Policy paper
Entertainment resort complex, Bedford: statement of reasons for the grant of planning permission
Published 22 December 2025
Applies to England
© Crown copyright 2025
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Planning permission – Special Development Order
The Secretary of State for Housing, Communities and Local Government made the Town and Country Planning (Entertainment Resort Complex, Bedford) Special Development (No.2) Order 2025 on 15 December 2025 and it was laid before Parliament on 16 December 2025 (the Order).
The Order is made under sections 59(1), (2)(a) and (3)(b), 60(1), (1A) and (2A) and 61(1) of the Town and Country Planning Act 1990. It grants planning permission from the date it is in force for the classes of development described in Schedule 2 (classes of development permitted) to the Order, relating to an Entertainment Resort Complex and associated development. The Order is in force from 12 January 2026[footnote 1].
The Order is available at The Town and Country Planning (Entertainment Resort Complex, Bedford) Special Development (No. 2) Order 2025.
The project is EIA development for the purposes of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations). The request to make a Special Development Order submitted to the Secretary of State was accompanied by an Environmental Statement (ES).
This statement
This Statement gives notice of the Secretary of State’s decision to make the Order in accordance with the published Handling, Publicity and Consultation Arrangements[footnote 2].
It provides the following information:
| Information | Location |
|---|---|
| Summary of consultation results, information gathered and how incorporated or addressed. | Schedule 1 |
| The Secretary of State’s reasoned conclusion on the significant effects of the development on the environment.[footnote 3] | Schedule 2 |
| The main reasons and considerations on which the decision is based. | Schedule 2 |
| Conditions to which the decision is subject which relate to the likely significant environmental effects of the development on the environment. | Schedule 2 |
| A description of any features of the development and any measures to avoid, prevent, reduce and, if possible, offset, likely significant adverse effects on the environment. | Schedule 2 |
| Monitoring measures considered appropriate. | Schedule 2 |
| The right to challenge the validity of the decision/procedures for doing so. | See below this table |
This Statement does not convey any approval or consent which may be required under any enactment, byelaw, order or regulation.
Right to Challenge the decision and procedures for doing so
As a statutory instrument, the Order can be subject to an annulment motion in Parliament during a period of 40 sitting days from the date it was laid[footnote 4].
The Order may also be challenged as unlawful by bringing a claim for Judicial Review within 6 weeks of the date it was laid.
Schedule 1 - consultation
The Ministry of Housing, Communities and Local Government (MHCLG) published and invited representations on the proposals in line with the published Handling, Publicity and Consultation Arrangements[footnote 5]. The consultation began on 3 July 2025 and ended on 31 August 2025. It was run on behalf of MHCLG by consultants Mott MacDonald.
MHCLG invited representations on the Environmental Statement (ES) and other documents, plans, and drawings that accompanied the request for planning permission, which were published on the gov.uk website on 3 July 2025.
A copy of the proposal, the ES, and the accompanying plans and other documents were provided to Bedford Borough Council, as the local planning authority. The documents were made available for inspection at the offices of MHCLG in Wolverhampton, and locally at Bedford Borough Council and at Central Bedfordshire Council. Hard copies of the documents were also available from the Promoter for a charge. Site notices were placed on land in the vicinity of the site. An advert was placed in a local newspaper explaining where the planning proposal, the ES, and the accompanying plans and other documents could be viewed and inspected and how a representation could be made. Notice was served to statutory bodies, landowners and occupiers of property on, and next to, the site, railway operators, and interested or affected parties.
MHCLG sent electronic copies of the documents to specific consultation bodies[footnote 6]. It also invited representations from organisations that MHCLG identified as likely to be affected or have an interest in the proposed development, unlikely to become aware of the proposal by means of a site notice or local advertisement[footnote 7].
Just over 500 representations, from residents, businesses and public bodies, were received by the close of the consultation period. Some late representations were received and considered along with relevant correspondence received before the consultation opened. Most of the representations (circa 80%) were submitted via an online Citizen Space survey. Of the circa 400 Citizen Space survey responses, around 75% supported the development, around 16% objected and the rest were neutral. Two-thirds of online respondents said they lived locally.
Following the expiration of the consultation period, the Secretary of State received 16 representations, which were categorised as late responses. The issues raised in late responses (excluding those which are duplicate, or multiple responses) mirrored the key themes seen in the responses received during the consultation period.
It was noted that two of the responses were duplicates of responses received during the consultation period. A further two were partial duplicates, largely identical to responses received during the consultation period, but providing additional supporting material.
All comments and representations were considered in the analysis of potential impacts of the proposed development, carried out by professional planning staff in MHCLG.
Local authorities
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Bedford Borough Council was supportive of the proposal, which they regarded as transformational for the local economy. It supported the mitigations proposed in the ES, notably those designed to mitigate likely adverse impacts on residents, particularly during construction. Central Bedfordshire Council expressed support for the proposal, acknowledging the potential benefits for local residents, communities and businesses. It provided recommendations on public transport impacts, flood risk, landscape, archaeology, proposed public rights of way and health and wellbeing. Luton Borough Council expressed support, welcoming the predicted positive economic regeneration in the sub-region. It made recommendations on transport and connectivity, including contingency planning for wider transport network impacts, Luton Station’s regeneration, and East West Rail. Its response notes that trade draw from existing town centres, such as Luton, would be likely to be offset by trade creation from new visitors associated with the ERC. Milton Keynes Council was supportive, citing positive benefits to the city will experience. Its response noted significant impacts on the local transport network and the need to consider interfaces with existing travel infrastructure planning (such as East West Rail). It recommended provision of a shuttle bus service for visitors by the Promoter. |
These issues were considered alongside the assessment of the noise, air quality, transportation and other issues in the ES. As noted in Schedule 2 to this Statement, scheme controls and limits have been imposed to regulate noise emissions, construction phase noise/vibration, dust and other impacts using management plans. Monitoring is also required in relation to several amenity areas and impacts on the elements of the local highway network considered most likely to be worst affected, with provision made for remedial measures. The Order requires the Promoter to provide a shuttle bus service between Milton Keynes Central station and Wixams station (and monitoring of service level requirements). The impact on footpaths was considered in the round and weighed against the benefits of the scheme. The Order secures the Promoter’s proposals for active travel routes. Wider scheme controls and limits to avoid unacceptable effects were adopted in the Order (and are summarised in Schedule 2 to this Statement, including Transport / Energy / Security and Emergency Management / Employment and Economy) |
Transport
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Concerns were raised in relation to potential congestion on the local road network, arising from visitor numbers once the development is operational, and on specific key routes including the M1, A421 and B530. Concerns were also raised in relation to the impact of construction traffic, particularly on local roads, and the risks to highway safety concerns. Concerns were also raised about parking in surrounding areas and dust from construction vehicles. Conversely, the use of active travel measures and improvements to rail infrastructure were supported by several respondents. Bedfordshire Hospitals NHS Foundation Trust; Bedfordshire, Luton and Milton Keynes Integrated Care Board; Bedfordshire Police; and East of England Ambulance Service raised concerns regarding emergency response times due to transport network effects. Local businesses, including G. Moore Haulage, Royal Mail Group and Asda, raised concerns with the transport effects of the proposal impacting on business operation. Network Rail raised initial concerns in relation to rail capacity and station impacts, local stations and the Marston Vale Line crossings and rail freight. However, noting clarifications from the Promoter and subsequent comments from NR, such concerns have been addressed. Central Bedfordshire Cranfield and Marston Ward Councillors, and the parish councils in the Cranfield and Marston Ward[footnote 8], jointly raised concerns on traffic impacts at Junction 13 of the M1 and on local road networks (alongside concerns about noise and landscape impacts). They requested further transport modelling and mitigation and an updated monitoring/management plan. The response also requested consideration for reinstatement of footpaths, interconnection between the EWR station and Wixams station, informal parking management and establishment of a community liaison group. The Canal and Rivers Trust noted that the Bedford and Milton Keynes (B&MK) Waterway lies within red line site boundary and recommends that the development addresses and integrates the waterway positively within the Entertainment Resort Complex. National Highways (NH) submitted that the proposal’s effect on the strategic road network could be accommodated by the proposed infrastructure, which is considered appropriate and proportionate. Additionally, NH stated that trip generation forecasting adopted a cautious, worst-case approach and that it was satisfied with the Promoter’s methodology and results. Several conditions were proposed. East West Rail East West Rail (EWR) Company EWR company’s consultation response requested several amendments to the Promoter’s proposed conditions. This included an amendment to a condition managing master planning and detailed design processes. This amendment would require that any Zonal Masterplan: “…must not include development on any part of the EWR Safeguarded Land unless the details of such development have been approved by the Secretary of State for Transport following engagement with EWR.” EWR company defined ‘EWR Safeguarded Land’ as all the land subject to the Direction. When read in conjunction with EWR company’s aspirations of developing a station by 2040, this amounted to a request to sterilise all safeguarded land within the site prior to, and even indefinitely beyond, 2040 unless approval is given by the Secretary of State for Transport. This would mean that two Secretaries of State would need to agree to any development on the safeguarded land. DfT DfT’s consultation response on this matter asked that in relation to all land subject to the Direction safeguarded for EWR a formal document of agreement between EWR and Promoter should be entered into before the Secretary of State can issue a planning decision, and to ensure the views of EWR are reflected in the decision. The Secretary of State for Transport subsequently wrote to the Minister for Housing on 24 October 2025 to confirm that: “Further to the Department for Transport’s response to the Special Development Order submission for Universal, the Department can confirm that we consider the East West Rail project and the Universal ERC project to be compatible. Where there are overlapping land requirements between proposals for Universal and the safeguarding boundary for EWR that was set out in directions in November 2024, the Department considers that these can be resolved through ongoing design development and discussion between East West Rail Company and Universal Destinations and Experiences. We do not require formal agreement between East West Rail Company and Universal prior to any consent. I am content for the above to be appended to the Department’s letter of 29th August to MHCLG on Universal’s planning application.” The email did not withdraw or amend DfT’s and or EWR company’s initial consultation responses, but the Secretary of State had regard to them when considering the balance to be struck in terms of whether to grant planning permission and whether to impose controls in the Order. |
Local road and strategic road network (SRN), rail and active travel effects were reviewed considering transport, air quality and other ES assessments, as well as consultee feedback from Network Rail and National Highways. Neither the latter nor the Department for Transport raised objections to the highways modelling provided by the Promoter. No severe impacts were considered to arise on the local network during operation of the development. Schedule 2 to this Statement summarises the range of measures required by the Order following consideration of these issues to avoid unacceptable effects. This includes shuttle buses, infrastructure (rail and road) provision, including active travel, signalisation works, rail crossing provisions and the requirement for an extended Wixams Station. Schedule 2 to this Statement summarises the way that the Secretary of State integrated the ES analysis and consultee feedback in relation to the assessment of the impact on the Strategic Road Network, including Junction 13 of the M1, where effects were considered material but not severe. The adequacy of the proposed station land included by the Promoter was considered and the Secretary of State agreed that it would not be of sufficient benefit to justify safeguarding it in the Order. The interrelationship between the Order scheme and the scope for the emerging EWR scheme to progress without serious prejudice was considered. The Order includes measures to limit the impact on the Order proposal of conflicting development arising from other permissions in a way that strikes an appropriate balance in facilitating the integration of the eventual EWR scheme and the Order proposal. |
Living conditions
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Representations were received from some residents who live within the vicinity of the site. They objected to the potential for excessive noise/vibration from the development (during both construction and operation), light pollution, pressure upon local services and upon local housing (including house prices). The potential for general disruption within the area, during construction, was also raised, alongside concerns the proposed development could put additional pressure on community services and amenities such as healthcare, put additional pressure on housing supply. Wootton Parish Council expresses support for the Proposal but raises concerns about additional traffic causing congestion and pollution and negatively impacting the A421, particularly in relation to the assessment of impacts on the Berryfields housing estate. Bedford Health and Wellbeing Board was supportive of the proposals, believing them to have a cumulative net benefit for the health and wellbeing of people living in the Bedford Borough area. Bedfordshire, Luton and Milton Keynes Integrated Care Board raised concerns about additional direct demand for services during construction and operation and additional indirect demand and indirect service impacts. East of England Ambulance Service supported the proposals, subject to the ability of emergency ambulance services to respond to increased demands arising from developments. The response discusses the impact of construction and operation of the Entertainment Resort Complex on delivering emergency healthcare services. Concerns raised include increased demand for services; the impact of increased traffic; increased workload for regional call centres; and the need to coordinate with other emergency services. The response also requested the inclusion of a helipad to enable Helicopter Emergency Medical Services to be able to land to take critically ill patients to hospital |
