4.3

Object

Representation ID: 6361

Received: 10/09/2021

Respondent: Bidwells

Agent: Bidwells

Whilst Taylor Wimpey have not reviewed all of the site assessments published by the Council, the general conclusions drawn and the approach to assessing the suitability of sites for development is concerning.
The site assessment forms have not been underpinned by a detailed review of the evidence available to the Council. Taylor Wimpey’s site at Wilstead (referred to as ID819) has previously been promoted for development and a planning application has been progressed (ref:
20/01666/MAO). However, none of the technical work or statutory consultee responses to this application are referenced in the form. For example, the Heritage Team and the Ecology Team both responded to the application, but the forms state that there is ‘uncertain or insufficient information’ or that there is the potential to cause harm. Another illustration of this is Environmental Health; the site assessment form states ‘A6 road noise’, however as part of the recent application Environmental Health responded that the proposed mitigation measures included as part of the proposal were acceptable and therefore no objection was offered in relation to the application. Similarly, Taylor Wimpey’s site at Willington (referred to as ID855) has previously been promoted for development and a detailed Vision Document was submitted providing a significant amount of evidence in relation to the site opportunities and constraints. None of this background information appears to have informed the site assessment forms published online.
The site assessment forms also lack any detailed assessment. For example, in relation to Wilstead, at 9a in the assessment form the Council have stated that ‘The site is not previously developed land as defined in the NPPF’. This is a simplistic response which does not properly represent the planning history of this site. The site was previously used as a camp site associated with Briar Bank Park to the north, and the remains of an amenity block building can be seen at the centre of the site, along with the access road and associated underground drainage system. The site is not a pure green field site. Linked to this, 9b which focuses on best and most versatile agricultural land, states that ‘The classification of the site is not known or it is not clear whether is classified as grade 3a or 3b’. The site is not used as agricultural land and has not been used as such for a long time due to the historic camping use; significant work would be required to bring this site back into agricultural use. Before any site selection process is undertaken, each site should be properly reviewed by members of the policy team.
The site assessment forms do not allow for a consideration of the potential planning benefits that sites may offer. For example, in relation to Willington, it is proposed that 10ha of this site is delivered as public open space and this should be given significant weight in the decision making process.
Moving forward, the assessment of sites should be more thorough and refer to the evidence base used and referenced in submitted representations to justify decisions. Other plans have been brought down in recent years because of a lack of transparency in the assessment process which was considered to undermine the conclusions made. All sites should be assessed on a fair and equitable basis, utilising the available evidence, which does not currently appear to be the case.

Site Assessment Process
The site assessment process needs to be made robust through the use of all available evidence when considering of site suitability.

Object

Representation ID: 6628

Received: 14/09/2021

Respondent: Taylor Wimpey

Agent: Taylor Wimpey

It is noted that at this stage the proformas for each of the sites contain very limited information to allow a proper assessment and comparison of the sites. It is noted that the consultation document states at paragraph 4.3 that more information will be added when it becomes available.
It is essential that the Council commit to undertaking additional, more detailed assessment work to allow a robust assessment of the sites on a comparable basis.
This is particularly important for the new settlements where a significant amount of further work in additional to the high level assessments undertaken to date will need to be undertaken to understand their suitability for development and any mitigation that will be required if they are to form part of the strategy moving forward.
In this regard, Taylor Wimpey are keen to work closely with the Council on exploring further the exiting opportunity that is available at Denybrook and developing the evidence base to underpin its allocation in the Local Plan.

Object

Representation ID: 8751

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

4.1 The Draft Plan seeks feedback on the 430+ sites that were submitted to them during the 2020 Local Plan Consultation.

4.2 We note that the focus of these sites is on their potential for housing development. The Trust does not have any specific feedback on any of the individual sites that have been proposed for housing. However, we are proposing the identification and allocation of the Bedford Hospital sites (North and South Wings) as ‘Special Policy Areas’.

