Functional Economic Market Assessment & Employment Land Review

Showing comments and forms 1 to 12 of 12

Object

Technical Reports

Representation ID: 9126

Received: 21/02/2018

Respondent: Aequitas Estates MK1 Limited and Prologis UK Limited

Agent: Porta Planning LLP

Representation:

04

Full text:

We object to the Strategic Employment Site Assessment Technical Document 2017 on the basis that it excludes allocating the sites that do not provide at least 40,000sqm of employment space. We consider that Employment Site Assessment Technical Document 2017 should not preclude the allocation of such sites because of size as these sites may be appropriate for employment development that will cumulatively meet the employment needs and contribute to the provision targets set out by Policy SP1.

Our client owns land adjacent to Junction 13 M1 (NLP323) which it requests is allocated for employment (warehouse and distribution) use in the New Local Plan. The site (former Goodes Transport site, Bedford Road) is situated between the A421 and Bedford Road and is situated immediately adjacent to Prologis Park Marston Gate. Having regard to the requirements of both draft Policies SP1 and EMP1, we consider:

* The site represents a medium scale site capable of development in the short term to meet national demand for warehousing logistics sector operations. Development of the site would not constitute piecemeal development and would not prejudice delivery of other development in this growth location;
* The site is not situated within Green Belt and there is a demonstrable demand and need for this type of accommodation in this location. Evidence of need and potential occupiers will be provided in support of a future planning application, as will evidence that delivery of additional strategic warehousing and logistics facilities in this location will not result in an over concentration in the market;
* The prosed site is adjacent to the strategic transportation network (namely the M1 and A421). Details of the accessibility of the site by sustainable modes of transport will be addressed in the Transport Statement supporting a future planning application; and
* The site is situated immediately adjacent to an area which is the subject of a wider allocation for 'strategic employment' and will comprise part of an existing cluster of similar uses strategically located adjacent to the M1 corridor.
* It is clear from the draft Local Plan strategy and the background studies that land around Junction 13 M1 is an appropriate location for further employment (particularly warehouse and distribution) development. The position of the site immediately adjacent to Prologis Park Marston Gate and well contained by recent road construction, together with the existing established 'storage and haulage' use on the site suggest that its development as proposed is appropriate and entirely reasonable in planning terms and can be developed in such a way that it would not have an unacceptable landscape and visual impact on the Forest of Marston Vale (as identified in your current Local Plan Policy CS16/DM14) and on residential properties at Brogborough.

Object

Technical Reports

Representation ID: 9130

Received: 21/02/2018

Respondent: Aequitas Estates MK1 Limited and Prologis UK Limited

Agent: Porta Planning LLP

Representation:

04

Full text:

We object to the Strategic Employment Site Assessment Technical Document 2017 on the basis that it excludes allocating the sites that do not provide at least 40,000sqm of employment space. We consider that Employment Site Assessment Technical Document 2017 should not preclude the allocation of such sites because of size as these sites may be appropriate for employment development that will cumulatively meet the employment needs and contribute to the provision targets set out by Policy SP1.

Our client owns land adjacent to Junction 13 M1 (NLP323) which it requests is allocated for employment (warehouse and distribution) use in the New Local Plan. The site (former Goodes Transport site, Bedford Road) is situated between the A421 and Bedford Road and is situated immediately adjacent to Prologis Park Marston Gate. Having regard to the requirements of both draft Policies SP1 and EMP1, we consider:

* The site represents a medium scale site capable of development in the short term to meet national demand for warehousing logistics sector operations. Development of the site would not constitute piecemeal development and would not prejudice delivery of other development in this growth location;
* The site is not situated within Green Belt and there is a demonstrable demand and need for this type of accommodation in this location. Evidence of need and potential occupiers will be provided in support of a future planning application, as will evidence that delivery of additional strategic warehousing and logistics facilities in this location will not result in an over concentration in the market;
* The prosed site is adjacent to the strategic transportation network (namely the M1 and A421). Details of the accessibility of the site by sustainable modes of transport will be addressed in the Transport Statement supporting a future planning application; and
* The site is situated immediately adjacent to an area which is the subject of a wider allocation for 'strategic employment' and will comprise part of an existing cluster of similar uses strategically located adjacent to the M1 corridor.
* It is clear from the draft Local Plan strategy and the background studies that land around Junction 13 M1 is an appropriate location for further employment (particularly warehouse and distribution) development. The position of the site immediately adjacent to Prologis Park Marston Gate and well contained by recent road construction, together with the existing established 'storage and haulage' use on the site suggest that its development as proposed is appropriate and entirely reasonable in planning terms and can be developed in such a way that it would not have an unacceptable landscape and visual impact on the Forest of Marston Vale (as identified in your current Local Plan Policy CS16/DM14) and on residential properties at Brogborough.

Object

Technical Reports

Representation ID: 9738

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

04

Full text:

See attached representation.

Object

Technical Reports

Representation ID: 10804

Received: 22/02/2018

Respondent: Biggleswade Residents Action Group

Number of people: 27

Agent: Mr Simon Denchfield

Representation:

04

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 11353

Received: 22/02/2018

Respondent: Defence Infrastructure Organisation

Agent: JLL

Representation:

04

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 11889

Received: 22/02/2018

Respondent: Bedford Borough Council

Representation:

EMPLOYMENT - ELR figures need updating

09

Full text:

See attachment

Attachments:

Comment

Technical Reports

Representation ID: 12102

Received: 22/02/2018

Respondent: IM Properties

Agent: Barton Willmore

Representation:

Alternative Site

09

Full text:

see attachment

Attachments:

Comment

Technical Reports

Representation ID: 12151

Received: 22/02/2018

Respondent: IM Properties

Agent: Barton Willmore

Representation:

ALTERNATIVE SITE PROPOSED

08

Full text:

see attachment

Object

Technical Reports

Representation ID: 14042

Received: 20/02/2018

Respondent: Potton Residents for Sustainable Growth

Representation:

METHODOLOGY - ELR recommendations do not appear to have been included in the Local Plan

04

Full text:

For the reasons stated in the uploaded document, we believe that Central Bedfordshire's Local Plan is fundamentally flawed and that it should not be adopted without further analysis and review. We respectfully request that the uploaded attachment is forwarded to the Inspector for consideration. In addition, please take this as notice that a representative of the group would like to speak at the public meeting of the Planning Inspector at which the Local Plan is expected to be decided.

Attachments:

Object

Technical Reports

Representation ID: 14081

Received: 22/02/2018

Respondent: Legal & General Capital

Agent: Savills

Representation:

METHODOLOGY - Policies based on sub-optimal Experian employment forecast - the EEFM forecasts should be adopted, which conclude that the baseline employment target should be 27,000 jobs between 2015 and 2035

TARGETS - Provision of additional jobs to meet the assessed demand for logistics and distribution uses inadequate -should be increased to overall jobs target of 35,000 jobs

04

Full text:

See attach representation.

Object

Technical Reports

Representation ID: 14082

Received: 22/02/2018

Respondent: FCC Environment

Agent: Sirius Planning

Representation:

METHODOLOGY - query number of jobs from ELR up to 2031, plan is to 2035

04

Full text:

FCC supports the councils desire to take a "positive and enabling approach to creating the right conditions for existing businesses to flourish and attract new inward investment that supports and enhances the existing employment offer." (para 12.1.7) and reference to "a series of enabling and positive policies" (para 12.1.41)

FCC consider the text within the overview of the employment and economy chapter very positive and aspirational in respect of not unduly restricting economic development and having the flexibility to respond to market conditions. However, the detailed policies which relate to this overview do not correspond to the positive and aspirational approach stated. This is discussed in more detail in Section 12.7 below.