These matters have been addressed by conditions and controls within the Order (albeit some local disruption is inevitable during any construction project). Summary information on Population and Human Health considerations and related measures is in Schedule 2 to this Statement. The noise methodology was scrutinised having regard to proposed noise limit measures (for sensitive receptors very close to/ within the site and the imposition of limits and monitoring controls to achieve this at these close locations), distance, limits on the location of the most noise generating uses with in the Core Zone and major road and rail infrastructure). Measures are summarised in the Population and Human Health section of Schedule 2 to this Statement. Potential pressure on local housing supply was considered. The delivery of sufficient housing is a matter for Bedford Borough Council to consider through its local plan process. Even so, the Promoter will be required to monitor construction worker take up of local accommodation and to provide alternatives should certain triggers be reached. The Secretary of State was satisfied that the provision of suitable security and emergency related infrastructure, and unified design and control by the site controller secured by the Order, along with coordination between relevant safety and security agencies, would result in appropriate development. |
Land contamination/remediation
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Few comments were received on this matter, which concerned, chiefly, the need for the developer to remediate the site. Some were directly positive about the remediation that would occur. The Environment Agency did not object but did recommend conditions to address the potential risk of contamination of watercourses (for example, from fire at battery energy storage systems), and to ensure watercourses remain suitable for fish and other aquatic wildlife. | This matter has been addressed by conditions within the Order. Further details can be found in Schedule 2 to this Statement (Ground Conditions, Land Stability and Contamination / Flood Risk, Drainage and Water Resources / Ecology and Biodiversity) In summary, land remediation will be required in areas of the site that have been identified as contaminated. Controls are in place to secure remediation of any contamination caused or encounter during construction. Controls are in place to protect watercourses. |
Landscape and visual effects/design
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| There were many concerns about the visual impact of such a large, and potentially tall, development upon the local landscape. Concerns were raised about artificial lighting from the proposal having a negative impact on the wider landscape. | This matter has been addressed by conditions within the Order. Further details can be found in Schedule 2 to this Statement. In summary, the landscape harm arising is recognised, and controls have been put in place. These include height limits and differentiation, lighting controls, and requirements for the endorsement of masterplans or detailed design proposals in specific zones. |
Flood risk, drainage and water resources
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Concerns were raised about the potential for the development to cause or exacerbate flooding in the surrounding area, as well as its impact upon water resources in a water stressed region. There was no objection to the proposal from the Environment Agency, subject to certain conditions being accommodated. Anglian Water supported the proposals subject to ensuring sufficient capacity within water supply and wastewater systems to serve the Entertainment Resort Complex. The Bedford Group of Drainage Boards (IDB) expressed no objection to the proposals on the understanding that the Promoter continues to consult it on any elements of the final design which are associated with any land drainage feature, surface water discharge, or are within nine metres of a watercourse. |
Schedule 2 to this Statement provides a summary of the approach to considering these issues (under Flood Risk, Drainage and Water Resources), as well as the summary measures imposed in response to the assessment of the environmental information received form the Promoter and consultees. In summary, conditions are in place to ensure land drainage is managed effectively. Controls ensure that connections to the potable water supply and foul sewer network are not possible until certain pre-requisites are met. The Order controls also include approvals for outfall design. The IDB also retains approval controls over these outfalls. |
Heritage
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| There were a few concerns about the potential for the development to have an adverse impact upon certain heritage assets (historic buildings and other features), notably from its presence in their setting. Historic England did not identify any substantial harm to heritage assets nor object to the proposal in their Statement of Agreed Position with the Promoter. The Garden Trust expressed concern over impact on Ampthill Park, identifying in its view less than substantial harm to the significance of the Registered Park and Garden. The main concern raised in the response was the increased level of the built form in one of the principal views from Ampthill Park, potentially changing the outlook from rural to an industrial landscape. The response also raised concerns about the increased noise and light pollution in the area disrupting the rural character of the park. The Trust requested additional screening and mitigation to reduce impacts on Ampthill Park. Central Bedfordshire Council shared the view that the assets on the Greensands Ridge were the key ones likely to be impacted by the development. |
The Secretary of State recognised the impact that the development would have upon the settings of Ampthill Park and Houghton House. He also recognised the possible impact of construction vibration upon the Kempston Hardwick Moated Site. Further summary can be found in Schedule 2 to this Statement. A condition is in place to keep vibration levels in the vicinity of the Moated Site to an appropriate level. The Secretary of State did not consider that specific actions were required regarding Ampthill Park and Houghton House, as the benefits of the proposal outweighed the less than substantial harm to their setting. Even so, those conditions relating to design and lighting/ skyline articulation will serve to keep the development within defined parameters. |
Ecology and biodiversity
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| Comments were received that were both supportive of, and concerned about, the development’s impacts upon ecology and biodiversity. The former were supportive of the opportunities it afforded for ecological enhancements; the latter concerned about habitat loss. There was no objection to the proposal from Natural England, The Wildlife Trust for Bedfordshire, Cambridgeshire and Northamptonshire or the Forest of Marston Vale Trust, subject to the application of conditions to secure mitigation. Natural England agreed that there would not be significant impacts to any nationally or internationally recognised nature conservation sites, having regard to its response to MHCLG’s Appropriate Assessment. Its response notes that there are still likely to be impacts on local landscapes. It recommended that the developer adopted the Biodiversity Net Gain metric and seek to deliver a minimum of 10% Biodiversity Net Gain. The Wildlife Trust agreed that the ecological surveys conducted adequately considered the impacts of the proposal on habitat. It supported the conclusion that there are unlikely to be any adverse impacts. However, the response expressed concern that the cumulative assessments do not adequately consider landscape scale habitat fragmentation and people disturbances. The Trust recommended undertaking a voluntary Biodiversity Net Gain assessment |
This matter has been addressed by conditions within the Order. Further details can be found in Schedule 2 to this Statement (Ecology and Biodiversity). In summary, a range of conditions control construction work, habitat creation and enhancement, tree protection, bat corridors and the protection of aquatic flora and fauna. The statutory regime for mandatory biodiversity net gain does not apply to Special Development Orders. The Secretary of State considered the adequacy of the ecological assessments provided, the nature and scale of proposed habitat retention, creation and enhancement (and management measures) proposed, having regard to national planning policy aims to integrate biodiversity improvements in new development. The Order includes minimum habitats provision and management arrangements as summarised in Schedule 2 to this Statement. |
Climate change and resilience
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| A small number of respondents referenced general climate change impacts arising from carbon emissions associated with the development. Others were supportive of the emphasis on public transport usage and active travel. | This matter has been addressed by conditions within the Order. Further details can be found in Schedule 2 to this Statement. In summary, conditions are in place to ensure the development is climate resilient and to reduce carbon emissions from building construction. Public transport and active travel route provision is also required. The Secretary of State accepts that any impacts arising from air travel cannot be controlled by the operator. |
Safety and Security
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| There were a very few responses from the public in relation to national security and safety, concerned chiefly with potential restrictions on e.g. drone flying. Neither national nor local security agencies, nor the emergency services, objected to the development (although some referenced future funding needs). The Health and Safety Executive noted that the site lies within consultation distance of a major hazard site: ASDA operates a Chilled Distribution Centre (CDC) adjacent to the site. This includes a Liquified Natural Gas (LNG) fuelling facility for its fleet, erected with the benefit of Hazardous Substances Consent. Consultation zones imposed by the Health and Safety Executive surround the fuelling facility. HSE had no objection subject to suitable controls being in place. ASDA objected to the development on the grounds that the proposals had not adequately demonstrated that they would be safe from a traffic management and safety or a health and safety perspective. The response also suggests that there has not been sufficient evidence that the proposals are satisfactory from an environmental health and existing business operation perspective. Specific concerns include highway safety; danger from hazardous substances; and conflict with the established environmental health regime. |
This matter has been addressed by conditions within the Order. Further details can be found in Schedule 2 to this Statement. In summary, production and implementation of a Security & Emergency Management Plan is a condition of the development. |
| Emergency services funding is something to be addressed through other mechanisms, unrelated to the Special Development Order process. Schedule 3 to the Order contains a condition to regulate works near to the LNG facility (including HSE risk assessment and Secretary of State approvals). |
Economic development and employment
| Summary of results and information gathered | Summary of ways incorporated or otherwise addressed |
|---|---|
| There was considerable support from consultees about the economic benefits that would accrue to the local area from the development, as well as for the range of job opportunities that it would bring. Across all responses from individuals, and organisations and representative groups (but excluding consultation bodies and statutory consultees), the most prominent issues raised in support of the proposed development relate to its perceived economic impact. These include that it will have a positive economic impact on the local area, that it will create new jobs for the local population, and that it will attract tourists, and their spending to Bedford. One consultee raised concerns about the potential impacts of trade diversion in the market and felt that the promoter should have been required to demonstrate a need for the development. Concerns were also raised regarding negative impacts on local businesses. |
Further details on this matter can be found in Schedule 2 to this Statement. A condition in the Order requires compliance with the Employment and Skills commitments made by the development’s Promoter. The Secretary of State judged that there was no requirement for the promoter to demonstrate need nor was there any substantive evidence of potential adverse market impacts. |
Schedule 2 - main considerations and reasons, reasoned conclusion on significance of effects on the environment, conditions, mitigation and monitoring measures
Overview of effects
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| The ES identifies residual likely significant effects arising from the project, after mitigation is considered. The Secretary of State considered that the ES presents a realistic worst-case scenario[footnote 10], other than in relation to the following, where the Secretary of State disagreed with the significance levels and/or approach to mitigation (n.b. the reasoning for this is set out in the relevant sections below): - Highways impacts at Broadmead Road (see discussion on operational highway effects below) - Heritage assets - Carbon emissions - Utilities connections - Sports pitches. The Secretary of State took the effects into account, securing mitigation by conditions in Schedule 3 to the Order. Some significant effects (both positive and negative) would remain. There would be residual beneficial effects. These include: the economy and employment, water and flood risk, ecology, noise and in terms of increased connectivity for non-motorised users (NMU) along Manor Road. Conversely, some residual adverse effects would arise including those relating to noise, living conditions, landscape, NMU fear and intimidation from construction traffic, driver delay along certain local carriageways during operation, behavioural modifications of motorists using the SRN, heritage and carbon. Overall effects are summarised below. |
Monitoring measures are included in the Order. In summary, these are in relation to: - Construction activities (e.g. noise, vibration, dust, construction traffic) - Temporary workforce accommodation - Ensuring that vehicle movements and traffic flows stay in line with those assessed by the Transport Assessment. - Analysing the means of transport used by visitors and staff (via Travel Plan requirements). - Monitoring provision of vehicle parking spaces relative to visitor numbers. - Use and provision of shuttle bus services from Milton Keynes Central and Wixams Stations to the Site. - Measuring surface water run-off against control requirements. - Ensuring the outcomes of the landscape and ecology management plan(s) are met. - Ensuring the development operates within defined noise / vibration parameters. |
The scheme
