Local Plan Central Council Priory House Monks Walk Shefford SG17 5TQ

Date: 25 August 2017 Our ref: 15572/HS/SF/14629185v2 Your ref:

Dear Sir/Madam

Representations to the Draft Local Plan Prologis Park Marston Gate On behalf of our client, Prologis UK Limited, Lichfields is pleased to set out representations to the ‘Central Bedfordshire Draft Local Plan’ (July 2017) (“the Local Plan”).

Prologis UK Limited (‘Prologis’) is the UK’s leading developer and owner of logistics property. Prologis has unrivalled experience in identifying and delivering strategic sites within the UK. Prologis currently manages 20 million sq ft of floorspace in locations across the country. The sites are all designed to a high quality standard and make a significant and sustainable contribution to the local communities within which they are located.

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.

Prologis Park Marston Gate Expansion, The Prologis Park Marston Gate expansion site is located adjacent to Junction 13 of the , near Brogborough. The site is located to the west of the established Prologis Park Marston Gate that currently comprises nine warehouses, with high profile occupiers including Amazon, Unilever and FedEx. The proposed expansion site would extend the existing facility by 43 hectares. Its relationship to existing operations means it can take full advantage of the strong links to existing infrastructure, notably the site is just 200m to the north of Station with regular services and links to Bedford and London. Prologis has developed plans to an advanced stage for the proposed expansion site with a view to the submission of an application for planning permission to Central Bedfordshire Council in the near future. A preliminary masterplan has been produced for the development of up to six logistics buildings, a new access route and approximately 9 hectares of new planting and landscape enhancement to protect the local amenity and preserve the character of the site’s wider setting. A master plan is attached to these representations for information in this regard. Prologis takes pride in the delivery of high quality buildings that seek to achieve BREEAM Excellent rating; this is through the use of sustainable building products and energy saving

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measures. The Council can be assured that the allocation of this site for strategic distribution development will result in a development of the highest standard of sustainability being delivered.

Prologis Park Marston Gate benefits from a significant range of Park Services, provided by Prologis. This includes: a liftshare scheme, on-site parking controls, centralised maintenance of private roads, drainage and landscaping, Park signage, litter picking, Park staff amenity open space provision and maintenance, shared building cleaning, on-site recruitment, snow cleaning and gritting, tenant estate and HR meetings and community liaison. The additional development which the proposed allocation would secure will provide the opportunity to justify enhancements to this level of service. As part of the supporting evidence for the Local Plan, the proposed extension to the existing Prologis Park as a strategic employment site for industrial and manufacturing (use class B2) and storage/distribution (use class B8) has been comprehensively considered within the Council’s Strategic Employment Site Assessment (Land at Ridgmont, Ref no NLP244). The Strategic Employment Technical Document is a robust document that has developed over the course of the preparation of the Local Plan. The initial assessment established a number of key tests that potential strategic employment sites should meet (Appendix D). The proposed Marston Gate expansion site passed the preliminary tests (Ref No. NLP24), the site was considered to have no overriding constraints and was considered suitable to accommodate a strategic employment site.

The further detailed assessment of the site (Appendix F) reviewed the site in three stages; Stage 1 included the suitability and availability of the site (Exclusionary Stage), Stage 2 provided an assessment of the suitability of the site and Stage 3 included an assessment of the availability of the site. The expansion site passed all three stages and the recommendation from the Stage 3 assessment included allocating the site as a strategic employment site in the Local Plan.

In comparison to other potential strategic distribution sites that were submitted for consideration, the proposed Marston Gate expansion site performs well in the strategic and detailed site assessments. The proposed expansion site not only provides an additional 43 hectares of land suitable for B2 and B8 uses, the site is also highly accessible to public transport and the visual impacts of its development can be reduced due to the site being adjacent to the established Prologis Park as well as its inherent topography and landscape containment. The proposed expansion site is both deliverable and sustainable and provides a logical expansion to the highly successful Prologis Park.

