Policy E1S

Support

Representation ID: 3553

Received: 11/08/2021

Respondent: Ms Claudia Dietz

The approach should be: brownfield sites first and expansion of existing employment areas before considering/allowing use of greenfield site.

Object

Representation ID: 3833

Received: 26/08/2021

Respondent: Roxton Parish Council

RPC firmly believes that this policy should refer to policy 75 in the Local Plan 2030, specifically that
development in the countryside would not create significant demonstrable harm of the area. RPC also
believes 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: 4400

Received: 31/08/2021

Respondent: Mr Kulwinder Rai

There is a singular lack of originality with respect to the amount and distribution of employment development planned in the rural area. That, however, is not so surprising given that the BCC's vision for the countryside is that it be preserved in amber as it is. BCC should be encouraging the formation and development of knowledge-based employment opportunities in rural areas. This would bring, in tow, massive improvements in the the delivery of high speed broadband infrastructure, which would benefit rural communities more generally.

Object

Representation ID: 4723

Received: 01/09/2021

Respondent: Barton Willmore

St Modwen Logistics respectfully request amendments to: (i) state that employment sites that are already allocated remain a focus for growth; and (ii) reflect the Town and Country Planning (Use Classes) (Amendment) (England) Regulations 2020 which took effect on 1st September 2020.

Support

Representation ID: 4789

Received: 01/09/2021

Respondent: Great Denham Parish Council

The Council would ask that reference is made in this section to the growing home-based businesses and how these will be supported (and measured) in the Local Plan 2040. Growth of home-based business, and also home-based employees, has increased as a result of the Covid-19 pandemic and is expected to continue. Suitable technology and policy provisions should be included to reflect this.

Object

Representation ID: 5923

Received: 08/09/2021

Respondent: Ellen Langdon, Director

Agent: Town Planning Services

Colworth Park is identified as an existing 'Key Employment Site' within the development plan and is therefore afforded support under Policy 70 of the adopted 'Bedford Local Plan 2030'. It is currently considered to fall
within the 'Protect and Maintain' category, based on the Bedford Borough Council 'Economy and Employment
Land Study' 2015 (Table 24). Sites within the 'Protect and Maintain' category are those which are "broadly fit
for purpose with a large proportion of floorspace … likely to meet ongoing requirements" ('Bedford Borough
Local Plan 2030' §11.10). The adopted development plan states that on such sites, the Council will support
investment and improvement in stock provision over the plan period.
The Council's 'Employment Land Study Review' 2021 provides a more recent assessment of existing
employment sites within the Borough, including Colworth Park. This now suggests the site now falls within the
'Protect and Enhance' category (§6.18).
In accordance with the adopted development plan, sites within the 'Protect and Enhance' category will "play the
primary role in supporting economic development and growth by offering attractive and available opportunities
for the development of additional land and sites to retain and support expansion of existing occupiers, as well
as helping secure new inward investment" ('Bedford Local Plan 2030' §11.11). The local plan goes on to state
that key growth sectors will include 'Research and Development' amongst others. It further remarks that:
" … Whilst in general the stock of employment space within the employment sites is fit for purpose and meets
current occupier requirements there are some areas of weaker provision which are unfit for purpose and that
could be redeveloped for employment uses to strengthen the offer that the key employment sites could provide
… "
At the outset, we would endorse the site's elevated status that is now recognised within the updated
Employment Land Study Review. Nevertheless, there are a number of corrections and clarifications to be made
within the Council appraisal of Colworth Park, and we believe that the future scope for the Park's development
is underestimated.
To assist, we attach an annotated version of the Council's site assessment. [see separate attachment] We will not repeat these
annotations, but it is helpful to review the key points. In particular, the site's status as a high quality research
and development centre should be recognised. Anchored by Unilver, Colworth Park provides a centre for
collaboration and acts as a community specifically created to support innovation and business growth in the
food and drink sector. It provides shared laboratory space together with offices, kitchens and production
facilities. It is intended to create a hub of established businesses alongside start-ups, academic research and
social enterprises. It has successfully attracted occupiers of international significance who wish to have
representation in the UK.
The focus of the Park reflects the site's location, equidistant between Oxford and Cambridge and Trinity
Investment Management is aware that there is considerable demand for high quality, affordable laboratory and research space.
The assessment of Colworth Park within the 'Employment Land Study Review' 2021 omits reference to the
site's most recent planning history. In this regard, the Council granted planning permission for the erection of
a new building of 3,360sqm gross floorspace. This will accommodate Unilever's Advanced Manufacturing
functions, providing engineering facilities needed for rapid prototyping and the development of new products
and manufacturing processes. Planning permission was granted at the beginning of 2021 (Planning Permission
Reference 20/02360/MAF. In addition, it should be recognised that planning permission was granted for the
development of a hydroponics facility of 8,446sqm gross floorspace Planning Permission Reference
20/02431/MAF granted 28 January 2021). The grant of these permissions demonstrates both the demand for
additional space, and the site's capacity to accommodate further development.
In addition, it should be recognised that the site contains a considerable quantity of vacant floorspace. Although
some redundant buildings have previously been developed, the site currently has some 5,500sqm of vacant floorspace. Once Unilever relocate to the new Advanced Manufacturing Facility a further 5,000sqm of
floorspace will become vacant.
Although the site occupies a 'rural' location, it must be recognised that it adjoins the defined settlement boundary of Sharnbrook. Sharnbrook is identified as a 'Key Service Centre' and is expected to accommodate an
additional 500 new dwellings within the adopted 'Bedford Local Plan 2030' (Policy 4S). Accordingly, it
represents a sustainable location and it important to provide employment opportunities to accompany the
anticipated housing growth within the settlement. It is anticipated that additional enhancement might be made
to the accessibility of the park to accompany further floorspace.
Taking account of the above, it is considered that the new local plan should seek to maximise the potential of
existing Key Employment Sites, alongside the allocation of new land. Colworth Park offers a considerable
potential to provide a flagship research and development centre within Bedford, capitalising upon its already
well-established focus on scientific research within the food and drink, flavouring, nutrition and fragrance
sectors. The site provides significant scope to accommodate new development to support this existing function
and to further consolidate its position in the Oxford-Cambridge Arc.
The delivery of new floorspace can be considered alongside the potential demolition of existing floorspace;
improvements to the Colworth House as a Grade II Listed Building; and appropriate enhancements to the site's
accessibility. We therefore believe that Colworth Park should be identified within the 'Maintain and Develop'
category, and that the site's capacity should be explored through the preparation of a masterplan.

