Central Council Priory House Monks Walk Shefford Bedfordshire SG17 5TQ

Our ref: CBC 22.02.18 CU-Draft LP Your ref:

22nd February 2018

Dear Sir/ Madam,

Central Bedfordshire Council Draft Local Plan Consultation 2018 Representation

This representation has been prepared by Turnberry on behalf of Cranfield University, who welcome the opportunity to comment on Council’s (CBC) Pre-Submission Local Plan which has been published for consultation until 22nd February 2018.

On behalf of the University we reluctantly object to the Local Plan on the basis that it is neither Justified or Effective under the terms of Paragraph 182 of the National Planning Policy Framework. In particular, we will address the following issues:

1) The lack of prominence of the University, Airport and their associated Technology and Air Parks within key planning policies and Policy EMP5 in particular; 2) The lack of an employment allocation for the Air Park; 3) The failure to consider the functionality of and its Air Park when drafting Policy SP5: Preventing Coalescence and Important Countryside Gaps.

These are addressed in turn below.

Central Bedfordshire Council Local Plan – Pre-submission Consultation 20th February 2018

1. The Importance of the University, Airport and their associated Technology and Air Parks

This representation relates to Cranfield University and Cranfield Airport (including the latter’s Air Park), both of which are significant assets to Central Bedfordshire and key contributors to the local and regional economy. Cranfield generates an estimated £360 million in GVA for the UK and supports over 4,200 FTE jobs. Alongside these contributions, the University is one of the top performing higher education institutions in the UK in terms of working with business, in 2015/16 Cranfield had the fourth largest number of research contracts with SMEs of any UK university and generated the eighth highest income from the provision of courses for businesses.

In line with adopted planning policy DM11, Masterplans have been prepared for both Cranfield University Campus (including the area formerly known as the Cranfield University Technology Park) and Cranfield Airport. The Campus Masterplan has been endorsed as Technical Planning Guidance, whilst the Airport Masterplan has been included within a planning application for the revised Air Park proposal at Cranfield Airport.

The University acknowledge the helpful amendments to draft Policy EMP5 as to the status of endorsed Masterplans in future planning decisions, but a further revision is needed in order to ensure the Policy provides certainty to the process Policy EMP5 is promoting, namely:

Where a management plan, development brief or masterplan for a facility identified above has already been produced and endorsed by the Council, this should will be a material consideration for future planning decisions.

This amendment would ensure the efforts made by Cranfield University to undertake the extensive masterplanning process, at significant expense, is appropriately recognised so that the effect of the Policy is not neutralised by uncertainty and will assist in de-risking future development projects.

Furthermore, Policy EMP5 should be amended to include the supportive strategic sentiments expressed in paragraphs 12.10.3 and 12.10.4 as the University remains concerned at the significant under-representation of the University and Technology Park (or indeed the other strategic facilities cited in Policy EMP5) given their importance within the District in terms of education, employment and innovation.

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Central Bedfordshire Council Local Plan – Pre-submission Consultation 20th February 2018

A final example of the disconnect between the strategic emphasis on key issues and their expression within Planning Policy can be found in respect of education at paragraph 12.8.2 in respect of Education facilities. The paragraph states:

“The Council will seek to support the continued delivery of high quality learning and education within Central Bedfordshire, and will seek to support the development of learning and higher education facilities.”

It is our contention that for this Plan to be Effective and Positively Prepared, this clear intent should be included within a specific Policy addressing education development.

2. Cranfield Air Park

In a similar vein, there is no reference to the importance of Cranfield Airport to the District, including its associated Air Park. We would expect the Local Plan to reference the Airport as an important aviation hub. Indeed, the Core Strategy provides some useful text at paragraph 4.6.18 that should be incorporated within a draft Policy, provided it is updated as follows:

“A number of local airfields are located in the district. Cranfield Airport is a busy general aviation airport which has world-class training facilities linked to Cranfield University’s School of Aeronautics and also and provision for private charter flights for both business and recreational purposes. It also relies on links to Cranfield University, given its academic/research focus on, and wider engagement with, the aerospace sector. Other smaller airfields at RAF and Park are also used for training and recreational use. It is recognised that these facilities all make an important contribution to the local economy by facilitating air travel for business users in the case of Cranfield Airport, and tourism in the case of Old Warden and the wider Shuttleworth Collection. The Council will therefore ensure that development proposals do not compromise their continued use for aircraft purposes.”

Policy EMP5 should therefore clearly identify Cranfield Airport and its Air Park as a Strategic Facility in the Countryside. Moreover, the Air Park should be identified as a specific allocation alongside other employment sites identified in the supporting Maps. Finally, paragraph 12.10.3 should be amended as follows:

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Central Bedfordshire Council Local Plan – Pre-submission Consultation 20th February 2018

“The NPPF is clear about the need to secure economic growth. It recognises that the challenges presented by a low carbon future can still be met while also delivering this core objective. In order to proactively plan for businesses in within the key growth sectors emerging sectors like the green economy, the Council supports the development of innovation, research and development industries, particularly around the existing cluster of high technology centres of excellence of Cranfield University (including the area formerly known as Cranfield University Technology Park), Cranfield Airfield Airport (including the Air Park) and Millbrook Proving Ground.”

3. Policy SP5 and CG5 Land North and South of Cranfield The allocation of two sites north and south of Cranfield Airport under Policy CG5 should be reconsidered. This Countryside Gap allocation is problematic at present and thus furthers the case that the draft pre-submission is unsound in its current form, for the following reasons:

1) Its inclusion is inappropriately sudden and without a suitable evidence basis; 2) The northern allocation clashes with both an approved and proposed Air Park proposals which, unlike this Local Plan, have been supported by detailed landscape analysis, and; 3) Both allocations are likely to hinder or prevent essential infrastructure upgrades in support of Cranfield Airport.

Policy SP5 is neither Positively Prepared or Justified. The first point highlights that the evidence base used in support of the policy is questionable. The supporting text outlines ‘coalescence’ as the motivation for including these gaps stating the following:

‘The Council will resist new development that would result in further growth in these areas that would harm the separate character or identity of the communities.’

However, these allocations do not separate any communities given their distance from nearby settlements. A distance of 3.5 miles separates the northern extent of Cranfield Airport’s current allocation (EMP4(6) in the 2011 Site Allocation Document) and the next settlement, Astwood, and so the risk of coalescence north-south is not threatening in this area. Indeed, if the allocation advised above be permitted, this distance would still be 2.7 miles, and coalescence therefore still impossible.

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Central Bedfordshire Council Local Plan – Pre-submission Consultation 20th February 2018

For potential coalescence east-west, from Broad Green to North Crawley, is also unlikely as the 2 miles stretch of countryside would not be filled in by the 0.5 mile stretch in question. Each of these figures warrants the reduction of the northern allocation to better allow for appropriate development of the Airport and Air Park.

In reality, CG5 merely restricts legitimate development in and around the Airport, clashing with approved and proposed developments that comply with the adopted Core Strategy and potentially preventing the development of essential Airport infrastructure. It seems that the Council is promoting the wrong tool to achieve its real objective: defined settlement boundaries. The approach is therefore fundamentally unsound.

In summary, the University is generally pleased to see the progress made by CBC, but it is reluctantly unable to support the draft Local Plan in its current form. The University would like to meet with the Council to discuss how, with minor modifications and a more in-depth review of Policy SP5, the Local Plan could be made Sound and the support of the University secured.

Yours sincerely,

Chris Pattison

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