Prologis agrees with the conclusions of the Council’s site assessments and considers the proposed expansion site to be a logical location for further employment, particularly in the form of logistics and distribution development. Furthermore, Prologis fully supports the recommendations from the Stage 3 assessment that the expansion site should be allocated within the Local Plan.

Responses to the Local Plan

Comments are made below on various draft policies that are of particular relevance to the proposed development site, in the context of paragraph 182 of the NPPF. The policies are addressed below in the order that they appear in the draft document.

Policy SP1 (Growth Strategy) Prologis supports this policy, with suggested amendments

Prologis supports the inclusion of “Area C – M1 Junction 13” as a strategic employment area, as designated in the proposed Policy SP1. The allocation of around 40 hectares for employment within this area refers to the Prologis expansion site in all but name. In light of this, Prologis supports the allocation of this strategic

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employment area within the Local Plan but would suggest that clear reference is made to the Prologis Park Marston Gate expansion as a specific allocation within the Local Plan.

The allocation of this area as a strategic employment area will significantly assist the Council in accomplishing the set target of 24,000 new jobs between 2015 and 2035. The established Prologis Park Marston Gate is a highly successful distribution and logistics centre that comprises nine warehouse units. The proposed Prologis Park Marston Gate expansion will provide approximately 160,000sqm of logistics floorspace for industrial and manufacturing (B2 use class) to storage and distribution (B8 use class) and will result in the creation of approximately 2,000 jobs. The proposed expansion site is consistent with paragraph 18 of the NPPF, in securing economic growth in order to create jobs and prosperity. Prologis has prepared an infographic summarising the economic benefits of the proposed development of the Prologis Park Marston Gate expansion as proposed in the draft allocation and this is attached to these representations to provide the Council with additional support for the proposed inclusion of the expansion of the existing logistics site in the Local Plan.

Policy SP1 also states that further assessments focused on the sustainability and deliverability of proposed sites will be undertaken as part of the preparation of the pre-submission Local Plan. Prologis would like to highlight that the extension site represents a natural progression of the existing Prologis Park Marston Gate site and that the site already benefits from key infrastructure to allow the delivery of the site. Prologis considers that the expansion site is both sustainable and deliverable and meets the requirements of Policy SP1. The site is held within a single land ownership in relation to which Prologis has a controlling interest and the site is wholly deliverable in the short term on this basis.

The Council’s spatial strategy also requires “the delivery of spatial options and strategic opportunities that could provide for longer term economic and housing growth at , and in the .” The strategy states that “this growth must be supported by; “new strategic infrastructure particularly…new rail stations/transport interchanges along the East West Rail route a Ridgmont, and north of Sandy.”

In light of this, Prologis would like to highlight that ongoing discussions are occurring between Prologis and the developers of the proposed Land at Boughton End Farm, which is located directly to the north of the proposed expansion site. Land at Boughton End Farm is being considered for allocation within the Local Plan for residential and mixed residential use (Ref. No NLP177). Prologis and the developers of Land at Boughton End Farm are exploring potential opportunities to secure direct public transport linkages between both site allocations, which would link to and enhance the functionality of . This would ensure the delivery of new transport infrastructure supporting both schemes and the local area and take advantage of the unique proximity of these two proposed allocations. The close proximity of the two sites contributes towards the Council’s spatial strategy, by providing a strategic opportunity for both long term economic and housing growth, focused within one sustainable location.

Prologis would like to emphasise the benefits of the Prologis Park Marston Gate Expansion site includes the provision of a new access from A507 junction, the designs of which have already been prepared and agreed with Highways England. The proposed expansion site will also contribute towards the expansion of Ridgmont Station as well as contributing to the wider transport strategy. The overall benefits of the delivery of the expansion site include the future economic growth of Central Bedfordshire; through job creation and investment into the local area.

