Strategic Employment Site Assessment Technical Document

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Object

Site Assessment Results (Housing & Employment)

Representation ID: 234

Received: 19/07/2017

Respondent: Thomas Harding

Representation:

NLP 510 Biggleswade This site is in EPA designated highest flood risk zone 3, zone 3b flood plain as defined by the LGA planning authorities. That is the highest risk of flooding. Any attempt to protect against flooding would have a detrimental affect on local existing residential areas. It would be extremely expensive. The site also suffers from access problems for traffic off the A1 and Hill Lane Biggleswade. This site is not suitable for conventional employment development.

Full text:

NLP 510 Biggleswade This site is in EPA designated highest flood risk zone 3, zone 3b flood plain as defined by the LGA planning authorities. That is the highest risk of flooding. Any attempt to protect against flooding would have a detrimental affect on local existing residential areas. It would be extremely expensive. The site also suffers from access problems for traffic off the A1 and Hill Lane Biggleswade. This site is not suitable for conventional employment development.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 236

Received: 19/07/2017

Respondent: Thomas Harding

Representation:

NLP 437 & ALP 442 Sites are in an area that has been the subject of opposition to a service station off the Roundabout. Applicant's consultant was unaware of potential commitment by Highways England regarding as a minimum modifications to the roundabout right up to re-routeing of the A1 as far south as Baldock. Until plans are firmed up it is premature to develop an area that could hinder HE plans, or have to be demolished when the plans are finalised. Acceptance by the Authority of these sites must be couched in heavy conditions at the developer's risk.

Full text:

NLP 437 & ALP 442 Sites are in an area that has been the subject of opposition to a service station off the Roundabout. Applicant's consultant was unaware of potential commitment by Highways England regarding as a minimum modifications to the roundabout right up to re-routeing of the A1 as far south as Baldock. Until plans are firmed up it is premature to develop an area that could hinder HE plans, or have to be demolished when the plans are finalised. Acceptance by the Authority of these sites must be couched in heavy conditions at the developer's risk.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 1768

Received: 24/08/2017

Respondent: Dawsongroup plc

Agent: Q+A Planning Ltd

Representation:

In summary, the evidence is ambiguous about how sites less than 10 ha should be dealt with. This appears to be an arbitrary figure and unless the Local Plan is clear on how smaller sites ought to be dealt with, this would be contrary to the Council's own evidence and the NPPF.

Full text:

Dawsongroup plc are an asset rental company in the transport and distribution sector, with a base in Milton Keynes and the surrounding area. On behalf of our client, we are promoting the development of a site titled by the Council as 'land south of Highfield Farm' for employment development (reference ALP421 showing as 5.84 ha). The development would be occupied by our client as their head office and would comprise office space as well as open storage and warehousing.

The outcome of this document is to allocate three strategic sites for employment. One of those three sites - namely NLP244 appears to take forward the Growth Allocation at Junction 13 of the M1. Clearly this technical document focuses on large sites over 10ha. However, we are concerned at the extent the Council's evidence and therefore its emerging plan appropriately addresses smaller sites that do not necessarily seek to deliver the strategic distribution developments as envisaged as part of NLP244.

It is critical that the Council's evidence base and plan is takes into account the growth of local businesses. The FEMA and ELR recognises the role of smaller allocations and the pipeline of smaller scale employment sites. Whilst our client's site is not necessarily small, it falls below the Council's 10ha definition of strategic employment and therefore for the purposes of the employment evidence would be small. However, given it would involve the expansion of a local business in a sector that is distinct from the distribution uses and would include a substantial office element, we consider it is an important site for the Council to consider.

The NPPF makes it clear that local planning authorities need to have a clear understanding of business needs and that they should work closely with the business community to understand their changing needs and barriers to investment (paragraph 160). In addition, paragraph 161 explains that the needs for all foreseeable types of economic activity should be assessed. The main point to make in respect of this evidence is that the assessment of smaller sites is absence and in a situation where the policy position on how such sites should be dealt with in the emerging plan is ambiguous, we are concerned that the evidence and the plan could potentially frustrate sustainable development of employment development to meet the needs of local businesses.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 2204

Received: 29/08/2017

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

We agree with positive site assessment, but disagree with the decision to then discount the site for strategic employment development. In addition, we note that some of the commentary in the site assessment is incorrect and should be amended including to reflect the findings of the technical reports prepared for the planning application at the site.

Full text:

Appendix E - Summary of Strategic Site Assessments & Appendix F - Full Strategic Employment Site Assessments: Land at Winterwoods Farm, Brogborough (Ref. NLP178)

Policy SP1: Growth Strategy in the First Draft Local Plan (FDLP) identifies land at M1 Junction 13 for strategic employment development. As set out in our representations to Policy SP1, we support the allocation of land in this location for strategic employment, and suggest that the M1 Corridor is identified as a priority location for Class B8 employment in Central Bedfordshire.

A planning application for Class B8 development at Winterwoods Farm was submitted in November 2016 and is currently being considered (Ref. CB16/05587/OUT). The application is supported by technical evidence on landscape and visual impact, transport and highways impact, and an economic and market assessment. There is an identified need for additional space to meet the needs of the logistics sector in the southern M1 Corridor, as set out in the Economic and Market Assessment Update Report July 2017 (prepared by GENECON and submitted for the planning application).

The Stage 2 Assessment Conclusion for the site states: "Appropriate landscape and archaeological mitigation would be required. Following this, the site is considered suitable to accommodate the proposed development with no overriding constraints. The site therefore passes stage 2". The Summary for the site states: "The site is considered appropriate to accommodate the proposed development. The site is located at M1 Junction 13, which is a strategic location for distribution uses. As such, this site could be successfully developed for distribution uses. The site passes stage 3, and is therefore recommended for allocation for strategic employment development in the Local Plan". However, the Council then concludes that the site scores 'red' and should be discounted as an employment location.

We agree with positive site assessment, but disagree with the decision to then discount the site for strategic employment development. In addition, we note that some of the commentary in the site assessment is incorrect and should be amended including to reflect the findings of the technical reports prepared for the planning application at the site.

