Employment Technical Paper [EXAM 112]
5. Supply of Employment Land
5.1.1. In considering the points raised by the Inspectors, particularly with regards to alternative options, the assessment of employment land supply has been considered in two parts (in line with the two elements of demand identified within the ELR); local need (the OAN) and the regional footloose demand (strategic warehousing)
5.2. Local need 'OAN'
5.2.1. Whilst EXAM 69 does not raise any particular points around the Plan's strategy for meeting the employment OAN (local need), it is important to make the process clear, for completeness. It was also requested, during the hearing sessions, 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 the two mixed use allocations proposed, that would enable this delivery.
5.2.2. Having established the demand for new jobs through the OAN, the next step was to determine how this demand could be accommodated within Central Bedfordshire. The Employment Land Supply and Job Numbers Note (EXAM 34) identifies that in order to meet the target of a minimum of 24,000 jobs within the plan period, 331,000sqm of B Class floorspace would be required. At a plot ratio of 40%, this equates to approximately 83ha of land.
5.2.3. The Council is keen to ensure that the local economy is supported and enhanced through the supply of appropriate employment land across Central Bedfordshire that is of the right size and quality, and within the most advantageous locations, to meet the needs of current-day employers, attract new businesses to the area and encourage existing businesses to expand and grow.
5.2.4. As identified within the Employment Land Review, Central Bedfordshire was in the unique position of having an ample supply of employment land. The ELR undertook an analysis of the existing employment stock and whilst it was identified at the time that the majority of the existing stock was well maintained and utilised, for a variety of reasons, some of the existing sites and employment allocations were not achieving their full potential and were considered unlikely to do so in terms of jobs delivery. The ELR therefore concluded that some sites and land across Central Bedfordshire could be released for alternative uses. This was one of the recommendations of the ELR and based upon this, a list of sites that could be released for alternative uses was identified and included as Appendix 4 within the submitted local plan.
5.2.5. In addition, positive policies were included within the plan to facilitate the change of use of employment land to non-B employment generating uses, where it could be demonstrated that the land or site was no longer required for B-use employment. These, however, will only be considered where a series of criteria as set out within the policy, is met. These criteria have been identified to ensure that key employment sites across the area are not unnecessarily lost to alternative uses.
5.2.6. Having considered the findings of the Employment Land Review, the Council concluded that the evidence showed that there was not necessarily a need to identify any additional sites to meet the 24,000 jobs OAN within the plan period. As Central Bedfordshire had an ample supply of employment land, a specific Call for Sites was not undertaken in relation to employment sites to meet the jobs target included within the plan.
5.2.7. However, the NPPF states that local plans should positively seek opportunities to meet the development needs of their area yet be sufficiently flexible to adapt to rapid change. Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas.
5.2.8. The delivery of strategic, mixed use schemes offers greater opportunities for self-containment, resulting in a reduced need to travel in order to access services, facilities and employment. Furthermore, mixed-use schemes enable the formation of new communities, promoting social cohesion as well as the health and well-being of residents. This is consistent with the Core Planning Principles as outlined within paragraph 17 of the NPPF (2012).
5.2.9. Thus, in order to deliver sustainable forms of development across the area, the Local Plan includes allocations for two large-scale, residential-led, mixed-use schemes. These are North of Luton (SA1) and Marston Vale New Village (SA2), which will collectively deliver 37ha of employment land within Central Bedfordshire and will contribute to ensuring that the minimum 24,000 jobs target is achieved within the plan period. This approach is supported by the Supplementary SA Report (EXAM 115), which recognises the positive sustainability effects of larger-scale developments, which enable employment uses to be provided alongside housing. Further information on the allocation of these sites, is provided within the Housing Technical Paper (EXAM 113).
5.2.10. The Housing Technical Paper outlines how these two proposed allocations form part of the strategy for meeting growth requirements as well as unmet housing needs arising from Luton through sustainable growth and development across Central Bedfordshire. The Housing paper also sets out the exceptional circumstances for the release of land from the Green Belt in order to accommodate the growth requirements of both Luton and Central Bedfordshire.
5.2.11. A modification is proposed to include a new appendix within the plan detailing the sites identified to deliver the 24,000 jobs across Central Bedfordshire. This has previously been committed to within Employment Land Supply and Job Numbers Note (EXAM 34).
