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

Object

Representation ID: 7466

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

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

Representation ID: 7468

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

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

Representation ID: 7469

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

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

Representation ID: 7470

Received: 21/09/2021

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

6.55 It is understood that as part of the Bedford Local Plan 2040, the Council will identify site’s to be allocated for employment land and these will be identified at the Regulation 19 Consultation Stage.
6.56 The methodology for this site selection process is set out in the Site Selection Methodology (2021). This sets out that each site is to be assessed against 15 sustainability objectives to test the social, economic and environmental impacts of development in response to key issues in the local area.
6.57 Sites are rated based upon how well they perform against each of the questions contained within the 15 objectives, from ‘major positive effect’ to ‘major negative effect’.
6.58 The initial assessment for all sites submitted as part of the 2020 Call for Sites process has also been published as part of the Reg 18 Local Plan. The Bedford Business Park is included within this as site reference 809.
6.59 Whilst we consider the Site Selection Methodology is a useful tool for considering sites suitable for residential development, we do not consider that all of the criteria are relevant when assessing sites for employment land allocations. For example, a number of the assessment criteria concern a site’s proximity to primary schools, food stores and sports facilities. We consider this is more important when considering the location of new housing developments and that there are different priorities when considering locations appropriate for employment uses, such as proximity to the strategic road network. In addition a number of these criteria are repeated under a number of the sustainability objectives which risks applying an inappropriate weighting to those criteria in the site assessment process.
6.60 Furthermore, the Site Selection Methodology is weighted towards housing development in terms of assessing flood risk. Sites which are located within flood zones 2 or 3a are automatically rated as having a negative or major negative effect on this basis. However, this does not take into account that the NPPF guidance sets out that less vulnerable uses (such as employment uses) may be suitable within flood zones 2 and 3. This therefore leads to such sites being scored negatively against this criterion despite policy not precluding such uses.
6.61 We also consider that the Methodology is unable to capture that large scale developments may be able to provide additional facilities as part of future development which would support the uses to be created. For example, the Bedford Business Park proposals include an element of retail uses, green infrastructure and other amenities in order to support future employees and complement the business offer. This therefore seeks to create a sustainable employment community in its own right and should therefore score highly against sustainability criteria.
6.62 The Methodology also fails to take into account the fact that some potential constraints can be mitigated against as part of future development to ensure there is no unacceptable impact. For example, whilst the Bedford Business Park site is located in an area where protected species are likely to exist, the proposals put forward an extensive series of mitigation measures to such species are protected along with enhancement measures to deliver net gains for biodiversity. We consider any assessment of the site should take the proposed mitigation measures into account and rated accordingly.
6.63 We therefore consider that it may be more appropriate to consider sites against the NPPF criteria concerning deliverability when considering allocations for employment land. As set out above, the site fully accords with the criteria and is demonstrated to be suitable, available and achievable for development.
6.64 Notwithstanding this, a full appraisal of the site has been undertaken in line with the site selection methodology criteria and is included in Appendix 2 This demonstrates that the proposals meet all the relevant criteria and should therefore be taken forward as a site 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.