The assessment criteria where amendments are required are as follows:
* 8 (Control of land): The current planning application for Class B8 development at the site was submitted by Hallam Land Management, who are an experienced developer. The landowner fully supports the submission of the application and the proposed development. We request that the score for this criteria is corrected to 'G - for Green'.
* 9 (Legal or ownership problems): There are no legal or ownership constraints to development at the site. The land ownership is known and as such it is not uncertain. As set out above the landowners were notified of the current planning application at the site. We request that the score for this criteria is corrected to 'G - for Green'.
* 10 (Planning status): A planning application for Class B8 development at Winterwoods Farm was submitted in November 2016 and is currently being considered (Ref. CB16/05587/OUT).
* 16 (Community consultation): A Statement of Community Involvement was submitted with the planning application. Section 6 of the SCI provided a response to the issues raised during public consultation.
* 20 (Distance to town centre/local centre): The site is less than 5km to Cranfield, Woburn Sands and Kingston Local Centre (in Milton Keynes). We request that the score for this criteria is amended to 'A for Amber'.
* 21 (Distance to bus stops): As set out in the Transport Assessment for the current planning application, the proposed development would provide a new bus service to serve the site. We request that the score for this criteria is amended to 'G for Green'.
* 22 (Distance to nearest train station): The site is approximately 1km from Ridgmont Station. As set out in current planning application, the proposed development would enhance the footway and cycleway connections, providing links to an existing bridleway and also to Ridgmont Station. In addition, we consider that any assessment of distances should consider the mode of transport and the purpose for the journey, with longer distances acceptable by bicycle and longer journeys made by people for commuting to work. The proposed amendments to the walking and cycling network should encourage travel by these modes of transport. We note that the site is one of the few Class B8 employment sites in Central Bedfordshire which benefits from close proximity to a railway station, and this fact should be acknowledged in the assessment of the site. We request that the score for this criteria is amended to 'A for Amber'.
* 26 (Pollution conflict with adjoining uses): Noise and air quality assessments were submitted with the current planning application, to consider the potential impacts on residents from pollution in the vicinity of the site from the proposed development. A Construction Environmental Management Plan would be prepared to control noise and dust associated with construction activities at the proposed development. Acoustic screens would be provided in some locations within the proposed development to protect neighbouring properties and uses from noise impacts. The operational plant equipment within the proposed development will be designed to reduce noise levels to acceptable limits and those noise limits would be controlled by planning condition. We anticipate that a planning condition would be attached to limit light pollution from the Proposed Development. The need for external lighting would be carefully assessed and all lighting would be designed by a specialist consultant in accordance with guidance issued by the Institute of Lighting Engineers (ILE) in order to prevent light pollution.
* 27 (Landscape character): A landscape and visual impact assessment of the proposed development was undertaken for the current planning application. A meeting was held to discuss the response to the application from the Council's Landscape Officer and as a result revisions to the scheme have recently been submitted to address concerns. The site is not covered by any local or national landscape quality designations. The site and surrounding area lies within the Forest of Marston Vale and the proposed development provides an opportunity to increase woodland coverage in accordance with strategic objectives for the area. A high quality design strategy has been prepared for the proposed development. The landscape and visual effects can be minimised through the proposed comprehensive package of design and mitigation measures. The green infrastructure framework will ensure that the proposed development would be well integrated within the local landscape, and would deliver a range of environmental enhancements. An attractive 'gateway' entrance feature is proposed along Salford Road and designed to be sympathetic to its rural aspect. The proposed development would not result in significant adverse visual effects within the wider landscape including upon settlements such as Hulcote or Salford, or upon the public rights of way network such as the Greensand Ridge Walk or John Bunyan Trail. We request that the score for this criteria is changed to 'G for Green'.
* 28 (Heritage/Archaeology): An assessment of heritage and archaeology was undertaken for the planning application to identify the significance and potential impact of the proposed development on heritage assets. The Assessment confirms that the proposed development lies outside of the setting of Brook Farm House. The Assessment acknowledges that there could be unrecorded archaeological remains present within the Application Site, and recommends that a condition is attached requiring a programme of archaeological evaluation to be undertaken. We request that the score for this criteria is changed to 'G for Green'.
* 29 (Ecological assets): The majority of the site comprises arable land with low species diversity and limited ecological value. The site contains suitable habitats for badgers, bats, breeding birds and Great Crested Newts. The proposed green infrastructure framework for the proposed development comprises substantial belts of woodland planting and diverse new habitats. The majority of existing hedgerow, trees and minor watercourse will be retained within the green infrastructure. New habitats including broadleaved woodland and hedgerow will be provided with native tree and shrubs as well as species rich grassland meadow. The sustainable urban drainage also includes wet grassland, wet woodland, aquatic/marginal vegetation and swales which will provide ecological benefits. The retention and creation of habitats within the green infrastructure framework will mitigate the impact of the proposed development on biodiversity. We request that the score for this criteria is changed to 'G for Green'.
* 30 (Open space/leisure and GI assets): The site lies within the Forest of Marston Vale and the proposed development provides an opportunity to increase woodland coverage in accordance with strategic objectives for the area. We request that the score for this criteria is changed to 'G for Green'.

Paragraph 182 of the NPPF identifies the four soundness tests for Local Plans. The 'justified' test is particularly relevant to the evidence used to inform Local Plans, and states: "the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;...". There is no evidence to support the decision that this site should score 'red' and be discounted as a potential strategic employment site. As set out above there are no technical constraints to development at the site. The proposed development would enhance the footway and cycleway connections, providing links to an existing bridleway and also to Ridgmont Station to encourage travel by these modes of transport. There is no reason to reject the site on landscape grounds and the proposed development includes substantial areas of green infrastructure and woodland planting to address any potential landscape impacts. In contrast, as set out in our representations to Full Strategic Employment Site Assessments (Appendix E & F) for Land at Ridgmont (Ref. NLP244), there are significant landscape reasons to reject this preferred site as a strategic employment allocation.

Therefore, the findings and conclusions of the assessment should be corrected to reflect the above comments.

We request that Land at Winterwoods Farm in Brogborough (Ref. NLP178) should be allocated as a strategic employment site.

Attachments:

Object

Site Assessment Results (Housing & Employment)

Representation ID: 2206

Received: 29/08/2017

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

We disagree with the Stage 2 Conclusions as they fail to acknowledge the earlier landscape assessment of the site. Therefore, the findings are not robust and do not fully consider the landscape and visual impacts of development.

We request that land at Ridgmont (Ref. NLP244) should not be allocated as a strategic employment site.

Full text:

Appendix E - Summary of Strategic Site Assessments & Appendix F - Full Strategic Employment Site Assessments: Land at Ridgmont (Ref. NLP244)

Policy SP1: Growth Strategy in the First Draft Local Plan (FDLP) identifies land at M1 Junction 13 for strategic employment development. As set out in our representations to Policy SP1, we support the allocation of land in this location for strategic employment. Land at Ridgmont (Ref. NLP244) is promoted as a potential site for strategic employment uses, and the site was assessed in the Strategic Employment Site Assessments document (see Appendix F). It is recommended that the site is included within the Local Plan as a potential standalone strategic employment allocation (see Appendix E).

We comment on the assessment of the site, with a particular focus on the potential landscape and visual impacts of strategic employment development. Item No.27 in the assessment considers landscape character, and considers some of the key landscape features that have informed the assessment.

Appendix F Item No.27 in the assessment considers landscape character, and considers some of the key landscape features. The conclusion is as follows: "Some limited scope for development in a parcel to the west of the right of way. Farmland to the east and north forms an attractive open setting to the Greensand Ridge. Any development would need to be secondary in scale and not detract from the distinctive roofline of the Amazon warehouse. Important to retain development west of the railway and not allow spread into open countryside, or limit the attractive views gained from Ridgmont bypass and from elevated land to the south and west". The site scores 'R for Red/A for Amber'.

The Stage 2 Assessment Conclusion for the site appears to ignore the significant landscape sensitivities of this site identified in the landscape commentary at Item No.27. The conclusions are as follows: "The site is considered suitable to accommodate the proposed development with no overriding constraints to development. Landscape impacts should be considered when determining the scale and mass of development. The site passes stage 2". The Summary for the site is as follows: "The site is considered suitable to accommodate the proposed development with no overriding constraints to development. The site is located at Junction 13 of the M1, which is a strategic location for distribution uses. There is less of a market for office uses, although ancillary offices and some light industrial would also be suitable. The site passes stage 3, and is therefore recommended for employment allocation in the Local Plan".