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| The project is an Entertainment Resort Complex (ERC) and associated development on a site area of roughly 268 hectares at a former brickworks and adjoining land at Kempston Hardwick, Bedford. The scale of the proposed ERC is without precedent in the UK, with the potential to attract 8.5 to 12.5 million visitors annually. The Order authorises development in several Classes: Class 1 – Visitor entertainment and hospitality facilities; Class 2 – Support for visitor entertainment facilities; Class 3 – Rail-related development; Class 4 – Utilities and services; Class 5 – Pedestrian and cycle routes and circulation spaces; Class 6 – Roads and associated infrastructure; Class 7 – Vehicle-related facilities; Class 8 – Security and reception; and Class 9 – Landscaping and environmental measures, miscellaneous visitor facilities and amenities. The proposed development is divided into four main areas: Core Zone, Lake Zone, West Gateway Zone and East Gateway Zone. The theme/amusement/water park(s) will be located within the Core Zone, while the West Gateway will be a mixed-use zone to include the main access from the A421 and a transport hub. The East Gateway Zone will include a four platform Wixams railway station and an associated transport hub, along with works to improve the existing Manor Road to dual carriageway standard. The Lake Zone will be a mixed-use area incorporating a range of hotels, retail, dining, conference and entertainment uses, together with the main utility compound area and areas of habitat creation and enhancement. The existing site at Kempston Hardwick is partly brownfield, incorporating hardstanding, buildings, spoil heaps and water bodies formed from clay pits and quarrying associated with the site’s former use as brickworks. These mineral extraction and related activities have now ceased. The remainder of the site is or has most recently been in agricultural use. The site is not subject to any on-site environmental or protective landscape designations, other than an area of a County Wildlife Site, which covers the former clay pits in the northern part of the site. There are no on-site built heritage or archaeological designations, but Kempston Hardwick Moated Site, a scheduled monument, stands just outside the site boundary. Construction is proposed to take place over several years, extending to at least 2050, with the initial construction period leading up to the planned opening of the site to the public in 2031. The Order provides for ongoing development, redevelopment and changes of use associated with the evolution of the ERC destination over time. The Order requires the ERC to be designed to be capable of hosting 8.5 million annual visitors and 55,000 visitors per peak day, at its Grand Opening, including at least: - an immersive entertainment and leisure experience and self-contained holiday destination theme park(s)/water park(s)/amusement park(s) of at least 32.37 hectares in size; - at least 500 hotel rooms available to accommodate visitors; - security facilities; - vehicle and cycle parking, including a minimum of 7,106 car parking spaces, 100 coach parking spaces, and 250 cycle spaces; - green infrastructure including habitat, creation enhancement, retention areas (of a minimum of 49.3hectares); - active travel routes throughout the site, which will facilitate connections from the ERC to the surrounding transport network; - associated infrastructure improvements: - a new junction on the A421 with dual carriageway on and off slip roads to provide the principal road access to the site; - realigned and upgraded Manor Road between Ampthill Road and the Marston Vale Railway Line to provide a dual carriageway access road from the east of the site; - an expanded Wixams Railway Station; and - shuttle bus services between Wixams Station and the site and Milton Keynes Central and the site. The Order restricts Class 1 uses until Grand Opening, but allows for some Soft Opening activities before the above requirements are met where the Secretary of State agrees to this under submitted schemes. |
The Zones are identified in the Reference Documents in Schedule 1 to the Order Conditions in Schedule 3 to the Order restrict the parts of the site where specific uses may take place (including Part 9 of Schedule 3 to the Order) Conditions in Schedule 3 to the Order restrict the Grand Opening of the development until: - the specified habitats have been provided (Condition 6) - landscape and ecology management plan has been approved (Condition 9) - vehicle parking has been provided (Condition 53) - sustainable drainage scheme has been approved (Condition 65) - the core ERC has been delivered (Condition 69) - public access arrangements are satisfied (Condition 71) - Level crossing and public rights of way requirements are met (Conditions 72, 73) - Wixams Station requirements are met (Condition 74) - A Travel Plan is in place (Condition 75) - Class 1 use restriction (Condition 76) |
Summary policy context
National Planning Policy Framework (The Framework)[footnote 11]
The Framework sets out national policies, which the Secretary of State concluded are the most relevant material considerations in this case, given they are more up-to-date and appropriate than the development plan to the scale and nature of the development. The Secretary of State gave significant weight to the Framework in reaching his decision.
There is no national or local policy specifically relating to the proposed development of an ERC on the scale envisaged. The Framework seeks, among other things, to:
- build a strong and competitive economy
- ensure the vitality of town centres
- promote healthy and safe communities
- promote sustainable travel
- make effective use of land
- achieve well-designed places
- meet the challenges of climate change and flooding
- conserve and enhance the natural environment
- avoid, minimise or remediate pollution
- conserve and enhance the historic environment
- remediate despoiled, degraded, derelict, contaminated or unstable land, and
- develop under-utilised land and buildings.
The Framework policy is that significant weight should be placed on the need to support economic growth and productivity, considering both local business needs and wider opportunities for development. This includes recognising the specific locational requirements of different sectors.
Development Plan
The development plan comprises the Bedford Borough Council Local Plan 2030 (2020), the Allocations and Designations Local Plan (2013), the Minerals and Waste Local Plan: Strategic Sites and Policies (2014) and saved policies of the Bedfordshire and Luton Minerals and Waste Local Plan (2005). Bedford Borough Council has been working on a replacement local plan for several years. It has decided to halt this and to start work on a new local plan.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that, where regard is to be had to the development plan for purposes of any determination under planning legislation, the determination must be made in accordance with the development plan unless material considerations indicate otherwise. This does not apply when considering the grant of planning permission by an SDO. The Secretary of State nonetheless had regard to relevant development plan policies as material considerations.
The Proposal is of a scale and nature that could not have been anticipated or positively planned for at the time of producing the Local Plan. Understandably, therefore, the plan does not provide for the type of development envisaged, in terms of its scale in a location classed as “countryside”. As such, the Proposal cannot be said to be in accordance with the spatial strategy of the development plan. The Secretary of State considered that this conflict with the Local Plan (in relation, chiefly, to the proposal’s open “countryside” location) weighed against the proposal in the overall planning balance. Even so, the proposal’s alignment with some of the Local Plan’s strategic objectives (to promote sustainable growth, re-use previously developed land, attract investment, boost the economy and create jobs (policies 69S and 75) was relevant when considering the countervailing weight of the proposal’s benefits.
Transport, highway safety and capacity
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
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| The Secretary of State considered the methodology for the submitted Traffic and Transport assessment (including forecast modelling and suppression of demand). The methodology, including the worst-case scenario depicted, was considered acceptable, noting that the Department for Transport and National Highways responding in their capacities as consultees were content in this regard. In terms of modelling rail effects, the Secretary of State was content that outputs were robust and reliable (noting that the scope and methodology for the modelling was confirmed to have been agreed by Network Rail). Highways - Construction During the weekday morning peak period (07:00 to 10:00) the network would experience a small increase (circa 11% change) in average delay during the peak construction period of around 37 seconds per vehicle. During the weekday evening peak period (16:00 to 19:00) the network would experience a moderate increase (circa 27% change) in average delay during the peak construction period of circa 88 seconds per vehicle. This results in a reduction in mean vehicle speeds at these times. There would also be some strategic highway network (SRN) routes where changes in journey times following the introduction of construction traffic would occur. The Secretary of State concluded that most residual construction effects on the local network SRN would be at a low level. Effects would not be so significant as to cause ‘severe’ effects in the planning context, regarding the tests at paragraph 116 of the Framework (and noting the absence of objection from DfT or NH). Nonetheless, construction effects would still result in flows that would be busier than at current off-peak periods. The network would also be busier in what are currently weekday peak periods, which would be particularly noticeable by Non-Motorised Users (NMUs). Secretary of State’s conclusion on the significant effects of the development on the environment (highways construction): The following residual ‘significant’ effects in EIA terms during construction scenarios would occur: - Moderate adverse effects in terms of NMU amenity and ‘fear and intimidation’ at Link 31 (Wootton – Woburn Road); and - Moderate adverse effects in terms of NMU amenity and ‘fear and intimidation’ at Link 35 (Woburn Road). |
Conditions in Schedule 3 to the Order are imposed to mitigate construction effects on local and strategic roads, including: - requiring the submission and approval of Construction Environmental Management Plans (CEMPs) for the carrying out of all works, other than preliminary works. Amongst other things this must include construction traffic management plan provisions - restricting the number of construction vehicles along specified routes until certain infrastructure is in place |
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Highway effects - Operation Several improvements to the SRN (A421) and local network are proposed. These include: - A new road junction on the A421, including an eastbound off-slip into the site, a westbound off-slip into the site and a westbound on-slip away from the site. This highway infrastructure has evolved through engagement with National Highways (NH). Department for Transport (DfT) and NH are both satisfied that it would be suitable, safe and deliverable. - Public Road A, as shown on the submitted Parameters Plan – Access and Roadways, would effectively link Manor Road to the A421, creating a through route from Ampthill Road to this part of the SRN. - Public Road B, as shown on the submitted Parameters Plan – Access and Roadways, would provide new roundabouts to secure access to the Core Zone and Lake Zone and to link to the Manor Road railway bridge currently expected to be delivered by NR and the A421. - Manor Road would be realigned and upgraded to a dual carriageway between Ampthill Road and the MVL. This realigned carriageway is identified as ‘Public Road C’ following clarifications received 24 November 2025. - Other local improvements include a signalised junction at Broadmead Road and Woburn Road/Bedford Road and changes to rail crossings. Concerns about potential increases in delays and congestion at Junction 13 of the M1 were among the main issues raised during consultation (see Schedule 1). The Secretary of State considered that that the project would materially affect the operation of Junction 13 of the M1, particularly in relation to the choice of journey times for some motorists. As a result, the project could result in inconvenience to the users of that part of the Strategic Road Network (SRN). This was considered an issue of significant weight against the proposals. However, the Secretary of State considered that effects on the SRN, including Junction 13 of the M1, during operation would not be to such a degree that would be classified as ‘severe’ regarding the tests in the Framework, nor would this justify the refusal of planning permission. The Secretary of State considered that no enhancements would be required to Junction 13 of the M1, or the A421/A6 Bedford junction, to make the proposals acceptable. In making this assessment, the Secretary of state was mindful of the absence of any objection from NH and DfT. The Secretary of State had regard to the potential material change in vehicle speeds (reduction in speeds of 23mph) along Fisherwood Road, being likely to be limited to during a single hour and only in one direction. No severe impacts were considered to arise on the local network during operation, noting the absence of any objection in this regard from NH and DfT. Secretary of State’s conclusion on the significant effects of the development on the environment: In reaching his conclusion, the Secretary of State disagreed with the Promoter’s assessment insofar as it identified a potential initial moderate initial adverse risk in terms of accidents and safety along Broadmead Road. This was an unduly precautionary approach, particularly given the small increase in traffic flows along this carriageway and the absence of pedestrian infrastructure here. Only a minor risk in this regard during construction (and operation) was considered likely, which applying the significance criteria was not significant in EIA terms. One residual effect that would be significant in EIA terms remained. This would be a moderate adverse effect given driver delay along Fisherwood Road. |
Conditions in Schedule 3 to the Order are imposed to mitigate highway effects during operation, including: - requiring the delivery of highway infrastructure before Grand Opening - requirements to provide shuttle bus services from and to both Milton Keynes Central Station and Wixams station - travel plan requirements The Promoter’s submitted Travel Plan included a mechanism to monitor and manage the proposal’s effect on the highway network. The Secretary of State’s monitoring and management requirements are imposed by condition in Schedule 3 to the Order SDO, to reflect the assumed operating assumptions for the scheme assessed in the ES (Condition 79). This includes ongoing monitoring against a baseline to ensure that the scheme operates within the parameters of the ES, and a process for carrying out required remedial actions. The conditions in Schedule 3 to the Order require monitoring of the use of the shuttle bus services to and from the site from both Milton Keynes Central Station and Wixams East Station following Grand Opening (to determine the level of future service provision). |
