Policy EMP7 Land at College Farm, Black Cat roundabout

Comment

Representation ID: 9260

Received: 27/07/2022

Respondent: Mrs Alison Myers

The site should be an exemplar for landscape integration as this is a highly visually exposed site and care is required to avoid linear development beside the A1. Quality drainage schemes would integrate with the quarry restoration .

Comment

Representation ID: 9693

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site, there is a grade II listed building, Brook Cottages, to the north of the site. To the south of the site lies to scheduled monument, Tempsford Bridge which is also grade II listed. Any development of this site has the potential to impact upon these heritage assets and their settings.
A heritage appraisal has been prepared for the site. However, the appraisal only considers the bridge and not the cottage to the north. The appraisal doesn’t make any recommendations for the site in terms of mitigation and enhancement measures. The heritage appraisal should be reviewed to include recommendations for the site.
Given the scale of the proposed employment development including warehousing and distribution, it is our view that development is likely to have an impact on the setting of the bridge.
The appraisal should make recommendations in relation to heights, mass, colours, materials and landscaping to help mitigate the impact of the development upon heritage.
We broadly welcome criterion v. There should be an additional criterion to refer to nearby heritage assets and including specific mitigation measures and enhancements informed by the revised heritage appraisal.

Comment

Representation ID: 9724

Received: 26/07/2022

Respondent: Historic England

For some sites an HIA has been prepared but is incomplete. Some are still marked Draft. Others only complete 2 or 3 steps of the 5 step methodology for HIAs set out on page 5 of the HE Advice Note 3 – Site Allocations in Local Plans:
https://historicengland.org.uk/images-books/publications/historic-environment-andsite-
allocations-in-local-plans/ Some do not identify impact (step 3), others do not consider maximising enhancement, avoiding harm and mitigation (step 4), others do not determine whether the proposed site allocation is appropriate in light of the NPPFs test of soundness (step 5).
These include sites EMP6, EMP7 and EMP8.
In these cases, please ensure that the HIA is complete and that any recommendations have been used to inform the policy wording in the Plan.

Comment

Representation ID: 9921

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: 10053

Received: 28/07/2022

Respondent: Mr - Brown

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.

Accordingly, this is a submission seeking changes to the employment approach in the local plan polices to facilitate development on land outside the settlement area, in and around the A421/Roxton which can add to the employment provision. This submission seeks to include land between Bedford Road and Roxton Road Roxton (site 820) 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. The new allocation of EMP8 now recognizes the principle that land around the black cat roundabout can be developed for warehousing and distribution.

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 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 Bedford Road Roxton allocated or the area identified as one supporting further logistics and warehouse 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 regard to the A421/ Bedford Road and would make a useful contribution as an employment allocation. It would meet those identifiable site characteristics. It would be a supportive allocation to EMP7 & 8.

It is correct CBC has allocated some supply for “footloose” demand, these sites were not to address supply in the immediate area and therefore these allocations should not be used to minimize the proposed current local plan allocations.

Comment

Representation ID: 10287

Received: 29/07/2022

Respondent: Roxton Parish Council

Section 4.98 – College Farm Development
Impact of the potential development at College Farm, Black Cat roundabout on the local area including Roxton. Noise, light pollution and 24 hr nature of such a site.

Support

Representation ID: 10303

Received: 29/07/2022

Respondent: Natural England

Policy EMP7: Land at College Farm, Black Cat roundabout, Policy EMP8 Land at Roxton, south west of the Black Cat roundabout
Natural England notes the principle outlined in both policies which states that a “submission of a wildlife and habitat survey with appropriate mitigation and enhancements” will need be required. As these policies are situated approximately between 17km and 18km away from Eversden & Wimpole Woods SAC, we welcome this commitment, as the SAC is designated for its Barbastelle bat (Barbastella barbastellus) interest, which can have a foraging range of up to 20km.