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

Support

Representation ID: 8981

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

Chapter 3 of the consultation document identifies that 171 hectares of new employment land will be required up to 2040. There are 48 hectares of employment supply identified in the District, it is therefore expected that the emerging Local Plan will need to identify 123 hectares of land in order to meet employment needs.

When planning for employment land required, the Local Plan 2040 should include a buffer in order to allow a choice in the market, alongside a range of site typologies in order to meet different requirements in the market. Whilst Chapter 3 acknowledges that there is a shortfall of 123 hectares of land, a further buffer of 10% should be applied to this figure and therefore the plan should be looking to allocate 135 hectares of employment land to allow for this flexibility.

Bedford Borough is located in the central area of the Oxford to Cambridge Arc. The vision for the Arc anticipates a significant level of residential and economic growth in the local authority as part of wider aspirations for the area. Consideration should therefore be given as to whether there is a need to go beyond the 135 hectares to maximise economic benefits for the area and deliver the arc vision. As is discussed further in the next section, given the limited opportunities for growth around the edge of Bedford, a starting point for this should be ensuring opportunities within the urban area, such as at Manton Lane, are taken to avoid the need to make difficult decisions about the release of agricultural land for development.

Object

Representation ID: 8982

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for growth were within the existing urban area, the A421 corridor and rail-based locations. The Sustainability Appraisal identified that urban growth and urban edge growth are the most sustainable approach to new development. This position is supported by Hampton Brook.

However, a substantial number of the sites that have been submitted to the Local Authority for consideration as potential development sites are being promoted as residential housing sites as opposed to employment land.

Additionally, it is noted in Chapter 3 of the consultation document that the Council wish to utilise both larger and smaller sites for use as employment sites. This indicates that opportunities outside those large sites in the A421 corridor will need to be identified moving forward. The Manton Lane site promoted by Hampton Brook, within an existing industrial site, is prime example of the type of site the Local Planning Authority should be looking to allocate to complement the inevitable strategic allocations.

The four Growth Options put forward by the Council all intend to deliver up to 51 hectares of employment on the edge of Bedford. Development on the edge of Bedford is constrained to the north/north-east as a result of issues such as landscape, topography, flood plain and potential coalescence with smaller settlements. There is also a pressure to deliver residential development within and on the edge of Bedford also and many of the available sites will be more suited to this use. This pressure reinforces the essential need to fully assess all available opportunities in the urban area and a finer grain assessment of site availability needs to be undertaken to inform the development strategy.

For example, Hampton Brook’s site in Manton Industrial Estate was historically used for playing fields, however, as noted above, the site is now the only opportunity available to increase the employment provision on this existing employment area due to the recent appeal decision to grant planning permission for a school on surrounding land. Given its surrounding context, the land is an ideal site for employment use with limited environmental constraints. There are options for mitigating the loss of the playing fields and indeed the current playing fields are not publicly accessible.

Object

Representation ID: 8983

Received: 03/09/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

From an initial review of the potential employment sites submitted to the Local Planning Authority for consideration, the conclusions to not appear to be underpinned by a detailed evidence base or all of the available to the Council.

The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. Before any site selection process is undertaken, each site should be properly assessed and a firm conclusion reached on whether key areas such as highways, heritage, noise, etc. are an insurmountable issue or not. Additionally, and importantly, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer.

The assessment process for sites should be thorough and draw information from an existing evidence base held by the Council. To be sound, and justify the selection of sites, there should be a greater degree of transparency in the site assessment process. This is an important consideration as it is noted that plans in other local authorities have been found unsound in recent years due to the failure to justify decisions and properly back up why certain sites have been chosen over others.

With regard to the land at Manton Lane, the only constraint to development is the historic use of the site as a sports pitch – the development of which could trigger a Sports England objection. This is effectively a policy constraint and should not be a reason for not allocating the site which is otherwise suitable for development.

On the site proforma, there are unsubstantiated references to potential harm to unmanned heritage assets. It is unclear what these assets are and how the conclusion has been drawn and indeed whether they take into consideration the impact of building out the consented school on the heritage assets. Similarly, there are ‘uncertain’ conclusions around matters such as ecology and biodiversity. These are examples of where the Council will need to commission further evidence to fully assess sites and enable a robust consideration of alternatives.

The benefits of allocating the site should also be recognised in the assessment process, particularly the fact that the use of the site can effectively replace the employment land lost to the approval of a secondary school on the adjacent site.