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Impact on the rail network The ES concluded that with the provision of Wixams Station to provide four platforms, the railway network has the ability to accommodate the proposed number of visitors travelling to and from the site by train, though once fully operational there may be a risk of demand exceeding capacity in the morning peak arrival period at the weekend. DfT and Network Rail confirmed that the proposed four-platform station and associated rail infrastructure upgrades to Wixams Station would be deliverable (by Network Rail) by the assessed intended opening date, and that there is sufficient capacity on the railway network to accommodate the demand forecasts. The Secretary of State had no reason to conclude otherwise. A DfT safeguarding direction is in place for the emerging East West Rail scheme, requiring consultation on planning applications being considered by local planning authorities, which could affect the EWR scheme. Although the Direction does not apply to decisions relating to SDOs, The Secretary of State nonetheless consulted EWR and DfT. He considered the representations from DfT and the EWR Company seeking the imposition of conditions relating to EWR, providing for a role by DfT in the subsequent approvals process and weighed the impact of the requested approach against the need for investor certainty, the effects on the emerging EWR scheme and scope of the Safeguarding Direction. He concluded that it would not be appropriate or necessary to impose the EWR Company requested restrictions having regard to the stage of the EWR scheme development, the requirements of the ERC scheme and conclusion that his intended approach would not prejudice the ability to progress the further design development of the EWR scheme. He also had regard to the overlap between the development authorised by the Order and the potential for there to be physical incompatibility with the scheme authorised by the existing Network Rail Transport and Works Act Order affecting parts of the site. He concluded that the extent of effects would be determined at a later stage, when rail crossing solutions are detailed, but that the effect of the Order scheme on the TWAO scheme could be adequately mitigated by Network Rail and on balance the interrelationship should not justify refusal. In terms of safety, improvements would be made to several crossings. Limited positive weight has been attributed to this in the overall planning balance decision. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State concluded that there would be no significant environmental effects in this regard. |
The conditions in Schedule 3 to the Order include: - A condition restricting Grand Opening until two PRoW within the site have been stopped up (Including Footpath 1, which crosses the Marston Vale Line within the site). - A condition ensuring that approved works at the Manor Road crossing are in place prior to Grand Opening. - Provisions preventing Grand Opening unless Wixams station is open to the public and scheduled rail services are stopping at it, unless an alternative temporary bus scheme is provided. - Provisions to secure improvements to Manor Road level crossing and Broadmead Road level crossing - Requirements for detailed design and Construction Environmental Management Plans that provide platforms for further consideration of development’s effect on the operational railway. |
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Provision of vehicle/cycle parking The submitted assessment showed that a minimum of 11,197 vehicle parking spaces, excluding parking spaces at railways and coach parking, would be provided. A maximum of 16,661 spaces would be provided at full build out (the point at which the development is capable for accommodating for 12.5 million visitors). A minimum of 7,106 non-rail car parking spaces would be provided at Grand Opening. The Secretary of State concluded that parking provision would be acceptable and would not result in parking stress away from the site. This conclusion was reinforced given the absence of any objection from the local highway authority. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State concluded that there would be no significant environmental effects in this regard. |
- Conditions in Schedule 3 to the Order require car and cycle parking. - Other conditions ensure that details of the overall quantum of parking are provided and that provision is made for electric or other sustainably fuelled vehicles is made. - Schedule 3 to the Order also includes a requirement to monitor parking provision for vehicle spaces, designated cycle spaces, coach bays and provision for sustainable vehicle charging. |
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Provision of active travel routes The proposal includes the provision of active travel routes. New pedestrian and cycle facilities would be provided at sections of Manor Road (Link 36), which currently has sections without any pavement. Changes to Manor Road level crossing are also proposed. The Promoter has submitted a travel plan which includes modal split targets (which includes 33.8% of visitors travelling by car following Grand Opening and 31.9% doing so by 2051). The Secretary of State broadly agreed with the objectives of the travel plan, and has sought the imposition of a condition that focuses on the outputs set out in the travel plan. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State considered the active travel routes would result in a significant (moderate beneficial) effect at Manor Road during operation in terms of connectivity. |
Conditions in Schedule 3 to the Order require: - Masterplans and detailed design to include the detail of proposed active travel routes and - The active travel routes identified on endorsed masterplans or detailed designs in the Core Zone, East Gateway Zone and West Gateway Zone to be open for public use prior to occupation of the authorised works. - Conditions also ensure that a Travel Plan would be submitted and approved and manage shuttle services and secure relevant modal split targets. |
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Impact on Public Rights of Way (PRoW) Footpaths A1 and 8 would be stopped up, as a temporary measure, during construction. Footpaths 1 and 2 would be stopped up permanently, although they would be temporarily stopped up initially. While the PRoWs do not appear to be particularly well-used, the Secretary of State acknowledged the effects of this scheme on potential users in the overall planning balance. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State concluded that there would be no significant environmental effects in this regard. |
Conditions in the SDO secure the timing of the permanent stopping up of Footpaths 1 and 2. |
Ground conditions, land stability and contamination
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| Some of the site has been used in the past for industrial purposes, chiefly brickmaking. This has resulted in the presence on the site of spoil heaps, tanks, clay pits (at least one of which has been converted to landfill) and numerous buildings, now mostly demolished. Areas of the site have been, and still are, in intensive agricultural use, with the accompanying applications of pesticides and herbicides. The Secretary of State concluded that there is need for provision to be made for land contamination to be addressed during construction, though significant adverse effects once the development is operational are unlikely. Once current work, under a separate consent, to stabilise land on the perimeter of the north-eastern part of the site has been completed, no other land stability issues have been identified. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State concluded that there will be no residual likely significant effects arising from ground conditions, land stability and contamination. He gave limited positive weight to the potential for improvements to ground conditions. |
Conditions in Schedule 3 to the Order require - the submission and approval of CEMPs for the carrying out of all works, other than preliminary works. The CEMP must include provisions to assess whether construction work will give rise to a contamination risk and setting out how unexpected contamination shall be addressed - that no construction work takes place on part of the site where surveys or investigations indicate that contamination could cause significant harm to human health or where significant pollution of controlled waters could occur, unless a strategy dealing with this has been submitted and approved by the Secretary of State. |
Heritage
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
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| The proposed development is not within a conservation area and there are no designated heritage or archaeological assets within the site. The Secretary of State considered the assessment of cultural heritage assets, their relationship to the site and nature of the proposals, the contribution of setting to their significance and the assessment of likely effects in Chapter 10 of the ES. He had regard to The Framework (202-216) and to the desirability of preserving the setting or any features of special architectural or historic interest which these designated assets possess (and to the need to pay special attention to preserving or enhancing the character or appearance of a conservation area) in reaching his decision. He noted that two assets derive some of their significance from the wider landscape in which the site sits: Houghton House (a scheduled monument and listed building) and Ampthill Park (a registered park and garden, containing scheduled monuments and listed buildings). In addition, Kempston Hardwick Moated Site is a scheduled monument located very close to the site boundary. The ruins of Houghton House stand in a commanding position on the Greensand Ridge with extensive, long-range views north across the vale in which the proposed development would be located. Ampthill Park once contained the long-demolished Ampthill Castle whose site is a scheduled monument and marked by the listed Katherine’s Cross. Ampthill Park House, a Grade II listed building, which is situated on gently sloping ground below the ridge on which Katherine’s Cross sits, is also encompassed by the Park. Kempston Hardwick Moated Site is a scheduled monument located on the floor of the vale rather than overlooking it and although situated close to the proposed development, the moated site has no physical or visual relationship with it The proposed development, especially the taller rides and buildings, would be visible (although at some distance) in views out from the ruins of Houghton House and from Ampthill Park. They would, however, be situated within a landscape that already includes tall structures, including wind turbines and an energy from waste plant, logistics warehouses and the East Midlands Railway line gantries. In the relatively recent past, the chimneys of the brickworks that were once on the development site, and those that existed at Stewartby, would also have risen from the vale floor. Historic England, the Government’s statutory advisor on the historic environment, did not object to the proposed development on heritage grounds. The Secretary of State placed considerable weight on their views. Secretary of State’s conclusion on the significant effects of the development on the environment: Other than in relation to the assets discussed above, the Secretary of State did not agree with the conclusions of the ES in relation to heritage. He considered that its findings of harm to many assets were overly cautious, given their distance from the site and the limited, if any, role the site plays in their heritage significance. He considered that, in ES terms, there will not be any Residual Likely Significant Effects on built heritage arising from the proposed development. For the purposes of his planning assessment, however, the Secretary of State took the position that the presence of the ERC, insofar as it gives rise to heritage harm to Houghton House and Ampthill Park, arising from impacts upon their settings, would result in less than substantial harm around the top of the scale. No other heritage assets were likely to experience harm to their significance. Although giving great weight to this harm, he considered that, in relation to the policy tests in the Framework, it was outweighed by the public benefits arising from economic and employment opportunities. |
Conditions in Schedule 3 to the Order - contains controls over structure heights and over external lighting - require masterplan and detailed design approvals for types of development outside the Inner Core Zone A specific condition in relation to the protection of the Kempston Hardwick Moated Site from piling vibration. |
Ecology and biodiversity
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
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| There are no nationally or internationally designated wildlife sites within the red line boundary of the proposed development. The site is comprised of agricultural land (some of which is best and most versatile meaning that its loss carries limited weight against the proposed development) and the remains of a brickworks. The agricultural land is still being farmed for arable crops, meaning that its ecological value as habitat is relatively limited. Of more significance in ecological terms are the trees and hedgerows forming the site boundaries. The former brickworks site, like many unused brownfield sites, now contains a mosaic of habitats accommodating many different species that would be impacted by the proposal. Around a third (roughly 27ha) of the Kempston Hardwick Pit County Wildlife Site (CWS) is located within the site boundary, along with around 5% (about 5ha) of the Coronation Pit CWS. Both areas would be subject to disturbance and change, impacting upon the waterbodies located within the former, and the trees/mixed scrub located within the latter. The site also lies within the area designated as the Forest of Marston Vale, one of 12 community forests established in 2000 to regenerate degraded landscapes near large urban populations. Several protected species, including mammals, birds and amphibians, are present. Relevant protected species licences will be required by the Promoter to enable the closure of certain badger setts and bat tree roosts. NE has provided Letters of Comfort setting out that it sees no impediment to the granting of such licences. Statutory Biodiversity Net Gain requirements do not apply to SDOs. The Secretary of State had regard to Section 40 of the Natural Environment and Rural Communities Act 2006 (which requires public authorities to have regard to the purpose of conserving biodiversity). The Framework also urges opportunities to improve biodiversity in and around developments should be integrated as part of their design. Around 49 ha of land within the site would be turned over to Ecological Enhancement Areas comprising a range of habitats, in addition to species specific habitat provision. The proposed development would result in disturbance to and loss of existing on-site habitat and necessitate the relocation of some protected species. New habitats would also be established through the conditions secured. Neither Natural England nor the Environment Agency raised in principle objections to the proposed development, subject to appropriate mitigation being secured, and the Secretary of State accords substantial weight to their views. Four Sites of Special Scientific Interest (SSSI) are located between 2.3km and 5.5km from the site. The scope for likely significant effects on the following designated habitat sites was considered: [Image: Bedford_statement_of_reasons_image_1.svg] The Secretary of State had regard to effects associated with Direct Loss of Habitat, Water Quantity, Volume and Flow, Water Quality (discharge of treated sewage effluent), Spread of invasive non-native species, Loss of functionally linked habitat, Recreational disturbance of species, Changes to predator-prey dynamics, Airborne pollution, Disturbance of qualifying species and Species Injury or mortality. He concluded, having regard to the distances and relationship between the Order site and these sites that there is no functional link with the proposed site, nor are there considered to be any impact pathways that could lead to significant effects on them (having regard to the submitted Shadow HRA findings including those relating to air quality effects[footnote 12]. The exception was in relation to the Ouse Washes SPA/SAC/Ramsar and Portholme SAC Habitat Sites. Unlike the Promoter, the Secretary of State did not consider that LSEs on these sites could be ruled out to the standard required by the Habitats Regulations. This was because the ultimate arrangements for potable water supply and foul water treatment are inchoate at this stage and it was not possible to entirely rule out the ultimate solutions to either being addressed in a way that involved a pathway to these two designated sites having regard to his own analysis and the response of Natural England. The ultimate solutions to both are regulated by conditions in Schedule 3 to the Order (that prevent foul/ potable water connections until the Secretary of State has reviewed and approved the approach having complied with the relevant duties in relation to designated habitats sites, waterbodies and wider considerations of water supply). While this results in an appropriate control on the scheme, it is reliant on specific preventative measures which the Secretary of State did not rely on for the ‘screening’ of LSEs. As such, taking a precautionary approach, the Secretary of State carried out an appropriate assessment (AA) in relation to the two sites where significant effects could not be ruled out without reliance on the foul/ potable water condition restrictions: Ouse Washes SPA/SAC/Ramsar and Portholme SAC Habitat Sites. Natural England was consulted on the AA and agreed with the AA conclusions below. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State agreed with the assessment of residual likely significant effects on Ecology and Nature Conservation[footnote 13]. He concluded that the project would not result in any likely significant effects on any habitat sites, disregarding mitigation measures, other than Ouse Washes SPA/SAC/Ramsar and Portholme SAC habitat sites. Having carried out Appropriate Assessment, the Secretary of State ruled out adverse effects on the integrity of those sites, having regard to the foul/ potable water condition controls set out in the Order. No residual likely significant effects would arise on any SSSIs by virtue of the proposed development The proposed development would accord with the requirements of the Framework in avoiding significant harm to biodiversity, SSSIs and irreplaceable habitats, as well as minimising impacts on and providing net gains for biodiversity. The Secretary of State considered the range of adverse impacts and beneficial outcomes concerning ecology and biodiversity, concluding that, overall, the matter should attract neutral weight in the planning balance. |
