Employment Technical Paper [EXAM 112]

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3. Points Raised by the Inspectors

3.1. Overview

3.1.1. The Inspectors wrote to the Council on 30th September 2019 (EXAM 69) outlining key points in relation to the proposed strategy for employment growth. The key points are summarised below.

Consideration of Alternative Options

3.1.2. The letter makes clear that the objective of the Plan to provide strategic warehousing sites to cater for 'footloose' demand in the logistics and distribution sector, is a positive response to substantial market demand along the M1/A1 corridors.

3.1.3. However, they raise concerns with the limited number of alternative sites/locations that were considered within the Sustainability Appraisal (SA). Their concerns specifically suggest that a site at Stratton Business Park should have been considered, albeit that it only came forward at the Regulation 19 stage of the process. The letter states that the consideration of further options and locations is especially important as the Plan is seeking to release land from the Green Belt and some alternatives that were promoted would not require Green Belt release.

Sundon Rail Freight Interchange (Policy SE1)

3.1.4. It is recognised within the letter that the proposal would make a positive contribution towards the need for strategic warehousing along the M1 corridor and have substantial economic and sustainability benefits, and that it is ideally located for such a development. However, the following issues were also identified:

  • The delivery of the RFI is dependent upon the new M1-A6 link road – have reasonable alternatives to the link road been considered;
  • The lack of wider site assessment for alternative locations outside of the Green Belt to serve the wider Luton/Dunstable/Houghton Regis conurbation or with neighbouring authorities; and
  • A lack of robust evidence to justify the exceptional circumstances necessary for the release of the land from the Green Belt

Marston Gate (Policy SE2)

3.1.2 The following issues were identified in relation to the proposed Marston Gate allocation:

  • The significant visual impact of the mass, size and type of development proposed on the surrounding network of public footpaths and local landscape character; and
  • An inconsistency between the Employment Site Assessment evidence and the SA in relation to landscape

Holme Farm (policy SE3)

3.1.5. The following issues were identified in relation to the proposed Holme Farm allocation:

  • Sustainable transport – inconsistencies between the assessment of this site in the SA and the Strategic Employment Site Assessment Technical Document (ED F02) in relation to proximity to public transport. Concerns also identified in relation to pedestrian and cycle access to the site;
  • Inconsistencies between the SA and FEMA & Employment Land Review (ED C08) in relation to the nature of strategic employment attracting workers from further afield and the not applying a jobs uplift to the housing requirement;
  • A contrived site boundary that would create two separate sites (lacking integration). The northern section would relate reasonably well to Biggleswade, but the remainder would extend the main built up area of Biggleswade and would result in visually prominent development that would impact the landscape character of the area; and
  • Warehousing would be inappropriate as it would block extensive views and create a sense of enclosure at a gateway to Biggleswade.

North of Luton and Marston Valley

3.1.6. Whilst no specific concerns were identified in the Inspectors letter about the delivery of jobs at these two locations, during the Hearing sessions, it was requested that confirmation be provided outlining the total quantum of land required to deliver the 24,000 jobs as well as the identification of the sites within Central Bedfordshire, in addition to these two new allocations, that would enable this delivery.

RAF Henlow

3.1.7. The letter raises concerns around postponing a decision on the future of RAF Henlow, risking the site becoming vacant with no positive strategy for its reuse. It also sets out the complexities of this site.

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