We disagree with the Stage 2 Conclusions as they fail to acknowledge the earlier landscape assessment of the site. Therefore, the findings are not robust and do not fully consider the landscape and visual impacts of development. The conclusion that there are no overriding constraints to development is not correct since landscape impact is clearly identified as a concern.

Paragraph 182 of the NPPF identifies the four soundness tests for Local Plans. The 'justified' test is particularly relevant to the evidence used to inform Local Plans, and states: "the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;...". As set out below, the Council's landscape assessment of this site does not provide the robust or credible evidence required to support a strategic employment allocation at this site.

FPCR has prepared a Landscape Appraisal of Land at Ridgmont which is submitted with these representations. The Landscape Appraisal provides a comprehensive landscape assessment of the site. FPCR consider that the Council's landscape assessment of the site contains errors and is inconsistent.

FPCR's conclusions on the site are as follows:
* The site is situated within a valued landscape which forms part of the attractive low lying open arable farmland at the foot of the distinctive Greensand Ridge and provides a setting to the historic settlements of Ridgmont and Husborne Crawley. The value of this landscape was recognised through its designation as an "Area of Great Landscape Value'' (AGLV) in the previous local plan.
* Analysis of various national and county level assessments confirm that the site lies within a valued landscape which is sensitive to development. FPCR's assessment of the site accords with the findings of CBC's published Landscape Character Assessment and Landscape Sensitivity Assessment. The agricultural landscape within which the site occurs is open in nature, with important views of the Greensand Ridge and historic villages which feature along the skyline.
* Development within the area would strongly affect the visual relationship with and setting of the Greensand Ridge and Ridgmont. The relevant landscape guidelines for the area state that the open land at the foot of the ridge should be safeguarded to provide the setting for the ridge and the associated villages on the Greensand Ridge.
* The well-used public rights of way network which crosses the site, includes the Greensand Ridge Walk, the John Bunyan Trail as well as other footpath and bridleway routes. These public rights of way provide important regional recreational routes along the Greensand Ridge and connect to the historic village of Ridgmont.
* A range of close range and longer distance views overlook the site, the majority of which are from the highly sensitive public rights of way network. Views across the site are over an open arable landscape, back dropped by the impressive Greensand Ridge which forms the near horizon. Highpoints along the Greensand Ridge include Boughton End to the north and Castle Hill, Ridgmont to the south. All Saints Church at Ridgmont and St James Church at Husborne Crawley (both Grade II* listed) form landmark buildings within local views. Ridgmont Station (Grade II listed) also features within local views. Arable fields within the site provide the foreground and setting within views to the Greensand Ridge, the historic villages and listed buildings. These existing views including from the Greensand Ridge Walk and John Bunyan Trail would be potentially replaced by views of employment development.
* Development of the site would potentially result in substantial adverse landscape and visual effects including long term harm upon the setting of the Greensand Ridge and historic villages; and for users of the Greensand Ridge Walk and the John Bunyan Trail.

Therefore, the findings and conclusions of the landscape assessment of the site should be corrected to reflect the landscape appraisal by FPCR. We request that land at Ridgmont (Ref. NLP244) should not be allocated as a strategic employment site.

Attachments:

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 2237

Received: 25/08/2017

Respondent: Mr Richard Parry

Agent: Mr Richard Parry

Representation:

On behalf of the owners of site ALP207 I fully support this oolicy

Full text:

On behalf of the owners of site ALP207 I fully support this oolicy

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 2239

Received: 25/08/2017

Respondent: ALP207

Agent: Mr Richard Parry

Representation:

On behalf of the owners of site ALP207 I fully support this technical document

Full text:

On behalf of the owners of site ALP207 I fully support this technical document

Object

Site Assessment Results (Housing & Employment)

Representation ID: 2260

Received: 26/08/2017

Respondent: Mr & Mrs Maureen Mander

Representation:

NLP082: If this site is built on, serious consideration should be made regarding traffic. The Greenway has become a major road due to the amount of Hanlon lorries using it for access to the A507. In the event of building here the widening of the Greenway should be a major issue. Also Gravenhurst Road would need to be widened to take any extra traffic.

Full text:

NLP082: If this site is built on, serious consideration should be made regarding traffic. The Greenway has become a major road due to the amount of Hanlon lorries using it for access to the A507. In the event of building here the widening of the Greenway should be a major issue. Also Gravenhurst Road would need to be widened to take any extra traffic.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 2454

Received: 27/08/2017

Respondent: j Donnelly

Representation:

I object to this.

Full text:

I object to this.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 2455

Received: 27/08/2017

Respondent: T Hirons

Representation:

I object to this.

Full text:

I object to this.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 2667

Received: 29/08/2017

Respondent: Mr B. Brennan

Agent: Aragon Land & Planning Ltd

Representation:

Appendix D
NLP 387. This was a site suggested for a Park and Ride and recreation facilities. It is a site that is in close proximity to Ampthill and Flitwick and irrespective of the potential for a Park and Ride it could provide recreational facilities. The land is close to Ampthill and this site could provide needed or additional sports facilities if required for existing, replacement or as an enhancement for the community.

Full text:

Appendix D
NLP 387. This was a site suggested for a Park and Ride and recreation facilities. It is a site that is in close proximity to Ampthill and Flitwick and irrespective of the potential for a Park and Ride it could provide recreational facilities. The land is close to Ampthill and this site could provide needed or additional sports facilities if required for existing, replacement or as an enhancement for the community.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 3772

Received: 29/08/2017

Respondent: Legal & General Capital

Agent: Savills

Representation:

Please see attached representation.

Full text:

Please see attached representation.

Support

Site Assessment Results (Housing & Employment)

Representation ID: 3944

Received: 29/08/2017

Respondent: Central Bedfordshire Council Assets

Agent: Woods Hardwick Planning Ltd

Representation:

See full representation

Full text:

CBC Assets welcomes and supports the assessment and conclusions set out for the proposed employment site on land to the west of the A1 at Biggleswade (Site Ref: NLP437 - Land West of A1, Biggleswade). It is considered that this site represents an excellent opportunity to deliver an exemplar employment development that will deliver significant social and economic benefits to Biggleswade and Central Bedfordshire.

The assessment recognises that the site is not subject to any significant environmental constraints that would hinder the delivery of the site or suggest that alternative sites should be considered. In itself, this would not be sufficient to support the site coming forward as an allocation. Employment land should be in the right location, be viable and be attractive to the market i.e. meet demand. To further support the allocation of this site, CBRE has been commissioned to prepare a report to review the Employment Land Review (ELR). The key facts and findings are included within these submissions.

Separate submissions have been made in response to the published Employment Land Review. It is considered that the ELR is an accurate reflection of the balance between the need for and supply of employment land in Central Bedfordshire, on the basis of past trends and through the use of an adopted methodology that this trialled and tested for assessments of this nature.

However, in light of market aspirations and investment, Central Bedfordshire is in an excellent position to benefit through significant economic growth. The socio-economic dynamics of the area will change over the plan period and beyond and this supports the adoption of a more innovative and ambitious approach to planning for employment in Central Bedfordshire.

The South East of England is emerging as a key focus for growth and investment, evidenced by the fact that central and local government/agencies are planning and committing significant infrastructure projects in this area with the aim of supporting and unlocking growth.