Conditions in the SDO to mitigate the impact on ecology and biodiversity include: - Creation, enhancement or retention of minimum types and extents of habitats before Grand Opening - Approval of Habitat Creation and Enhancement Plans before the commencement of construction work in specified areas of the site - Approval of Landscape and Environmental Management Plan - Bat corridor provision - Measures to protect fish and other aquatic life - Restriction on connection to potable water network - Restriction on connection to foul water network - Protection of a veteran tree - Measures to safeguard aquatic wildlife, including requiring details of any outfalls to Elstow Brook or Harrowden Brook. |
Population and human health
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
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Air quality The existing sources of air pollutants relating to the site include road and rail traffic and a range of industrial developments. Two Air Quality Management Areas (AQMA) are within or around 5km from the site. These are the Bedford Town Centre AQMA and No 3 Ampthill AQMA. The likely adverse impacts on air quality arising from the proposed development are dust arising from construction and increases in pollution from road traffic during both construction and operational phases. Because of its distance from the site, the proposed development would not result in any material effects on the annual NO2 reduction objective in AQMA No 3 Ampthill. There would be negligible residual impacts upon the Bedford Town Centre AQMA, and upon ecological receptors (including the nearest SSSI and County Wildlife Sites) and on residential properties in Kempston Hardwick arising from road traffic emissions and dust. Secretary of State’s conclusion on the significant effects of the development on the environment: In light of the proposed mitigation, the Secretary of State’s concluded that there would be no residual likely significant effects on air quality arising from the proposed development. Taking a cautious approach he, nonetheless, considered it reasonable to attribute limited adverse weight to this matter in the planning balance. Living conditions Parts of the development would be visible from existing homes in the wider area, during the day and at night. Most of these dwellings are at such a distance that the development’s impacts upon them would be slight. There are, however, some dwellings very close to the site, which have the potential to experience direct adverse effects from the proposed development both during construction and in operation. These are on the northern side of Manor Road, Kempston Hardwick, within the site red line boundary, on Brick Crescent, Stewartby, looking out over what would be the Core Zone and a single dwelling of Broadmead Farm on Broadmead Road, abutting the southern boundary of the Core Zone, not far from Brick Crescent. The Promoter has purchased several of the dwellings on Manor Road, which are now empty. For all residential properties that remain occupied close to the site, the main impacts on the future living conditions of inhabitants would arise from increased vehicle movements and general disruption on and around the site during construction of the main complex, as well as from works to highways and rail infrastructure. Once built, there is considerable potential for privacy to be compromised by outlooks from tall structures, and the intrusion of illumination and pyrotechnics. Design controls imposed by the Secretary of State, in relation building heights and building distances from properties, would mitigate some of these impacts. Overall, therefore, taken in the round, the Secretary of State concluded having regard to the nature of the impacts upon living conditions of a small number of residents living close to the site in light of the control measures applied, that they carried limited weight against the proposed development overall. Noise and vibration The proximity of the site, and particularly the Core Zone, to the closest residential properties means that there will inevitably be adverse noise and vibration impacts affecting them during construction and once the ERC is operational. Many interested parties have raised concerns about noise and vibration, including Bedford Borough Council, commercial operators, businesses, and residents living in nearby properties. The initial construction period, before opening to the public, is expected to take around five years, although construction activity would be likely to continue on some parts of the site after opening as new facilities are developed and the mixed uses in the Lake Zone are provided. The noise and vibration associated with construction on the scale expected would be very noticeable to local residents, even where mitigation measures are incorporated. Once complete, during a typical day of operation, neither the daytime nor nighttime impacts on nearby receptors would be likely to be unacceptably harmful. The greatest impacts are likely to arise during special events, such as Halloween and New Year’s Eve celebrations, which might involve amplified music from shows running until late at night, in addition to the noise arising from rides and visitors. To provide some certainty about the maximum noise levels that might be expected from the development, the Promoter proposed limits on the noise from operations associated with the Core Zone (excluding fireworks, which are subject to controls under the Fireworks Regulations 2004). Whilst the proposed levels are relatively high, they must be considered in the context of the existing ambient noise levels, which are also relatively high, such that the increase in noise would be less noticeable. There is also expected to be significant scope for mitigating noise impacts through detailed design as the development progresses. The Secretary of State attached conditions to the planning permission, which seek to reduce these effects as far as practicable by setting noise limits that must be monitored and adhered to. The Secretary of State concluded that these should apply to the site as a whole and not just to the Core Zone, contrary to the suggestion of the Promoter. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State’s conclusion was that the proposed development has the potential to give rise to significant adverse impacts upon the living conditions of the residents of a limited number of dwellings in and beside what would be a very large development. The development would be at odds with paragraph 135 of the Framework, which, among other things, seeks to ensure that new development creates places with a high standard of amenity for existing users and minimise impacts. The Secretary of State concluded that adverse noise and vibration effects are likely to be limited to those receptors closest to the Core Zone but, nevertheless, represent a significant adverse impact and, as such, should attract significant weight against the proposal. Considering the above alongside the positive effects arising, including a significant benefit from employment and training opportunities for future workers, the Secretary of State concluded that the impacts upon Population and Human Health as a whole were neutral in the planning balance. |
Flood risk, drainage and water resources
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
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Flood Risk Most of the site is in flood zone 1 (lowest probability of flooding). There are some parts of the site in the northern part of the Lake Zone, and adjacent to Elstow Brook and the A421 in the West Gateway Zone. which are in flood zones 2 and 3 (and at higher risk of flooding). Development should generally avoid areas at risk of flooding and so the Framework requires that a sequential approach to site selection is applied. The Promoter concluded that there are no other sites of a sufficient size that would also meet the locational requirements for the proposed development. The Secretary of State agreed that there are no suitable and reasonably available alternative sites at a lower risk of flooding, and that the sequential test is satisfied. The Promoter intends a sequential approach within the site, so that development is located according to its relative vulnerability to flood risk, having regard to the Framework. This approach is set out in the submitted Flood Risk Assessment, and the Secretary of State applied a condition to secure substantial accordance with this document. Where it is necessary to undertake development in the relatively small areas of the site at higher risk of flooding, the Secretary of State considered that suitable mitigation measures can be incorporated, such as raising ground levels (with compensatory lowering elsewhere where necessary), or ensuring buildings and uses are resilient to water. Again, these are controlled by condition. Having considered the general layout of the scheme, and parameters, it is likely that ‘more vulnerable’ development (mixed use/hotels) and ‘essential infrastructure’ (spine roads), having regard to the Framework definitions, would be located in Flood Zone 3a, and so it is necessary to apply the Framework’s exception test. Surface water runoff from the site would not be increased beyond that of the existing greenfield runoff rate. This is secured by condition. This would ensure that the development is safe for its lifetime, taking account of the vulnerability of its users, without increasing flood risk elsewhere. On this basis, the Secretary of State concluded that the exception test was met. The EA raised no objection, considering the proposed development to be acceptable subject to the imposition of appropriate conditions. Drainage The Promoter intends that all water is directed to storage bodies within the site and released to Elstow Brook and Harrowden Brook at a controlled rate, to prevent flooding elsewhere, but maintaining the greenfield runoff rate to ensure the watercourses are not starved of flows. Pollutants would be removed from water before it discharges into the drainage storage bodies. The Secretary of State is satisfied with this approach and applied a condition to secure substantial accordance with this approach to drainage of the site, including the submitted Drainage Strategy. The Promoter would be responsible for necessary watercourse diversions within the site, maintaining all drainage infrastructure within the Core Zone and Lake Zone, and for maintaining SuDS throughout the Order Land. The Secretary of State secured these responsibilities by condition. Water resources The site lies over two aquifers (Kellaway Sand Member Secondary Aquifer and the Cornbrash Formation Principal Aquifer). To avoid contamination risks, the Secretary of State requires the CEMP to include a strategy for any piling proposed. The site is within Anglian Water’s (AW) Ruthamford South water resource zone, which is classed by the EA as seriously water stressed. AW could supply potable water sufficient to meet domestic water supply needs (subject to infrastructure upgrades), but not for non-domestic uses. These are required to be met through strategic rainwater harvesting in the Lake Zone water bodies, which would be stored and pumped to an on-site non-potable water treatment works from where it will be distributed within the site. The Secretary of State was satisfied that this approach to non-potable water supply (which also requires his endorsement of any alternative proposals) would be sufficient to meet all non-domestic water demand including irrigation, park washdown and supply to water features and attractions. Nonetheless, the development would be a significant user of water in a seriously water stressed area. The ultimate arrangements for potable water supply and foul water treatment are inchoate at this stage and are regulated by conditions in Schedule 3 to the Order that prevent foul/ potable water connections until the Secretary of State has reviewed and approved the approach having regard to effects on designated habitats, waterbody status and wider supply considerations. The conditions prevent any connection to potable/ foul water supplies unless the Secretary of State has confirmed that sufficient capacity is available before any connection is made. The site would not be at risk of flooding and would not increase the risk of flooding elsewhere. There would be no material conflict with policies 25, 32, 44, 47S, 92, 50S, 52, 92 or 93 of the LP, Bedford Borough Council’s Sustainable Drainage Systems SPD or the national standards for sustainable drainage systems (SuDS) in so far as they require a sequential approach, suitable assessment of flood risk, water efficiency, the incorporation of sustainable drainage systems and pollution controls. The Proposal would be in accordance with the similar objectives of the Framework and PPG. The Secretary of State concluded that having regard to the mitigation controls, the proposed development would be in accordance with the objectives of the Framework and PPG and that, overall, effects associated with flood risk, drainage and water resources were neutral in the planning balance. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State concluded that, after mitigation to be secured by a range of conditions proposed, no significant adverse effects on flood risk, drainage and water resources are anticipated to occur either during construction or operation of the proposed development. He agreed that there would be moderate beneficial significant associated with proposed improvements to on-site waterbodies. He considered that the Order controls would ensure that there will be no deterioration in waterbodies during the construction and operational phases and the proposal would not hinder the River Basin Management Plan from achieving its objectives or the UK’s ability to comply with the Water Framework Directive. |