4.3 There are two key reasons why the Hospital sites should be allocated on the Policies Map in this way:

• The Hospital sites play a fundamental role in the delivery of essential and high- quality healthcare to the population of Bedford Borough and beyond. As noted in previous sections of this Representation, healthcare infrastructure is a crucial element in supporting the delivery of growth. The Trust’s clinical strategy will require the development and improvement of both sites during the forthcoming plan period, and this change should be supported by the Council’s local land use planning policies.

• The South Wing site is very likely to be impacted by the emerging EWR project, and the need to plan for change is therefore imperative. The South Wing occupies a constrained and land-locked site, with limited opportunities for physical expansion. Indeed, the land between the Hospital and St Johns Station would likely have comprised the best location for intensification and future development (and some of this area is now identified under EWR Option 1 for the relocation of Bedford St Johns Station, closer to the Hospital). The Trust needs to safeguard the ongoing and future viability of the Hospital and will also need to ensure operational continuity during any construction works. This requires foresight and careful planning, including looking at different spatial options and their land use planning implications.

4.4 We are of the view that a ‘Special Policy Area’ (SPA) policy approach would be appropriate in relation to both the North and South Wing sites. The remit and scope of this form of allocation would need to be set out in the emerging Local Plan 2040. We present our considerations, below.




‘Special Policy Area’ Allocation

4.5 In some local plans, ‘Special Policy Areas’ are designated for strategic sites where major development is proposed during the forthcoming plan period.

4.6 Barton Willmore LLP has experience of this policy approach being followed by Chelmsford City Council, in respect of their Local Plan (adopted May 2020). Chelmsford Local Plan identifies six SPAs, crucially including Broomfield Hospital under SPA1. We provide the relevant extracts from their Local Plan at Appendix 1, for your ease of reference.

2.10 We believe that a similar rationale for allocating these SPAs would apply to that set out in the Chelmsford Local Plan:

“The SPA designation enables the operational and functional requirements of these facilities or institutions to be planned in a strategic and phased manner. The SPA sites are shown on the Policies Map.

The key objectives are to:
• Enable Special Policy Areas to be planned in a strategic and phased manner
• Ensure future development reflects the operational and functional requirements of the Special Policy Areas
• Ensure future development minimises the impact of development on their surroundings, sites important for nature conservation, wildlife and heritage assets
• Strengthen access to the sites by sustainable modes of transport and minimise traffic pressures on local roads
• Achieve high quality design”

(Chelmsford Local Plan 2020, paragraphs 7.363-7.364)

4.7 A specific policy (or policies) should be included within the Bedford Local Plan 2040, setting out the Council’s support for development proposals which support the role, function and operation of the North and South Wing sites.


4.8 Supporting text should also be provided, setting out the significance of Bedford Hospital as an important medical facility and providing a brief description of the North and South Wing sites, their key characteristics and constraints in land use planning terms, and the changes envisaged during the plan period (including the emerging clinical strategy as well as the EWR project). Further details on both sites are set out in Sections 5 and 6 of this Representation Report, including site plans.

4.9 We would be keen to discuss matters further with the Council, including the wording of policies and supporting text and the detailed boundaries for site allocations.

5.0 SOUTH WING SITE

The Site

5.1 The Bedford Hospital South Wing Site is located circa 1km southwest of Bedford town centre, as shown by the Site Location Plan at Appendix 2. It lies to the south of the River Great Ouse and southwest of the Bedford St John’s Railway Station. The Hospital’s main buildings lie to the southeast of Kempston Road, southwest of Britannia Road and the northwest of the A6 Ampthill Road. These buildings provide clinical, clinical support and non-clinical support functions. To the northeast of Britannia Road, the wider Hospital site includes non-clinical support buildings and car parking areas.

5.2 The South Wing site provides a range of essential healthcare services to the population of Bedford and beyond, including an Emergency Department, operating theatres, pathology, x-ray, inpatient wards and outpatient services.