Central Bedfordshire lies within the SEMLEP area. SEMLEP's seeks to support business investment and drive economic success and to creating the necessary infrastructure that the area needs to create new homes and jobs for the South-East Midlands.

In seeking to achieve those objectives, key projects have been identified to support economic growth. These primarily focus on transport and movement, in particular across the country to support the current strong north-south transport corridors. Central Bedfordshire is to be supported by the East-West rail link and the Oxford-Cambridge Expressway, both of which will be close to Biggleswade. The geographic band will be an area where economic growth is concentrated.

For a number of years, the M1 corridor has been the principal area for concentration of new employment land development. However, there are supply constraints and a resulting increase in occupational costs which come about as a result of competition, higher land costs and availability of labour.

The A1(M) corridor is well placed to offer an attractive solution for occupiers with lower occupational costs, improved choice and greater availability of labour. Occupational costs are critical when considering how best to meet market demand across all sectors and as stated, costs rise when supply is constrained.

A constrained supply of land will normally result in growth sectors occupying the most desirable sites, pushing other sectors, in need of support, to less desirable sites. The knock-on effect of this is impact upon development viability which in turn can reduce the overall quality of development.

Land West of the A1 offers an excellent opportunity to deliver a large strategic employment site that will offer a range of choice to all sectors of the market, thus keeping occupational costs at a reasonable level so as to be attractive to a wide range of potential occupiers. There is a strong market for the national sector which comprises large format occupiers and the delivery of a large strategic site will appeal across a range of employment functions. To compliment this, the site would also meet regional and local demand for smaller scale businesses. The benefits of co-locating a wide range of businesses are significant and enables a site to adapt to changing market demand and a potential to meet changing sector demand.

The identification of employment land at the scale proposed significantly improves development viability and deliverability of the site. Sites are subject to substantial infrastructure costs to enable development to come forward and by maximising the size of the site, those costs can be more easily absorbed into the overall development costs i.e. the infrastructure costs per hectare are lower the bigger the site.

CBC Assets highlight the research and analysis set out in the CBRE report, demonstrating that there is sufficient demand for the scale of development proposed. CBC, through the current development plan, has allocated employment sites. However, a number of those sites have not come forward as the supply does not suit market demand.

As an economy, the UK manufactures a relatively small proportion of goods and largely imports them. Therefore, the vast majority of floorspace is taken up by storage and distribution i.e. logistics occupiers. This sector has experienced significant demand over the past 10 years but recently supply has been constrained which has affected the take up of floorspace.

Demand will not fall away as e-commerce continues to grow, with the UK having the highest growth forecast in the retail market of all European countries. All evidence clearly points to a growing and sustained demand for logistics in the UK and to meet demand, the planning system must act to plan to meet that growth.

This site is excellently placed to meet that demand for growth. The logistics sector requires excellent highway accessibility, a large flat site (with no major physical constraints and an available pool of labour. This site meets all of those requirements.

Whilst this site would be logistics led in terms of market demand, it is also suitable for light industrial (B1) and general industrial use (B2), both of which would complement B8 uses. Again, the size of the site would provide a range of choice to cater for market demand across the different sectors.

The allocation of this site is not only ideally placed in relation to the strategic road network (both existing and proposed) and the availability of a labour but is also very well located in relation to planned residential growth for Central Bedfordshire over the next 20 years. The Draft Local Plan is proposing substantial residential growth at Tempsford and to the east of Biggleswade. Those sites along with this employment site follow the sound planning principles of aligning housing with employment growth, creating sustainable travel to work patterns.

The scale of development proposed would enable sustainable transport measures to be put in place to serve the development and provide good links between Biggleswade town centre and surrounds. On a wider sustainability agenda, the scale of development and viability would allow for greater energy efficiency measures and power generation initiatives to be implemented e.g. Combined Heat & Power energy generation to serve the development, innovative construction methods, use of sustainable drainage systems etc.

The site lies on the Biggleswade Green Wheel, which crosses the northern part of the site. This can be incorporated into the site and enhanced to promote cycling and walking through the surrounding area within a Green Infrastructure corridor.

Employment growth will also bring with it socio-economic benefits, which will be significant for the scale of the site proposed. This will be delivered through jobs created by the development itself and in-direct jobs associated with servicing of or benefiting from the site coming forward. An estimate based on HCA floorspace densities, would mean that the site could generate a total of 2,500 direct jobs and 1000 indirect jobs off-site. This job creation will obviously reduce unemployment, increase household incomes and expenditure and upskill the labour force.

Central Bedfordshire Council Assets as the landowner and promoter of the scheme would be able to deliver significant benefits to the administrative area as a whole. The sale and/or long-term lease of the site would generate a significant financial income for the Council, which would be recycled to deliver Council services to all residents. Furthermore, there would be ongoing receipt of business rates, which would also be used for the delivery of Council services. This constitutes a major benefit resulting from the allocation of the site.

The site is being promoted for c.125 hectares and the foregoing submissions provide justification for the allocation of that quantum of land. However, there is future potential for the amount of available land to increase and deliver further employment beyond the plan period. By the end of the plan period, the wind farm development may potentially have ceased, which will provide an opportunity to extend the site beyond the current area proposed.

The CBRE analysis of demand supports the provision of additional land over and above that currently envisioned along the A1. CBC Assets has promoted further land adjacent to the A1 at Stotfold, which has not been deemed appropriate for consideration as an allocation in this plan. However, it is considered that there will be sufficient future demand, given the growth and investment proposed and the future potential for the A1, to support the allocation of the site at Biggleswade AND the allocation of the site at Stotfold. If the site at Stotfold is not an option in this plan period then it is critical that full advantage is taken of the availability of land at Biggleswade.

To summarise, CBC Assets fully supports the assessment of the LPA in taking the land west of the A1 forward for consideration as an allocation. The following key points apply:

* Central Bedfordshire is excellently placed to benefit from significant investment to support and stimulate economic growth;
* Due to the changing nature of demand and the sale of goods, there will be sustained growth in the logistics market;
* Future demand will likely exceed the amount of land proposed, supporting the allocation of the entirety of the site and potentially further land beyond the plan period;
* The site is of a scale that infrastructure costs will be less of a per hectare basis, the site will be more viable and there should be no issues with deliverability;
* The associated occupational costs will be reduced making the site more attractive to all employment sectors, maximising its attractiveness to the market and providing choice;
* The site meets the key criteria for a strategic employment site i.e. excellent highway accessibility, is a large flat site with no major constraints and there is an available pool of skilled labour;
* The location is aligned with planning housing growth for the area;
* The site can deliver an exemplar scheme and is of a size where innovative and sustainable measures can be incorporated;
* There will be significant socio-economic benefits from job creation and increased expenditure in the area; and
* The site would be brought forward by Central Bedfordshire Council as landowner, with all revenues generated recycled into the provision of all Council services.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 4629

Received: 19/07/2017

Respondent: Thomas Harding

Representation:

NLP510
Site is within Flood Zone 3, mediation of this would be expensive and detrimental to local residents, Traffic issues along the A1 and Hill Lane Biggleswade

Full text:

NLP 510 Biggleswade This site is in EPA designated highest flood risk zone 3, zone 3b flood plain as defined by the LGA planning authorities. That is the highest risk of flooding. Any attempt to protect against flooding would have a detrimental affect on local existing residential areas. It would be extremely expensive. The site also suffers from access problems for traffic off the A1 and Hill Lane Biggleswade. This site is not suitable for conventional employment development.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 4631

Received: 19/07/2017

Respondent: Thomas Harding

Representation:

NLP437, ALP442
plans to bring forward sites here could conflict with Highways England plans for modifications to the roundabout.