Conditions in Schedule 3 to the Order to mitigate flood risk, drainage and water resources impacts include: - The submission and approval of a scheme to ensure the authorised works are flood resilient. This must be based on detailed modelling of fluvial and surface water flooding and be in substantial accordance with the submitted Flood Risk Assessment document. - A condition stipulating that authorised development must not result in any net loss of space that is available to hold excess water temporarily during a design flood event. - A restriction on increasing surface water runoff from the site (Condition 63) - CEMP piling strategy (Condition 12) - A requirement that the authorised works must not be constructed or operated so as to result in the rate or volume of surface water discharged from the land. This condition also requires the rate to be monitored. - Flood Risk compliance measures (Condition 57) - Submission and approval of a maintenance and management plan and a maintenance schedule for the system of sustainable drainage serving authorised works. - A requirement that the CEMP includes a strategy in relation to any use of piling. - Provisions regarding the use of non-potable water and rainwater harvesting in line with the submitted Water Strategy (Condition 59) - Controls on the connection to offsite sewerage and waste water infrastructure, and the public water supply (Conditions 66, 67). - Scheme to be substantially in accordance with the Drainage Strategy, Water Strategy and Flood Risk Assessment. |
Design, parameters and standards
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| The ES relies on submitted parameters and design standards to provide an envelope of external dimensions and design criteria, which the development must meet. This was proposed to ensure that the ERC can respond to market demand, and can innovate as technology changes, over a period of construction extending to at least 2050. The Promoter submitted what it referred to as ‘controlling documents’ - these include Parameter Plans, a Travel Plan, Design Standards, a Security and Emergency Management Plan, Environmental Controls Document, and tables setting out proposed Land Use Limitations and Dependencies, where key elements of infrastructure are required before construction and/or operation of the proposal can proceed. The Promoter proposed that detailed design of the scheme would come forward in stages, in line with the controls in these documents. For the Inner Core Zone, no masterplans nor further detailed designs are required by the Secretary of State, as the Promoter requires considerable flexibility to update this part of the ERC in response to changing trends and market requirements. On the edge of the Core Zone, and in other parts of the proposed development, detailed architectural and landscaping proposals for individual buildings or zones would be addressed through subsequent submissions of master plans and design codes. The Secretary of State considered that in principle the proposed parameters, design standards and limitations, particularly height of buildings, contained in the submission appropriately indicate (and can be used to control) aspects of how the future development of the site would progress without imposing restrictions that might unnecessarily limit flexibility or innovation having regard to the nature of the proposals. Having considered the nature of the proposed development, international comparisons, special planning regimes and the site’s context, the Secretary of State was satisfied that a process for considering and approving the details of development after the grant of planning permission would be reasonable in principle. He accepted that the parameter plans are appropriate for use in the Order as part of these controls and that other standards and controls could be included either by reference (or, for the reasons below, by inclusion in the Order). In reaching this conclusion, he considered that the assessment approach had considered a realistic worst case having regard to the nature and duration of the development proposed and proper assessment of the LSEs. The Secretary of State considered the adequacy of the proposed scheme controls to deal with the assessed worst case. He considered, however, that several of the proposed controlling documents submitted by the Promoter were not expressed in a sufficiently precise way to ensure that the balance between desired flexibility and reasonable certainty of what was to be permitted (through relevant planning controls) was maintained. As a result, he required several of the relevant standards to be expressed more clearly in the Order than had been done in the submitted documents, to ensure clarity and certainty over the operation of detailed controls. The Secretary of State did not, therefore, approve the submitted ‘controlling’ documents, but used them as the basis for controls imposed in the Order, with adjustment to ensure an appropriate level of certainty balanced against the flexibility sought. He concluded that the Order controls reflect the approach considered reasonable and effective to secure the level of control intended in line with the basis of assessment. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State’s judgement overall was that there would be no significant adverse effects arising from the design of the proposal (having separate regard to the assessment of landscape/visual and heritage asset effects), which was a neutral factor in the overall planning balance. |
- Schedule 1 to the Order includes Reference Documents, including parameter controls. - Schedule 4 to the Order includes specific Height Parameters, which are applied in conditions (including Condition 10 (bat corridor), 23 (Height controls) and 28 (detailed designs)) - The following standards and parameter controls also controlled by conditions in Schedule 3 to the Order: - Drainage Strategy - Environmental Controls - Design Standards (Part 8 of Schedule 3 to the Order) - Landscape and ecology management standards - Outline CEMP - Tree Protection Measures - Access and Roadways locations / Active Travel routes |
Climate change and resilience
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| The Climate Change Act 2008 as amended sets the legislative basis for the UK’s action on climate change, making net zero a statutory requirement. The Framework expects the planning system to support the transition to net zero by 2050. In terms of construction emissions, the Promoter relies on a Carbon Management Plan, aligning with PAS 2080:223 and the Leadership in Energy and Environmental Design (LEED) standard, as a means of addressing greenhouse gas emissions from the development. In terms of emissions from transport, a significant proportion of visitors would use private vehicles to reach the site. The Proposal seeks to maximise public transport opportunities, notably travel by rail, with a view to minimising emissions. The largest proportion of the overall greenhouse gas emissions attributable to the proposed development would come from air travel, accommodating international visitors. There is no industry standard method for assessing the potential effects of climate change on development of this kind. The ES relied on the application of professional judgement in relation to the data and approach used to establish a baseline and for forward modelling. The Secretary of State considered this to be a reasonable and realistic approach. In addition, as reflected in the ES, the Secretary of State agreed that there can be little certainty about the number and origin of visitors that may use air travel to visit the proposed development nor about whether the proposed development would be the sole destination for anyone travelling into the United Kingdom by air. Or, conversely, whether the presence of the ERC would result in less air travel to, for example, entertainment complexes in mainland Europe or to the United States from the United Kingdom. The ES nonetheless identifies that greenhouse gas emissions from air travel, as a proportion of the development’s overall emissions, would be anywhere between 70-96% (depending on from where in the world most visitors could be travelling). This would be significant in ES terms. The Secretary of State had regard to the 2027 requirement that all international flights, including those into and out of the UK, will be subject to offsetting requirements to support the 2050 goal for net-zero. The Government’s Jet Zero strategy is also targeting delivery of net zero emissions for the UK aviation sector by 2050. Neither of these changed his assessment of a significant effect in ES terms. The Secretary of State considered that, while the Promoter’s carbon management proposals, insofar as they relate to construction impacts, are laudable, it is challenging to quantify carbon reduction benefits at this stage. Taking a precautionary approach, the Secretary of State did not consider that the ES conclusions in relation to no residual Likely Significant Effects, following mitigation, could be evidenced. Nevertheless, the proposed measures would represent tangible steps to addressing national planning policy requirement in relation to achieving a low-carbon economy, mitigating climate change and reducing greenhouse gas emission. Based on the analysis undertaken, a range of design measures to address climate resilience (specifically in relation to the effects of variable and extreme precipitation, temperature and wind) are therefore secured by conditions in the Order. Secretary of State’s conclusion on the significant effects of the development on the environment: Adopting a cautious approach to mitigation, the Secretary of State concludes that there would be a residual likely significant effect in terms of carbon dioxide emissions, both in relation to transport and construction/ operation. Overall, considering the mitigation proposed, included in the SDO as conditions, the Secretary of State concluded that appropriate consideration had been given to the need to mitigate for and adapt to climate change, as well as addressing carbon emissions. The Proposal would be in accordance, therefore, with relevant aims and objectives contained in the Framework. This was a matter of neutral weight in the overall determination. |
- Conditions in Part 8 (Design Standards) of Schedule 3 to the Order integrate climate resilience into the design standard requirements - Conditions in Schedule 3 to the Order also require - Environmental performance to the LEED standard for specific types of buildings (Condition 54) - Compliance with the Carbon Management Plan (Condition 55) |
Economy and employment
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
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Context The UK does not have a globally significant theme park destination. Disneyland Paris is the nearest similar development in Europe, receiving 16.1 million visitors in 2023. This context is reflected in the scale and nature of the proposed ERC, which would attract between 8.5 and 12.5 million visitors per year. The Promoter forecasts that about 30% of the visitors on opening would be international, rising to 48% when fully operational. Tourism is a significant economic, cultural and social asset to the UK and a catalyst for economic growth and job creation. Government policy (most recently expressed in The UK’s Modern Industrial Strategy Creative Industries Sectoral Plan 2025) is to grow the sector and drive international competitiveness. The development of a global ERC within the UK presents a substantial benefit to the UK economy and a significant opportunity to create a tourism attraction beyond London. In addition, a large conference/convention centre is proposed as part of the proposed mixed-use development. This will support further support economic growth. Decisions about the size, scale, nature and location of the proposed development have been informed by the Promoter’s experience of operating such schemes around the world and the commercial opportunity identified for a resort in Europe. The Promoter considered alternative sites, including in mainland Europe, and concluded that the proposed site in the UK best met its requirements. The Secretary of State’s conclusion is that there is no statutory or national policy requirement for the Promoter to demonstrate the need for this proposal (in the way major infrastructure is described in national policy statements for types of development subject to the Planning Act 2008, for example). This is a commercial judgement by the Promoter in the context of its analysis of the existing competition in the UK and the potential future market. Regional considerations Bedford is in the south Midlands / outer Southeast where large-scale growth has been underway for a long time, centred on Milton Keynes and Northampton. It is now part of the Oxford/Cambridge growth corridor. The New Towns Taskforce has recently announced that Tempsford, about 7 miles northeast of Bedford, is a preferred location for a new settlement, maximising the potential benefits of East West Rail (EWR). Because the New Town proposal is at a very early formative stage, and there is no physical overlap between the Proposal site and the potential New Town location, the Secretary of State gives little weight to the possible interaction between the potential new town and the ERC development. The strategic EWR scheme is at an early stage and is proposed to provide a new transport spine between Oxford and Cambridge, elements of which are now constructed and operational. The EWR operator has carried out several rounds of non-statutory consultation to progress the next stages of the project. Revised safeguarding directions for consultation purposes were issued by the Secretary of State for Transport in November 2025. Final proposals for EWR are to be submitted in an application for a development consent order (possibly in late 2026). The Secretary of State’s conclusion is that provision of an EWR station to serve the site would be beneficial to the scheme, providing greater opportunities for sustainable travel, but is regarded as a bonus. The development does not rely on a new EWR station being delivered. The ERC would generate a substantial number of new jobs in hospitality and in new creative sectors. It would also be likely to drive up the demand for housing in the sub region. In terms of transport improvements to support local economic growth, a two-platform station is under construction at Wixams on the Midland Main Line. This would need to be expanded to four platforms to serve the proposed development. The Secretary of State accepts that the scheme has been designed to enable this increase in capacity. Economy The analysis in the ES is that the proposed ERC development would result in a substantial economic benefit, including large additional visitor spend and demand for new hotel accommodation, both on and off the site. Most visitors would be new to the area, generating spending that would not otherwise be available. A large proportion of this expenditure would arise from international visitors. It is not expected that the proposed ERC would materially divert trade from other existing theme parks in the UK, which are aimed at a different market and provide an entirely different experience in terms of scale and nature. Many of the proposed uses, such as retail, leisure, entertainment and tourism developments, are those which would typically be provided in a town centre location. Consequently, in accordance with the requirements of the Framework, an impact assessment of the effects on Bedford town centre and other town centres in Central Bedfordshire was carried out by the Promoter. The Promoter’s considered that the development should not be viewed as a traditional retail or leisure development but requires a bespoke approach. An ERC of this scale and nature could not sensibly be located in or on the edge of a town centre, given the type of development proposed and the amount of land required. The Secretary of State agrees. The proposed mix of uses forms part of a single destination. The component parts are functionally linked as an ERC, so that they would not make an offer comparable to town centre shops nor draw trade away from them. Rather, in drawing large numbers of people to the area, the proposed development is likely to have a net positive effect on town centres. This conclusion is, however, reliant on control over the maximum floorspace for the proposed main uses (e.g. retail in certain Zones of the development). This should allow for reasonable