5.3. Employment Land Supply Update
5.3.1. An update of the employment land supply has been undertaken by the Council and has been analysed by Stantec (formerly PBA). This update has informed the Employment Land Update Note (EXAM 109) and uses data with a base date of March 2020, offering the most up-to-date information available. This shows that the position in terms of land supply has changed slightly since the submission of the local plan.
5.3.2. As set out within EXAM 34, the previous floorspace demand of 24,000 jobs was calculated to be approximately 83ha of land. However, updated monitoring data shows that since 2015 (the base date of the plan) 93,000sqm of B class space (approximately 23ha) has been lost to other, non-employment uses with a further 46,000sqm of floorspace (approximately 12ha) now with planning permission for alternative, non-employment uses. Taking account of these losses from the supply and mindful that such losses to other uses need to be replaced, the employment floorspace need has increased to 470,000sqm which would require around 118ha of land.
5.3.3. In relation to permitted space, the ELU identifies that whilst 136,000sqm of stock (approximately 34ha of land) has been added to the supply through new planning completions since the start of the plan period in 2015, only 59,000sqm (approximately 15ha), has been delivered for non-strategic, local employment uses.
5.3.4. Whilst there is currently a permitted pipeline of 375,000sqm of space (93.75ha) within Central Bedfordshire, this is again predominantly all large strategic warehousing, with just 6 sites accounting for 325,000sqm (81.25ha). These include Lidl to the north of Houghton Regis and the Coop site at Stratton Park, Biggleswade. The remaining 50,000sqm of supply, is distributed over 56 sites with an average site size of 880sqm. This therefore shows that in essence, there is only 50,000sqm, or 12.5ha of permitted land in the pipeline for non-strategic, non-specialist demand.
5.3.5. The Council also has a number of previously allocated sites that have carried forward from previous plans. These remaining allocations, without permission, total 38ha of land. However, 12ha of this are Cranfield AirPark and are therefore considered as specialist-uses and unavailable to the 'normal' market, which reduces the available land to 26ha (104,000sqm).
5.3.6. The ELU states that it is clear that a lack of allocated land for strategic warehousing has resulted in warehousing demand displacing 'normal' employment uses from the stock and pipeline of site. This has been the case in relation to both the Lidl and coop permissions, where single, large strategic units have replaced mixed B uses. Overall, setting strategic warehousing and specialist uses aside, the Council's current land supply is only 38.5ha, which comprises 12.5ha with planning permission and 26ha of allocations.
5.3.7. As identified at 5.3.2 above, in order to deliver 24,000 jobs, the Council needs 118ha of non-strategic, non-specialist land. However, at the current time, only 38.5ha of land is available. Taking into consideration the 59,000sqm (approximately 15ha), that has been delivered for non-strategic, local employment uses since 2015, this provides a requirement for approximately 64.5ha.
Supply to meet non-strategic need
Allocations carried forward
New permissions since 2015
Table 1. Supply to meet non-strategic Need
5.3.8. Fortunately, as discussed in para's 5.2.9 to 5.2.11 of this paper, despite there being sufficient land already committed to meet the OAN, additional employment provision was provided for non-strategic needs via the two new mixed use allocations proposed within the submitted local plan – 30ha at Marston Gate and 7ha at North of Luton. This brings the total pipeline to 75.5ha. However, in considering the updated supply figures, it now results in a small shortfall of 27ha, based on the allocations as proposed. This will be discussed further in Section 6 of this paper.
5.3.9. This only serves to demonstrate the strength of the market for employment provision in Central Bedfordshire, particularly footloose demand, which has taken up some of the supply previously committed to meet local (non-strategic needs), as well as the fluidity of the supply figures in terms of meeting this demand. This supports the flexible approach to employment land provision that is advocated in the NPPF and that Central Bedfordshire's Local Plan seeks to provide.
5.4. Strategic Warehousing & Footloose
5.4.1. As outlined in Section 4 above, the Employment Land Review (ED C08) identified that there is a very high demand for both strategic national/regional warehousing and also a 'new generation' warehousing, and that this 'footloose' demand will largely look to be located where there is supply of good quality and highly accessible land available. Given that two strategic transport corridors run through Central Bedfordshire – the M1 and the A1, it is considered that Central Bedfordshire is well placed to contribute to meeting some of this footloose demand.
