Bedford Borough Local Plan 2040 Plan for Submission

Support

Representation ID: 10310

Received: 29/07/2022

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

My clients would like to express their support for the draft plan which includes the identification of their
site ‘Land to the South West of Black Cat Roundabout’ as an employment allocation (LPA ref: EMP8).
My client confirms that this site remains available for development and is deliverable within the plan
period.
In this representation I will identify key matters of note in the emerging plan and will seek to highlight
areas which I consider require further attention.
At the outset, it is important to note that paragraph 82 of the National Planning Policy Framework (NPPF)
(2021) is clear in that planning policy should identify strategic sites ‘to meet anticipated [employment]
needs over the plan period’. Paragraph 81 of the NPPF also states that ‘significant weight should be
placed on the need to support economic growth and productivity, taking into account both local business
needs and wider opportunities for development...’
In terms of ‘anticipated needs’, there is significant demand for warehouse and distribution units in
Bedford Borough, surrounding authorities and in the country as a whole. Warehousing and distribution
need in Bedford Borough is recognised by the Council in the Bedford Employment Land Study (May
2022) where it states that ‘additional land should be allocated in the local plan to meet a range of
employment needs, including some warehousing’ and that ‘warehousing sites will be required in the
borough to meet local needs and ‘final mile’ distribution.’ The report further notes that local agents have
expressed that in Bedford Borough there is a ‘strong demand and occupation of ‘big box’ warehouse
permitted premises, whether new build or second hand, with consistently short void periods’.
We consider that the need for warehousing and distribution units goes beyond just Bedford Borough. It is
noted that the Council have argued in the Bedford Employment Land Study (May 2022) that
regional/national distribution centre warehousing need has been met by allocations from neighbouring
authorities. However, my clients would instead argue that the Council have downplayed this need and
that market evidence continues to show a severe supply restriction and significant demand for warehousing/distribution units along the M1 (see Bidwells Arc Market Databook Spring 2022), the A421,
the A428, the A1 and other key road routes through the wider region and the country. We therefore
believe that this adds to the justification for allocating sites such as EMP8 through the Local Plan, in
accordance with the requirements of the NPPF.
When considering potential warehousing and distribution locations, Bedford Borough Council have
logically sought to align these with key transport links and interchanges. According to the Bedford
Employment Land Study (May 2022), the Council consider that ‘the local plan should emphasise the
need for a number of well-located sites that are close to transport networks’ and that future sites should
‘have good access to strategic transport routes (road and rail)’. This is in line with paragraph 11a of the
NPPF states that development plans should ‘align growth and infrastructure’ and paragraph 83 of the
NPPF, which adds that storage and distribution uses should be positioned at ‘suitably accessible
locations’.
EMP8 is located at a strategically important position to the south-west of the Black Cat Roundabout
between Bedford Road and the Great North Road (A1,making it an ideal location for warehousing and
distribution use. The site benefits from exceptional access to the existing and proposed road network,
including the A421 which heads west towards Milton Keynes and the M1, the A1 and the soon to be
upgraded A428 which will improve connections between Bedford and Cambridge. Improvement plans for
the A428 and the Black Cat roundabout are now at an advanced stage, with final proposals being
examined by an Examination Authority and a decision expected from the Secretary of State in August
2022.
Overall, the approach taken by the Council to assessing the need for new employment floorspace and
identifying a strategy to deliver it, aligning warehousing and distribution use with key road links in this
location, is considered sound, with the strategy being positively prepared, effective, justified and
consistent with national policy, as per the tests of soundness set out in paragraph 35 of the NPPF.
In addition to the strategic considerations, and as noted in previous representations, it is reiterated that
the site is suitable for development. The majority of the site is currently in arable use. There is, however,
an element of previously developed land comprising buildings and hardstanding of an existing garden
centre. These would be demolished to accommodate the proposed development.
There are limited landscape features on the site, however Rockham Ditch runs west to east through the
site and links to the Great Ouse river to the east. The entirety of the site is within Flood Zone 1 and
therefore it is not identified as an area at risk of flooding, and there are no known heritage assets on this
site or that will be impacted by the development of this site.
In terms of ecology, there are a number of priority species including Corn Bunting and Lapwing identified
in this area. However, the site’s location sandwiched between two major roads is likely to act as a hard
barrier to wildlife, making it a poor habitat for many species.
Access to the site is also considered achievable in this location.
Necessary surveys and supporting evidence would accompany any planning application for this site and
mitigation put in place where required.
Overall, the site is considered to be suitable for development with no constraints that would limit the
delivery of the proposed employment use.

Comment

Representation ID: 10311

Received: 29/07/2022

Respondent: Ms Sharman, Mrs Banks, Huntingdon Freemen’s Charity, Mr Russell and the Rowanmoor Trustees Limited

Agent: Bidwells

General Comments on EMP8
My client would like to note the following in relation to allocation EMP8 which they would welcome a
further review of:
- The Bedford Employment Land Study (May 2022) states that ‘the borough has in the last few years
had a number of high value business inward investments into larger industrial space for uses other
than warehousing and which would more suitably fit within a light industrial permission profile’. My
clients consider that in order to create flexibility in terms of what can come forward in allocation
EMP8, the policy should be amended to include ‘industrial’ as a potential end use alongside
‘warehousing and distribution’. It is noted that this provision is made in Allocation EMP7 and that
there is little to distinguish these sites in terms of nature and location.
- The Council could consider amending policy EMP8 and/or the proposals map in order to clarify the
site area that is proposed. The evidence base for this site (including the Call for Sites submission,
Site Assessment form and Regulation 18 representation) state that the site has an area of circa 22
hectares, however Policy EMP8 states that the site is 17 hectare employment site. It is noted that
difference is likely to reflect the fact that land on the eastern boundary of the site is being compulsory
purchased in order to facilitate improvements at the Black Cat roundabout and the surrounding
highway network. This leads to a discrepancy between the size of the site and the area identified for
the site on the proposals map. Whilst I do not think this affects the soundness of the plan, for clarity
and to allow comprehensive development of the site, it is best to retain the red line as currently
shown (i.e. around the full 22 hectare site) and clarify the position with appropriate wording in the
policy. If the Council are though to make any amendment to the red line, this should only remove the
area explicitly identified for CPO.
Given the location adjacent to two major highway routes, it is considered that there may be some
merit in the policy allowing roadside uses on the part of the site nearest the Black Cat roundabout. It
is noted that policy EMP7 makes reference to such a use and we consider that there is no material
reason why policy EMP8 could also not have this use built into the policy to allow flexibility for such a
use to come forward in the future if there is demand.
Conclusion
In conclusion, my client considers that the emerging Local Plan is sound, as per the tests of soundness
set out in paragraph 35 of the NPPF and would note that:
- There is a significant demand for and a need to create additional supply of warehouse and distribution
units in Bedford Borough and the surrounding area, justifying the allocation of land to meet this need.
- Bedford Borough have correctly sought to locate additional warehouse and distribution sites at key
road and infrastructure locations as part of their growth strategy, in keeping with national policy
expectations.
- Allocation EMP8 will help to meet identified warehouse and distribution needs and is located at a
strategically important location in the highways network in keeping with national policy.
- Allocation EMP8 represents a suitable site for warehouse and distribution uses, and remains
available for development.
- The Council should consider adding industrial and roadside uses to the allowed employment uses on
EMP8 to provide flexibility when developing this site, consistent with EMP7.