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Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 4718

Received: 01/09/2021

Representation Summary:

Whilst welcoming a flexible approach to development at Thurleigh Airfield, St Modwen Logistics consider Thurleigh Airfield should be prioritised as a location for Class B (and Class E) employment development. The ELS assessment considers 70% of the site is developable. As such, even with a flexible approach, which St Modwen Logistics welcome and support, the site is a significant source of future employment land and St Modwen Logistics respectfully request that this is taken into account in the Local Plan 2040.

Full text:

These representations are made on behalf of St Modwen Logistics. St Modwen Logistics own and manage Thurleigh Airfield, an established business park and existing allocation, classified as Protect and Enhance and subject to Policy 70 of the Local Plan 2030 (adopted January 2020).

The Employment Land Study, June 2021 (ELS) identifies Thurleigh Airfield as having potential for intensification and recommends that the site remains in the Protect and Enhance category, which St Modwen Logistics support.

However, in considering sources of future supply (Section 8), the additional capacity at Thurleigh Airfield is excluded from the listed existing employment areas that are considered to be able to accommodate future employment growth (paragraphs 8.3-8.4). This is despite the ELS going on (paragraph 8.6) to state that the site has “significant potential to accommodate further B Class employment.”

The ELS (paragraphs 8.6-8.9) identifies Thurleigh Airfield as an ‘Exception Site’ – that is, a site with a “unique offer” where growth “is likely to be driven by factors that are not part of the general economic trends” with sector specific demand more likely (paragraph 8.6), highlighting sectors linked to aerospace, motorsport, life science, recording/ rehearsal space and communications technology (paragraph 8.7). The ELS goes on (paragraph 8.9) to state that due to the site’s location - that is, relative distance to the strategic road network – it is “less attractive to general employment demand” requiring a more flexible approach in terms of uses to ensure a mix of activities that support the aims of the borough and sector specific growth.

Whilst welcoming a flexible approach to development at Thurleigh Airfield, St Modwen Logistics consider Thurleigh Airfield should be prioritised as a location for Class B (and Class E) employment development. Thurleigh Airfield is a thriving and established business destination that at present caters for automotive, communications and logistics industries, offering open storage, warehouse and industrial space with excellent access via the A6 for logistics businesses. In this respect, the ELS assessment of the site notes it as being close to the A6 with adequate direct site access. The ELS assessment considers 70% of the site is developable. As such, even with a flexible approach, which St Modwen Logistics welcome and support, the site is a significant source of future employment land and St Modwen Logistics respectfully request that this is taken into account in the Local Plan 2040.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6674

Received: 14/09/2021

Representation Summary:

Employment strategy
It is understood that the Employment Land Study identifies a need for an additional 53 hectares of land for B8 warehousing and logistics for the period through to 2040. However, the consultation documents explain that the Draft Plan would not seek to make any further provision for B8 warehousing and logistics over and above existing commitments and allocations. The focus of the Draft Plan is creating jobs within other sectors, which is understandable. However, the lack of provision for B8 is likely to be problematic.
The Draft Plan relies upon existing commitments and new allocations now made within the Central Beds Local Plan 2035 to accommodate this demand. It is stated that Central Beds are content with this approach as their plan’s allocations are partly intended to accommodate such ‘foot loose’ demand. However, it is noted that their plan only covers the period to 2035 and that Central Beds will be embarking upon an imminent review and production of a new Local Plan.
Reference is also made within the consultation documents to the fact that the Milton Keynes East allocation within Plan:MK makes additional provision for B8 use for the period through to 2031 and beyond. Whilst this is correct, the precise quantum of B8 land to come forward within Milton Keynes East is still to be determined and, in any event, would be assigned to meeting Milton Keynes’ own demand for such land uses over that period, rather than seeking to meet demands arising beyond Milton Keynes for the period to 2040. It is not clear if that is the intention of the Draft Plan, but if so then this would need to be agreed on a cross-boundary basis as part of the Duty to Cooperate following further technical work and discussion as to how such demands could be met through a ‘larger than local’ strategy for employment land, but in particular land for B8 warehousing and logistics.
There may be merit in pursuing a ‘larger than local’ strategy for meeting B8 demand taking in not just Bedford and Milton Keynes, but also Central Beds and adjacent authorities along the M1 corridor. Such a strategy would be able to take account of how retail and associated warehousing/logistics trends may be shifting as a result of the pandemic and new international trading arrangements for England and the UK, both of which will have effects for businesses within the M1/A421 and A1 transport corridors. It is suggested that this could be raised as a matter for SEMLEP to lead on given the geography it covers.
Notwithstanding the above, based on the Draft Plan as it exists today, we are concerned that a lack of provision to meet the demand for B8 warehousing and logistics land within Bedford through to 2040, with a reliance on provision elsewhere, would ultimately undermine the Local Plan 2040 without the agreement of neighbouring authorities via the Duty to Cooperate. The lack of provision in Bedford over this period is likely to create additional demand for land in neighbouring authorities connected via strategic transport corridors for B8 warehousing and logistics, which may not be capable of being met or would be contrary to their own Economic Strategies.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7468

Received: 21/09/2021

Representation Summary:

