be fully tested or understood and limits opportunities for increasing the role of the borough in the regional economy through the provision of new employment land.
 Secondly, the model uses the rate of economically active residents as a “proxy” for jobs in the borough, stating that “This is reasonable as it is assumed that there will be no change in the number of unemployed persons and so the growth over the period is the same for economically active and job numbers” (paragraph 7.25). This is a significant move away from the usually accepted approach to employment land forecasting which relies on FTE employment to be able to use the Density Guide assumptions to translate jobs into floorspace. The ELR offers no comparison as to the relative levels of economic activity and employment in the Borough.
 Fundamentally the two measures assess different things. The level of economic activity records data for the number of borough residents who are economically active (regardless of their place of work etc) whereas the EEFM jobs projections measure the number of (FTE) jobs provided in the borough. Based on data provided by the ONS in July 2022 the Annual Population Survey recorded 83,200 economically active residents, of which 80,000 were in work. However, the Business Register and Employment Survey (BRES) suggests that 81,000 jobs existing in the borough in 2020, suggesting that while the numbers are relatively closely aligned they do not present the same output.
 The use of the economic activity data in the way described presents some challenges for long term economic projections as activity rates will be influenced by a range of factors that would not necessarily impact the provision of jobs. For example, economic activity levels will vary by population age profiles, levels of education and training and unemployment as a result of local economic conditions (e.g. a decrease in retail provision in an area which has historically had high employment there) – a jobs based projection is less susceptible to these locally specific issues given they relate to much broader economic trends.
3.65 Overall, both approaches have a range of technical limitations that could lead to a mis-allocation of both a scale and type of employment land within the borough, which is exacerbated by the lack of integration of the market trends. These should be addressed to ensure the draft Local Plan strategy for employment land is based on a sound, robust and evidence-led understanding of the potential of the borough’s economy.
Scenario Testing
3.66 The most significant change to the ELR evidence base is the introduction of a series of scenario tests to the base forecasts, these are based solely on the ORS population based model, and therefore suffer the same technical issues as the base forecast described above.
3.67 The scenarios seek to test different approaches to the delivery of the overall B class employment figure within the ORS model – a figure of 10,406 ‘jobs’ (noting these are based on economic activity rather than jobs).
3.68 In line with the previous work by GVA the first tests consider how development may come forward and what this means for the translation of floorspace into land via different plot ratios. In truth, this is more of a sensitivity test of the original forecast rather than an alternate scenario and therefore has little difference in its robustness to the base forecast.
3.69 The other alternative scenarios have greater differences, in the main seeking to redistribute the share of employment growth across use classes in a different way to the EEFM suggests – primarily this profiles employment away from the warehousing sector to the office sector, with a marginal decrease also in the industrial sector. Limited commentary and evidence is given for the modelled redistribution other than referring to the expectation that new trends will emerge and drive a need for more office/high tech space – the main point of reference is listed as the Economic Growth Ambitions Topic Paper – which itself relies on a small number of recent property deals and company activity and a longer term view of the influence of the OxCam Arc.
3.70 By combining different plot ratios and the redistributed growth, the ELR now presents four different scenarios beyond the baseline that mean the need for warehousing land ranges between 36 and 61 ha.
3.71 Whilst it may be desirable to have more evidence for the sector redistribution in order to understand how robust and deliverable it is the ability to understand what may be needed land-wise to help the borough’s economy evolve is not, in and of itself, an unreasonable scenario to test. However, the approach to achieving it could be improved in order to better reflect the full potential of the Bedford economy, rather than constrain one sector in order to promote another.
3.72 Critically, all the scenarios tested constrain growth to 10,406 jobs, a figure which in itself is arrived at from a forecasting approach that constrains jobs growth to an arbitrary ratio of homes to jobs. As noted above, this ratio may actually limit the potential to fully realise the role Bedford can play in sub-regional and regional markets in the future, particularly in the logistics sector.
