J/PB: Protecting existing business space

Support

This should be considered on a case basis and not a blanket rule.

Hazlewell Court, Bar Road, Lolworth (Site URN 676) is currently used for commercial purposes, supporting a small but well-occupied rural business park. In protecting the business space and creating further employment land, the proposal will allow for an increase in local employment opportunities and as mentioned by the Local Authority, the protection of business and employment land will help to develop a more inclusive economy.

Furthermore, the development would have the potential to further support the sustainability and extension of this small business park, providing supporting services such as hotels, multui-functional conference and meeting space, aswell as welfare services such as food outlets, and a gym. The presence of these would help to make the existing business park be more sustainable, reducing the need to travel further afield to use similar services and supporting sustainable growth at an existing employment location.

Abrdn understands and supports the ambition to protect existing business space. Abrdn notes that
the proposed policy J/PB is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed. Abrdn requests that the proposed policy recognises that it is becoming increasingly important for town centres to cater for flexible uses and that office uses are not always required.

Abrdn notes that an effective way of better utilising land is to redevelop brownfield land and re-provide the existing uses alongside co-located residential uses. This is a proven way of addressing both the housing shortage and the need for other uses.

USS understands and supports the ambition to protect existing business space. USS notes that the proposed policy J/Al is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed which USS supports.

USS notes that an effective way of better utilising land is to redevelop brownfield land and re-provide
the existing uses alongside co-located residential uses. This is a proven way of addressing both the housing shortage and the need for other uses.

Proposed policy J/PB should ensure it does not restrict the ongoing operation of existing uses in the interim period before redevelopment. USS intends to bring forward its asset at Clifton Road Industrial Estate for re-development within the plan period; however, prior to its redevelopment it is critical that the existing tenants are not restricted in the operation of their businesses.

Huntingdonshire District Council has no comment on this matter.

We support this policy. If business is required to relocate, accommodation needs to be available for employees who relocate.

I support this policy

USS understands and supports the ambition to protect existing business space. USS notes that the proposed policy J/Al is intended to state that where loss is proposed, it will need to be justified by evidence that it is no longer needed which USS supports. USS requests that the proposed policy recognises that it is becoming increasingly important for town centres to cater for flexible uses and that office uses are not always required.

USS notes that an effective way of better utilising land is to redevelop brownfield land and re-provide the existing uses alongside co-located residential uses. This is a proven way of addressing both the housing shortage and the need for other uses.

The Local Plan needs to ensure that there is enough industrial space to accommodate General Industrial use on sites that will not be hampered by surrounding land uses. DB Group operate in Bourn and their site is in close proximity to the Bourn Airfield New Village. The following operations and processes are undertaken on site:
- Sand grading – filtering sand to provide different levels of fineness;
- Production of additives used in concrete mixes – blending of powders from silo storage;
-Warehousing – receipt and dispatch of goods either manufactured or purchased off site for resale.
The blending and grading processes undertaken on site generates external noise, particularly in respect of the extraction system used to capture and recycle dust particles from the manufacturing processes to maintain air quality. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.
The company currently employs 21 full time staff on site with a further 40 being primarily field based and visiting the site approximately once a week.
DB Group are currently exploring a number of expansion opportunities. One of these is a volumetric truck operator to supply concrete directly to customers. Activity at their existing site at Bourn associated with this operation would be external and would entail filling the various hoppers on the vehicle. This would require at least one further silo on site and the use of a mechanical loader to take aggregates and sand from external storage bays. These operations have the potential to increase the level of noise generated at the site and would also increase HGV movements.
A further opportunity exists in the production, cutting and finishing of precast concrete products. This would require concrete mixing equipment, supplied from bagged and/ or additional bulk silo stocks, as well as the use of stone-cutting saws.
In light of the above, it is essential that the proposed Bourn Airfield New Village takes full account of DB Group’s existing operations and will not hamper future expansion plans. This will require particular consideration being given to adequate distance separation from noise sources, site and building layout / orientation, provision of acoustic barriers as deemed necessary as a result of detailed assessments, particularly with regard to noise and air quality.
This accords with the Planning Practice Guidance (PPG) which states:
“How can the risk of conflict between new development and existing businesses or facilities be addressed?
Development proposed in the vicinity of existing businesses, community facilities or other activities may need to put suitable mitigation measures in place to avoid those activities having a significant adverse effect on residents or users of the proposed scheme.
In these circumstances the applicant (or ‘agent of change’) will need to clearly identify the effects of existing businesses that may cause a nuisance (including noise, but also dust, odours, vibration and other sources of pollution) and the likelihood that they could have a significant adverse effect on new residents/users. In doing so, the agent of change will need to take into account not only the current activities that may cause a nuisance, but also those activities that businesses or other facilities are permitted to carry out, even if they are not occurring at the time of the application being made.
The agent of change will also need to define clearly the mitigation being proposed to address any potential significant adverse effects that are identified. Adopting this approach may not prevent all complaints from the new residents/users about noise or other effects, but can help to achieve a satisfactory living or working environment, and help to mitigate the risk of a statutory nuisance being found if the new development is used as designed (for example, keeping windows closed and using alternative ventilation systems when the noise or other effects are occurring).”
DB Group have recently received pre-application advice (reference 21/50156/PREAPP) from South Cambridgeshire District Council advising that an extension in hours of operations would be unlikely to be supported as a result of a “detrimental impact on the living conditions of existing neighbouring properties and future occupiers in the New Village development”.
This is constraining DB Group’s expansion plans and their ability to expand employment opportunities at their site. The Councils protection for existing business space also needs to extend to ensuring that expansion opportunities at existing successful business are supported. This includes ensuring that other development that is supported by the Plan does not unduly constrain existing successful business sites.