Full text:

NLP 437 & ALP 442 Sites are in an area that has been the subject of opposition to a service station off the Roundabout. Applicant's consultant was unaware of potential commitment by Highways England regarding as a minimum modifications to the roundabout right up to re-routeing of the A1 as far south as Baldock. Until plans are firmed up it is premature to develop an area that could hinder HE plans, or have to be demolished when the plans are finalised. Acceptance by the Authority of these sites must be couched in heavy conditions at the developer's risk.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 4708

Received: 29/08/2017

Respondent: Mr Sam Franklin

Agent: Mr Sam Franklin

Representation:

Objects to NLP210 being excluded from further assessment

Full text:

NLP210 Land at Manor Farm Brogborough
This site offers a strategic commercial development opportunity in a sustainable location.

It is adjacent to an approved commercial site in a strategic corridor close to the East West rail terminal proposal at Ridgmont station and Junction 13 of the M1 Junction with the Oxford Cambridge Expressway, offering superior connections to national transport routes.

Commercial development in this location is unlikely to be highly visible as the landscape is lower than suggested and natural screening is already in place and development would adjoin an existing distribution site and the A421 embankment.

Support

Site Assessment Results (Housing & Employment)

Representation ID: 4846

Received: 29/08/2017

Respondent: Central Bedfordshire Council Assets

Agent: Woods Hardwick Planning Ltd

Representation:

- CBC well placed to benefit from investment
- sustained growth in logistics market
- future demand will exceed the amount of land proposed
- no issues with site delivery
- occupational costs will be reduced, making the site more attractive
- meets criteria for a strategic employment site
aligned with planning housing growth for the area
- can deliver an exemplar scheme
- significant socio-economic benefits from job creation

Full text:

CBC Assets welcomes and supports the assessment and conclusions set out for the proposed employment site on land to the west of the A1 at Biggleswade (Site Ref: NLP437 - Land West of A1, Biggleswade). It is considered that this site represents an excellent opportunity to deliver an exemplar employment development that will deliver significant social and economic benefits to Biggleswade and Central Bedfordshire.

The assessment recognises that the site is not subject to any significant environmental constraints that would hinder the delivery of the site or suggest that alternative sites should be considered. In itself, this would not be sufficient to support the site coming forward as an allocation. Employment land should be in the right location, be viable and be attractive to the market i.e. meet demand. To further support the allocation of this site, CBRE has been commissioned to prepare a report to review the Employment Land Review (ELR). The key facts and findings are included within these submissions.

Separate submissions have been made in response to the published Employment Land Review. It is considered that the ELR is an accurate reflection of the balance between the need for and supply of employment land in Central Bedfordshire, on the basis of past trends and through the use of an adopted methodology that this trialled and tested for assessments of this nature.

However, in light of market aspirations and investment, Central Bedfordshire is in an excellent position to benefit through significant economic growth. The socio-economic dynamics of the area will change over the plan period and beyond and this supports the adoption of a more innovative and ambitious approach to planning for employment in Central Bedfordshire.

The South East of England is emerging as a key focus for growth and investment, evidenced by the fact that central and local government/agencies are planning and committing significant infrastructure projects in this area with the aim of supporting and unlocking growth.

Central Bedfordshire lies within the SEMLEP area. SEMLEP's seeks to support business investment and drive economic success and to creating the necessary infrastructure that the area needs to create new homes and jobs for the South-East Midlands.

In seeking to achieve those objectives, key projects have been identified to support economic growth. These primarily focus on transport and movement, in particular across the country to support the current strong north-south transport corridors. Central Bedfordshire is to be supported by the East-West rail link and the Oxford-Cambridge Expressway, both of which will be close to Biggleswade. The geographic band will be an area where economic growth is concentrated.

For a number of years, the M1 corridor has been the principal area for concentration of new employment land development. However, there are supply constraints and a resulting increase in occupational costs which come about as a result of competition, higher land costs and availability of labour.

The A1(M) corridor is well placed to offer an attractive solution for occupiers with lower occupational costs, improved choice and greater availability of labour. Occupational costs are critical when considering how best to meet market demand across all sectors and as stated, costs rise when supply is constrained.

A constrained supply of land will normally result in growth sectors occupying the most desirable sites, pushing other sectors, in need of support, to less desirable sites. The knock-on effect of this is impact upon development viability which in turn can reduce the overall quality of development.

Land West of the A1 offers an excellent opportunity to deliver a large strategic employment site that will offer a range of choice to all sectors of the market, thus keeping occupational costs at a reasonable level so as to be attractive to a wide range of potential occupiers. There is a strong market for the national sector which comprises large format occupiers and the delivery of a large strategic site will appeal across a range of employment functions. To compliment this, the site would also meet regional and local demand for smaller scale businesses. The benefits of co-locating a wide range of businesses are significant and enables a site to adapt to changing market demand and a potential to meet changing sector demand.

The identification of employment land at the scale proposed significantly improves development viability and deliverability of the site. Sites are subject to substantial infrastructure costs to enable development to come forward and by maximising the size of the site, those costs can be more easily absorbed into the overall development costs i.e. the infrastructure costs per hectare are lower the bigger the site.

CBC Assets highlight the research and analysis set out in the CBRE report, demonstrating that there is sufficient demand for the scale of development proposed. CBC, through the current development plan, has allocated employment sites. However, a number of those sites have not come forward as the supply does not suit market demand.

As an economy, the UK manufactures a relatively small proportion of goods and largely imports them. Therefore, the vast majority of floorspace is taken up by storage and distribution i.e. logistics occupiers. This sector has experienced significant demand over the past 10 years but recently supply has been constrained which has affected the take up of floorspace.

Demand will not fall away as e-commerce continues to grow, with the UK having the highest growth forecast in the retail market of all European countries. All evidence clearly points to a growing and sustained demand for logistics in the UK and to meet demand, the planning system must act to plan to meet that growth.

This site is excellently placed to meet that demand for growth. The logistics sector requires excellent highway accessibility, a large flat site (with no major physical constraints and an available pool of labour. This site meets all of those requirements.

Whilst this site would be logistics led in terms of market demand, it is also suitable for light industrial (B1) and general industrial use (B2), both of which would complement B8 uses. Again, the size of the site would provide a range of choice to cater for market demand across the different sectors.

The allocation of this site is not only ideally placed in relation to the strategic road network (both existing and proposed) and the availability of a labour but is also very well located in relation to planned residential growth for Central Bedfordshire over the next 20 years. The Draft Local Plan is proposing substantial residential growth at Tempsford and to the east of Biggleswade. Those sites along with this employment site follow the sound planning principles of aligning housing with employment growth, creating sustainable travel to work patterns.

The scale of development proposed would enable sustainable transport measures to be put in place to serve the development and provide good links between Biggleswade town centre and surrounds. On a wider sustainability agenda, the scale of development and viability would allow for greater energy efficiency measures and power generation initiatives to be implemented e.g. Combined Heat & Power energy generation to serve the development, innovative construction methods, use of sustainable drainage systems etc.