convenience shopping, aimed at guests to the ERC, but prevent larger format retail units, such as supermarkets, that are intended to serve a wider catchment. The Secretary of State has, therefore, imposed conditions in the SDO to that effect. Employment In terms of employment creation, the ES suggests the proposed development would support 5,380 direct construction jobs at the peak of the primary phase in winter 2029. It is estimated that over 80% of these jobs would be filled by UK workers, with most likely to be local residents, facilitating a considerable boost to local employment. This will be reinforced by training and skills initiatives where appropriate. The scale of this construction employment demand is comparable with the peak workforce requirements of other large projects in the UK, such as Hinckley Point C. Experience from the implementation of that project suggests that the potential effects of a large temporary workforce on the local community, in terms of antisocial behaviour and impacts on the local housing market, must be acknowledged. It is not expected that the demand for temporary accommodation generated by the proposed development during construction would exceed the local supply. The site is not in an isolated location, and the workforce can be drawn from a wide area. Nevertheless, it is recognised that there is an inherent uncertainty around the future availability of accommodation across the area, given fluctuation in demand and supply and the variability of construction workforce demand throughout the construction period. If demand for temporary accommodation becomes excessive then bespoke on-site or off-site accommodation to house these workers may be required. The Secretary of State has imposed a condition to monitor the need for temporary workforce accommodation and to secure such accommodation where required. Once operational, it is estimated that the proposal would directly support 8,050 jobs in the opening year (2031) rising to 12,465 jobs by 2051. These would include a wide variety of jobs in new and fast-growing sectors including retail, engineering and robotics, digital and creative industries. In many ways, the potential opportunities for creation of many new jobs in such sectors, and indeed in sectors which have yet to be invented, is one of the most substantial benefits of the proposed development. Even if these forecasts for the levels of economic development and employment are optimistic, the general outcome would be firmly in accordance with the objectives of the Framework. The Secretary of State’s conclusion is, therefore, that the economic and employment benefits weigh substantially in favour of the proposed development. Town Centres Planning decisions should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation. The sequential test should be applied to proposals for main town centre uses, as defined in The Framework, which are neither in an existing centre nor in accordance with an up-to-date local plan. Preference should be given to locating main town centre uses in town centres, then edge of centre locations, and only if suitable sites are not available (or expected to become available within a reasonable period) should out of centre sites be considered. The site is out of centre. The proposals include a range of main town centre uses, with retail and leisure uses cumulatively exceeding both the default threshold in The Framework of 2,500sqm, requiring an impact assessment, and the LP’s lower threshold of 500sqm for retail. The Promoter considered the sequential approach and suggested that the Proposal is a unique proposition that must be considered as a whole. The Secretary of State accepted that the development should not be viewed as a traditional retail or leisure development, instead requiring a bespoke approach. The primary element is a ticketed theme park, water park and/or amusement park to be located within the Inner Core Zone. However, this is only one component, as the operation of the resort would rely upon several associated uses, from hotel accommodation to restaurants, retail and bars. The proposed mix of uses would be complementary, providing visitors with a variety of opportunities, as part of an integrated offering making up the ERC as a whole. This model reflects that of similar resorts around the globe, including those operated by Universal and its competitors. He considered that the types of uses proposed would form part of a single destination and be functionally linked as part of the ERC, albeit that members of the public would be able to access non-ticketed areas. This area is referred to by the Promoter as the Entry Plaza and would form the gateway into the ticketed area. This would include shops, bars and restaurants, which seek to attract visitors before and after the ticketed area is open, thus spreading arrivals and departures to the site. Many of the associated uses would be themed around the resort or offer convenience shopping for the benefit of visitors to the ERC. The Secretary of State considered that the proposed uses would not result in an offer comparable to town centre shops, or similar uses, with the effect of drawing trade away from the centre. He considered that they are likely to use the range of facilities as part of a visit to the resort, but may also spend time visiting the local area, making use of the established businesses in the town centre or other nearby tourist attractions. The socio-economic chapter of the ES considers the potential market catchment for the proposal and expects that most visitors likely to utilise the retail and leisure provisions would be new to the area, attracting spending that would not otherwise be available. A large proportion of this expenditure would arise from international visitors to the ERC. Primary residents (residents within a one-hour commute of the proposed development) are expected to spend £71m on-site in the opening year, according to the ES. As a cautious worst-case scenario, if it were assumed that all of this spend may otherwise have gone to town centres in Bedford and Central Bedfordshire, and future baseline spending in these town centres was otherwise unchanged, this would equate to a reduction of 1.8% in town centre spending. This would be an adverse impact on existing town centres. The Secretary of State had regard, however, to the fact that expenditure in the town centres is not reliant only on the spend of local residents. Total expected spend in Bedford and Central Bedfordshire (from all types of visitors) is expected to reach £175m in the Proposal’s opening year, just over twice as much as the spending by primary residents on-site. As such, even if the forecast reduction in town centre spending by residents was to occur, this would be more than offset by the increase in spending from other visitors. The socio-economic assessment finds that visitors attracted to the proposed development would provide a new source of income for local businesses, increasing existing retail turnover by 4.4% in the CSA, compared with the 2031 baseline and 2.9% in the SRCA, after excluding spend on visitor accommodation. Overall, the effect on town centres is predicted to be beneficial. The Secretary of State accepted that to be competitive in the global market, the development must offer the full range of uses expected at a world class theme park and resort. This is evident from other resorts of a similar scale, such as Disneyland Paris and Universal Studios in Orlando, where international visitors are served by a variety of uses necessary during their stay, such as hotels, restaurants, bars, shopping and entertainment. Co-location of such uses means that guests’ needs can be conveniently met without creating additional travel needs or putting undue pressure on town centre infrastructure. He considered the proposal as a whole on this basis, accepting for these reasons that various uses cannot practically be expected to disaggregate to different sites or locations. He considered that the proposals would not have a detrimental effect on public or private investment in any centre, or to the vitality or viability of town centres. Rather, in drawing large numbers of people to the area, the ERC is likely to have a net positive effect on town centres and the local economy, as set out in the submitted impact assessment. The result would be a positive effect on local businesses. The Promoter considered whether there were alternative sites that could accommodate the proposed development (as a whole) and concluded that there were not. Bearing in mind the specific locational requirements of the development (including a minimum size of 80.94ha in single ownership, relatively flat topography, good transport accessibility, proximity to London, adequate employment catchment, whilst avoiding significant planning, ecological or landscape constraints), the Secretary of State agreed with this conclusion. An ERC of this scale and nature could not sensibly be in or on the edge of a town centre given the type of development proposed and the amount of land required. As such, the sequential test is satisfied, and the conclusions of the impact assessment are robust. Indeed, it would be a perverse outcome if the development and its anticipated benefits for town centres were to be prevented by a policy that aims to protect them. This approach is reflected in control over the proposed main town centre uses included in the Order, bearing in mind that facilities could attract local people where a ticket is not required for entry. The ERC would require a wide range of supporting uses, from offices, to warehousing, kitchens, laboratories, training and health facilities. The Order requires that these uses are functionally associated with the core uses. A similar approach is taken to retail and other town centre uses. Given the expected net positive impact on town centres, he Secretary of State did not consider it necessary to control the floorspace of units for other proposed uses. Although main town centre uses would form part of the Core Zone, as described above, these would be closely linked to the theme park(s) and of a scale commensurate with this predominant use. The Secretary of State considered that would be no conflict with The Framework nor with Local Plan policies 77S, 78 or 85 insofar as they give preference to town centre and edge of centre sites for main town centre uses, require an impact assessment for out of centre retail and leisure development, and seek to avoid detrimental effects on adjacent uses or the character and amenity of the area. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State agreed with the conclusions of the ES, which found Moderate Beneficial (“significant”) effects likely in relation to a range of factors, which would be of temporary, medium term and permanent beneficial impacts. There would be temporary and medium-term employment during construction, including through Employment & Skills commitments secured by the Order, within the Labour Catchment Area and Core Study Area (“CSA”); permanent, long-term, benefits arising from employment opportunities in the CSA once the development is operational (from opening in 2031 to full completion in 2051); permanent, long-term benefits arising to business from additional spending, visitor accommodation needs and new trade opportunities, notably for local businesses in relation to supply chain changes. These would impact at the CSA, Sub-Regional Context Area and national scales. In the planning balance, the Secretary of State concluded that the benefits to the economy attracted substantial positive weight. |
- Condition 52 secures controls over shop floorspace. - A condition in Schedule 3 to the Order requires compliance with the submitted Employment and Skills commitments (Condition 90) - Article 4 of the Order grants permission in way that requires supporting uses to be functionally associated with the core uses - The Conditions in Schedule 3 to the Order also: - Restrict use of Class 1 floorspace (which includes retail) until Grand Opening of the ERC has occurred, subject to limited exceptions (Conditions 76) - Require submission of a ticketed area and limit certain uses to this area (Condition 2, 70(1)(b)(ii)) - Limit dedicated conference/ convention centre use (Condition 40) and other floorspace (Condition 52) - Maximum floor space restrictions and requirement for some supporting uses to have a functional link. |
Landscape and visual effects
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
| For the purposes of planning policy, the site is within the countryside. The proposed development would create a wholly new character for the area, during both the day and the hours of darkness. It is inevitable that the proposal’s size and nature would cause landscape and visual harm during construction and operation. There are no nationally designated landscapes on the site or within its vicinity. The closest formally designated landscape is the Chilterns National Landscape, which is 12km to the south of the site. The local landscape character area of the site is the North Marston Clay Vale. This area is mainly in arable use, interspersed with the villages of Stewartby, Houghton Conquest, Marston Moretaine, Shortstown, Wixams and Wootton. Although the site has the legacy of industry centred on clay extraction and brickmaking, its predominantly open character makes a positive contribution to the immediate rural setting. The Greensand Ridge, around 4km southwest of the site, is a prominent and extensive landscape feature. The first phase of the proposed development to 2031 would take place in the Core Zone, plus infrastructure works such as the new highway access to the A421 and a new junction, changes to Manor Road and the development of additional platforms at Wixams station. This would be the peak period of construction and, so, the maximum degree of visual and landscape change. The construction phase would involve large scale civil engineering operations, including the mass grading of land, and the construction of ride attractions, up to 115m in height, and other development up to 75m in height. Construction activity would, therefore, markedly urbanise the immediate setting and would, over a sustained period, introduce visually prominent features visible particularly from the high points of the Greensand Ridge, including significant night-time effects from lighting. Some mitigation would be secured, in terms of controls over loss of vegetation and new planting to provide screening, which would take some time to offer amelioration of adverse landscape and visual effects. Once operational, the dynamic, kinetic nature of prominent attractions, coupled with lighting, fireworks, pyrotechnics and drones, especially at nighttime, would fundamentally change the character of the existing site permanently, as well as views into the site from elevated vantage points and surrounding footpaths and bridleways. Conditions would control construction activities through the submission of CEMPs and the implementation of mitigation measures involving landscaping and creation of new habitats. Secretary of State’s conclusion on the significant effects of the development on the environment: The Secretary of State’s conclusion is that the urbanising effects of the proposed development would change the perception of the local rural landscape and its visual character, as well as cause visual harm to residential receptors. Moderate and large adverse effects would arise in landscape and visual terms. This is “significant” in EIA terms. The Secretary of State attributed significant adverse weight to this matter. |
Conditions in Schedule 3 of the Order mitigating landscape and visual effects include: - Conditions securing a Landscape and Ecology Management Plans; - Height controls, including those to foster an open sky articulated skyline concept; - Condition securing design standards for landscaping and external lighting; - Conditions managing fireworks and drone displays; and - Conditions requiring detailed approval of infrastructure, including associated landscaping. |
Loss of agricultural land
The proposed development would involve the permanent loss of at least 12ha of BMV land and a further 31ha (not surveyed) are assumed to be BMV land as a worst-case scenario, making a total of circa 43ha or about 16% of the site.