Site Development

5.3 The Trust’s current clinical strategy requires the strategic estate development of the Bedford site over the next 15 years. This has been agreed by the Executive and includes:

a. Significant infrastructure development to support the corporate and national agenda and objectives to achieving net zero carbon. In terms of the physical estate, this will require significant infrastructure developments e.g. new sub stations, an energy centre, new efficient buildings, green space.
b. Additional operating theatres to accommodate increasing demand and to replace old, sub-standard theatre accommodation.
c. Additional outpatient capacity to accommodate the demand for secondary care services. This can be divided into accommodation for outpatients, diagnostics and ambulatory care.
d. Inpatient beds for elective day care to accommodate growth in demand and for acute admissions to accommodate demand for an ageing population.

5.4 The car parking and access strategy for the site must also be progressed. The outcome of this will ultimately require a new multi-storey car park on site, on Trust owned land between Britannia Road and the Danfoss site. The Trust currently lease around 1000 car


parking spaces on the Danfoss site from Arch Co 1. This is a short-term measure. Car parking provision and cycling facilities to support access to the Trust is a priority for the Trust. This links in with the Trust’s corporate objective to drive forward Net Zero Carbon.

Considerations

5.5 The South Wing Site benefits from an accessible, edge-of-centre location close to St Johns Railway Station. The Trust is keen to work with the Council to develop an integrated sustainable transport strategy, promoting walking, cycling and public transport modes. However, there is also a need to ensure safe and adequate car parking provision for those who need to use a private vehicle (and for emergency vehicles).

5.6 The main Hospital site and its associated support buildings to the northeast of Britannia Road lie within Flood Zone 1, whilst some of the car parking land closer to the railway lie within Flood Zone 2.

5.7 The South Wing site includes the Hospital Administrative Block and Children’s Ward Grade II statutory listed building.

5.8 The East West Rail Consultation 2021 proposes changes to the railway track alignment in the vicinity of the South Wing site, with Option 1 proposing the relocation of Bedford St Johns Station closer to the Hospital. Whilst this would have the advantage of improving accessibility to the Hospital via public transport, the proposals would result in an immediate impact on existing Hospital car parking provision. Options for car parking re- provision will need to be carefully considered.

5.9 South Wing occupies a constrained and land-locked site, with limited opportunities for physical expansion. Indeed, the land between the Hospital and St Johns Station would likely have comprised the best location for intensification and future development.

Proposed Allocation

5.10 We propose that the Bedford Hospital South Wing Site is allocated on the Policies Map and with a specific policy.

5.11 We propose the following wording for your consideration:


1 Arch Co is JV between Telereal Trillium and Blackstone who have a lease from Network Rail for all of their surplus land assets, primarily under bridge arch spaces.

POLICY SPA1 – BEDFORD HOSPITAL SOUTH WING SPECIAL POLICY AREA

The Council will support health related proposals which support the role, function and operation of Bedford Hospital’s South Wing Site and surrounding area. This includes significant infrastructure development to support achieving net zero carbon; the provision of additional operating theatres; the delivery of additional outpatient capacity and inpatient beds to accommodate demand; improving access, including through public transport, pedestrian links, cycle provision and car parking. The Council will work with the Trust and other partners in developing plans for the land between Britannia Road and the railway, including under Policy 14 Area and as may be necessitated by the emerging East West Rail project.


6.0 NORTH WING SITE

The Site

6.1 The Bedford Hospital North Wing site is located circa 1km northeast of the town centre in an accessible location, as shown by the Site Location Plan at Appendix 3.

6.2 The North Wing site is a health village for Bedford. It includes Gilbert Hitchcock House, Florence Ball House, Enhanced Services Centre, Shires House, Dental Care Centre, Archer Unit, Cedars House and Fountains Court.

Site Development

6.3 In partnership with colleagues across the ICS, the Trust are a key player in leading strategic estate change to drive clinical service advancement which effectively aims to deliver primary care at scale, supporting patients to receive better quality care and ultimately improved health outcomes. There is a significant impact on social value bought about by this change programme.

6.4 The change programme alluded to above sees the transformation of primary care with GP practices brought together into primary care hubs, with clear alignment to and support from, secondary care (the Acute Trust).

