Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10048

Received: 28/07/2022

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The Spatial Strategy is considered logical in its approach. It is clearly appropriate to deliver the bulk of the new development requirements within the urban area, on the edge of the urban area and along the East West Rail / A421 corridor.

The A421 is the main east west route and links Bedford with the A1 to the east and M1 to the west. It has been and is the subject of further investment in the plan period.
In this regard the strategy it is supported by the Howbury Hall Estate.

We do however raise concern regarding that the apparent lack of provision for at least some small scale development in and around some of the Boroughs more sustainable villages.

Whilst the Council considers that some development in the rural area will come forward organically within settlements and / or through neighbourhood plans, experience to date with this strategy in the 2030 plan is that this has not been delivered. Many villages have proposed neighbourhood plans, sought designation of a neighbourhood plan area but progress has then slowed or ceased.

When querying the progress of Neighbourhood Plans a frequently used response from various Parish Clerks has been that they are under no pressure to progress and produce a plan as the Borough plan does not specifically require them to do so. Further, if a plan is progressed it is unlikely to include any development proposals, again as there is no requirement to do so.

A complete lack of development in the villages leads to their stagnation. Housing prices rise and there is little or no chance for younger people to access housing in those areas. Local shops and services gradually fail through lack of use.

Comment

Representation ID: 10049

Received: 28/07/2022

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

The plan to 2040 does not seek to direct any new development to the Boroughs smaller settlements / villages but rather seeks to rely upon existing allocated sites in the plan to 2030 and development coming forward through neighbourhood plans.

This element of the plan is unsound as it will not be ‘effective’ (paragraph 35 of the NPPF) in ensuring that a reasonable mix of housing sites are delivered across the plan as a whole. It will similarly ensure that little or no housing comes forward within or adjoining the villages.

The NPPF, paragraph 79 states:

“79. To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby”

The failure to distribute some small scale growth to the villages runs contrary to paragraph 79 and will reduce choice and flexibility in the housing market.

Comment

Representation ID: 10050

Received: 28/07/2022

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

It is considered that the ‘Vision’ set out at paragraph 2.1 of the Plan is in the most part a positive narrative which seeks to summarise the way in which the policies within the draft plan will impact the borough in the coming plan period.

The Howbury Hall Estate supports the Vision in this regard.

The Estate does however seek to raise two points:

Firstly, there is only a quite incidental reference to the Oxford to Cambridge Growth Arc where East / West Rail is mentioned rather than any specific commentary upon the important role that Bedford will play as a sustainable settlement located centrally within it.

Policies within the plan, particularly those related to employment and housing growth do place more emphasis on this aspect which we submit should be included in the Vision.

Secondly the Vision notes that in the period to 2040 the plan and its proposals will:

“…..have a positive impact on the local economy attracting high tech employment sectors, creative industries and supporting existing retail centres.”

Whilst again this is supported as set out in our separate representations regarding the Spatial Strategy and proposed allocation at Water End / St Neots Road (EMP6), it is considered that it is important that the plan does not turn entirely turn its back on those areas of the local economy which have proved successful historically in this area and which can complement and deliver a mix of jobs an prosperity alongside the aspiration to attract the high tech and creative industries to the area.

Comment

Representation ID: 10051

Received: 28/07/2022

Respondent: Howbury Hall Estate

Agent: Phillips Planning Services

or the avoidance of any doubt, the Howbury Hall Estate (the Estate), fully supports the allocation of its land under Policy EMP6 and seeks to work with the Council to bring it forward for development in the manner generally set out in the draft Policy.

Following publication of the draft plan an extremely positive and productive meeting has been held between the Estate and relevant Officers of the Council to discuss the allocation and the Council’s vision for the site as set out within the draft policy criteria.

The Estate has also begun to engage with appropriate advisors and has taken the opportunity to visit and gain an understanding of the key aspects that have driven the success of other successful innovation / science parks. There have also been positive discussions with leading agents in this field, relevant educational establishments and also potential development partners with experience of bringing forward parks of this nature.

This submission builds upon the initial meeting with the Council, the evidence gathering undertaken by the Estate and the initial discussions with key market players. As a result, it seeks minor clarifications and some alterations to the detailed wording of the draft Policy. These proposed changes do not seek to alter the principle of the allocation or the key aims and objectives for the site which are wholly supported. Rather they are aimed at minimising the potential scope for differing interpretations of the Policy at the development control stage and to ensure that it is ‘Effective’ in NPPF terms of guiding, facilitating and delivering the development of the site.

