Issues and Options
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New search10.1 Whilst not appearing to be formally part of this consultation, we note that the HELAA and Site Selection Methodologies have been published alongside the Issues and Options consultation. 10.2 What is of note is that neither methodology appears to recognise the inherent differences between residential and employment sites, and in turn how they should therefore be assessed differently. 10.3 We therefore contend that the Council should produce a separate methodology for employment and residential site assessments and selection, focused on the specific characteristics of each use. 10.4 As a final comment, we would like to reiterate our case that the land at Broadmead is a logical and highly sustainable location for future employment growth. This site is capable of providing an important contribution to current and future employment needs, as evidenced by the live planning application on the site (as summarised in our Call for Sites submission enclosed at Appendix 2 of this Statement). The application includes a marketing report by Savills which sets out the demand for employment development of this type, in this location. 10.5 The Local Plan Review should take the opportunity to proactively plan for the employment needs of the Borough in this highly sustainable location.
2.1 The scope of the Local Plan Review should include specific reference to the Ox-Cam Arc (‘the Arc’) as a key national issue that will have significant impacts and relevance to Bedford Borough. 2.2 There should, therefore, be a specific aim included within the scope of the Local Plan Review that addresses issues and proposals relating to the Arc. 2.3 It is acknowledged that the Government’s White Paper on proposed reforms to the Planning System was published partway through this consultation. Clearly, the scope of the Local Plan Review may have to be adjusted to consider any changes to National Policy which result from the consultation, albeit the timetable for any such changes is currently unclear.
3.1 Firstly, the draft Vision starts with the wording “by the end of the Plan Period”. Whilst the Plan Period sets out the timetable for the Plan’s Policies to achieve their aims, a Local Plan will ultimately have far reaching consequences well beyond the period. 3.2 This is an unambitious and negative approach, and instead, the Vision for the Plan should be one that provides a pathway for life beyond the Plan Period. 3.3 Secondly, the Vision’s focus appears to be on Bedford and greater consideration within the Vision should be given to other areas, particularly Marston Vale, and the opportunities for strategic employment growth. 3.4 This would then reflect the opportunities to deliver a significant increase in high quality employment within the Borough, lowering out commuting and attracting skilled workers to the area. The importance of this as an opportunity is recognised in the Sustainability Appraisal Scoping Report, at para 7.13 3.5 There would then in turn be significant knock on benefits, and therefore the Vision should include a statement that recognises this. Additional wording is therefore suggested as follows: The Vision for Bedford Borough runs through and will extend beyond the Plan Period…. Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 4 In areas such as Marston Vale, the Borough will deliver new high quality jobs which will keep and attract a skilled workforce to the area, and reduce out commuting. This will encourage and deliver sustainable transport and commuting patterns which will in turn deliver environmental benefits for the Borough, its residents and workforce.
4.1 The Plan Period should run to 2050. A period to 2040 is only 10 years beyond the existing Local Plan and is not a sufficiently long enough extension to effect real change. 4.2 As the Council will be aware, strategic growth and development, along with wide scale change, takes many years to deliver. Sites take a long time to plan correctly and then commence delivery, and thus a longer Plan Period should be allowed for. 4.3 Furthermore, by extending to 2050, this would bring the Plan in line with others in the Arc, such as the MK2050 Vision and the Oxford 2050 Plan. Given the strategic and important role that Bedford Borough plays within the Arc, it would represent ‘good planning’ and a holistic approach to align the Local Plan Period with those other areas.
5.1 We propose that an approach including a combination of elements is the most appropriate one to take in this instance. As the consultation sets out, each proposed approach will have advantages and disadvantages. 5.2 For example, taking an urban based growth approach is unlikely to meet the housing and job needs for the Borough, and will also miss opportunities to support and strengthen local communities outside of the urban areas. Meanwhile, a reliance upon new settlements will not meet needs in the shorter term given the long lead in time for new settlements. 5.3 A dispersed approach is inefficient as it discourages sustainable transport given the rural nature of much of the Borough. 5.4 A logical and sustainable approach would be a combination of urban, with a focus on the transport corridors of the A421 and rail corridors, so a combination of “Brown”, “Yellow”, “Pink” and “Orange”. Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 5 5.5 Locations such as that south of Bedford in the Marston Vale show that there are suitable sites which meet most of these criteria, being on the edge of urban areas, close to the A421 and adjacent to the mainline railway line.
6.1 A key element of infrastructure that is often overlooked at the outset is power. The ability to power developments, and, either alongside this or independently, for new renewable energy developments to connect to the grid, is a significant cost consideration. 6.2 Therefore, BBC should be giving careful consideration to energy infrastructure and the ability for development needs to be met at the outset, without large investment sums required that in some instances can prevent sites from coming forward
7.1 The location of employment sites is critical to their success; far more so than housing. In general terms, wherever homes are allocated, they tend to be built and purchased. However, if an employment allocation is put in the wrong location, it may never be realised. Employment site needs are far more specific than housing needs in many ways, and therefore it is vital that employment land is allocated in the most appropriate locations to meet market needs. 7.2 In this region, the strategic road network encourages the growth of large ‘sheds’ – i.e. B8 uses. Whilst historically these were viewed as less skilled, in modern times they now include a large proportion of skilled workers, as their needs and demands have changed. Technicians, programmers and skilled engineers are commonplace in such facilities, whilst they frequently include ancillary offices, with some company HQs located within these facilities. 7.3 Therefore, locations such as those close to the strategic road and rail network are prime locations for such development and should be the focus of future employment allocations. 7.4 AWEL proposes that the land at Broadmead, Marston Vale, is one such suitable, sustainable and deliverable location for a significant new employment site in the Borough. Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 6 7.5 Our submission to the Call for Sites process is set out in more detail within those submissions. In summary, the proposed employment site at Broadmead is a 96ha site for strategic employment development. At this scale, it would be capable of delivering in the region of 335,000sqm of gross employment floor space in an excellent location for strategic employment growth. 7.6 Located adjacent to the railway line, the Broadmead Site is in a sustainable location where it can be accessed by sustainable, nonvehicular means of transport. Employees and visitors could access the site by rail, whilst it is also a commutable cycling distance from Stewartby, Wixams and Wootton. 7.7 A copy of the Call for Sites submission is enclosed within this Statement at Appendix 2.
8.1 Guidance in respect of responding to climate change should be included within the Local Plan, rather than as an additional document. In order to achieve BBC’s Vision and aims, and to respond to climate change, the approach to responding to climate change should be at the heart of the Plan. It should not be left to additional guidance, and instead should be set out in the appropriate level of detail within the Plan. 8.2 In addition, the approach to climate change should include support for innovative and changing technology. It should not be prescriptive, and it should recognise that technology will change rapidly over the lifetime of the Plan. In particular, it should support and actively encourage those applicants who are proposing innovative and ground-breaking solutions which respond to climate change.
9.1 The consultation document sets out sensible suggestions such as safe and green cycleways, dedicated busways or more innovative transport systems and modes. However, what it does not recognise is the importance of locating development in the correct locations which will in Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 7 turn encourage people to make greater use of sustainable modes of transport. 9.2 Placing development near to sustainable transport nodes, or developing new transport nodes and interchanges, will make it more attractive for residents to use those methods of travel. Locating jobs near to existing settlements and homes and new/growing developments, as well as near to existing railway stations will encourage residents to commute by foot, cycle, bus and rail, rather than the car. 9.3 Similarly, improving connectivity between these various locations for non-vehicular means of travel will encourage the use of transport methods other than the private car.