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Policy EMP1: Strategic Warehousing and Logistics Prologis supports this policy, with suggested amendments

Policy EMP1 requires the “continued supply of land appropriate for strategic warehousing and logistics”. Prologis acknowledges the importance of the demand for additional warehousing within Central Bedfordshire. The proposed expansion site meets the policy requirements set out in Policy EMP1; the site is not located within the Green Belt and is adjacent to a strategic transportation network.

The supporting text to Policy EMP1 identifies specific “Priority Sectors” in the Local Plan, including Transport and Logistics. The supporting text refers to the delivery of key employment sites and allocations to meet national strategic warehousing and distribution needs, specifically along the M1 corridor. Market analysis undertaken as part of the supporting evidence in the preparation of the Local Plan highlights the national need for additional warehousing and distribution sites within the UK. The 2016 Employment Land Review specifically refers to the demand for storage and distribution floorspace along the M1 due to the key strategic connectivity. This is in accordance with paragraph 2.45 of the National Planning Statement for National Networks which “requires the logistics industry to develop new facilities that need to be located alongside the major rail routes, close to major trunk roads…” In light of this, Prologis would like to highlight that the existing Prologis Park is ideally positioned within close proximity of Junction 13 of the M1 and serves the Midlands and South East markets. Prologis consider that the expansion site is an ideal location for a strategic employment site and will strengthen the existing Park.

The allocation of the proposed Prologis Park Marston Gate expansion site within the Local Plan will provide the Council with growth and investment in the warehousing and distribution sector (B8 use class). The expansion site will greatly contribute towards meeting national warehousing and distribution needs, whilst also providing a site for local industrial employment uses.

Policy EMP2: Employment Sites and Uses

Prologis supports this policy, with suggested amendments

The proposed policy EMP2 states that “…planning permission will be granted for appropriate B1, B2 and B8 uses.” The policy also states that: “Opportunities to strengthen existing clusters through the delivery of complementary employment generating uses will be encouraged.”

The existing Prologis Park Marston Gate site is an established logistics and distribution site within Central Bedfordshire that consists of nine warehouse units of use classes B2 and B8. The proposed expansion site is within a strategic location for distribution uses and will complement the existing Prologis Park by encouraging the development of further B2 and B8 uses. The proposed site is therefore considered by Prologis to be an appropriate site for allocation as a strategic employment site. The proposed extension is in line with the policy requirements of Policy EMP2 and will continue to contribute towards providing additional B2 and B8 uses within Central Bedfordshire. Prologis are committed to ensuring the delivery of the extension and suggest that the expansion site is formally allocated within the Local Plan. The proposed expansion site performs positively within the site assessments of the supporting Strategic Employment Technical Document. The priority within this local area is for strategic employment specifically related to B8 uses, the proposed expansion site will contribute towards meeting this need. The close proximity and existing connections of the established Prologis Park also ensure that the proposed expansion site is deliverable.

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Prologis would like to highlight that the allocation of the site within the Local Plan will provide a positive and robust approach to meet the employment targets for Central Bedfordshire. Furthermore, the proposed expansion site is consistent with NPPF paragraph 14 which requires local planning authorities to positively seek opportunities to meet the development needs of their area.

Conclusions

The Prologis Park Marston Gate expansion site is a highly strategic location for logistics and distribution uses being a natural extension to the existing successful distribution development. Expansion of an existing development has the advantage of utilisation of existing infrastructure without the need to ‘open up’ new areas of land with new infrastructure, such as highways access or public transport provision. The site is adjacent to a railway station from which direct access is available and proposed new housing development whereby economies of scale in terms of public transport delivery can be achieved. Increasing the critical mass of logistics space at Prologis Park Marston Gate will have the benefit of enabling greater Park Services provision beyond the already substantive level of service.

The allocation of the site as a strategic employment site will help accomplish employment targets as set out within the emerging Local Plan as well as enabling economic growth within Central Bedfordshire, facilitate economic growth within Central Bedfordshire, contribute towards improving local infrastructure and will help meet both national and local demand for B2 and B8 uses.

