Policy HOU1 Land at Greyfriars North, Bedford

Object

Representation ID: 9560

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HOU1 Land Use at Greyfriars Road. Pedestrian/cycle access should be used for connectivity benefits plus improved bus access.

Comment

Representation ID: 9663

Received: 26/07/2022

Respondent: Historic England

A small part of the Bedford Conservation Area lies within the site boundary, while other parts of the Conservation Area lie adjacent to the site. There are several grade II listed buildings nearby along Bromham Road. Any development of this site has the potential to impact upon these assets and their settings.
We note that a heritage appraisal has been prepared for the site. The appraisal raises some concerns about the capacity of the allocation and the likely density of any development having a negative impact on the heritage assets and their settings.
The appraisal discusses the need for careful siting, design and materials as well as the need for building heights to step down near the conservation area and heritage assets. These measures are currently not articulated in the policy. The policy should be amended to include these mitigation measures and further consideration should be given to the capacity of the site. We advise that the site capacity may need to be reduced.
We welcome the reference to heritage assets in criterion 1. However, we recommend changing the wording from ‘preserve…heritage assets’ to ‘Development should conserve or where appropriate enhance the significance of heritage assets (noting that significance may be harmed by development within the setting of an asset) including…’.

Comment

Representation ID: 9726

Received: 26/07/2022

Respondent: Historic England

The final category of sites include those sites where an HIA has been prepared but the recommendations from the HIA have not been incorporated into the policy
wording for the site.
These include sites HOU1, EMP4, HOU13, HOU14, HOU15, HOU16, HOU17, HOU18 and HOU19. We suggest including a diagram for HOU6 to illustrate the
extent of open space,
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide ‘a clear
indication of how a decision maker should react to a development proposal’.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002- 20190315Revision date: 15 03 2019 also makes it clear that, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.’
Historic England’s Advice Note on Site Allocations HEAN3 includes a section on site allocation policies at paragraphs 3.1 – 3.2. It states, ‘The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to
be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are
implemented.’
Therefore, should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
In these cases, please ensure that the policy wording is amended to include the recommendations from the HIA. It is helpful if the recommendations are also shown
on a diagram in the Plan.
Without the completion of this evidence base, some sites are not justified and so are not sound. Furthermore, without suitable amendments to policy wording, some
of the policies are not effective and so are not sound.

Object

Representation ID: 10475

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Having worked with Bedford Borough Council during the preparation of its Local Plan and Infrastructure Delivery Plan, Bedfordshire Police (BP) is very disappointed with the outcome of this in two key respects:

1. Policies HOU1 – HOU 19 do not reference the police, or indeed the emergency services, infrastructure that will be required to support the developments they propose.

2. Although BP provided the Council and its consultants (AECOM) with a detailed Infrastructure Plan detailing precisely the police infrastructure required to support new housing growth in the Borough, only its contents in relation to premises requirements have been allowed for in the Council’s Infrastructure Delivery Plan (IDP) and even then inaccurately. The Council’s IDP also erroneously states that BP will eventually be able to meet the costs of delivering the infrastructure required to the growth envisaged by the Local Plan. In fact developer funding will be required to meet the costs. This was explained and evidenced at length in the Infrastructure Plan submitted by BP.

The above outcomes contrasts starkly with the basic expectation that when people move into a new housing estate or other development, they are protected by police and other emergency services that can operate efficiently and effectively in that vicinity. This applies to all levels of service, whether they ring 999 should the worst happen, or are simply benefitting from the reassurance of day-to-day neighbourhood policing for example.

It means in turn that the delivery of police and other emergency services infrastructure needs to be planned and funded in advance of a new development scheme, in the same way as utilities, education, health, transport and other public services that are currently specified in various places in Policies HOU1 – HOU19.

The potential impact on the police and other emergency services from a new development is not simply due to an increase in population, but also the location of where that new population is arising and the impact that it will have on the present disposition of emergency services resources. Delivery of services to the new communities is also not just about responding to crimes or incidents, but also includes community assurance, delivery of crime safety advice and where necessary providing referral responses when there are expressed concerns about the safety of children, the elderly or those with special needs, for example.

The experience of BP shows that new developments quickly take on the characteristics of surrounding areas in terms of calls, incident types and crime numbers, even from the point when materials are delivered to a site. Therefore, service provision needs to be expanded accordingly, as do those of other public service providers.

This is very important as development growth, particularly new housing development, has significant and permanent implications for the emergency services once delivered. Whether it takes place on green fields, urban centres or redundant factory sites, new schemes invariably result in an increased demand for ‘blue light’ services.

Hence why planning policies (i.e. HOU1 – HOU19) have a key role to play in ensuring that the police and other emergency services can provide the same level of service to the residents/occupiers of a new development as for existing residents, without compromising frontline services. After all, it is only possible to create successful places and support new communities if they are brought forward alongside adequate services and infrastructure.

BP would also like to point out at this juncture that mitigating the impact of a given scheme on the emergency services is not a false choice between design or infrastructure measures. These in fact go together to ensure a development is safe and secure. The emergency services want to see schemes that incorporate fire safety measures, adopt Secured by Design guidance, include suitable access for response vehicles (police cars, fire engines and ambulances alike) and provide the infrastructure necessary to enable service delivery and on-going coverage for the scheme in question. Current legislation and policy do not permit ambulance services, fire and rescue services and the police to downgrade the level of their provision to a new development scheme because it incorporates fire safety and/or crime prevention design measures. Appropriate new infrastructure for the police and other emergency services is therefore always required.

This is why sustainability of a development to the police and other emergency means two things. It firstly means schemes that both passively (through design measures) and actively (through infrastructure provision) preserve community safety. If a building or place does not provide these things, there can be no quality of life for the people who will reside, work or visit there, leading ultimately to an unsustainable development.

This is not only the view of our organisations. We are sure you will agree those who purchase properties on a development, who may bring up families there, or for whom it may be a place of work, will want to know that it is a safe environment underpinned by emergency services providing effective and efficient services. It is not only in the interests of the continual well-being of the new residential and/or business community that has been created, but also to protect those in existing communities that will border the development in question. Conversely, there would be great anxiety amongst all these people, new and existing, if the emergency services network was stretched to beyond capacity.

Turning to what is meant by ‘infrastructure’ in this context, the Council’s IDP takes the view that police infrastructure is purely new buildings or works to existing buildings. However, in an police and other emergency services context (and as BP showed in the infrastructure plan it submitted to the Council), infrastructure includes


• Vehicles of varying types and functions as needed to cover the development in question e.g. deployment for emergency response, patrol or follow-up for incidents.

• Personal equipment for officers and staff e.g. workstations, radios, protective equipment, uniforms and bicycles;

• Radio cover e.g. base stations, hardware and signal strengthening equipment;

• CCTV and Automatic Number Plate Recognition (ANPR) cameras;

• Mobile IT technologies e.g. body worn cameras and smart tablet computers; and

• Firefighting equipment such as Fire Lances and thermal imaging cameras.

This may seem an unnecessarily expansive definition, but what constitutes ‘infrastructure’ in any given case is what would not be otherwise directly needed by the emergency services but for the new development.

It is a view shared by the Government. Under Schedule 11 (204N(3) of the Levelling-up and Regeneration Bill, the emergency services are classified as infrastructure and the Bill also states that this encompasses facilities and equipment.

This is why we consider that in the absence of references to planning for police and emergency services infrastructure in Policies HOU1 – 19, they are unsound in the context of paragraph 35 of the National Planning Policy Framework.