The site lies on the Biggleswade Green Wheel, which crosses the northern part of the site. This can be incorporated into the site and enhanced to promote cycling and walking through the surrounding area within a Green Infrastructure corridor.

Employment growth will also bring with it socio-economic benefits, which will be significant for the scale of the site proposed. This will be delivered through jobs created by the development itself and in-direct jobs associated with servicing of or benefiting from the site coming forward. An estimate based on HCA floorspace densities, would mean that the site could generate a total of 2,500 direct jobs and 1000 indirect jobs off-site. This job creation will obviously reduce unemployment, increase household incomes and expenditure and upskill the labour force.

Central Bedfordshire Council Assets as the landowner and promoter of the scheme would be able to deliver significant benefits to the administrative area as a whole. The sale and/or long-term lease of the site would generate a significant financial income for the Council, which would be recycled to deliver Council services to all residents. Furthermore, there would be ongoing receipt of business rates, which would also be used for the delivery of Council services. This constitutes a major benefit resulting from the allocation of the site.

The site is being promoted for c.125 hectares and the foregoing submissions provide justification for the allocation of that quantum of land. However, there is future potential for the amount of available land to increase and deliver further employment beyond the plan period. By the end of the plan period, the wind farm development may potentially have ceased, which will provide an opportunity to extend the site beyond the current area proposed.

The CBRE analysis of demand supports the provision of additional land over and above that currently envisioned along the A1. CBC Assets has promoted further land adjacent to the A1 at Stotfold, which has not been deemed appropriate for consideration as an allocation in this plan. However, it is considered that there will be sufficient future demand, given the growth and investment proposed and the future potential for the A1, to support the allocation of the site at Biggleswade AND the allocation of the site at Stotfold. If the site at Stotfold is not an option in this plan period then it is critical that full advantage is taken of the availability of land at Biggleswade.

To summarise, CBC Assets fully supports the assessment of the LPA in taking the land west of the A1 forward for consideration as an allocation. The following key points apply:

* Central Bedfordshire is excellently placed to benefit from significant investment to support and stimulate economic growth;
* Due to the changing nature of demand and the sale of goods, there will be sustained growth in the logistics market;
* Future demand will likely exceed the amount of land proposed, supporting the allocation of the entirety of the site and potentially further land beyond the plan period;
* The site is of a scale that infrastructure costs will be less of a per hectare basis, the site will be more viable and there should be no issues with deliverability;
* The associated occupational costs will be reduced making the site more attractive to all employment sectors, maximising its attractiveness to the market and providing choice;
* The site meets the key criteria for a strategic employment site i.e. excellent highway accessibility, is a large flat site with no major constraints and there is an available pool of skilled labour;
* The location is aligned with planning housing growth for the area;
* The site can deliver an exemplar scheme and is of a size where innovative and sustainable measures can be incorporated;
* There will be significant socio-economic benefits from job creation and increased expenditure in the area; and
* The site would be brought forward by Central Bedfordshire Council as landowner, with all revenues generated recycled into the provision of all Council services.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 4905

Received: 29/08/2017

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

NLP244 - Ridgmont:

Should fail initial assessments,
did not fully consider landscape character assessment made on the site by the internal consultant.
impacts of Greensand Ridge,
Impact on views,
Impact on listed buildings, in this case a church,
impact on John Bunyan Trail

Full text:

Appendix E - Summary of Strategic Site Assessments & Appendix F - Full Strategic Employment Site Assessments: Land at Ridgmont (Ref. NLP244)

Policy SP1: Growth Strategy in the First Draft Local Plan (FDLP) identifies land at M1 Junction 13 for strategic employment development. As set out in our representations to Policy SP1, we support the allocation of land in this location for strategic employment. Land at Ridgmont (Ref. NLP244) is promoted as a potential site for strategic employment uses, and the site was assessed in the Strategic Employment Site Assessments document (see Appendix F). It is recommended that the site is included within the Local Plan as a potential standalone strategic employment allocation (see Appendix E).

We comment on the assessment of the site, with a particular focus on the potential landscape and visual impacts of strategic employment development. Item No.27 in the assessment considers landscape character, and considers some of the key landscape features that have informed the assessment.

Appendix F Item No.27 in the assessment considers landscape character, and considers some of the key landscape features. The conclusion is as follows: "Some limited scope for development in a parcel to the west of the right of way. Farmland to the east and north forms an attractive open setting to the Greensand Ridge. Any development would need to be secondary in scale and not detract from the distinctive roofline of the Amazon warehouse. Important to retain development west of the railway and not allow spread into open countryside, or limit the attractive views gained from Ridgmont bypass and from elevated land to the south and west". The site scores 'R for Red/A for Amber'.

The Stage 2 Assessment Conclusion for the site appears to ignore the significant landscape sensitivities of this site identified in the landscape commentary at Item No.27. The conclusions are as follows: "The site is considered suitable to accommodate the proposed development with no overriding constraints to development. Landscape impacts should be considered when determining the scale and mass of development. The site passes stage 2". The Summary for the site is as follows: "The site is considered suitable to accommodate the proposed development with no overriding constraints to development. The site is located at Junction 13 of the M1, which is a strategic location for distribution uses. There is less of a market for office uses, although ancillary offices and some light industrial would also be suitable. The site passes stage 3, and is therefore recommended for employment allocation in the Local Plan".

We disagree with the Stage 2 Conclusions as they fail to acknowledge the earlier landscape assessment of the site. Therefore, the findings are not robust and do not fully consider the landscape and visual impacts of development. The conclusion that there are no overriding constraints to development is not correct since landscape impact is clearly identified as a concern.

Paragraph 182 of the NPPF identifies the four soundness tests for Local Plans. The 'justified' test is particularly relevant to the evidence used to inform Local Plans, and states: "the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;...". As set out below, the Council's landscape assessment of this site does not provide the robust or credible evidence required to support a strategic employment allocation at this site.

FPCR has prepared a Landscape Appraisal of Land at Ridgmont which is submitted with these representations. The Landscape Appraisal provides a comprehensive landscape assessment of the site. FPCR consider that the Council's landscape assessment of the site contains errors and is inconsistent.

FPCR's conclusions on the site are as follows:
* The site is situated within a valued landscape which forms part of the attractive low lying open arable farmland at the foot of the distinctive Greensand Ridge and provides a setting to the historic settlements of Ridgmont and Husborne Crawley. The value of this landscape was recognised through its designation as an "Area of Great Landscape Value'' (AGLV) in the previous local plan.
* Analysis of various national and county level assessments confirm that the site lies within a valued landscape which is sensitive to development. FPCR's assessment of the site accords with the findings of CBC's published Landscape Character Assessment and Landscape Sensitivity Assessment. The agricultural landscape within which the site occurs is open in nature, with important views of the Greensand Ridge and historic villages which feature along the skyline.
* Development within the area would strongly affect the visual relationship with and setting of the Greensand Ridge and Ridgmont. The relevant landscape guidelines for the area state that the open land at the foot of the ridge should be safeguarded to provide the setting for the ridge and the associated villages on the Greensand Ridge.
* The well-used public rights of way network which crosses the site, includes the Greensand Ridge Walk, the John Bunyan Trail as well as other footpath and bridleway routes. These public rights of way provide important regional recreational routes along the Greensand Ridge and connect to the historic village of Ridgmont.
* A range of close range and longer distance views overlook the site, the majority of which are from the highly sensitive public rights of way network. Views across the site are over an open arable landscape, back dropped by the impressive Greensand Ridge which forms the near horizon. Highpoints along the Greensand Ridge include Boughton End to the north and Castle Hill, Ridgmont to the south. All Saints Church at Ridgmont and St James Church at Husborne Crawley (both Grade II* listed) form landmark buildings within local views. Ridgmont Station (Grade II listed) also features within local views. Arable fields within the site provide the foreground and setting within views to the Greensand Ridge, the historic villages and listed buildings. These existing views including from the Greensand Ridge Walk and John Bunyan Trail would be potentially replaced by views of employment development.
* Development of the site would potentially result in substantial adverse landscape and visual effects including long term harm upon the setting of the Greensand Ridge and historic villages; and for users of the Greensand Ridge Walk and the John Bunyan Trail.