Below we set out in bold italics each element of the policy / policy criterion upon which we comment followed by the Estates response. The minor changes sought are set out in response to question 6 as required.

“Land at Water End and St Neots Road will be developed for a campus-style development (primarily research and development with elements of manufacturing, warehousing and distribution)”

This initial element of the Policy is extremely important as it seeks to make clear the uses that will be permitted as part of any development at the site and will in effect be the ‘headline’ that guides future planning applications.

In discussions with officers regarding the Council’s desire to see a very high quality “campus style” development, it was acknowledged that the site will need to deliver an offer which is new and original and so extremely attractive to both the companies looking to locate into this area and also to the high skilled employees that companies of the nature need to attract.

This point has also been made clear in market feedback to the Estate. To be successful an environment must be created which in addition to high quality / high specification buildings in which people work there must also be high quality, ancillary uses that make the development attractive to and complement the lifestyle desired by those who are drawn to work there. Such elements may include some convenience retail provision, restaurants and cafés, a gym, children’s nursery, sports facilities and good quality parks and open spaces.

The development would also benefit from the provision of a hotel which would provide visitors with a convenient place to stay close to where they may be meeting or working.

Another aspect highlighted in discussions has been the potential for some small scale associated residential provision. For clarity this does not mean general housing but rather a small apartment or apart hotel element that would specifically service the park. We are advised that firms of the nature that it is hoped can be attracted to the site will tend to recruit from a wider geographical area i.e., from all parts of the country and also from overseas, Europe, North America etc. to secure the skills required. The idea of the residential element would be to enable companies within the park to rent the space for new / relocating employees. This may be for a period of perhaps 3, 6 or 12 months whilst they become familiar with the area and seek longer term accommodation or simply can be offered as part of employee packages when contracts relate to specific projects which may be for 1, 2 or 3 years and people don’t wish to relocate fully, purchase a house etc. Such aspects are not uncommon as part of developments to the north side of Cambridge associated with the science parks.

Given the above it is considered that the Policy should make clear that there is an acceptance of these kinds of ancillary uses which are required and help facilitate the delivery of a high quality campus style development of the nature envisaged. This would remove uncertainty and provide investor confidence.
“i. A research campus of approximately 30 hectares in total on two sites at Water End and St Neots Road;”

There are two points we seek to make in respect of this criterion.

Firstly, the land promoted for development within the Applicants ownership i.e., the ‘red line’ area comprises approximately 40 hectares. The policy seeks to bring forward 30 hectares of this for actual development. This leaves 10 hectares of land which will not be the subject of built development.

The Estate wishes to ensure that the additional 10 hectares can be utilised as boundary buffer planting and for biodiversity net gain purposes etc. This will assist in ensuring that generous separation of the built development from the edge of the adjacent villages can be provided.

Notwithstanding the fact that the site lies outside of the Marston Forest area the estate has already begun discussions with the Marston Forest regarding the potential for woodland planting associated within the development and sees this as an important part of the high quality campus style development that is proposed.

Secondly the criterion uses the wording a “research campus” which appears somewhat more restrictive and does not exactly reflect the main introductory wording of the Policy which states that the development will be “a campus style development primarily research and development with elements of manufacturing, warehousing and distribution).”

It is considered that the wording should be more general and reflective of this wider description rather than using the narrower term “research campus” currently proposed.

ii. Preparation by the applicant of a masterplan and design code to be completed prior to and submitted with any planning application. The master plan and design code will ensure that the site is developed as a high value business park providing primarily research and development space in a landscaped setting;

No objection is raised in respect of the need for a Master Plan and Design Code. Indeed, the Estate is keen to set a standard for the development which must be followed throughout.

However, the use of the term “high value” business park leaves some room for interpretation and it is unclear how whether something is high ‘value’ would be assessed. We seek a change to this wording to reference ‘high quality’ rather than value.

We also again seek to remove any inconsistency with the main policy description.

vi. Development should be designed where possible to preserve and where opportunities arise, enhance the significance of heritage assets and the contribution made by setting…….

Whilst there is no objection in principle to this criterion and scope exists as noted above within the 40 hectare land ownership to ensure that the setting of nearby land, property and in particular heritage assets is preserved, is difficult to see how development of the land, which is currently open agricultural fields, located some distance from the heritage assets referenced, could realistically deliver enhancements to their significance and setting.