3.73 The scenarios presented treat employment and economic growth as a ‘zero sum game’, baking in an assumption that the economy can only grow by a certain amount and that any growth in one sector will limit the opportunity of another – therefore for aspirational reasons only the decision is made to constrain the logistics sector in order to allow the office sector to grow.
This is an unnecessary and unhelpful starting position to take as there is no evidence to suggest that there is a ‘ceiling’ on employment growth, or that by allowing one sector to grow investment in another will be stymied. Indeed, from experience there is no reason why both forms of growth cannot be delivered in parallel or in sequence over the plan period given the different levels of market maturity, the different locational and site requirements of the office and logistics sector and different employment profiles they offer.
3.75 In simple terms, by supporting both sectors to succeed, the Borough would be able to provide more jobs for residents and increase the economic benefits that flow to the borough rather than limit any theoretical future potential.
3.76 Looking more widely across the East Midlands, the logistics sector is seen as a key growth priority not only because of the strength of the sector itself but also from a recognition of the role it plays in supporting high value innovation, production and manufacturing activity as a core part of the supply chain. The provision of appropriate space for logistics will allow a more rounded economic ecosystem to form in Bedford that will support other activities to grow over time.
Market Signals + Trends
3.77 We have previously made representations to the plan making process that the first two approaches to forecasting future need do not fully capture the scale and nature of future need within the logistics sector given a. the relationship between employment growth and floorspace demand is no longer ‘linear’ given changing operational practices within the industry and b. past trends in property demand are constrained by available supply, which is significant issue for the logistics sector given their changing needs and the inappropriateness of significant amounts of existing stock to meet their needs.
3.78 In both cases, a sole reliance on either employment forecasts or past trends to determine future needs would most likely lead to an undersupply of appropriate land and premises for future logistics activity, an issue that is recognised to exist across the country and clearly articulated in the BPF’s Logic of Logistics report.
3.79 The current Employment Land Study, the Economic Growth Ambitions Topic Paper and, therefore, the draft Local Plan all recognise the role logistics has played previously in driving employment and economic activity. Our work historically for the Council identified that Bedford’s economy and market operated at different scales depending on the activity and market segment considered. It recognised that for industrial and logistics activity the borough had a much more significant role to play in the sub-regional economy than it did for office based activity, largely related to its location, road connections and site opportunities. Conversely the office market was seen to be locally focussed, given the proximity to larger, more established offers in the likes of Milton Keynes.
3.80 The new ELR carries forward this conclusion from a FEMA perspective, recognising the larger role the Borough plays in the industrial/logistics market, which is welcomed. This should be the basis on which the ELR, and therefore the draft Local Plan, then develops an appropriate strategy to assess and accommodate future needs. However, this is not the case; indeed the remainder of the ELR gives little attention or weight to these market forces and the role they play in shaping the borough’s future employment land needs.
The Logistics Sector
3.81 To appropriately plan for the future needs of the logistics sector, it is important to not only consider the local dynamics but also develop an understanding of the strategic factors and trends that are, and will continue to, influence demand. The growth and performance of the logistics sector over the last decade is well recognised and documented and it is therefore possible to base the borough’s employment land strategy on a deep and wide-ranging evidence base, something the Council fail to do. In absence of this analysis we provide a brief overview of the sector below.
3.82 A variety of forces have combined to generate heightened demand for industrial and distribution space. Over the past 5 years the UK economy has experienced significant changes. The COVID-19 pandemic has accelerated trends and brought the critical role of the logistics sector into sharp focus. However, wider changes to consumer and business behaviour were already underway and influencing demand for property across the UK. A combination of changing consumer demand and the emergence of new sectors provide new economic drivers for the demand for large spaces in well-connected locations. These are not captured in historic economic forecasts and therefore are not included in most of the evidence base reports that direct local employment land policy.