Therefore, the findings and conclusions of the landscape assessment of the site should be corrected to reflect the landscape appraisal by FPCR. We request that land at Ridgmont (Ref. NLP244) should not be allocated as a strategic employment site.

Attachments:

Object

Site Assessment Results (Housing & Employment)

Representation ID: 4928

Received: 24/08/2017

Respondent: Dawsongroup plc

Agent: Q+A Planning Ltd

Representation:

In summary, we object to the suggestion that development will be planned for at a 'selection' of the locations listed. It is critical for the Local Plan to provide certainty to local businesses wishing to invest in the area and our client's site should be allocated for employment development to help deliver the objectives for the Growth Area and to provide for choice to the market

Full text:

Dawsongroup plc are an asset rental company in the transport and distribution sector, with a base in Milton Keynes and the surrounding area. On behalf of our client, we are promoting the development of a site titled by the Council as 'land south of Highfield Farm' for employment development (reference ALP421 showing as 5.84 ha). The development would be occupied by our client as their head office and would comprise office space as well as open storage and warehousing.

On behalf of our client, we object to the suggestion that development will be planned for at a 'selection' of the locations listed. It is critical for the Local Plan to provide certainty to local businesses wishing to invest in the area. Whilst we understand further testing of sites is due to take place (which we comment on separately), the Local Plan must be clear that additional development will be supported in the locations list. We also suggest that our client's site is allocated for employment development to help deliver the objectives for the Growth Area and to provide for choice to the market.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 4932

Received: 24/08/2017

Respondent: Dawsongroup plc

Agent: Q+A Planning Ltd

Representation:

In summary, whilst the general aspiration for additional employment development at Junction 13 of the M1 is supported, our client's site (ALP421) should be allocated to provide a mix of employment space consistent with the Council's evidence.

Full text:

Dawsongroup plc are an asset rental company in the transport and distribution sector, with a base in Milton Keynes and the surrounding area. On behalf of our client, we are promoting the development of a site titled by the Council as 'land south of Highfield Farm' for employment development (reference ALP421 showing as 5.84 ha). The development would be occupied by our client as their head office and would comprise office space as well as open storage and warehousing.

Our client is generally supportive of the broad Area C - East-West Growth Area for M1 Junction 13 (around 40 hectares for employment). On closer inspection of the supporting evidence, it appears this area is referring to site NLP244, which is 'Land at Ridgmont Land to the north of A507, MK43 0XP' (which extends to 43 ha). However, we note that there is nothing within the Plan itself that confirms that this is the expected site to deliver this strategic allocation.

Whilst we have no comment per se on the suggested allocation, it is clear that our client's site falls very close to the growth area as shown on Figure 8.1 and we consider that the intended development of the site can assist in delivering the additional employment development as expected as part of this wider growth strategy, irrespective of the suggested allocation. The sector proposed by our client is distinct from the established logistics and distribution uses in the area and that would be expected to be included within NLP244. It represents a significant investment by a locally based company to provide for jobs for local people, including a substantial quantum of office floorspace.

The allocation of our client's site would be entirely consistent with the Council's evidence. The development is likely to be a mixed use class, but the Council's FEMA and ELR (2016) provides clear support for the type of employment expected to grow during the plan period. In particular, it states at paragraph 9.6 that 'In relation to industrial employment, growth is more limited but land transport, storage and post (distribution), specialised construction activities and wholesale are the main areas of forecast employment growth over the plan period'.

Furthermore, Recommendation 5 of the FEMA and ELR states that 'to improve local choice in the network of towns and villages, the Council should consider new small-scale employment allocations that can be provided on a freehold basis to meet local needs'. It also states that the 'market review identified that the pipeline of small-scale employment sites should be bolstered. To address this, we recommend that when readjusting the portfolio, the Council should look to identify new, smaller sites in the main towns and villages which are purposefully allocated to meet local demand and free of strategic warehousing pressure'. Our client's falls in this category and it is therefore it is important that it is allocated to provide for the diversity of employment needed to meet the expected jobs growth.

Object

Site Assessment Results (Housing & Employment)

Representation ID: 5326

Received: 23/08/2017

Respondent: Mr Anthony Kinns

Agent: Woods Hardwick Planning Ltd

Representation:

NLP176

Site should be reconsidered,
Wharley End should be considered a settlement in its own right,
would compliment existing development at Wharley End,
availability of PDL,
recent application for 300 dwellings and associated infrastructure

Full text:

These representations are submitted on behalf of our client, Mr A. Kinns, who is promoting land around Wharley End Farm, Wharley End, Cranfield (Site Ref NLR176) for sustainable residential development, as detailed in the Call for Sites submissions made in 2014 and 2016. Separate submissions having been made on the Draft Local Plan (DLP) and other Technical Documents of relevance to our client.

Our client wishes to object to the conclusion reached in respect of site NLP176 (Now NLR176 following the correction of the Map identifying the site to include all of the land promoted) that it does not proceed beyond Stage 1B and has not been identified as a growth location, this is on the basis it is not of sufficient scale to be self-contained and does not relate well to the existing settlement of Cranfield as defined by the settlement envelope and is separated from it by the Airfield.

Robust representations have been submitted on the DLP itself arguing that Wharley End should be considered a settlement in its own right, separate from Cranfield Village, given the substantial built development that exists there as part of the Cranfield University Campus and Technology Park. The Masterplan for the University recently the subject of consultation details major expansion plans. The University and Technology Park are one of the biggest employment areas in Central Bedfordshire, as recognised in the DLP (Section 13), however, there is only a limited amount of housing within the University Campus, meaning students and employees at the University, as well as people working at the Technology Park, have to commute from further afield resulting in considerable traffic movements to and from the area daily.

The allocation of a reasonable amount of new housing to the area would complement the existing development at Wharley End, whilst encouraging more sustainable transport patterns by allowing people the opportunity to live in close proximity to where they work or study. This is in accordance with the key aim of the DLP set out at paragraph 7.2.1 of growing existing communities so that they are more sustainable, in this case by locating housing close to existing facilities and crucially jobs.

This seems eminently logical and the case is further strengthened when you consider that a large proportion of the land being promoted by our client (Site NLR176) is previously developed. Paragraph 7.3.4 of the DLP implies that the Council is committed to maximising the use of available previously developed land, but suggests there is only a limited amount of this available meaning a need to allocate greenfield sites to meet the housing target. However, here we have a situation whereby previously development land is available, being actively promoted by a landowner and located immediately adjacent one of the biggest employment areas in Central Beds, yet it has been overlooked in the DLP.