Support

Representation ID: 6070

Received: 09/09/2021

Respondent: Countryside Properties

Agent: Phillips Planning Services

3.25. We support the policy of creating a minimum of 8,642 net additional jobs up to 2040. A reasonable proportion of this growth should be facilitated along the A421 in line with the Governments objective of providing over a million jobs across the Oxford – Cambridge Arc by 2050.

3.26. Land West Of The Village Of Great Barford South Of The A421 (Site 878) has excellent links onto the A421. Small scale employment provision in this location would further enhance the sustainability of Great Barford as a Key Service Centre.

Object

Representation ID: 6187

Received: 09/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy E1S (Amount and Distribution of Employment Development) – Comment
2.1 The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended Plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
2.2 However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in Key Service Centres and Rural Service Centres. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
2.3 Our client’s site at Highfield Road, Oakley, would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters (including access, ecology, and landscape). these parameters would be satisfied.
2.4 Additionally, and should our client’s land not be allocated, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the expansion and intensification of existing safeguarded employment uses within suitably located adjacent sites.
2.5 Paragraph 6.12 of the Council’s consultation document is also noted with regards recent changes to the Use Classes Order. As well as amending policies within the existing LP2030 it is necessary that criteria (i) and (ii) of proposed Policy E1S also recognise that support for economic development in accordance with the strategy, and on unallocated sites, extends across Use Classes B2, B8 and Class E. Criteria (ii), as drafted, refers only to ‘B-uses’. It is not considered necessary for suitable opportunities to be limited only to ‘business’ uses within Class E as suggested by the Council’s paragraph 6.12.
2.6 This is contrary to the flexibility sought by the changes to the Use Classes Order. This approach is also ineffective, as it would not apply to existing lawful former B1 uses within existing employment areas would in most cases benefit from opportunities to provide a wider range of commercial uses under Permitted Development Rights. This could, for example, in principle allow a more diverse range of occupiers at the existing Highfield Park site, commensurate with its location well-related to the settlement of Oakley and wider transport network. The same flexibility should be applied to the Council’s policy criteria when assessing new development proposals.

Support

Representation ID: 6248

Received: 09/09/2021

Respondent: IM Land

Agent: Barton Willmore

Due to the reassessment of the need for employment land, Policy 69S of the adopted Local Plan 2030 will need to be updated. This will therefore be replaced by proposed ‘Policy E1S - Amount and distribution of employment development’. This requires that:
“A minimum of 8,642 net additional jobs will be provided to 2040.
i. The main focus for jobs growth will be in accordance with the plan’s development strategy.
ii. Applications for B use class employment on sites that are not allocated will be determined in accordance with Policy 72S of Bedford Local Plan 2030. Proposals for non-B class employment on key employment sites will be determined in accordance with Policy 70 of Bedford Local Plan 2030.”
We agree with the amended drafting of the policy to reflect an increased requirement of jobs (although the exact require should be subject to consideration of responses of this consultation) and the changes to the spatial strategy.