3.83 Even before the onset of the pandemic in early 2020 the UK had one of the highest levels of online expenditure in the world with 19% of all expenditure happening online in 2019 compared to 15% in Germany. Unsurprisingly, with the closure of physical retail stores for a large part of 2020, this figure increased substantially to an average of 26% of all sales in 2020 happening online having peaked at 36% in late 2020.
3.84 Whilst the first half of 2021 saw this rate of expenditure decrease slightly, there is no sign that it will return to pre-pandemic levels, with online shopping expected to have reached a value of c.£122bn in 2021. Indeed, forecasts by Experian (Retail Planner Briefing Note 14, 2022) indicated that online sales could increase back to 30% by 2025 and reach at least 37% of retail expenditure by 2040. This continued growth will drive further needs for warehouse and distribution space in particular. This reflects irreversible changes in consumer behaviour, particularly in older age groups who had previously been slower to adopt online shopping.
3.85 As online sales have grown, as a proportion of total expenditure, demand for large distribution space has increased. An 80% growth in online grocery shopping has seen food retailers significantly expand their distribution capacity.
3.86 2021 was another record year for the UK industrial market as take-up of Grade-A space over 100,000 sq ft surpassed 49 million sq ft, totalling c.50 million sq ft. In line with recent trends e-commerce continued to dominate the occupier market. This huge increase in demand has led to a reduction of stock, and a surge in land and rental values.
Figure 8 National Take Up of Large Units (100,000sqft +)
3.87 Take-up of large (100,000 sq ft+) units increased by 28% compared to 2020. This represented an increase of 57% on the five-year average. There was an increase in demand from non-food retailers, who accounted for 48% of all take-up, compared with 41% in 2020. Third-party logistics accounted for 27% of all market activity throughout the year.
3.88 Availability of these large spaces totalled 24.2 million sq ft at the end of 2021, indicating a national availability rate of just 2.9%. This level of available stock is 6% lower than at the end of 2020 and meaning, for the second consecutive year, there is less than a year’s supply of available stock in the market.
3.89 Critically, demand has grown in all parts of the country, as operator requirements have changed and there is an increasing need to be closer to end users, as shown below.
3.90 As shown above the East Midlands remains the primary area of focus for the sector, with over 15mn sqft of take up in large units during 2021. The comparison to the 5 year average shows the strengthening of the East Midlands market over the period, suggesting the region remains a focus for occupiers.
3.91 This focus on the East Midlands and the continued demand for space is underlined by the scale of ‘live’ requirements currently seeking space in the area. The following table sets out a summary of known requirements for units in excess of 100,000sqft, which has been provided by Savills, the requirements list is up to date as of 28/07/2022 – clearly this can change on a regular basis, but it provides the most up to date potential needs in the market.
3.92 Requirements in the market relate to the specific location needs of a particular business, who will define an area of search relevant to their operations. Some will define fairly narrow search parameters (i.e. identify a particular town/city), others will define much larger areas in recognition that their market is larger or their needs harder to accommodate (for example), a size range is usually also provided, again in recognition of the flexibility required to find an appropriate location. The table therefore seeks to stratify the data by the nature of the search area and the minimum and maximum site needs.
3.93 As shown, there is c. 13.8mn sqft of need identified that is specifically seeking space within Bedford/Bedfordshire based on minimum size requirements, however the same occupiers could also occupy c.23.5mn sqft if their upper end space requirements are considered. It should be noted that whilst these businesses have a specific focus on Bedford/Bedfordshire, they may also consider other locations to find the ‘right’ space.
3.94 A significant number of businesses have much wider search areas, ranging from the South East Midlands (broadly reflecting the LEP area) through to the Greater South East. Again there is a significant level of need here of between 9.5mn sqft and 17.5mn sqft. Given their search requirements all of these businesses would consider any opportunity to locate in Bedford, however the ‘need’ for them to be there is much lower.
