Infrastructure Delivery Plan

Comment

Representation ID: 9748

Received: 29/07/2022

Respondent: Mr Kevin Levvit

9. If the plan is designed to dissuade people from using their cars to visit shops and the town, fine – if not, nowhere in the infrastructure statements does it state that multiple recharging points [electric vehicles] or some other technology will be available to fuel the vehicles at various points around the borough – hard coded into the plan - nor was the requirement to have these specific facilities in the home documented for future developers in include in their planning applications. It is all well expecting the 30 somethings to utilize cycles, not so the increased population of pensioners in 2040 and beyond.

Object

Representation ID: 9866

Received: 29/07/2022

Respondent: CPRE Bedfordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Transport
Cycling
21. There remains a complete absence of any detailed recognition of the need for a sustainable network of safe segregated cycle routes across the Borough - e.g. North South linking the Wixams (bridging the A421) to Milton Ernest through the centre of Bedford.
22. There is also no mention of a safe segregated cycle route to Bedford Station - it is deeply
unsatisfactory that the there is still no segregated cycle route to Bedford station from any direction.
23. Cycling is the way forward at a time of Climate Change and Biodiversity Loss - it will significantly improve the health and wellbeing of residents but people do not trust lines on a highway – they do not feel safe.
24. The Council needs to take the bull by the horns, dismiss the gainsayers and move forward at pace with plans for an integrated, safe, segregated network of cycle routes across the Borough, moving the priority away from cars. Our neighbouring cities of Oxford, Cambridge and Milton Keynes are showing the way forward and BBC should move swiftly into the modern era.

Rail Travel - “A Rail Strategy for Bedford” May 2022
25. It is deeply unsatisfactory that BBC has introduced an updated Rail Strategy without any public consultation and without it being discussed and agreed at a Full Council Meeting where councillors of all political parties are in attendance, members of the general public and the media. Like the Council’s previous submission to the East West Rail consultation, secrecy seems to have been the motivation.
26. This paper is a major update of the previous Rail Strategy and in view of the considerable concern regarding the impact of East West Rail on our Borough this document should have followed an open democratic process.

Rail Travel - Proposed site of new Wixams Station reduces East West Rail route options
27. The opportunity to reconsider the route choice and to switch attention from the currently proposed northern route in Bedford to a southern route following the A421 transport corridor, is currently threatened by progress on the development of a new station at Wixams.
28. As far as we understand the location of this station has been identified with other priorities in mind and would be unable to operate as an EWR station interchange with Midland Main Line and Thameslink.
29. CPRE Bedfordshire urges EWR Co to intervene in this development and ask for the project to be paused so that alternatives could be considered which would serve the needs of EWR as well as residents of Wixams.
30. CPRE Bedfordshire strongly supports EWR in principle and would like to see the new railway being progressed and delivered, but only if these major concerns are addressed and EWR Co changes course to focus on a more environmentally alternative route.
(CPRE Bedfordshire has also made these comment to the current Wixams New Station Consultation.)

Comment

Representation ID: 10347

Received: 29/07/2022

Respondent: Barton Willmore

5.1 Paragraph 4.21 of the Submission Local Plan states:
“An Infrastructure Delivery Plan (IDP) has been prepared to support the Local Plan 2040. It identifies the infrastructure required to meet the level of growth anticipated in the borough in a sustainable manner. The document covers all types of infrastructure from transport and mobility hubs to waste water and supply, energy to schools, health to policies and fire services. The IDP identifies the infrastructure projects that will be required to meet the needs arising over the local plan period.”
5.2 The IDP has been prepared by AECOM and was published in May 2022 as part of the evidence base for the emerging Local Plan. The IDP identifies the infrastructure required to meet the level of growth anticipated in the Borough. This includes sections on both Primary and Acute Healthcare.
Primary Healthcare
5.3 Section 6.5 ‘Primary Healthcare’ makes reference to the BLMK CCG’s April 2021 publication, Our Commissioning Strategy 2021-2024 and the separate Our Primary Care Strategy.
5.4 In looking forward at planned projects, the IDP sets out the emerging model for integrated health and care hubs. Paragraph 6.5.25 identifies five planned hubs, including:
“North Bedford Primary Care Hub, Health Village site, Kimbolton Road, Bedford (pre-2026, work in progress, £7.08 cost, NHS capital available in principle).”
(We assume £7.08 million)
5.5 Paragraph 6.5.38 provides cost information for three of the identified projects, including:
“North Bedford Primary Care Hub, Kimbolton Road, Bedford: £7.0m (assume funded – NHS capital available in principle).”
5.6 Paragraphs 6.5.39-40 provide an estimate of project costs, and also set out an alterative approach to estimating costs based on the ‘NHS Healthy Urban Development Unit Model’ which is based on 199 sqm per GP and £3,130 per sqm. The findings are set out in Table 6.14 (page 169), resulting in a cost of approximately £17m for 28 full-time equivalent GPs over the period to 2040.
Acute Healthcare: Hospitals
5.7 Section 6.6 ‘Acute Healthcare: Hospitals’ includes hospitals and specialist care services, including mental health care. Paragraph 6.6.3 explains that the Trust acts as the provider of acute healthcare in Bedford Borough and the BLMK CCH commission acute healthcare from the Trust, acting together as partners within an Integrated Care System (ICS).
5.8 Paragraphs 6.6.18-22 refer to the Trust’s Clinical Strategy and wider plans for estate development over the next 15 years.
5.9 Paragraph 6.6.29 refers to cost information for three identified projects:
• “The estimated cost for the redevelopment of Shires House for inpatient mental health facilities is £60m.
• The estimated cost to deliver an additional operating theatre is approximately £6.8m.
• Electrical infrastructure upgrades will cost approximately £3.4m, although associated works represent Phase 1 of a larger infrastructure development programme.”
5.10 Paragraph 6.6.34 provides information on funding and states that
• “Funding for a new operating theatre is mostly yet to be secured, although £1m has been secured from an allocation received from the Department of Health and Social Care as part of COVID-19 recovery monies Funding for electrical infrastructure upgrades has been secured via the NHS.”
5.11 In summary, this section of the IDP concludes (paragraphs 6.6.39-40):
“Bedfordshire Hospital Trust is formulating a Clinical Strategy and a Development Control Plan for Bedford Hospital involving a variety of capital projects. These include, at the South Wing Site, additional operating theatres, additional outpatient capacity, additional inpatient beds, and a progressed car parking and access strategy. At the North Wing site, planned investments include the development of a primary care hub, a joint scheme between the CCG and BHT...
”Costs associated with the full programme of works at Bedford Hospital are not yet available. However, acute healthcare equipment, technologies and infrastructure are high cost, and the overall programme of works of Bedford Hospital is likely to cost tens of thousands of pounds.”
5.12 We would like to clarify that the latter reference should be to “hundreds of millions” rather than tens of thousands. Significant investment is required.
5.13 The Trust has been happy to engage with AECOM in their work preparing the IDP 2022. The IDP helpfully references the Trust’s emerging strategies and associated projects. We would caveat that the IDP represents a ‘snap shot’ in time, and priorities and funding opportunities/constraints will change over time.
5.14 The Trust will seek to work closely with the Council and other partners, sharing their emerging plans for the South and North Wing sites to ensure the ongoing delivery of essential healthcare to support growth and development in Bedford and the wider area during the forthcoming plan period.

