Plan for submission evidence base

Object

Representation ID: 10018

Received: 29/07/2022

Respondent: St Modwen Logistics

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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).

Economic Growth Ambitions Topic Paper (May 2022)

Looking at the Economic Growth Ambitions Topic Paper (May 2022), key strengths and weaknesses in relation to the economy are recognised as the existing presence of key companies being in Bedford, the higher than regional average levels of resident skills and qualifications and the over investment in logistics – leading to a low productivity economy.

The paper notes that whilst, “B8 allocation is still required, this is largely saturated and there is a push towards increasing B2/E(g) allocations to create a more higher value balanced economy.”

To counteract this over saturation in land uses and the dominance of the logistics sector within Bedford, the paper supports the provision of local clusters of sectors.

Whilst Thurleigh Airfield does include B8 space for logistics businesses, it is also already hosting emerging clusters of alternative sectors including Mologic – a medical diagnostics cluster and Millennium Studios, providers of production and rehearsal space, supporting creative industries.

This demonstrates how the current variety of uses and future potential of Thurleigh Airfield align with the Council’s economic growth ambitions and should be considered as a site for allocation and to provide a firm commitment to the Council’s employment land supply, and not as an “exception site” as set out in the ELS (2022).

Object

Representation ID: 10019

Received: 29/07/2022

Respondent: St Modwen Logistics

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.

Object

Representation ID: 10021

Received: 29/07/2022

Respondent: St Modwen Logistics

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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.