Bedford Employment Land Study part two

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Plan for submission evidence base

Representation ID: 10021

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 2 (Site Assessments)

Within Part 2 of the ELS, each existing site is assessed for its future use/potential. Thurleigh Airfield performs well in this assessment. The site is identified as being suitable for redevelopment and intensification, refurbishments, and re-use of existing buildings, allowing for a wide range of development options.

The site is seen to have no restrictive planning designations and adequate access and parking provision. At present only 25% of the site is seen to fall within non-B Class uses, demonstrating their dominance despite the ELS conclusions that it hosts “unusual development”.

The ELS concludes “There is significant intensification and development potential for this site, which is considered to be of good quality overall.” Furthermore 70% of the site is considered to be developable. St Modwen support this assessment and outcomes, and capacity of the site to deliver more employment space.

Taking this 70% figure, this equates to circa 218.8 hectares of brownfield land available for employment uses, on a single site.

Paragraph 4.30 of the emerging Local Plan references the Employment Land Study topic paper which sets out that it is appropriate for the Plan to identify between 118 and 142 hectares of employment land. Emerging Policies HOU 12, HOU 19 and EMP 1 - EMP8, seek to identify sufficient land to meet the upper end of this forecast, as set out under emerging Policy DS5(s). Despite Thurleigh Airfield having the space and capacity to accommodate more than this upper limit of employment growth, the current strategy proposes 10 new allocations in the emerging Local Plan. St Modwen questions the efficiency of this approach, given it has Thurleigh Airfield, a brownfield site, which is demonstrated by the Council’s own evidence base to be suitable and available for future employment provision. St Modwen consider Thurleigh Airfield can contribute to and should be allocated in the Plan, rather than be excluded from the current future supply of employment land.