5.5 It is clear that the Bedford Business Park proposals have the potential to deliver substantial social, economic and environmental benefits for both Bedford and the wider region.
5.6 Due to the nature of the proposals and the opportunity presented, there has been a significant amount of market interest in the site for employment uses. It is envisaged that the provision of much needed high quality employment space in this location will be attractive to both new businesses relocating to the area and existing local businesses looking to grow. This includes large scale industrial and logistics occupiers, advanced manufacturing and research and development companies which are increasingly seeking high-spec new build premises, rather than second-hand stock. SEMLEP has confirmed that Cloud Wing’s proposals fit well with the strategic economic vision for the area (Appendix 1).
5.7 Furthermore, due to the unique scale and locational characteristics of the site, there is potential to capture regional and national opportunities that would not be possible on a smaller site. Indeed Cloud Wing has been approached by SEMLEP and the DIT to explore the potential for the site to accommodate an EV Gigafactory to support the Country’s transition to electric vehicles which would deliver significant high-quality employment opportunities for Bedford and secure major international investment in high-tech manufacturing.
5.8 It is also being explored whether the site might be well-placed due to its size and location to contribute to the wider modal shift of logistics from road to rail through rail freight opportunities being promoted by the NIC. This modal shift is being driven by wider challenges facing the UK’s freight system including decarbonisation, congestion and how technological advancements can assist in meeting increasing societal demands. The role of rail freight in addressing these challenges has recently been endorsed by the Government in its response to the NIC’s Report ‘Better Delivery: A Challenge for Freight’ which confirms that the ‘Future of Freight’ Strategy is due to be published by the DfT later this year.
5.9 This therefore demonstrates the substantial benefits and opportunities afforded by the Bedford Business Park, which will not only boost local job creation and economic growth, but provide the ability for Bedford to contribute to, and benefit from, national growth objectives and opportunities, shaping Bedford’s identity as a new hub of prosperity at the heart of the Arc.
6.45 The PPG states that a site is: “considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.46 Cloud Wing control the site and therefore there are no legal ownership or other technical impediments to delivering development on the site.
6.47 Furthermore, the site is being actively promoted for economic development and is the subject of an outline planning application currently pending determination.
6.48 Accordingly, the site is available now in NPPF terms.
Availability
“considered available for development, when, on the best information available… there is confidence that there are no legal or ownership impediments to development. For example, land is controlled by a developer or landowner who has expressed an intention to develop”.
6.49 As per the NPPG, a site is considered achievable for development where there is a reasonable prospect that the particular type of development will be developed on the site at a particular point in term, including an assessment of the economic viability of a site.
6.50 Given the scale of development proposed for the site, the development will be delivered over several phases. This will include ground remediation works and the delivery of transport infrastructure in the first phases, as set out below:
Achievable
Phase 1 – ground remediation works in the location of the former Kempston Hardwick brickworks
Phase 2 – construction of bridge proposed over the railway line and main road infrastructure
Phase 3 – construction of employment uses in areas where no ground remediation works are required
Phase 4 – construction of employment uses on the former Kempston Hardwick brickworks location
Phase 5 – construction of employment uses in the south of the site.
6.51 Whilst the timings for delivery are dependent on achieving a planning permission and identification of a Development Partner, both of which are currently ongoing, it is anticipated that it would be possible to start on site with site clearance, remediation and enabling works within 6 months of receiving an outline planning permission, following the discharge of any relevant planning conditions. It is anticipated that works to deliver the primary infrastructure for the first phase would then commence approximately 6 months later, following the grant of reserved matters, with the aim of the first phase being complete and ready for occupation within 18 months. 6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
6.52 As set out above, there are no significant site constraints that might prevent development or make the development unviable.
6.53 Therefore, it is considered that the site is achievable for development as there is a realistic timeframe for development and there are no economic viability constraints that would hinder delivery.
Deliverability Summary
6.54 Therefore, it is considered that the site is deliverable in line with the NPPF as it is a suitable location for development, it is available and there is a realistic prospect that development will be developed on the site.
Changes requested:
– That the Council recognise the substantial benefits and opportunities presented by the Bedford Business Park by identifying it as a proposed allocation in the emerging Local Plan.
– We request that the site is formally allocated for economic development within the emerging Local Plan and that the Site Selection Methodology be amended to better reflect the range of factors and key characteristics that are relevant for assessing the merits of employment land.
See 59 page attachment relating to Bedford Business Park.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8066

Received: 03/09/2021

Representation Summary:

The current plan policy in the BBLP 2030 which was adopted in January 2020 plans provides polices and allocations until 2030. However, 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. 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 new build 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 a need for small business premises continues to be change in the type of employment being delivered.

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, in and around the Great Barford which can add to the employment provision. This submission seeks to include land between Addington Road and New Road Great Barford as an area which can accommodate employment provision. This is an area which is going to see considerable infrastructure improvements as a result of the A421/East West Rail Link and is well located to provide employment opportunities close to these improvements. Additionally, it is well located to provide employment for Great Barford. National Planning Framework supports the provision of rural employment.

A considerable number of the existing employment sites are simply not suitable for modern employment use and portfolio of employment sites needs to be increased to encourage the economic diversity required for sustainable growth. The employment study confirms it has not taken account of the vacant stock and this is a weakness in the conclusions then enshrined in the Issues and Options. The vacancy of the sites indicates not a lack of interest, but a lack of suitability.

The options for growth identified as 2a, 2b, 2c and 2d seek new settlements at Wyboston and or Little Barford. In conjunction the EEH transport study provides a framework across the region for transport growth. The Employment Study at para 9.6 recognises the importance of this new infrastructure. However, it needs to consider that some rural employment use is needed to support the rural economy.

The options for growth in 2d seeks growth along the eastern transport corridor. The site is, and the surrounding land is well placed to contribute to that growth and could form part of the employment requirement.

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. A number of additional rural sites could be provided to address supply matters and support the need for types of employment not well suited to existing or the new employment business parks but can be accommodated in rural employment areas.

This is a site which should be protected for employment purposes.

The plan and evidence need to consider the role that rural employment sites can contribute to the supply in greater detail. Polices 69, 70 and 71 should be revised to address this matter.