5.4.2. As footloose demand is not a requirement specific to Central Bedfordshire, it does not necessarily have to be met by this Local Plan. However, given the significant strategic transport connections, it was considered that it should be investigated to determine whether there were suitable sites within Central Bedfordshire that could be allocated, over and above the jobs OAN, to contribute to meeting those 'footloose' needs.
Strategic Warehousing Land Supply Update
5.4.3. The Employment Land Update Note (ELU) has considered the most recent position in relation to the provision of strategic warehousing, providing an update to the previous evidence base, which was based on 2015 data.
5.4.4. The ELU reconfirms that the strength of the warehousing sector is undeniable and that there is a risk that without a new supply of land for this use, sites currently in the supply calculation to meet local needs will be taken up, like has been seen with the Lidl and Coop examples, leaving limited supply for 'local' needs.
5.4.5. Updated market evidence shows 425,000sqm of large unit space (for strategic warehousing) has been taken up in Central Bedfordshire over the past 5 years which is an average of 85,000sqm of space per year. The ELU identifies, that if this trend were to continue for the remainder of the plan period (a further 15 years) around 320-425ha (depending on a plot ratio of either 30% or 40%) would be taken up by strategic warehousing within Central Bedfordshire.
5.4.6. The ELU concludes that the warehousing demand within Central Bedfordshire is strong and far in excess of any jobs forecast-derived estimate. The plan strategy currently addresses this by allocating up to 140ha of land for strategic warehousing on sites considered to be qualitatively suitable. It is considered that additional supply will be required in the longer-term, which can be addressed through the early partial Local Plan review that the Council has already committed to.
5.4.7. Whilst not a requirement specific to Central Bedfordshire, taking into account the level of take-up already seen, and the demand demonstrated by the ELU, it is considered that the risk of not allocating land for strategic warehousing, is that such uses will be displaced on to the 'normal' local supply and/or possibly less suitable sites with sustainability implications i.e. further away from the strategic road network.
5.4.8. The local Plan strategy has therefore been, twofold – to promote a supply of land for 'local' uses in addition to a supply of land for strategic warehousing, where the evidence supports this; in terms of allocating sites in market favourable locations and that are suitable from a planning perspective. This is set out in more detail below.
Whether or not to meet the demand
5.4.9. A review of the Sustainability Appraisal (SA) (EXAM 115) has been undertaken, which, in line with the concerns raised in EXAM 69, identified that there are alternative overall strategies for employment growth that should have been considered.
5.4.10. In terms of employment provision, the Supplementary SA takes a step back and first assesses the broader question of whether the CBC Local Plan should cater for the 'footloose' demand in the logistics and distribution sector or not. The Supplementary SA assesses the following two options:
- Option 1: Provide land to meet some of the footloose regional demand for strategic warehousing, in addition to the land allocated to meet local employment need.
- Option 2: Do not provide land to meet some of the footloose regional demand for strategic warehousing.
5.4.11. The appraisal of these two options focuses on the likely 'in principle' sustainability effects of providing or not providing land to meet some of the footloose regional requirement for strategic warehousing.
5.4.12. The Supplementary SA agrees that Central Bedfordshire is in a good location to meet this footloose demand and identifies that whilst the effects of Option 2 are predominantly negligible on the SA objectives as no development would be provided, not making provision for footloose demand would have a minor negative effect on SA Objective 4: Employment. The Supplementary SA identifies that "if the Council were not to make any provision for such footloose warehousing through the Local Plan, this would have a minor negative effect on support for the regional and local economy and would also reduce the number and range of job opportunities that would otherwise be made available".
5.4.13. In relation to Option 1, the effects are considered to be varied, with the effects being generally positive in relation to social and economic SA Objectives, but generally negative in relation to environmental SA Objectives.
5.4.14. It is noted that in all cases, the negative effects are uncertain until specific site locations and designs are known, and mitigation proposals identified. The Supplementary SA recognises that effects may therefore be mitigated.
5.4.15. Furthermore, as the effects at this strategic level of assessment are so uncertain, it is identified within the Supplementary SA, that it is difficult at this stage to conclude whether the social and economic benefits of warehouse sites could outweigh the potential negative effects.
