Employment Land Update [EXAM 109]

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Object

Employment Land Update [EXAM 109]

Representation ID: 14553

Received: 12/08/2020

Respondent: Barnack Estates

Agent: DLA Town Planning Ltd

Representation:

The Inspectors have raised significant concerns in relation to the Council’s proposed employment allocation at Holme Farm, Biggleswade. The Council has reassessed the Holme Farm site against a potential alternative on the east side of the A1. However, there are other reasonable alternatives available, such as land at Hill Farm, Biggleswade and this should be considered,
either in addition to or instead of the Holme Farm site.

The Council’s updated evidence points to a clear need for more employment space, particularly for Small and Medium-size Enterprises. The Council’s proposal to repurpose some of the land at the Holme Farm for local economic growth is not supported and the allocation of land at Hill Farm for local economic growth should be taken forward instead.

A02
P07
Propose alternative site

Change suggested by respondent:

Land at Hill Farm, Biggleswade should be included in the Local Plan, either instead of or as well as the Council’s proposed allocations.

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Object

Employment Land Update [EXAM 109]

Representation ID: 14638

Received: 12/08/2020

Respondent: Legal & General Capital

Agent: Savills

Representation:

Having regard to EXAM 109 and 112 it is concluded that the latest evidence base this provides confirms that there is a real prospect that the needs of the strategic logistics providers will not be met over the policy period to 2035. Consequently, the CBLP is not sound because it is not positively prepared, is not justified as the appropriate strategy, and is not consistent with national policy and guidance contained in the NPPF and PPG.
In order to address the shortfall in allocated land for strategic warehousing, and to protect the proposed job growth expected, CBC should allocate land at J10a of the M1.

A02
P07
Strategy for identifying employment land is not effective, should increase jobs target to 35,000.

Change suggested by respondent:

Having regard to EXAM 109 and 112 it is concluded that the latest evidence base confirms that there is a real prospect that the needs of the strategic logistics providers will not be met over the policy period to 2035. Consequently, the CBLP is not sound because it is not positively prepared, is not justified as the appropriate strategy, and is not consistent with national policy and guidance contained in the NPPF and PPG.

Policy SO5 should be amended to set a specific target to address the requirements of strategic warehousing, of at least 8,000 jobs.

Policy SP1 should be modified to allocate land in LGC’s ownership at J10a off the M1. This would ensure that the identified shortfall in employment land is met to meet strategic warehousing / distribution users needs over the period of the Local Plan.

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Comment

Employment Land Update [EXAM 109]

Representation ID: 14695

Received: 12/08/2020

Respondent: Prologis UK Limited

Agent: Lichfields

Representation:

Prologis has submitted evidence that supports the findings of EX109 regarding the nature of both demand and supply for strategic warehousing within Central Bedfordshire. Demand for warehousing is set to strengthen with the combined influence of COVID and Brexit, and the associated requirement for additional on-shore capacity and resilience within the distribution supply chain. This combined with the increase in on-line shopping (again a trend significantly strengthened by attitudes during the pandemic) will only increase demand for strategic warehouse further. These findings further reinforce the council’s strategy to include for the needs of strategic warehousing within the Local Plan.
With the current economic conditions, the Local Plan’s Strategy, to specifically cater for the distribution sector through strategic warehousing site allocations is likely to be particularly important to the Borough’s economic performance (in terms of meeting job targets) over the Plan period

A01
P02
Support for planned provision of strategic warehousing

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
A01

Support

Employment Land Update [EXAM 109]

Representation ID: 14722

Received: 12/08/2020

Respondent: O&H Properties

Agent: Varsity Town Planning

Representation:

A01
P07
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.

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.

Comment

Employment Land Update [EXAM 109]

Representation ID: 14770

Received: 12/08/2020

Respondent: O&H Properties

Agent: David Lock Associates

Representation:

A01
P07
Marston Valley development will deliver 30ha of employment land to contribute to CBCLP’s job target and will help to attract a skilled workforce to the area. supports the Council’s efforts to undertake a review and reconfirm the 24,000-job target for the CBCLP.

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 Land Update [EXAM 109]

Representation ID: 14785

Received: 12/08/2020

Respondent: Prologis UK Limited

Agent: Lichfields

Representation:

A01
P03

Comments on Supply

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
A01