Comment

Representation ID: 9709

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

4.5 The evidence underpinning these policies has also failed to consider all reasonable alternatives, including a larger amount of employment land27. The SA’s assessment of the employment land options is flawed. It considers three options: C) 90Ha (more high density office development); D) 142Ha; and E) 206Ha (lower density office/ business park dev with more warehousing). These options do not appear to be consistent with those presented in the Employment
27 We note that the employment land options considered in the Sustainability Appraisal Report do not appear to reflect those presented in the Employment Land Study 2022. It is not clear why this is the case.
Land Study 2022. In addition, the SA concludes that ‘Option E’ (i.e. the option delivering the most employment) is worst performing including in terms of ‘improving air quality’, ‘reducing carbon dioxide’, ‘improving energy efficiency’, ‘reducing the need to travel and promote sustainable modes of travel’.
4.6 The SA appears to have reached this conclusion on the basis that this option would result in greater increase in private car use and commercial vehicle use than other options with less warehousing. However, this assessment is overly simplistic and fails to consider that the Council’s strategy of relying on neighbouring authorities to meet strategic warehousing needs could result in promotion of less sustainable commuting patterns and freight movements than would be the case than if those needs were met locally within close proximity to the existing and proposed population in Bedford. It also fails to recognise the strategic importance of logistics as critical infrastructure nationally, regionally and locally or the Government’s ambitions to achieve a net zero freight sector by 2050.
4.7 Option E also scores more poorly than Option D against the objective of promoting a strong, sustainable and balanced economic growth stimulating job creation across a range of sectors. It is not clear why this is the case, the SA simply suggests that low density office development with greater proportion of warehousing “uncertain whether this will be viable locally”. The market evidence above clearly demonstrates that warehousing is viable in this location.
4.8 The Development Strategy Options Paper (DSO) and SA also consider a range of strategy options as ‘reasonable alternatives’. The SA notes that for the purpose of identifying ‘reasonable alternatives’ the aim is to consider options that could meet the dwelling and employment requirement to 2040. However, it later goes onto state that the employment requirement is not considered an overriding constraint in generating options. Indeed, it is acknowledged in the DSO that most of the ‘reasonable alternatives’ identified would fail to achieve the amount of employment land contemplated in the Plan without additional sites being identified along the A421 corridor, the implications of which do not appear to have been considered as part of the assessment of strategy options. Overall, whilst we agree with and support the identification of the area around Kempston Hardwick as a location for significant growth, Cloud Wing is concerned that the approach to the distribution of other employment land in the Borough is not appropriately justified.
4.9 Cloud Wing is also concerned that the approach taken means that the opportunity presented by a larger Business Park, incorporating a mix of employment uses, on Cloud Wing’s land to the South of Bedford as part of the overall spatial strategy and distribution of employment growth, has not been appropriately considered or assessed as a ‘reasonable alternative’ as part of the Council’s Local Plan evidence base. This approach risks missing a major opportunity for economic growth on a transformative scale that is well-located to benefit from improved rail connectivity.
4.10 More generally, the Council’s approach to the assessment of and selection of ‘other employment sites’, particularly those along the A421 Corridor, is not clear or transparent. Para 5.18 of the DSO states that other potential employment locations “have been assessed according to their accessibility, visibility and proximity to strategic transport routes, and their compatibility with neighbouring uses”. However, there does not appear to be any evidence of this in the evidence provided beyond the general site assessment proforma in the appendices to the HELAA and no explanation on how judgements have been reached about particular sites.
4.11 Cloud Wing remain concerned that the Council’s proposed spatial strategy results in a ‘piecemeal’ approach to employment development elsewhere across the Borough, and an over-reliance on ‘innovation’ uses to deliver its economic needs. This approach would result in a number of individual developments
without the critical mass to generate the level of investment required to facilitate the infrastructure needed and deliver sustainable economic development. It is also unlikely that innovation uses alone would be able to generate the significant uplifts in land value that major industrial and logistics schemes generate28 and that are often needed to fund strategic infrastructure requirements (e.g. new and improved junctions on the strategic road network and link roads) and can support the delivery of other infrastructure that is required to support housing delivery on mixed-use schemes.
4.12 For example, at the Linmere development in Houghton Regis in Central Bedfordshire the delivery of large scale logistics space alongside 5,000 dwellings and other uses has provided upfront funding to support the delivery of early infrastructure for the wider scheme29. A piecemeal approach to employment development across Bedford and over-reliance on innovation uses would result in individual developments each without the critical mass and market conditions to generate the level of investment required to facilitate the infrastructure needed to support the scale of development anticipated and deliver sustainable economic development.
28 BPF (2022) Levelling up - Logic of Logistics
29 BPF (2022) Levelling up - Logic of Logistics