Secretary of State’s conclusion on the significant effects of the development on the environment:
The Secretary of State agreed that there would be a direct, temporary/permanent, long term residual effect of Large or Very Large (‘Major Adverse’) significance.
Overall, however, he concluded that the loss of agricultural land had limited weight against the Proposal in the overall planning balance.
Other considerations
| Main considerations and reasons Reasoned conclusion on significance of effects on the environment |
Conditions, mitigation and monitoring measures [footnote 9] |
|---|---|
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Utilities (other than water) The development would not require diesel or gas for power, other than in specific circumstances and for set timescales following Grand Opening. Utility operators have indicated their ability to meet the required needs of the proposed development through upgrade works to existing infrastructure. The detailed provision of utilities will be established at later stages of scheme design and development. Overall, the Secretary of State concluded that effects on utilities arising from the proposed development were neutral in the planning balance. |
Conditions imposed in Schedule 3 to the Order restrict the location of some utility works to the designated utility compound (Condition 42). They also restrict the use of diesel and gas for power (Condition 51). |
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Minerals and Waste The planning history of the site includes various consents for the extraction of minerals and for subsequent land restoration. Although the operational life of these consents is still in place, there is no ongoing minerals extraction at the site. It has been at least ten years since any work on restoration proposals took place. As such, these permissions do not appear to be live, and no past mineral consent currently has any effect on the proposed development submission. However, all the proposal site is identified as a Minerals Safeguarding Area (MSA) for Oxford Clay in the Minerals and Waste Local Plan. Monitoring by local planning authorities indicates that Oxford Clay is not a scarce mineral resource and, since the closure of the brickworks, the demand for Oxford Clay extraction in Marston Vale has ceased. Consequently, the Secretary of State concluded that, notwithstanding MSA policy requirements, there would be no real-world harm arising such as to justify or require extraction of clay from the site prior to construction commencing. There would be no conflict with the requirement in the Framework to protect MSAs. The development will result in waste from the construction of the ERC and its operation, but detailed calculations of the volume and type of waste generated and disposal methods will only become possible as detailed design work is progressed. Overall, the Secretary of State concluded that effects on minerals and waste arising from the proposed development were neutral in the overall planning balance. |
Conditions imposed under Schedule 3 to the Order require waste management arrangements associated with construction to be dealt with in CEMPs to minimise and control waste impacts, and the management of soils during construction (Condition 12). |
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Sports Pitches The proposed sports pitches are subject to controls, meaning that they may be provided only in the Lake Zone. There was not considered to be any planning policy or other requirement to secure their provision by condition in the Order. As such, the Secretary of State did not give them material weight in the overall planning balance. |
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Security and major accident risks The proposed development would be a tourist attraction attracting millions of visitors per year. As such, the Secretary of State considered public safety and wider security matters, including potential impacts on local emergency services. The site is bounded by several roads with the potential for emergency access serving different zones. These give access to several different roads, including Broadmead Road, the A421, Manor Road and Ampthill Road for the evacuation of the site and also for access by emergency services. The Promoter engaged with national and local security agencies and the emergency services. None raised an objection to the development, but some did raise concerns about future funding needs. The Secretary of State was satisfied that the provision of suitable security and emergency related infrastructure, and unified design and control, along with coordination between relevant safety and security agencies, accords with the Framework. These are matters covered by conditions. Overall, effects on security and major accidents arising from the proposed development were found to be neutral in the planning balance. Local and Emergency Services There would be adequate on-site infrastructure and services, such as medical facilities, alongside those in the local area, such that any additional impacts from the Proposal would not have a material impact. That said, there would be some potential negative pressure on emergency services and some negative impacts from potential traffic delays and on demand. Overall, the impacts on local and emergency services carry limited weight against the Proposal. |
Conditions imposed under Schedule 3 to the Order require: - Implementation of a Security and Emergency Management Plan - Unified control over key site facilities. |
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Airport Capacity and Aviation Safety It was considered that the Proposal would not have any material effect on airport capacity. Turning to safety, the site is relatively close to several airports, including Cranfield Airport and Old Warden Aerodrome. Mitigation in relation to aviation safety would be managed by the civil aviation regime, governed by the Civil Aviation Authority (CAA). This includes that the CAA would be notified of events such as pyrotechnics/firework shows and drone shows occurring within the site boundary. Subject to mitigation, managed by another regulatory regime, the Secretary of State found that there would be no harm in relation to aviation safety. That said, although not identified by the Promoter as necessary mitigation, in the interest of aviation safety the Secretary of State considered it appropriate to impose a condition to the Order to secure a Glint and Glare Assessment with details submitted for buildings over 45m in height. |
- Condition 29 includes glare assessment requirements |
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Agent of Change The Secretary of State considered the noise / vibration assessment material provided by the Promoter and the scope for existing adjoining businesses to be subject to future nuisance claims arising from the proposals. |
The Secretary of State recognised that there are a variety of surrounding noise generating uses (including trunk road and railway lines in the vicinity) with relatively high background noise levels providing masking to other noise. Having regard to that, and the nature of the existing uses, Agent of Change principles did not justify refusal of permission or imposition of wider scheme controls. |
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Permitted Development Rights Article 1(2) of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended) (the “GPDO”) provides that the GPDO only applies to land which is subject to an SDO to the extent that is specified in the SDO. Article 1(3) of the DMPO similarly provides that where land is subject to an SDO the provisions of that Order only apply to the extent that is specified in the SDO. The Secretary of State decided that permitted development rights should continue to apply insofar as they do not relate to the development authorised by the Order itself. |
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Human rights and equality The Secretary of State considered the potential for human rights impacts arising from the proposed development, in accordance with the Human Rights Act 1998, and had regard to the factors required under the Public Sector Equality Duty (section 149 of the Equality Act 2010). He did not consider that any issues were identified that suggested planning permission should be refused. |
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The Secretary of State’s overall judgement as to weight, having considered the various competing issues in the round (both positive and negative aspects), was, in summary, as follows:
| Category | Judgement |
|---|---|
| Economy and employment | Substantial positive |
| Landscape and visual | Significant against |
| Design and appearance | Neutral |
| Transport, highway safety and capacity | Significant against |
| Rail Safety | Limited positive |
| Noise | Significant against |
| Flood risk, drainage and water resources | Neutral |
| Living conditions | Limited against |
| Local & Emergency Services | Limited against |
| Heritage | Limited against |
| Ecology and biodiversity | Neutral |
| Ground conditions, land stability and contamination | Limited positive |
| Loss of agricultural land | Limited against |
| Air quality | Limited against |
| Population and human health | Neutral |
| Utilities | Neutral |
| Minerals and waste | Neutral |
| Climate change and resilience | Neutral |
| Security and major accidents | Neutral |
There are several harms which weighed against the Proposal. These include highway capacity, heritage, landscape and visual effects, loss of BMV land, noise, air quality, effect on services and impacts upon the living conditions for some local residents. Several matters were neutral. A range of conditions and limitations was proposed to mitigate the adverse effects as far as practicable. However, even after mitigation, it is almost inevitable that some harm would result from a development of this scale and nature. These adverse impacts, taken together, attract significant weight.
On the other hand, the Proposal would deliver many benefits, including the delivery of a world class Entertainment Resort Complex to the benefit of the UK tourism industry. and to the local and national economies, on an unprecedented scale; provide a substantial number of jobs; re-use previously developed land; and remediate contaminated land. Highway and rail improvements that would enhance local transport infrastructure and, potentially, mitigate constraints on other development have also been committed to as part of the Proposal. Together, these benefits attract very substantial weight.
The Secretary of State concluded that, overall, the benefits would far outweigh the identified harms and that planning permission should be granted subject to the necessary controls set out in the Order.
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With the exception of article 1(5) which came into force on 17 December 2025. ↩
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Request for planning permission: Entertainment Resort Complex, Bedford: Environmental Impact Assessment Handling, Publicity and Consultation Arrangements (July 2025). ↩
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Taking into account examination of the ES and other environmental information. ↩
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Excluding any periods where Parliament is not sitting for a period longer than four days. ↩
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Request for planning permission: Entertainment Resort Complex, Bedford: Environmental Impact Assessment Handling, Publicity and Consultation Arrangements (July 2025). ↩
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Referred to in the Handling, Publicity and Consultation Arrangements as: those defined in regulation 2(1) of the EIA Regulations, those referred to in article 18 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 and any infrastructure manager of relevant railway land under it (Consultee Bodies). ↩
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Referred to as Additional Consultees. ↩
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Cranfield Parish Council, Lidlington Parish Council, Ridgmont Parish Council, Brogborough Parish Council, Marston Moreteyne Parish Council and Hulcote and Salford Parish Council. ↩
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This is a summary only. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13
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Chapter 19 of the ES (Document 2.19.0) summarises the Residual Likely Significant Effects (LSEs) and the cumulative effect position (Table 19-15). The Secretary of State agreed with the summary conclusions on LSEs, other than where stated in this Statement. ↩
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7 February 2025. ↩
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Submitted Report to Inform Habitats Screening Assessment (Document 6.13.0). ↩
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Table 19-2 of Chapter 18 to the ES. ↩