Support

Representation ID: 8985

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

2.1 Chapter 3 of the consultation document identifies that 171 hectares of new employment land will be required up to 2040. There are 48 hectares of employment supply identified in the District, it is therefore expected that the emerging Local Plan will need to identify 123 hectares of land in order to meet employment needs.
2.2 When planning for employment land required, the Local Plan 2040 should include a buffer in order to allow a choice in the market, alongside a range of site typologies in order to meet different requirements in the market. Whilst Chapter 3 acknowledges that there is a shortfall of 123 hectares of land, a further buffer of 10% should be applied to this figure and therefore the plan should be looking to allocate 135 hectares of employment land to allow for this flexibility.
2.3 Bedford Borough is located in the central area of the Oxford to Cambridge Arc. The vision for the Arc anticipates a significant level of residential and economic growth in the local authority as part of wider aspirations for the area. Consideration should therefore be given as to whether there is a need to go beyond the 135 hectares to maximise economic benefits for the area and deliver the arc vision. As is discussed further in the next section, given the limited opportunities for growth around the edge of Bedford, a starting point for this should be ensuring opportunities within the urban area, such as at Manton Lane, are taken to avoid the need to make difficult decisions about the release of agricultural land for development.

Support

Representation ID: 8986

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

3.1 The Development Strategy Topic Paper states that at the Issues and Options stage, the most popular options for growth were within the existing urban area, the A421 corridor and rail-based locations. The Sustainability Appraisal identified that urban growth and urban edge growth are the most sustainable approach to new development. This position is supported by Hampton Brook.
3.2 However, a substantial number of the sites that have been submitted to the Local Authority for consideration as potential development sites are being promoted as residential housing sites as opposed to employment land.
3.3 Additionally, it is noted in Chapter 3 of the consultation document that the Council wish to utilise both larger and smaller sites for use as employment sites. This indicates that opportunities outside those large sites in the A421 corridor will need to be identified moving forward. The Manton Lane site promoted by Hampton Brook, within an existing industrial site, is prime example of the type of site the Local Planning Authority should be looking to allocate to complement the inevitable strategic allocations.
Figure 1: Call for Sites Map Extract
3.4 The four Growth Options put forward by the Council all intend to deliver up to 51 hectares of employment on the edge of Bedford. Development on the edge of Bedford is constrained to the north/north-east as a result of issues such as landscape, topography, flood plain and potential coalescence with smaller settlements. There is also a pressure to deliver residential development within and on the edge of Bedford also and many of the available sites will be more suited to this use. This pressure reinforces the essential need to fully assess all available opportunities in the urban area and a finer grain assessment of site availability needs to be undertaken to inform the development strategy.
3.5 For example, Hampton Brook’s site in Manton Industrial Estate was historically used for playing fields, however, as noted above, the site is now the only opportunity available to increase the employment provision on this existing employment area due to the recent appeal decision to grant planning permission for a school on surrounding land. Given its surrounding context, the land is an ideal site for employment use with limited environmental constraints. There are options for mitigating the loss of the playing fields and indeed the current playing fields are not publicly accessible.

Support

Representation ID: 8987

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

4.1 From an initial review of the potential employment sites submitted to the Local Planning Authority for consideration, the conclusions to not appear to be underpinned by a detailed evidence base or all of the available to the Council.
4.2 The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. Before any site selection process is undertaken, each site should be properly assessed and a firm conclusion reached on whether key areas such as highways, heritage, noise, etc. are an insurmountable issue or not. Additionally, and importantly, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer.
4.3 The assessment process for sites should be thorough and draw information from an existing evidence base held by the Council. To be sound, and justify the selection of sites, there should be a greater degree of transparency in the site assessment process. This is an important consideration as it is noted that plans in other local authorities have been found unsound in recent years due to the failure to justify decisions and properly back up why certain sites have been chosen over others.
4.4 With regard to the land at Manton Lane, the only constraint to development is the historic use of the site as a sports pitch – the development of which could trigger a Sports England objection. This is effectively a policy constraint and should not be a reason for not allocating the site which is otherwise suitable for development.
4.5 On the site proforma, there are unsubstantiated references to potential harm to unmanned heritage assets. It is unclear what these assets are and how the conclusion has been drawn and indeed whether they take into consideration the impact of building out the consented school on the heritage assets. Similarly, there are ‘uncertain’ conclusions around matters such as ecology and biodiversity. These are examples of where the Council will need to commission further evidence to fully assess sites and enable a robust consideration of alternatives.
4.6 The benefits of allocating the site should also be recognised in the assessment process, particularly the fact that the use of the site can effectively replace the employment land lost to the approval of a secondary school on the adjacent site.