6.5 The North Wing site is a health village for Bedford. Land ownership is varied and clinical service management is aligned to a multitude or organisations. The Trust owns one of the buildings on the North Wing site, Gilbert Hitchcock House, and delivers services from the Archer Unit.

6.6 In partnership with commissioners, the Trust are co-leading a strategic estate programme to enhance the delivery of primary and some secondary care from the North Wing site. An options appraisal is underway and one consideration is to extend the buildings to create additional healthcare capacity and deliver the opportunity to bring services together. This programme will see an increase in demand for healthcare services on the North Wing site.

6.7 Other projects underway on the North Wing site include the development of Shires House to create inpatient facilities for mental health services.




Considerations

6.8 The North Wing site benefits from an accessible location. The Trust is keen to work with the Council to develop an integrated sustainable transport strategy, promoting walking, cycling and public transport modes. However, there is also a need to ensure safe and adequate car parking provision for those who need to use a private vehicle (and for emergency vehicles).

6.9 The North Wing site lies within Flood Zone 1, and is therefore considered to be at a low risk from flooding.

6.10 The site lies within the Bedford Town Centre Air Quality Management Area (AQMA).

6.11 Shire House is a Grade II listed building which has also been significantly affected by fire damage. The site is not within a Conservation Area, but lies adjacent to the Bedford Conservation Area.

Proposed Allocation

6.12 We propose that the Bedford Hospital North Wing site is allocated on the Policies Map and with a specific policy.

6.13 We propose the following wording for your consideration:

POLICY SPA2 – BEDFORD HOSPITAL NORTH WING SPECIAL POLICY AREA

The Council will support health related proposals which support the role, function and operation of Bedford Hospital’s North Wing site and Bedford Health Village. This will involve a partnership approach towards a strategic estate programme to deliver enhanced healthcare provision from the site. Development will include the redevelopment of Shires House for mental health services, along with other building projects on other parts of the site.

APPENDIX 1 OF ATTACHMENT CONTAINS EXTRACT FROM CHELMSFORD LOCAL PLAN 2020

APPENDIX 2 OF ATTACHMENT CONTAINS HOSPITAL SOUTH WING SITE LOCATION PLAN

APPENDIX 3 OF ATTACHMENT CONTAINS HOSPITAL NORTH WING SITE LOCATION PLAN

Support

Representation ID: 8987

Received: 01/10/2021

Respondent: Hampton Brook (UK) Limited

Agent: Axiom Great Barford Limited

4.1 From an initial review of the potential employment sites submitted to the Local Planning Authority for consideration, the conclusions to not appear to be underpinned by a detailed evidence base or all of the available to the Council.
4.2 The site assessment forms also fail to provide any detailed assessments or conclusions on key topics. Before any site selection process is undertaken, each site should be properly assessed and a firm conclusion reached on whether key areas such as highways, heritage, noise, etc. are an insurmountable issue or not. Additionally, and importantly, the site assessment form also does not allow for a consideration of the potential benefits that sites may offer.
4.3 The assessment process for sites should be thorough and draw information from an existing evidence base held by the Council. To be sound, and justify the selection of sites, there should be a greater degree of transparency in the site assessment process. This is an important consideration as it is noted that plans in other local authorities have been found unsound in recent years due to the failure to justify decisions and properly back up why certain sites have been chosen over others.
4.4 With regard to the land at Manton Lane, the only constraint to development is the historic use of the site as a sports pitch – the development of which could trigger a Sports England objection. This is effectively a policy constraint and should not be a reason for not allocating the site which is otherwise suitable for development.
4.5 On the site proforma, there are unsubstantiated references to potential harm to unmanned heritage assets. It is unclear what these assets are and how the conclusion has been drawn and indeed whether they take into consideration the impact of building out the consented school on the heritage assets. Similarly, there are ‘uncertain’ conclusions around matters such as ecology and biodiversity. These are examples of where the Council will need to commission further evidence to fully assess sites and enable a robust consideration of alternatives.
4.6 The benefits of allocating the site should also be recognised in the assessment process, particularly the fact that the use of the site can effectively replace the employment land lost to the approval of a secondary school on the adjacent site.