The site proforma within Appendix F of the Strategic Employment Site Technical Document concludes that the site (Ref. NLP244) should be recommended for employment allocation within the Local Plan. Prologis supports this recommendation and considers that there is substantial merit in identifying the Prologis Park Marston Gate expansion site as a specific allocation in the Local Plan.

Prologis requests however, that the Local Plan includes appropriate policy support for the Prologis Park Marston Gate expansion site by formally allocating the site within the Local Plan by identifying the site more specifically on the Local Plan Proposals Map and by name as the Prologis Park Marston Gate Expansion Site in Policy.

Please contact me to discuss any of the points raised herein, or to request any further detail or clarification on any of the representations made.

Yours faithfully

Justin Gartland Chairman

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Annex 1: Masterplan for Marston Gate [Ref: 30893-FE-28, August 2017]

Pg 6/7 14629185v2 AREA SCHEDULE GIA

1sqmsqft Unit 23,993 258,257 Offices 1,675 18,030 Sub total 25,668 276,287 Ha acres PLOT AREA 4.951 12.24

2sqmsqft Unit 16,422 176,765 Offices 1,167 12,560 Sub total 17,589 189,325 Ha acres PLOT AREA 3.483 8.61

3sqmsqft Unit 11,977 128,920 Offices 840 9,040 Sub total 12,817 137,960 Ha acres PLOT AREA 2.455 6.07

4sqmsqft Unit 60,536 651,610 Offices 4,234 45,575 Sub total 64,770 697,185 Ha acres PLOT AREA 13.609 33.63

5sqmsqft Unit 24,810 267,055 Offices 1,736 18,685 Sub total 26,546 285,740 Ha acres PLOT AREA 5.164 12.76

6sqmsqft Unit 7,414 79,805 Offices 939 10,105 Sub total 8,353 89,910 Ha acres PLOT AREA 1.892 4.68

Training / Innovation Centre 743 8,000 Ha acres PLOT AREA 0.833 2.06

TOTAL 156,486 1,684,407 Ha acres TOTAL NET PLOT AREA 32.391 80.04 ESTATE ROAD 1.988 4.91 INFRASTRUCTURE LANDSCAPING 8.293 20.49

Ha acres TOTAL GROSS SITE AREA 42.673 105.45

Annex 2: Infographic – ‘The Economic Benefits of Logistics Development at Ridgmont’

Pg 7/7 14629185v2 The Economic Benefits of Logistics Development at Ridgmont The proposals provide a unique opportunity to deliver high quality logistics floorspace and an education / innovation centre at Junction 13 on the M1 strategic corridor, generating employment, creating value and supporting a key growth sector of the wider regional economy.

The Proposal: New Logistics Park Education / 43 ha 159,100sqm B1 & B8 Total Area Logistics Floorspace Uses Innovation Centre

Construction Benefits 325 Jobs 495 Jobs Direct Employment Indirect/Induced Employment [estimated to create 1,045 person-years of [495 ‘spin-off’ FTE jobs could be supported temporary construction employment over the c.3 in the supply chain per year of construction] year period of the build] £53m GVA £105m Economic Output Construction Value [expected additional GVA p.a. from direct and [estimated total cost of construction] indirect jobs]

Operational Benefits 990 1,990 Jobs Total Jobs [1,990 jobs will be created across a range of occupation groups and skill 415 levels] 250 160 160 815 Jobs Indirect/Induced Employment [815 FTE supported in the supply 15 chain] Warehouse Staff Warehouse Support Staff Staff Office Drivers Managers Education 1,990 Jobs

Up to £105m £4.1m Planning Contributions [S106 or CIL] Economic Output Additional Business [Additional GVA per annum] Rate Revenue [per annum in perpetuity]

© Analysis and design by Lichfields (February 2017) CL15572