Paragraph 7.5.1 of the DLP sets out the 'Spatial Strategy Approach' and includes a commitment to maximising potential opportunities for intensification and redevelopment. This further reinforces the need for the Submission Local Plan to include an allocation for residential development at Wharley End if it is to be considered the most appropriate strategy, when considered against the reasonable alternatives as required by the NPPF.

Part of our client's land has already been deemed suitable for development by virtue of its inclusion as an employment allocation in the adopted Site Allocations Plan under Policy EA5. The Employment Land Review published with the DLP considered the site (Reference CM005) and is fairly unenthusiastic about the prospects of employment being delivered, concluding that it is 'hard to tell' if the site would be successfully developed were it offered to the market for employment use free of supply-side constraints. As already argued, residential development would be deliverable and would complement the existing substantial employment development already at Wharley End.

As further evidence supporting the appropriateness of Wharley End as a location for new housing, Gladman Developments Ltd has recently submitted an outline planning application for up to 300 dwellings with land for a new primary school, land for a local centre, allotments and public open space on land immediately adjoining that being promoted by our client. Were it permitted, it would increase the sustainability of Wharley End further through the provision of a primary school and the local centre. It would also result in our client's land being surrounded on all four sides by development.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 5809

Received: 29/08/2017

Respondent: Aequitas (Milton Keynes) Ltd

Agent: Porta Planning LLP

Representation:

new site

Full text:

The exclusion of potential employment sites from assessment in Stage 3 of the Strategic Employment Site Assessment Technical Document 2017 should not preclude the allocation of such sites in the Submission version of the Local Plan. Whilst the assessment undertaken specifically excluded sites because of their size, where there are a number of sites clustered in one location but separated by physical features and/or land ownership, these sites may be appropriate for employment development to cumulatively meet employment needs and contribute to the provision targets set by Policy SP1.

Our client owns land adjacent to Junction 13 M1 which it requests is allocated for development in the Local plan. The site (former Goodes Transport site, Bedford Road - see attached plan) is situated between the A421 and Bedford Road. Immediately opposite the site on Bedford Road (east) is Prologis Park Marston Gate.

Having regard to the requirements of both draft Policies SP1 and EMP1:
* 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 comprises part of the wider allocation of this area 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.
The area around Junction 13 M1 is already the subject of considerable interest for development. An EIA screening request by MKSE Consortium for the development of up to 750 houses was progressed in 2016 for land to the south of the M1, and all of the land around Prologis Park Marston Gate has been promoted for development in the 'call for sites' exercise.

Attachments:

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 6270

Received: 28/08/2017

Respondent: Prologis UK Ltd

Agent: Lichfields

Representation:

Prologis appreciates the opportunity to work with Central Bedfordshire on the production of the Local Plan.
This letter provides information on the proposed Prologis Park Marston Gate expansion site, detailing the benefits of the allocation of the site within the Local Plan.
see attachment

Full text:

see attachment

Attachments:

Object

Site Assessment Results (Housing & Employment)

Representation ID: 7329

Received: 29/08/2017

Respondent: Landowners & IM Properties

Agent: Barton Willmore

Representation:

Old Park Farm - Harlington

Full text:

See attachment

Attachments:

Object

Site Assessment Results (Housing & Employment)

Representation ID: 7330

Received: 10/08/2017

Respondent: Prologis UK Ltd

Agent: David Lock Associates

Representation:

Sundon RFI - this should be referred to within the consultation document as a growth location. expect RFI to be removed from Green Belt and identified as a site allocation for the next stage.

Full text:

We are responding to this consultation on behalf of Prologis UK Ltd., which is promoting land under its control adjacent to Sundon Quarry for a rail freight interchange (Sundon RFI).

Against the backdrop of the Council's adopted Framework Plan (2015), the draft versions of the Development Strategy and before that the Joint Core Strategy, we are surprised that Sundon RFI is not specifically referred to within the consultation document as a potential growth location / site allocation to be removed from the Green Belt in the emerging Local Plan.

We do note, however, that the RFI is treated as an employment land commitment in the Luton Housing Market Area Growth Options Study and that the Council's site assessments of the RFI proposal demonstrate its strong performance.

We therefore fully expect the RFI to be removed from the Green Belt and identified as a site allocation in the forthcoming Pre-Submission version of the Plan, in accordance with the Council's adopted Framework Plan and the evidence base underpinning the emerging Local Plan.

Finally, we express strong support for the early delivery of the M1-A6 Link Road, to which we expect the RFI to make a proportionate financial contribution.
We look forward to continuing to work with the Council in delivering this long planned RFI.

Attachments:

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 7333

Received: 24/08/2017

Respondent: R & O Rogers Dec'd

Agent: Kirkby Diamond

Representation:

NLP178

Agree with assessment as being suitable for strategic employment/distribution development
Site is unconstrained, located adjacent to J13 and the A421 E/W corridor interchange
Consideration should be given to extending the allocation to include adjacent land (inc. Hulcote Farm) to ensure the benefits of the location are optimised and to relieve pressure on other, less suitable locations
Consideration should be given to formulation of a strategic plan for this location ensuring the area is sensitively/comprehensively planned, minimising impact on Hulcote/Salford/Husborne Crawley
Consideration needed re: optimisation of land use in this location, ensuring provision is made for future expansion/structural landscaping

Full text:

See attachment

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 7334

Received: 29/08/2017

Respondent: Hallam Land Management

Agent: Carter Jonas LLP

Representation:

As set out in our representations to the assessment of Land at Winterwoods Farm in the Strategic Employment Site Assessments (Ref. NLP178), we request that this site should be the preferred one for a strategic employment allocation at M1 Junction 13 and allocated accordingly.

Full text:

Section 13.5 relates to strategic warehousing and logistics, and Policy EMP1 seeks to maintain a continuous supply of land for these uses. As set out in our representations to Policy SP1, we support the allocation of land at M1 Junction 13 for strategic employment.
A planning application for Class B8 development at Winterwoods Farm was submitted in November 2016 and is currently being considered (Ref. CB16/05587/OUT). The application is supported by technical evidence on landscape and visual impact, transport and highways impact, and an economic and market assessment. There is an identified need for additional space to meet the needs of the logistics sector in the southern M1 Corridor, as set out in the Economic and Market Assessment Update Report July 2017 (prepared by GENECON and submitted for the planning application).

As set out in our representations to the assessment of Land at Winterwoods Farm in the Strategic Employment Site Assessments (Ref. NLP178), we request that this site should be the preferred one for a strategic employment allocation at M1 Junction 13 and allocated accordingly. There are significant adverse landscape impacts associated with the alternative site on Land at Ridgmont.

Requested Change
We request that Land at Winterwoods Farm is specifically referenced in Section 13.5 and Policy EMP1 as the preferred location for strategic employment at M1 Junction 13. It should be acknowledged that the M1 Corridor is the primary location for Class B8 development in Central Bedfordshire.

Comment

Site Assessment Results (Housing & Employment)

Representation ID: 7335

Received: 29/08/2017

Respondent: KK Parrish &Co

Agent: Fisher German

Representation:

NLP007 /008 /009 / 010 see comments on employment sites

Full text:

see attachment

Attachments: