Policy HOU3 Land at Ampthill Road, Bedford

Object

Representation ID: 9561

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HOU3 Provision of layout should take full account from noise environment related to railway lines.

Comment

Representation ID: 9667

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets on the site or in the immediate surrounding area.
No comments

Support

Representation ID: 9919

Received: 29/07/2022

Respondent: WN Developments Ltd

Agent: Tetra Tech Planning

Tetra Tech Planning have been instructed by Glashill Ltd to make representations to the Regulation 19 consultation on the draft Local Plan 2040.
We wish to comment on the proposed allocation of Land at Ampthill Road under draft Policy HOU3. The site, which has been vacant since 2000, comprises an irregular shaped parcel of land, which extends to 7.11 hectares in size. The site was previously occupied by the Krupp Camford Works and is therefore previously developed land (PDL). The site is located approximately 1.9km south/south-west of Bedford town centre fronting onto the Ampthill Road, a principal arterial route into Bedford town centre.
The site is within Flood Zone 1 and not deemed at risk of flooding from fluvial sources, although some potential for surface water flooding has been identified on the southern sections.
There are no known protected ecological sites within or surrounding the site. Within the site there are several groups of mature trees. There is one TPO protected tree within the site area.
There are no listed buildings or other heritage assets within the site. The nearest listed building is at Bedford Hospital to the north of the site, and a further cluster to the south-east around the Moot Hall at Elstow.
For the avoidance of doubt, the site is not located within an Area of Outstanding Natural Beauty (AONB) or Site of Special Scientific Interest (SSSI). The site is not located within the Green Belt or a designated Conservation Area.
Due to the site’s location at the edge of Bedford town centre, the site is within easy reach of key services and facilities, including, but not limited to:
• Bus stops located on Ampthill Road within a 100m walking distance of the site, with the
central bus station within a 2km walk of the site;
• Bedford St John’s station within 1km walking of the site, with Bedford Rail Station within a 2km walk;
• Local retailers (Aldi, Morrisons) immediately adjacent to the site;
• Local nursery and primary schools within 400m (Southway Early Childhood Centre to the south and Cauldwell School to the north respectively); and
• Medical facilities within 800m (Bedford Hospital, Cauldwell Medical Centre).
There are no Public Rights of Way within the red line of the site. However, private access rights exist to serve the following uses:
• Network Rail – for access to the Depot; and
• Morrisons – for servicing.
The site is not located within an Air Quality Management Area (AQMA) but is within close proximity to the Bedford Town Centre AQMA north of the site.
The site has been subject to a number of planning applications and extensive pre-application engagement with the LPA has occurred over the years. The site was identified as an Opportunity Site in Policy 26 of the adopted Local Plan 2030 which stated that the site had redevelopment potential for housing. Therefore, we fully support the draft allocation of the site in the emerging Local Plan 2040 for a mixed use, residential-led development.
On 27th July 2022, a full planning application was submitted on site for the redevelopment of the site consisting of 508 dwellings (Use Class C3) to include 1, 2 & 3 bedroom apartments in a series of 7 separate buildings varying from 5 to 8 storeys, with associated surface and undercroft car parking, cycle parking, servicing and plant, 2 storey 96-bed care home building (Use Class C2), 2 storey Advance Technology Building (Use Class E), single storey Drive Thru Coffee Shop (Use Class Eb), surface car parking, on site open space, pedestrian and vehicle access, landscaping and all associated works (reference: PP-11419822).
The site is therefore suitable, available and deliverable for the development as described in the wording of the emerging allocation and provides a significant number of benefits including open space/public parks, access for teachers to the school car park and a pedestrian access for students to the school, significant landscaping, play areas, an appropriate housing mix and affordable housing. Furthermore, all of the necessary technical work has already been undertaken and pending planning permission being granted, the site is available to be built out straightaway and readily, meaningfully contribute to housing land supply. In addition to this, the
site is within single ownership.
We therefore believe that the site is a strong choice for allocation and should remain within the Local Plan 2040.
We agree with the proposed wording for Policy HOU3, save for the “provision of a mobility hub” listed in subsection vi, and suggest that this be modified to state, “provision of a development accessed by a range of means of sustainable transport options”. We therefore request to speak at the Examination in Public to discuss the exact wording for Policy HOU3.

Object

Representation ID: 10477

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.