Draft Bourn Airfield Supplementary Planning Document - June 2019

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Draft Bourn Airfield Supplementary Planning Document - June 2019

1. Introduction

Representation ID: 168105

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

1.3 KEY ISSUES - 5 RELATIONSHIP WITH THE EMPLOYMENT SITE

It is essential that the proposed Bourn Airfield New Village, with its significant residential content, 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 (to be provided at the developer's expense), particularly with regard to noise and air quality.

Full text:

Point 5 of section 1.3, Key Issues, of the draft SPD (Relationship with the employment site) acknowledges the existing manufacturing uses which operate from Bourn Airfield which includes DB Group. DB Group's business was founded in the early 1970s and has been a pioneer in the construction industry since those times. It was originally established to provide specialist sands to industry for cement testing and fuse manufacturing and is still exporting sands all over the world today.

The site which DB Group operate from is located on the north east corner of the Bourn Airfield site. The site is accessed via a shared private road, Wellington Way, which links the site to the roundabout for Highfields Road and St. Neots Road (the old A428). Wellington Way is a no-through road, providing access to the site and other industrial and storage buildings to the eastern edge of the airfield only. The site includes mature areas of woodland which screens the site from views to the south and partially to the west. There is also mature woodland adjacent to the site which screens views from the east.

DB Group began operating from Bourn Airfield in 2012 following comprehensive works to facilitate the use of the site for their operations (refer to planning permission reference S/1712/12/FL). These works facilitated the relocation of their operations from their former site in Lolworth. This relocation was necessary in order to expand production and increase employment as a result of new developments within the construction industry.

The site at Bourn Airfield was, and continues to be, ideal for meeting DB Group's needs. It was chosen as being within commuting distance for its employees; and provided significant expansion potential within the acquired plot (and possibly onto neighbouring land too). South Cambridgeshire is, therefore, an optimum location for the continued presence and expansion of this well-established local firm.

The operations and processes which take place on site include the following:
* 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.

These uses, in combination, amount to a B2 General Industrial use. The blending and grading processes undertaken on site generate 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 27 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 on site. 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 carried out externally 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.

In light of the above, it is essential that the proposed Bourn Airfield New Village, with its significant residential content, 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 (to be provided at the developer's expense), 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)."

Paragraph: 009 Reference ID: 30-009-20190722
Revision date: 22 07 2019

Comment

Draft Bourn Airfield Supplementary Planning Document - June 2019

2. Site Context

Representation ID: 168107

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

2.2 OWNERSHIP

DB Group confirms their intention to continue operating from their existing site at Bourn Airfield. The proposed development of Bourn Airfield New Village must therefore ensure that full account is taken of the existing operations at the site and that future development will not hamper their expansion plans.

Full text:

DB Group confirms their intention to continue operating from their existing site at Bourn Airfield. Additionally, the company has expansion plans which include a volumetric truck operation 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.

The company currently employs 27 full time staff on site with a further 40 being primarily field based and visiting the site approximately once a week. The company's expansion plans have the potential to create a further 16 jobs on site in the relatively near term and potentially more in the future.

The proposed development of Bourn Airfield New Village must therefore ensure that full account is taken of the existing operations at the site and that future development will not hamper their expansion plans.

Comment

Draft Bourn Airfield Supplementary Planning Document - June 2019

2. Site Context

Representation ID: 168109

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

2.3 SITE FEATURES AND SURROUNDING CONTEXT

The description of the established employment area at section 2.3 should be expanded upon to include a full description of DB Group's operations. Given their industrial nature, this is essential to ensure the future development that comes forward surrounding the site is appropriate.

Full text:

The second paragraph of section 2.3, Site Features and Surrounding Context, of the draft SPD states:

"A small established employment area is sited within the north-eastern corner of the site and is accessed via Wellington Way."

It is considered that this description should be expanded upon and include the following information in order that the context of the site is fully set out and can inform future development proposals:

The site which DB Group operate from is located on the north east corner of Bourn Airfield. The site is accessed via a shared private road, Wellington Way, which links the site to the roundabout for Highfields Road and St. Neots Road. Wellington Way is a no-through road, providing access to the site and other industrial and storage buildings to the eastern edge of the airfield only. The site includes mature areas of woodland which screens the site from view to the south and partially to the west. There is also mature woodland adjacent to the site which screens views from the east.

The operations and processes which take place on site include the following:
* 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 process undertaken on site generates external noise, particularly in respect of the extraction system used to reduce material spillage and particles in the air. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.

The company currently employs 27 full time staff on site with a further 40 being primarily field based and visiting the site approximately once a week.

Support

Draft Bourn Airfield Supplementary Planning Document - June 2019

2. Site Context

Representation ID: 168110

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

2.9 OPPORTUNITIES AND CONSTRAINTS - FIGURE 21 KEY CONSTRAINTS

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 (to be provided at the developer's expense) as a result of detailed assessments in accordance with the PPG.

Full text:

The Key Constraints plan at Fig.21 identifies the "Sensitive Relationship with existing employment uses" which surrounds the existing employment area at Bourn Airfield.

This includes the site which DB Group operate from. The operations and processes which take place on site include the following:
* 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.

These uses, in combination, amount to a B2 General Industrial use. The blending and grading process undertaken on site generates external noise, particularly in respect of the extraction system used to reduce material spillage and particles in the air. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.

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 (to be provided at the developer's expense) as a result of detailed assessments in accordance with the PPG.

Comment

Draft Bourn Airfield Supplementary Planning Document - June 2019

4. Spatial Framework

Representation ID: 168111

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

4.2 SPATIAL FRAMEWORK PLAN - FIG 22

As this Spatial Framework Plan will guide development coming forward within Bourn Airfield New Village it is essential that the Spatial Framework Plan 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 in accordance with the PPG.