3.95 The majority of these businesses require space with the next 3 years, with the rest needing space within 5 years. This suggests that there is a significant opportunity for Bedford to capture a share of this demand and realise a series of economic and employment benefits at a time when the wider economy is looking increasingly challenged.
3.96 Even if only a small proportion of the Bedford/Bedfordshire need were considered as ‘required’ to be met within the borough (ignoring wider more ‘footloose’ demand that could be captured), adjusting the requirements set out in the ELR for these market signals would result in a significant uplift in the land requirement. For example, seeking to accommodate 10% of the minimum Bedford/Bedfordshire focussed requirement would require c. 1.3mn sqm of floorspace and over 320ha of land at a plot ratio of 0.4.
3.97 Whilst these requirements are focussed on the next 5 years, driven by immediate business needs, it is expected that the broad demand trends for large space will continue over the medium to long term given consumer behaviour is now embedded and there is now increased competition for such spaces from a range of traditional sources including existing businesses looking to increase their warehouse space to accommodate the continued growth in
demand, a need to upgrade stock to meet new operational approaches or environmental performance standards, growth in industries such as film/TV/digital content production and new sub-sectors such as Q-commerce operators.
3.98 This competition is increased further by a range of new activities and sectors that have emerged in recent years and look set to become major new components of the economy in the future, including:
• The drive towards net zero has led to demand for more sustainable methods of construction. As a result, the UK has seen significant new demand for offsite construction manufacturing facilities, with the likes of TopHat, Swan Housing and Countryside all seeking or occupying major units in the last 18 months.
• As we move towards greater use of electronic vehicles (EVs) there is new demand for ‘gigafactories’ where vehicles and their batteries are developed. Britishvolt have been a pioneer in the UK, planning a 2.7mn sqft factory in Blyth.
• Home working and increasing demand for video streaming, social media, downloaded content for home entertainment, for ‘big data’ solutions and cloud-based computing have driven a rapid expansion in datacentre demand, with an expectation of 10% growth per annum over the next 5 years.
• More niche activities such as vertical farming are also expected to expand significantly.
3.99 Critically, these demand side drivers are not fully taken into account within econometric forecasts, and therefore any assessment of future land requirements based solely on an employment forecast will under-estimate the need for additional land. As noted above given the ELR recognises the important role the Borough plays in the logistics market these strategic trends the approach to land designation should have paid more direct attention to the needs of the sector in the future, that lie beyond simply employment growth forecasting.
Office and Innovation Space
3.100 As recognised in the ELR, the market for office/innovation space (hereafter referred to solely as office) is less established/proven. The ELR noted that over the past 6 years, on average, less than 100,000sqft of space has been let per annum. As noted in our previous submission to the Local Plan process, even this may be something of an over-exaggeration of the market scale given (as recognised in the ELR) it includes the re-leasing of Colworth Park to Unilever – space they already occupied and, as noted in the ELR, a specialist R+D facility that has been their base for a significant period of time and they have invested heavily in.
3.101 The scale of the market is also reflected in other key statistics, with CoStar data presented by the Council showing in most years the majority of deals were for very small (sub-1,000sqft) units, with a peak in 2014-15 of 4 deals for space above 5,000sqft – again this was a year skewed by the Unilever lease renewal. Contrary to the conclusion set out in the ELR (which states on Page 21 that “there is no consistent trend discernible in transaction size over time”), it is clear, as was established in the previous employment land assessment we completed, that the Bedford market is dominated by smaller transactions, a function of those office sectors being focussed on SMEs.
3.102 That is not to say that there is no requirement for additional office space. As noted in the Economic Growth Ambitions Topic Paper, there has been recent investment into Bedford from businesses that have ‘spun out’ of some of the larger employers already in the area (such as Unipath, Mologic and GAD which can all trace their heritage back to Unilever) as well as new activity from existing businesses such as Fujifilm.
3.103 However, at this point, they remain relatively small entities that require smaller office spaces from which to operate. Again, Savills have provided some data (sourced from CoStar) that helps to highlight the scale of the Bedford market. The table below shows the number of deals completed each year for office spaces in excess of 10,000sqft alongside the total space let in those deals. The size threshold is important as it represents the minimum size Savills consider ‘viable’ in the Bedford market to deliver office space. Year No. of Transactions Total sqft let
2017-2018
0
0
2018-2019
2
23,000
2019-2020
1
10,000
2020-2021
2
20,000
2021-2022
1
35,000
Source: Savills, 2022
Figure 12 Office Transactions over 10,000sqft
3.104 As shown in the last 5 years there have been a total of 6 transactions that have exceeded the size required to unlock office development. This suggests that whilst there is a need for office space to be delivered, the scale and timing of that need is less certain – with space likely to come forward in the medium to long term. This timing is reinforced by the Economic Growth Ambitions Topic Paper, which clearly links the future growth in office/innovation based sectors to the success of the OxCam Arc and the delivery of East-West Rail to enhance the interlinkages between Bedford, Oxford and Cambridge.
Conclusions
3.105 There are clearly market signals that the Borough needs to provide both additional office and industrial land, however at present the draft Local Plan only appears to respond to the ‘early’ market signals regarding the potential to grow any innovation based economic offer and gives little weight to the more established market signals relating to the logistics sector.
3.106 It is clear that the Council are treating the evidence related to each sector differently in order to follow a pre-determined economic strategy - whilst it is within the gift of the Council to pursue that strategy to increase innovation, there is no justification for why this is the chosen approach at the expense of growth in the logistics sector. Both the demand projections and the market signals highlight expected growth in the logistics sector, with the market signals in particular highlighting locally specific needs and demand.
3.107 The market signals are evidently much stronger for the logistics sector, suggesting that there are significant opportunities to deliver employment growth in the Borough early in the plan period. Conversely the weaker signals for the office sector suggest that the realisation of the Borough’s ambitions will take longer, most likely in the middle and end of the plan period.
3.108 As such, there appears no apparent conflict in economic terms between the two sectors being promoted on equal terms - this would deliver jobs growth throughout the plan period and (given different spatial requirements) not absorb land in the early part of the plan period that would be needed to accommodate later growth.
3.109 On this basis, we conclude that the Council fails to appropriately assess and identify its objectively assessed employment needs, particularly those in the logistics sector. Policy DS4(S) therefore fails to plan for these needs. It is, therefore, inconsistent with Paragraph 11 of the NPPF and is not ‘positively prepared’ in accordance with paragraph 35 of the NPPF.
Future Sources of Supply
3.110 The Local Plan includes the following sources of supply to meet future need - there is some overlap with the sites identified in the ELR, however not all sites are included in both documents and the naming and referencing is not consistent making direct comparisons more difficult to make. It should be noted that not all sites in the Local Plan are attributed a specific use (or mix of uses) and for these we have assumed they could come forward for the full range of (former) B class activities.
3.111 As shown, whilst the Borough has identified a number of sites which in total provide sufficient capacity to meet the overall identified requirement, they do not necessarily cater for the qualitative requirements of the individual sectors forecast to grow. This most acutely impacts the B8 sector, where only one site is allocated specifically for that use, and this lies to the east of the Borough with the least direct connections to the M1. Other sites do include Class B8 as part of their mix. However, the majority of these are small and would therefore be most likely attractive to the non-B8 uses identified or would provide space for smaller scale storage and distribution units as part of their mix.
3.112 The ELR identifies a requirement of between c.36 and 61ha of land, with a broad recommendation to allow for the lower end of this range (contrary to the evidence available to the Council). In the absence of any detailed guidance on what proportion of each site will be used for each use class, if it is assumed that each allocation was to attribute an even proportion of land to each identified use class (i.e. those identified for B1/B2/B8 would see 33% of land used for each use) then the Borough would have a stock of 48ha of B8 capacity – with the majority of land at Kempton Hardwick and Roxton (23ha and 17ha respectively). This suggests that in quantitative terms the Borough could accommodate the lower end of the need range for B8 but would have a shortage if need were in the mid or upper end of the range.