Object

Representation ID: 6553

Received: 13/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

Policy E1S (Amount and Distribution of Employment Development) – Comment
2.1 The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
2.2 However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in Key Service Centres and Rural Service Centres. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
2.3 Our client’s site at Rushden Road, Milton Ernest, would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters (including access, ecology, and landscape). these parameters would be satisfied. Criteria (i) should be modified to reflect that the Development Strategy supports the expansion and intensification of existing sites.
2.4 Additionally, and should our client’s land not be allocated or specifically designated within the Policies Map, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the expansion and intensification of existing safeguarded employment uses within suitably located adjacent sites.

Support

Representation ID: 6667

Received: 14/09/2021

Respondent: Stevington Parish Council

SPC is generally supportive of the employment policies although it may well be sensible to consider the addition of a policy condition to the supply timeline similar to point 3.5 (Growth and spatial strategy options) that allows for employment site delivery to be linked to known housing demand as the two are intrinsically linked.
SPC would support particular attention being paid to attracting companies and employment opportunities which will support local efforts to decarbonise the economy (e.g., electrification of transport and homes)
and enhance the biodiversity of the borough (e.g., many more ecologists/ wild life /environmental specialists will be needed to enable the county to deliver a greener more biodiverse environment.

Object

Representation ID: 7168

Received: 17/09/2021

Respondent: C Jackson & Sons (Bedford) LTD

Agent: Phillips Planning Services

We support the creation of a minimum of 8,642 net additional jobs up to 2040. However, the policy does not support the expansion of existing employment sites, and for the plan to be considered as “positively prepared”, we would welcome a more positive policy framework which supports the principle of the expansion of existing employment sites wherever they are in the Borough. A more positive policy context would then encourage proper investment in exploring these opportunities.

Object

Representation ID: 7448

Received: 03/09/2021

Respondent: Phillip C Bath Ltd

Agent: DLP Planning Limited

The policy sets out the requirement for a minimum of 8,642 net additional jobs will be provided to 2040. Principally we support Policy E1S and meeting the requirement for additional allocations to meet needs for economic development over the extended plan period. Support for the approach is provided notwithstanding our wider objection to the Council’s position regarding forecasting demand for jobs growth (potentially failing to ensure a sustainable balance between jobs and homes) and its Preferred Options published for consultation (too inflexible).
However, in order to be considered sound proposed policy criteria (i) also requires modification. This is in order to reflect that the development strategy includes providing support for economic development in the ‘east’ corridor parishes outside of potential strategic allocations. This is necessary in terms of maintaining sustainable patterns of development and the ability to respond flexibly to changing patterns of demand.
Our client’s site at High Barns Farm would satisfy this requirement and would satisfy other appropriately worded policy parameters on all technical matters.
Additionally, and should our client’s land not be allocated or specifically designated within the Policies Map, criteria (ii) should be modified to specify that the circumstances where providing support for development on unallocated sites include the re-use and conversion of existing sites in the rural area to support diversification and a prosperous rural economy.
Paragraph 6.12 of the Council’s consultation document is also noted with regards recent changes to the Use Classes Order. As well as amending policies within the existing LP2030 it is necessary that criteria (i) and (ii) of proposed Policy E1S also recognise that support for economic development in accordance with the strategy, and on unallocated sites, extends across Use Classes B2, B8 and Class E. Criteria (ii), as drafted, refers only to ‘B-uses’. It is not considered necessary for suitable opportunities to be limited only to ‘business’ uses within Class E as suggested by the Council’s paragraph 6.12.
This is contrary to the flexibility sought by the changes to the Use Classes Order. This approach is also ineffective, as it would not apply to existing lawful former B1 uses within existing employment areas would in most cases benefit from opportunities to provide a wider range of commercial uses under Permitted Development Rights. The same flexibility should be applied to the Council’s policy criteria when assessing new development proposals.

Object

Representation ID: 7566

Received: 21/09/2021

Respondent: L&P Chess Ltd

Agent: Eclipse Planning Service

Turning to Section 6 and employment, we acknowledge that the relationships between land, plot ratios and jobs are difficult to define. We note draft Policy E1S which refers to the remarkably precise figure of 8,642 net additional jobs in the Plan period. Yet there are wide variations in the amount of land proposed to meet this requirement. Not all job growth will necessarily be in sectors which require the allocation of land. We note what paragraph 6.6 says about the “most appropriate” figure of 171 hectares in total and the net requirement of 123 hectares. However, neither of these figures can be related (on the basis of what appears in this document) to the range of 131 to 179 hectares in the four options; nor is there any indication of whether these figures are themselves gross or net. Paragraph 6.8 is inconsistent with both paragraph 6.6 and the options: making due allowance for the word “about” in relation to the three sites of 30 hectares, the total here amounts to around 153 hectares. The key point however is that whatever figure for employment land eventually emerges from the Local Plan process, Site 951 should be regarded, for employment as well as housing, as a common element to all options.