Policy DM8 New employment development in the countryside

Object

Representation ID: 9416

Received: 29/07/2022

Respondent: O&H Land

Agent: Varsity Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

As currently drafted, Policy DM8 is unclear, overly restrictive and will be difficult to interpret and apply.

Support

Representation ID: 9434

Received: 29/07/2022

Respondent: Bourne Rural Planning Consultancy Limited

Support

Object

Representation ID: 9441

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Please see attached report

Comment

Representation ID: 9696

Received: 26/07/2022

Respondent: Historic England

We suggest that criterion ix specifically mentions the historic environment (we appreciate that policy 41S is the historic environment policy).

Comment

Representation ID: 9821

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

Policy DM8 New employment development in the countryside – The current Policy 75 of Local Plan 2030 contains an additional requirement: “The proposed use needs to be in the rural area and cannot be located within a Settlement Policy Area or within a designated Small Settlement.” It is not explained why this is now omitted and we must question this.

Comment

Representation ID: 9923

Received: 28/07/2022

Respondent: Amnaat Ltd

Agent: Aragon Land and Planning

Employment and the nature of the local economy has seen significant changes with regard to the needs for employment in the region and Bedford Borough. Some of these changes have also been influenced by the Pandemic which has resulted in a number of employment changes, including a significant growth in home working and a greater demand for logistics and storage. The trend locally has also seen both a significant increase in large warehouse development on the edge of Bedford/A421 and second, very little or new employment in the older and historic employment areas whilst some re use has occurred very little inward investment in the older employment areas has taken place.

There have been notable changes of use away from employment uses to retail and leisure opportunities within these historic employment areas as the market readjusts to try and re use some of these sites. Bedford with its connections to the M1 and A1 and central location is also well positioned to provide for logistics. The Pandemic has highlighted the importance and value of logistics and with retail changes this continues to be change in the type of employment being delivered.

The Framework in para 85 strongly recognises that sites are needed to meet local business and community needs in the rural area.

Accordingly, this is a submission seeking changes to the employment approach in the local plan polices to facilitate development on land outside the settlement areas and allocate land close to Great Barford for Employment purposes. This is an area which is going to see considerable infrastructure improvements as a result of the A421/East West Rail Link. The new allocation of EMP8 (and EMP7) now recognises the principle that land around the black cat roundabout can be developed for employment, however land closer to settlements like Great Barford would achieve a fundamental sustainable objective of placing employment need housing.



Some of this B8 demand is described as “footloose “and it will not all be achieved within Central Bedfordshire. It is likely this further footloose demand around the transport interchanges can be expected to continue and again will contribute to employment supply and this further weakens the need for these smaller older central sites to remain as part of the employment supply. The concept of storage and employment located towards the east of Bedford is now established in principle.
The infrastructure changes with the A421, the East-West rail link will see a much wider opportunity to locate employment and distribution around these hubs which are significantly better served for more up to date forms of employment and closer to transport links. The employment study at 9.3 recognizes
The local plan should make sufficient land allocations to meet this quantitative requirement, however it should also recognise that non-B class employment and complementary uses also need land. Experience has shown that the attributes that make employment land attractive to B class activities also attracts a variety of ancillary and complementary non-B class activities.

The Employment Study needs to take a more critical look at the existing employment vacancy and how realistic it is for sites having remained vacant to realistically contribute to employment land supply. This vacant land needs to be taken out the supply figures and new sites such as land at New Road Great Barford allocated or the area identified as one supporting local employment growth. The point(s) made at 9.11 in the Employment Study which lists the characteristics for identifying land. This is a site which sits next to an existing employment use and is well screened with a mature tree cover and can meet the site characteristics needed for identifying the land. Some further changes to DM8 could also support the allocation.

Comment

Representation ID: 10295

Received: 29/07/2022

Respondent: Roxton Parish Council

6.68 Employment in the countryside:
Regarding Policy DM8, it is the strong view of Roxton Parish Council that any development to the Southwest of the Black Cat roundabout in the vicinity of Roxton will contravene this policy, specifically with regards to clauses viii, ix and x. Roxton PC also believe that clauses (i) to (v) will not be met if considered at this point in time.
RPC request policy DM8 should refer to policy 75 in the Local Plan 2030, specifically that development in the countryside would not create significant demonstrable harm of an area. RPC also believe that this policy should refer to policy 7S of Local Plan 2030 in terms of the need to demonstrate community need, community support and Parish Council support.

Object

Representation ID: 10309

Received: 29/07/2022

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our client supports with reservations the Council’s proposed update to Policy 75 of the adopted Local Plan 2030 and the policy objective to improve opportunities for new employment in the countryside.

This representation addresses our client’s interests that were submitted and the subject of comments at previous consultation stages:

• Land at Rushden Road, Milton Ernest (Site ID: 852) – supporting the intensification and enhancement of existing commercial floorspace
• Land at Highfield Road, Oakley (Site ID: 1000) – providing opportunities for economic development and jobs growth adjacent existing employment provision

In both cases our client’s interests would be supported by the proposed criterion in Policy DM8 to enable the enlargement of existing employment areas. Our client would endorse that these provisions are necessary for consistency with national policy to support a prosperous rural economy and to allow all settlements to grow and thrive. This was advocated as part of our client’s previous submissions, noting in-particular the distribution of land for economic development across Key Service Centre and Rural Service Centre locations to the north of the borough (including at these two locations) and the reasons to support housing and employment growth at these centres within the settlement hierarchy.

Notwithstanding this, we have reservations regarding the soundness of the proposed approach in terms of the effectiveness of the policy, specifically in relation to the definition of enlargement of existing employment areas. This is considered to be overly restrictive and potentially imprecise in terms of the opportunities the policy would support. The supporting text to the policy does not explain whether this approach would support development outside of existing settlement policy area boundaries or the circumstances where this would be appropriate.
For example, our client’s land at Highfield Road operates on a tightly defined site enclosed by existing road boundaries. However, land to the south and west is functionally well-related to the successful existing facilities and functionally-related to the adjoining settlement at Oakley and thus would represent a suitable location for economic development in accordance with the objectives of the policy and wider strategy.

Therefore, as drafted we consider that Policy DM8 is unsound as it is not effective, but is capable of Modifications as described below.

Object

Representation ID: 10396

Received: 29/07/2022

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM8 – New employment development in the countryside –
This policy is intended to replace Local Plan 2030 Policy 75 in order to make it more effective in its implementation.
We support the amendments to this policy, which include an update to the wording at criterion (i) which now allows new development within an existing employment area whereas previously, this criterion related only to development within a defined employment area. This provides greater flexibility for sustainable development to come forward on existing employment sites within the countryside.