3.113 Critically, it would also mean that there would be a very fragmented distribution of land across the Borough, made up of a series of smaller sites that would limit the ability for sites to accommodate larger units, of which there is a clear and demonstrable need. It would also lead to challenges in deliverability as the market would be forced into delivering the same type of units on most sites, which could risk an oversupply of similar spaces, making viability more challenging.
3.114 As noted, when considering the approach to identifying the objectively assessed need, the Council has chosen to disregard any demand arising from ‘regional’ needs and any need to accommodate larger units. The Council’s rationale/strategy for doing this is that the allocations made in other Boroughs will be sufficient to address and accommodate any market-led/subregional growth.
3.115 Our previous submissions questioned the evidence and support for such an approach, noting that there was a heavy reliance on Central Bedfordshire in particular but no statement of common ground on the topic existed and Central Bedfordshire’s evidence to their own Local Plan examination stated that despite allocating land specifically for local and ‘footloose’ demand, it may need “topping up” during the Plan Period.
3.116 The approach to relying on Central Bedfordshire’s land allocations appears even less sound now given recent submissions they have made to the Bedford Local Plan consultation process. Central Bedfordshire appears to disagree that Bedford Borough can rely on its stock to meet demand for strategic warehousing stating that this is “not an appropriate strategy”.
3.117 Whilst Bedford has produced a series of ‘Duty to Cooperate’ Position Statements’ (April 2022) these are not a ‘Statement of Common Ground’ in accordance with the requirements of Part c) of paragraph 35 of the NPPF and they do not include the scope of information that the NPPG states SoCG should contain, including details of activities undertaken in addressing cross-boundary issues and whether the authorities can meet their identified needs, for example, strategic employment needs.
3.118 On this basis, it is impossible to conclude whether the Council has complied with the legal Duty to Cooperate and if the Plan would be ‘Effective’ (i.e. sound) in working on ‘cross-boundary strategic matters’ and that these issues “have been dealt rather than deferred”. Indeed, in line with the suggestion made by CBC that further assessment of the demand for strategic warehousing provision in Bedford should not be ruled out, a further assessment of demand is required.
Conclusions
3.119 Overall, we consider that the ELS and draft Local Plan 2040 do not capture or reflect recent economic trends and market signals, particularly in the logistics sector, and is poorly aligned with the wider national and regional context which sees major growth across a range of sectors including in innovation, advanced manufacturing and logistics. This results in a Plan which: i) significantly underestimates the scale of employment needs required in the Borough; ii) does not appropriately address wider strategic economic needs; iii) fails to reflect the needs of other sectors; iv) risks the Borough losing out on the economic benefits associated with this growth; and v) fails to appropriately identify and meet its objectively assessed employment needs in accordance with paragraph 11 and 35a of the NPPF.
3.120 As a result, we conclude that Policy DS4(S) is unsound (i.e. is not justified, positively prepared, effective or consistent with national policy).
3.121 Cloud Wing note that Policy 72(S) of the adopted Local Plan 2030 is proposed to be retained. This Policy allows proposals for new “B” use class development on sites of 5 ha and above, not previously allocated for those uses to be supported subject to compliance with a number of criteria. Whilst Cloud Wing’s view is that the draft Plan needs to make sufficient provision to meet employment needs now and for the identified needs to be treated as a minimum, it supports the retention of Policy 72(S) as a means of incorporating additional flexibility to accommodate needs not anticipated in the plan, and to enable a rapid response to changes in economic circumstances in accordance with Paragraph 82 of the NPPF.
for accompanying figures see attachment