1. Introduction

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Support

Employment Technical Paper [EXAM 112]

Representation ID: 14735

Received: 12/08/2020

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

A01
P07
Supports Council's attempts to alleviate inspector's concerns.

Full text:

This is one of multiple submissions. The attachment letter covers all submissions. The documents are submitted against each consultation document as a separate submission SEE ATTACHMENTS

Comment

Employment Technical Paper [EXAM 112]

Representation ID: 14738

Received: 12/08/2020

Respondent: O&H Properties

Agent: Varsity Town Planning

Representation:

A01
P07
continue to support the release of the ‘Appendix 4’ sites that
were identified by the Employment Land Review.

Full text:

RESPONSE TO CENTRAL BEDFORDSHIRE COUNCIL’S CONSULTATION ON ADDITIONAL LOCAL PLAN EVIDENCE - O&H LAND (WIXAM PARK)
This representation focusses on the Employment Land Update (EXAM 109) and the Employment Technical Paper (EXAM 112). It is submitted on behalf of O&H Land, in consideration of their land at Wixam Park (Policy
MA3) and supplements the representation made by David Lock Associates in respect of O&H’s landholdings at the Marston Vale Villages.
O&H are broadly supportive of both EXAM 109 and EXAM 112. They provide helpful updates as to the current situation with regard to the jobs target and the employment land supply. The approach is considered to be in line with the NPPF and provides a sound and flexible basis for moving forward.
The comments that follow are intended to be constructive and to assist both the Council in their preparation for the EiP and the Inspector’s in reaching a positive conclusion on the soundness of the Plan.
Exam 109 – Employment Land Update Note
Para 2.4.8 – Could it be clarified that the quantum of allocated employment sites that are being carried forward into this Local Plan exclude the Appendix 4 sites? It would be helpful if the 38 hectares of land were listed in a table or appendix, or simply cross-referred to a
separate Exam Document.
Throughout the document, reference is made to assumptions about plot ratios on employment land being at approximately 40% of the total site area. Scenarios are also tested at a 30% plot ratio as explored in the Aspinall Verdi report. O&H suggest that 40% should be regarded as a minimum plot ratio. O&H’s emerging site at Marston Valley assumes a plot ratio of 40% in reaching the 30 hectares of B1 and B2 uses that are set out in Policy SA2 and enshrined in the current outline planning application
(ref: 18/01969/APP). This plot ratio takes into account the policy Local Plan requirement for 30% tree canopy cover in the Forest of Marston Vale.
Whilst strategic landscaping would be required on all sites, the 30% tree canopy cover is geographically limited and would not apply in the eastern part of the District where the Council acknowledge that the employment
land deficit is more acute. To that end, we suggest that a more generous plot ratio could be applied to sites in the east of the District, perhaps more akin to the emerging employment sites around Cambridge where 40% plot
ratios are a minimum.
O&H are satisfied that the Council’s flexible approach is in line with the NPPF. They are effectively demonstrating a five-year supply of employment land, after which any deficit would be addressed through the Local Plan review. They are also suggesting an interim approach whereby land at Holme Farm, Biggleswade, could be re-purposed to meet demand.
Exam 112 – Employment Technical Paper
5.2.4 – O&H continue to support the release of the ‘Appendix 4’ sites that were identified by the Employment Land Review. O&H have significant experience in trying to deliver these smaller, general employment sites as
part of mixed-use developments in the Marston Vale. Despite years of thorough marketing, they simply do not satisfy local demand. They are generally too small to be of interest, too distant from strategic infrastructure and tend to carry restrictive conditions to protect the
neighbouring residential uses.
O&H support the 10 hectare threshold for strategic employment sites and suggest that the future strategic allocations should be sited specifically to meet the requirements of local businesses. The historic scenario of small allocations on mixed use sites has been proven not to be successful in Central Bedfordshire.
If we can assist by providing additional detail on any of the above, please do not hesitate to get in touch.