5.4.16. The Supplementary SA is just one piece of evidence that informs the plan, so the results of this assessment demonstrate the need for potential sites to be assessed and considered in more detail.
Identification of Sites to meet Footloose Demand
5.4.17. A Call for Sites was undertaken in early 2016 to identify land that had the potential to meet the identified strategic warehousing needs. The Call for Sites specifically requested sites that were a minimum of 10ha in size and that could accommodate at least 40,000sqm of floorspace. The sites that were submitted to the Council were compiled with a number of strategic-scale employment sites that had been submitted during a previous Call for Sites in 2014/15, relating to a then proposed Site Allocations Plan. Whilst that Site Allocations plan was not progressed, the sites submitted were kept on file.
5.4.18. In total, through the two Call for Sites processes, 77 sites were submitted to be considered for the delivery of employment, either as mixed-use proposals or as stand-alone employment sites. Whilst the Council was specifically seeking stand-alone strategic sites, it was considered appropriate that in the first instance, all sites capable of accommodating the required 40,000sqm of floorspace should be assessed.
5.4.19. However, of the 77 sites submitted, 30 were below the 10ha threshold which was used to determine if a site could deliver strategic-scale employment and were therefore discounted from the process.
5.4.20. 47 sites were therefore taken forward and were subject to a detailed site assessment process undertaken by PBA (now Stantec), to identify whether they were suitable, available and achievable, in line with national guidance, to deliver strategic, stand-alone scale employment to meet footloose demand.
5.4.21. The Strategic Employment Site Assessment Technical Document (ED F02) sets out the process that was undertaken by PBA and includes the site assessment forms for all 47 sites. Stage 1 of the assessment was an exclusionary stage and eliminated the most unsuitable sites. Stage 2 of the assessment provided a more detailed assessment of the remaining sites and included input from internal experts within the Council in areas including archaeology, ecology, contamination, flood risk and landscape, leisure, minerals and waste and environmental health.
5.4.22. As detailed within document ED F02, those sites that passed the stage 2 assessment progressed to stage 3, where the viability of each site was considered alongside market signals. At the end of the assessments, PBA applied professional knowledge and judgement which resulted in 15 sites passing the assessment overall.
5.4.23. Following the identification of the 15 sites through the assessment process, bearing in mind not all of these would be required to deliver strategic scale employment within the current plan period, a further assessment was undertaken by Officers.
5.4.24. In undertaking this final stage of assessment, officers used their professional knowledge and judgement to determine whether the site had the potential to be included within the Local Plan as a stand-alone, strategic employment allocation. Factors such as proximity to the strategic road network, and whether the site could realistically be considered for the delivery of sustainable strategic employment, were considered. Three sites were ultimately identified through this process, as detailed within the Strategic Employment Site Assessment Technical Document (ED F02), and allocated within the Local Plan: Sundon Rail Freight Interchange, Land at Ridgmont (M1 Junction 13) - Marston Gate, and Land West of the A1, Biggleswade - Holme Farm.
5.4.25. This approach was discussed during the Examination Hearing Sessions, and, as reflected in the Inspectors letter (EXAM 69), it was considered that this level of site assessment should have, in fact, been undertaken as part of the SA process, so that sites could be fairly assessed against the defined SA objectives. Therefore, whilst alternative options were robustly considered by the Council (via this assessment), the SA was subsequently criticised for not having assessed all 15 of the potential employment sites that passed the initial site assessment. An independent review of the SA has now been undertaken, which addresses this point.
5.4.26. In addition to the 15 sites referenced above (that passed the assessment undertaken by PBA/Stantec), a further site has also been added for consideration within the SA. This site, (NLP067) known as Land at New Spring Farm, Biggleswade, was initially submitted for and assessed as a housing site but was also identified by the site promoters on the Call for Sites form as being suitable for employment uses as an alternative to residential. An internal oversight meant that this site was not taken forward for consideration as an employment site and it was not assessed by PBA/Stantec along with the other 47 sites. The Council have, therefore, subsequently assessed the site and the Site Assessment Form, which is included as Appendix 7.1 to this paper, has been reviewed by Stantec to ensure a consistent approach with the original site assessment process. Having passed the site assessment, Spring Farm has been included within the Supplementary SA, taking the total number of sites being considered to 16.
5.4.27. The findings of the Supplementary SA work are discussed in section 6 below.