Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9719

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

Representation Summary:

6.1 Cloud Wing supports the principle of the allocation of the land at Kempston Hardwick for development. However, for the reasons set out in detail at Sections 3, 4 and 5 of these representations, Policy HOU14 proposes insufficient employment land on Cloud Wing’s land at Kempston Hardwick. Cloud Wing also has significant concerns over the overreliance and inappropriate emphasis on delivery of innovation uses at the site, which do not appear to be justified and pose risks to the delivery of economic needs and the overall effectiveness of the Plan. The allocation should state “employment uses”, rather than specifically identifying innovation uses. It should also be amended to recognise the fact that additional Class B8 logistics uses would generate significant uplifts in land value, that could support early investment in the infrastructure required to support housing development at the site.
6.2 Cloud Wing is also concerned by references in the draft Plan and its supporting evidence which suggest that development at Kempston Hardwick and other strategic sites would only be able to come forward post-2030 following the delivery of East-West Rail and completion of various highway improvements, which in turn appears to be driving the Council’s proposed approach to a stepped housing trajectory.
6.3 However, for the reasons set out in detail at paragraphs 6.9 to 6.69 below, a larger amount of employment land, including industrial and logistics uses, could start to be delivered earlier than 2030. The site is already a suitable location for employment growth. It is accessible by public transport and would be capable of supporting early delivery of infrastructure improvements including improvements to the surrounding highway network (i.e. the package of improvement works to Junction 13 of the M1 and the junction of the A6 and A421 which have been developed in detail through discussion with Highways England as part of the outline planning application for the Bedford Business Park) and deliver sustainable transport improvements (i.e. improvements to pedestrian and cycle accessibility and public transport).
6.4 On this basis, the Plan and draft Policy HOU14 risks unnecessarily delaying delivery of growth in a sustainable, suitable location and failing to meet economic needs in the short-term. Cloud Wing support the principle of mixed-use development at Kempston Hardwick and the allocation of the land in HOU14 as a strategic allocation for growth in Bedford Borough. However, for the reasons set out above, the quantum of employment development on Cloud Wing’s land should be increased. AWG is promoting further land directly adjoins the HOU14 that could accommodate additional residential development, where required.
6.5 In this context, it is in Cloud Wing’s view entirely inappropriate for employment development at the site to be delayed until late in the plan period and for the policy to prevent permission being granted until such time that a Supplementary Planning Document has been prepared by the local authority. Whilst we agree that further work would be required to develop a robust Infrastructure Delivery Plan for the site and support the Council’s view that development at Kempston Hardwick should be landscape-led and of high quality design, underpinned by an appropriate masterplan, the proposed approach has the potential to delay and undermine delivery of development early in the plan-period. The Policy should, therefore, be amended to allow flexibility for the landowners/ developers to prepare their own masterplan and design code, in accordance with paragraph 129 of the NPPF.
6.6 The detailed criteria set out in Policy HOU14, the concept plan and the infrastructure identified in the Infrastructure Delivery Plan and Transport Strategy would also need to be reviewed, updated and amended, as appropriate, to reflect changes to the quantum and mix of residential and employment development proposed in response to our comments above.
6.7 Our comments on the assessment of the site as part of the appendices to the HELAA and Sustainability Appraisal remain as set out in the comments on the Strategy Options and Draft Policies Consultation (see Appendix 2).

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