The purpose of this policy will be to protect employment land from loss to other uses and in this context, Marshall wishes to comment in respect of its existing business at Cambridge Airport and its relocation proposals. As identified, Cambridge East is one of the largest and most sustainable brownfield sites in Greater Cambridge. Its location and the scale of the opportunity make it an important part of Greater Cambridge’s growth strategy over the next 20+ years.

Marshall has recently announced that its preferred site for relocation of its aerospace and defence business is at Cranfield Airport. The evidence prepared confirms that there is no obvious commercial, planning, technical or regulatory impediment to a move to Cranfield, a position which will further crystalise through the preparation of the Outline Planning Application. Marshall is confident that the proposed site at Cranfield can meet its current space and operational requirements. As such, Marshall has begun the process of preparing an outline planning application, with submission planned in Autumn 2022. Marshall is aiming for the planning permission to be issued in early 2023. Planning permission would give the GCSP and Department for Levelling Up, Housing and Communities further confidence that Cranfield is a deliverable option for Marshall and that this in turn would enable Cambridge East to be delivered.

Whilst the aerospace and defence parts of the business need to be relocated due to reliance and need for an accompanying, there are other parts of the business that are able to function without a runway. On that basis, Marshall are considering options for retaining elements of the business in either Greater Cambridge or wider Cambridgeshire, which would align with the positive intention of Policy J/PB.

Therefore, the development of Cambridge East has two consequences of strategic importance. As well as unlocking the development of a world class anchor development at Cranfield that builds on significant synergies with Cranfield University, the relocation to Cranfield would significantly contribute to sustainable economic growth in the East. The relocation then paves the way for the delivery of a truly mixed-use scheme in Cambridge East that optimises the use of the land and will provide the range and mix of jobs Cambridge needs.

Jobs policies
74. It is clear that the draft Local Plan is focused on the continuation of ‘growth’ in the Cambridge area. CPRE
believes this is a mis-guided approach. The Greater Cambridge area is one which DHSS would consider to
have effectively full employment, with just the usual rotation of people out of work or seeking work.
Therefore, any growth in jobs will require inward migration to fill them. Inward migration creates pressure
on local housing availability and prices, and hence pressure for more house-building. It is an anti-climate
cycle.
75. As stated above CPRE would like to see the skills and resources of Cambridge-based organisations used to
encourage employment and redevelopment in other regions of the country where housing and water
capacity already exist and, in doing so, greenhouse gas emissions would be minimised.
76. CPRE are concerned by policies J/RE: Supporting the rural economy and J/AL: Protecting the best
agricultural land. We think both of these policies should be strengthened and properly enforced. The rural
economy can be diversified but at its core are farmers and their interests must be protected. For example,
the opening up of tracks and bridleways on the scale proposed by the Greater Cambridge Partnership will
cause increasing levels of damage to farms and farm equipment and increased security risk to farm
properties. It will make illegal activities such as hare-coursing easier and the police enforcement job
harder.
77. We think it is in the national interest to stop building on South Cambridgeshire farm land, most of which is
Grade 2 with some Grade 3a. http://publications.naturalengland.org.uk/publication/127056 This land is already needed to assist the minimisation of food imports and it will be even more needed when the Fens
flood and national food supply is reduced by an estimated 20 – 25%.
78. According to the NFU, the Fens produce one third of England’s fresh vegetables, 20% of England’s potatoes,
more than 20% of England’s flowers and bulbs, 20% of England’s sugar beet as well as a significant
percentage of the country’s cereal, oilseed rape and protein crops. Agriculture in the Fens employs 80,000
people and produces £3bn pa for the rural economy.
79. The government recognises that the UK currently imports 45% of its food; however, some sources estimate
this to be as much as 80%. The Environmental Audit Committee has already warned government that the
UK cannot continue to rely on food imports on this scale because climate change is going to damage foodgrowing areas further south.
80. Building on good Cambridgeshire farm land just does not make sense. There may be short-term economic
pressures to do so but it is not in the national interest.
81. CPRE supports Policy J/PB: Protecting existing business space and Policy J/RW: Enabling remote working.
We also recognise that local affordable workspace can reduce commuting and increase local employment
opportunities, Policy J/AW: Affordable workspace and creative industries. We are concerned to ensure
that existing buildings which could be used for employment are not demolished to make way for maximum levels of housing and maximum profit for developers as we are aware has occurred in some districts.
82. With respect to Policy J/RC: Retail and centres, CPRE are aware of increasing levels of internet shopping
and decreasing footfall in retail centres. This may lead to re-purposing for housing under “Permitted
Development”. CPRE is believes that all such development should be brought back under local authority building control and not be the appalling low-quality free-for-all that it is now.

See attached document.