Object

Representation ID: 10355

Received: 29/07/2022

Respondent: East of England Ambulance Service NHS Trust

Agent: James Lawson Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Infrastructure Delivery Plan (IDP) is considered to be unsound as an evidence base to the local plan as it is not ‘justified’ - insofar as the current approach does not reflect the most appropriate strategy taking into account the reasonable alternatives, and based on proportionate evidence.

The omission to include reference to the ambulance services and facilities provided by The East of England Ambulance Service NHS Trust (EEAST) and its funding requirements to mitigate planned growth as an essential social infrastructure provider, is unwarranted and the IDP therefore ought to be updated.

Object

Representation ID: 10467

Received: 29/07/2022

Respondent: Cambridge Meridian Academies Trust

Agent: DLP Planning Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Please see accompanying Representations Report (Chapter 2)

As part of the Summer 2021 Consultation upon Preferred Strategy Options and Draft Policies (para 1.45 and 8.35) our client objected to the failure to prepare a Draft Infrastructure Delivery Plan to inform the testing of reasonable alternatives and identification of an appropriate strategy.

The Council’s submission version Bedford Local Plan 2040 and its evidence base, including the published IDP, both fail to recognise the requirements for expansion at Lincroft Academy notwithstanding our client’s earlier submissions and that this need is acknowledged by the Borough Council’s Education department.

In relation to our client’s interests at Lincroft Academy Site ID: 832 / 839 MAT further objects to the failure to respond to the school’s clear and urgent requirement for expansion as part of determining the spatial strategy and distribution of growth through the plan-making process.

Object

Representation ID: 10513

Received: 29/07/2022

Respondent: National Highways

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Supporting Documentation - Infrastructure Development Plan & Funding
The Infrastructure Development Plan (IDP) aims to set out the infrastructure required
to accommodate this anticipated growth and how this is to be delivered. Appendix C
of the IDP lists 43 road schemes with a cost of £242.5m.
18 Transport Schemes are listed within the IDP (Table3-1), 8 are related to the SRN,
5 are related to rail, bus or active travel and 5 are solely related to the Local Road
Network (LRN).
The IDP states three of the schemes are committed and planned. 2 of these schemes
are related to Rail but one is related to the SRN which is the A428 Black Cat to Caxton
Gibbet roundabout. At this stage the EWR project is still subject to a Statutory
Development Consent Order process, so there is some uncertainty with its delivery
at this time.
Appendix C of the IDP outlines the Project Schedule for all infrastructure
requirements. The table in the appendix outlines the infrastructure category, scheme
description and the associated costs. The table also identifies the secured funding
and the funding gaps for each scheme. The figures presented exclude a number of
large schemes which serve a wide geographical area beyond Bedford Borough.
The IDP delivery strategy indicates that it is highly unlikely that the 10,400 dwellings
could come forward without key transport mitigation schemes being in place prior to
or at the very early phases of development. The key transport infrastructure is judged
to directly support the delivery of eight of the largest development sites (four housing
and four employment). These sites support a total of 10,400 dwellings and
approximately 8,300 jobs.
Page 5 of 6
There is a significant funding gap which at present equates to around 83.4% of the
total estimated project costs. National Highways has concerns that this will have a
significant impact on the delivery of the spatial strategy.
In the event that funding is constrained, National Highways would wish to see
sensitivity transport modelling tests undertaken to understand the consequences, and
to ensure a suitable package of affordable interventions which can mitigate any
impact on the operation and resilience of the SRN can be identified.
National Highways therefore would welcome the opportunity to work closely with the
Council on any required modelling, prioritisation of projects and the exploration of
specific combination of funding sources is likely to be most appropriate in each
instance.