Para 12.1.11 makes reference to 23,900 jobs expected up to 2031, however, this figure is then referenced again in para 12.1.14 as being up to 2035. The ELR has considered projections up to 2031; therefore a full review of job numbers is required up to 2035. In addition, reference is made to meeting some of the unmet need from Stevenage, however no detail is provided with regards to specific quantities. Further clarity regarding all the employment land figures is required in order to determine whether the Plan is positively prepared and justified and therefore, whether it could be considered sound.

Object

Technical Reports

Representation ID: 14085

Received: 22/02/2018

Respondent: FCC Environment

Agent: Sirius Planning

Representation:

METHODOLOGY - Clarity required in relation to demand figures and employment land portfolio in terms of site specifics.

METHODOLOGY - land supply/demand figures stated in ELR unclear and queried

04

Full text:

FCC supports the acknowledgement that "availability and choice in the range and size of land and premises" (para 12.4.2) will be required and that "new employment land allocations will be delivered as part of mixed-use developments as well as stand alone employment sites meeting both local and national need" (para 12.4.4).

However, further clarity is required as to the demand figures relating to these new employment allocations as well as the extent of the employment land portfolio provision including specific sites, their site boundary and potential capacity.

It is noted that the Plan allocates new mixed-use development sites and strategic employment sites, which are marked on the Proposal Map, they are all of a significant scale and do not provide the mix of sites which the Plan references as being required within the Strategic chapters, and thus does not meet the needs specified in the ELR. It is not clear whether the council are inferring that these needs are met within the existing allocations; as these have been illustrated on the Proposal Map with the residential development it is not possible to distinguish between them. Furthermore, no separate information regarding the sites is provided including site boundaries, capacity and phasing.

The Plan clearly states that there is a deficiency in the current supply of employment sites but does not provide the transparency or clarity for it to be determined if those sites proposed for allocation meet all the test of soundness.

In addition to the above, further clarity is required regarding the floorspace supply and demand figures stated within the ELR. Table 6.1 states there is a need for 239, 375 sqm (63 ha) employment floorspace within Central Beds up to 2031. Paragraph 7.53 of the ELR summarises that there is a supply pipeline of 300,000sqm which is either permitted or allocated. This would result in a surplus of 60,625 sqm (although this is caveated within the ELR that the majority of the space is for industrial use and therefore further site allocations are required in order to promoted a variety of sites to meet demand), It is therefore unclear where the 203,656 sqm surplus listed with Table 8.3 has arisen.

FCC have a significant landholding within Central Bedfordshire comprising the former Arlesey landfill and former Brogborough Landfill sites. Both of which include areas of previously developed land suitable for employment development that could be tailored to meet the shortfall identified within the ELR:

"to improve local choice in the network of towns and villages, the council should consider new small-scale employment allocation that can be provided on a freehold basis to meet local needs" (para 20).

"the exception to this rule in Central Bedfordshire is the market for smaller-scale development. Smaller businesses, in both the office and industrial markets, are often service-related. They are more likely to take secondary space close to the communities they serve before looking elsewhere for modern property" (para 5.18)

"There is also a market for smaller office spaces in Central Bedfordshire. This market is mainly driven by small, local occupiers such as law and accountancy firms. Demand for this type of space is spread throughout the area because these businesses are often focused on serving local communities..."(para 5.24)

"There is a strong market for smaller industrial spaces in Central Bedfordshire...Although these uses are not often glamorous and in come cases may be considered "bad neighbours", the demand for smaller industrial property is strong, and the services offered are of value to local communities" (para 5.78)

"Although larger speculative industrial warehousing is available, agents report that demand is likely to outstrip supply. Sites are available for industrial use on a design and build basis, but there are only a small number of speculative properties" (para 5.89)

"There is a particular gap in the market for new build units from 2,000 sqm to 10,000 sqm. Agents state that if such property were provided, demand is such that it would be taken quickly"(para 5.90)

Further information regarding the sites is provided within the attached documents.