Bedford Employment Land Study part one

Showing comments and forms 1 to 3 of 3


Plan for submission evidence base

Representation ID: 9454

Received: 29/07/2022

Respondent: Prologis

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Please see attached reports

Full text:

Please see attached main representation report.


Plan for submission evidence base

Representation ID: 10019

Received: 29/07/2022

Respondent: St Modwen Logistics

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

St Modwen Logistics own and manage Thurleigh Airfield, an established business park and existing allocation, classified as being within the Protect and Enhance Category and subject to Policy 70 of the Local Plan 2030 (adopted January 2020).

Bedford Employment Land Study Parts 1 & 2 – May 2022 (ELS)

St Modwen previously responded to the June 2021 ELS. We note the update to the ELS and wish this up to date evidence is reflected in the Local Plan.

Part 1

The updated ELS (May 2022) continues to offer support for the intensification of employment development at Thurleigh Airfield which St Modwen support.

The ELS does, however, note that this intensification is only modest on most potential sites, except for three of the largest sites, including Thurleigh Airfield, which “...represent the best opportunities for growth and increasing employment capacity” (see paragraph 6.18). This is a conclusion that St Modwen also support.

Thurleigh Airfield also remains within the “Protect and Enhance” category. The ELS notes at paragraph 10.9 that such sites “could be brought into use and provide truly additional capacity over and above what is there today. These sites should be protected and an enhanced offer (in terms of the quality of and range of stock and improved public realm) encouraged.” St Modwen agree with this conclusion but consider this needs to be reflected in the Plan.

Overall, Part 1 of the ELS continues to provide a positive commentary for Thurleigh Airfield and its future development for employment uses. Despite this, Thurleigh Airfield is currently excluded from the allocations for potentially available employment land (paragraph 8.3) and is identified as an “Exception Site” (paragraph 8.6). This is despite the Council’s commentary that the site has “… active employment uses and significant potential to accommodate further B class employment.”

Given the current mix of uses and occupiers on the site, the ELS considers these “unusual development opportunities” (paragraph 8.9) cannot be predicted and forecasted using general economic trend data, a more site specific and flexible approach to Thurleigh Airfield’s development is likely be required. Due to this and the location of the site within a more rural area (despite recognised as having direct site access to the A6 trunk road), further from the strategic road network, the ELS concludes the site is less attractive to general employment demand. Thurleigh Airfield is therefore not being considered as a potential employment land area. We disagree with the description of the site and its attractiveness to the market.

Whilst St Modwen continue to support having a more flexible approach to the development of Thurleigh Airfield, which will be further enhanced with the introduction of Class E uses, they consider Thurleigh Airfield should be prioritised as a location for Class B (B2 and B8) and Class E (Business and Service Uses) for employment development. Thurleigh Airfield is recognised as a thriving and established business destination, which caters to wide variety of industries including automotive, communications and logistics industries all of which require Class E (formerly B1), B2 and B8 uses which the Council have demand for.

The ELS incorrectly references the need for B Class employment land provision, including B1 uses, which are now a revoked and fall within the more flexible Class E – as introduced in the September 2020 update to the Use Class Order.


Plan for submission evidence base

Representation ID: 10078

Received: 28/07/2022

Respondent: Milton Keynes Borough Council

Representation Summary:

The Employment Land Study (May 2022) identifies a need for between 118 to 142 hectares of land for B8 warehousing and logistics over the period through to 2040. It recommends a focus upon high quality business park development to maximise the location at the centre of the Ox-Cam Arc. However, of this need, between 36-61 hectares is identified for warehousing, which is a land use that is generally ‘foot loose’ across areas with good access to the strategic road network. The Local Plan 2040: Plan for Submission allocates land for a total of 136 hectares for employment uses across a variety of sites of differing sites, which is towards the upper end of the forecasted need range.
The allocations appear to provide a suitable and diverse supply of sites for warehousing to meet needs over the plan period. However, it should be recognised that there is uncertainty over how attractive those sites would be to the market based on specific-locational factors and site characteristics.
Notwithstanding this, the strategy for meeting employment needs does not raise concern in terms of unmet needs creating further demand for land within Milton Keynes for logistics and warehousing. This change and clarification between the draft plan stage and the Local Plan 2040: Plan for Submission has addressed the concerns previously raised and is welcomed.