Full text:

The Spatial Framework Plan (Fig.22) contained in the draft SPD illustrates residential development in close proximity to the existing Employment area which is to be retained.

This employment area includes the site which DB Group currently operate from. The operations and processes which take place on site include the following:
* 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.

These uses, in combination, amount to a B2 General Industrial use. The blending and grading process undertaken on site generates external noise, particularly in respect of the extraction system used to reduce material spillage and particles in the air. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.

The draft SPD states that "The overarching framework for Bourn Airfield new village is summarised below by theme, and spatially illustrated in the Spatial Framework Plan opposite."

As this Spatial Framework Plan will guide development coming forward within Bourn Airfield New Village it is essential that the Spatial Framework Plan 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 in accordance with the PPG.

Comment

Draft Bourn Airfield Supplementary Planning Document - June 2019

5. Creating the Place - Section 3: Locally Distinctive

Representation ID: 168112

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

FIX F GREEN EDGES AND CORRIDORS - 5 EMPLOYMENT SITE EDGE

It is therefore essential that the employment site edge which comes forward as part of the 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 and the provision of acoustic barriers along this edge as deemed necessary (to be provided at the developer's expense) following detailed assessment in accordance with the PPG.

Full text:

Creating the Place; Fix F, Green Edges and Corridors; 5, Employment Site Edge:

The provision of new or enhanced hedgerow planting buffer between the existing employment site and proposed surrounding development is supported.

The edge to the employment site should also ensure that the proposed surrounding development is sufficiently offset from the existing employment uses to avoid any adverse impacts. The operations and processes which take place on site include the following:
* 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.

These uses, in combination, amount to a B2 General Industrial use. The blending and grading process undertaken on site generates external noise, particularly in respect of the extraction system used to reduce material spillage and particles in the air. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.

It is therefore essential that the employment site edge which comes forward as part of the 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 and the provision of acoustic barriers along this edge as deemed necessary (to be provided at the developer's expense) following detailed assessment in accordance with the PPG.

Comment

Draft Bourn Airfield Supplementary Planning Document - June 2019

5. Creating the Place - Section 3: Locally Distinctive

Representation ID: 168113

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

FIX F GREEN EDGES AND CORRIDORS - EMPLOYMENT SITE LINK

In light of the existing industrial operations which take place within this employment area, particularly those of DB Group, it will be essential to ensure that a safe route can be created which ensures that pedestrians and cyclists are separated from vehicular traffic. It is also important that DB Group retains flexibility for unfettered access to its site to enable its existing operations, short term future expansion plans and the company's continued long term growth.

Full text:

Creating the Place; Fix F, Green Edges and Corridors; Employment Site Link:

The draft SPD states: "A formal green landscape which creates a legible and direct route through the employment site, providing a link between the eastern HQPT stop/mixed use area and the residential area to the south".

Fig.43, Green Edges and Corridors, illustrates this employment site link. As a result of the scale and detail of this figure the exact route of this corridor is unclear.

In light of the existing industrial operations which take place within this employment area, particularly those of DB Group, it will be essential to ensure that a safe route can be created which ensures that pedestrians and cyclists are separated from vehicular traffic. This is considered to be of particular importance as a result of the HGV movements which are associated with DB Group's existing operations (currently an average of 5 HGV vehicles coming in and out each day - and this will increase with the company's expansion plans). Another consideration is that the precise activities of most companies do change over time as product/markets change and changes in technology dictate that processes need to change to remain competitive and deliver what the customer wants. It is important that DB Group retains flexibility for unfettered access to its site to enable its existing operations, short term future expansion plans and the company's continued long term growth.

Object

Draft Bourn Airfield Supplementary Planning Document - June 2019

5. Creating the Place - Section 5: Responsive and Sustainable

Representation ID: 168114

Received: 29/07/2019

Respondent: DB Group (Holdings) LTD

Agent: Carter Jonas

Representation Summary:

5G NOISE, LIGHT AND AIR QUALITY

The bullet points fail to mention the need for the proposed development to take full account of the existing employment development, including DB Group's site.

An additional bullet point should therefore be added which reads as follows:

Planning applications should be accompanied by a Noise Impact Assessment and Air Quality Assessment, and the new village will be required to mitigate the impact of noise and air quality from existing employment uses by virtue of suitable design. For example, a buffer using acoustic screens if appropriate, building layout and orientation and suitably ventilated buildings.

Full text:

Creating Place; 5G, Noise, Light and Air Quality:

The draft SPD states: "The new village should provide a safe, comfortable and healthy environment for its residents and should minimise the impacts it has on landscape, ecology and residential amenity of the site and its surroundings. Development proposals will be expected to mitigate the impacts of noise, air quality, light and human disturbance on the environment."

The following bullet points fail to mention the need for the proposed development to take full account of the existing employment development, including DB Group's site. The operations and processes which take place on site include the following:
* 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.

These uses, in combination, amount to a B2 General Industrial use. The blending and grading process undertaken on site generates external noise, particularly in respect of the extraction system used to reduce material spillage and particles in the air. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.

The proposed development will therefore need to ensure that it 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. This to include visual impact of more buildings, silos and vehicles even with the same activities.

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)."

Paragraph: 009 Reference ID: 30-009-20190722
Revision date: 22 07 2019

An additional bullet point should therefore be added which reads as follows:

Planning applications should be accompanied by a Noise Impact Assessment and Air Quality Assessment, and the new village will be required to mitigate the impact of noise and air quality from existing employment uses by virtue of suitable design. For example, a buffer using acoustic screens if appropriate, building layout and orientation and suitably ventilated buildings.

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