Policy HOU5 Abbey Field, West of Elstow

Showing comments and forms 31 to 36 of 36

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10306

Received: 29/07/2022

Respondent: Mrs Rachel Reynecke

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The proposed policy outlines that it “ recognises the importance of retaining the separate entity of Elstow” however the proposal of the additional housing and employment allocation shows that this is not the case and rejects the very sentiment that this proposal claims to want to fufil.
This new development proposed for Elstow means that it will be merged with Bedford. Elstow is an historic village with the Church, the Abbey and Moot Hall all being key features. The new housing and employment developments will swamp what is a unique, rural village and thereby change forever the character of the village. The proposals are not in keeping with the nature of this village.
The additional houses will inevitably mean more cars and therefore greater congestion. The roads in and around Elstow will not be able to cope with this. The alternative sites of Kempston Hardwick and Little Barford have better road networks to manage this problem.
There is no guarantee that this housing proposal will remain at 200 houses. Once planning permission is granted there are several opportunities for the developer to vary planning conditions, whether that be be adding more houses or moving the placement of them.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10308

Received: 29/07/2022

Respondent: Mr Terry Webster

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The proposed policy outlines that it ‘recognises the importance of retaining the separate identity of Elstow’, however the very proposal of additional housing and an employment allocation, shows that this is not the case and rejects the very sentiment that this proposed policy claims to want to fulfil.

The addition of more housing to Elstow will result in the urbanisation of a small village immersed in history. The historical importance of Elstow will be lost as the development site of housing and employment being in such proximity will mean the village of Elstow will no longer be a village but merely an extension of Bedford. The village of Elstow is steeped in history and has distinctive characteristics (the Abbey, Moot Hall etc) which will be engulfed through the addition of significant housing and a business park which is completely out of character for the village.

The sites proposed are in extremely rural and are not densely populated areas, so not only does this make the proposal out of character for the area, but the visual impact on the Abbey will be affected as well as the increase in traffic, which is already heavily congested at the traffic lights on Ampthill Road. This congestion already goes all the way back onto the Abbey fields road and will often mean that I can’t leave my estate. The addition of 200 houses is going to heavily exacerbate this and the infrastructure is simply not there to support the addition of all this housing. This will often lead to large vehicles travelling through the centre of Elstow and the small village roads are not equipped to facilitate those types of vehicles. In addition, there seems to be no consideration of the school capacity. Since moving to the area, my partner and I have witnessed 3 near collisions with children nearly being hit by cars due to the massive congestion around school pick up and drop off, incidents have been reported to Elstow primary school and the police. Adding 200 houses to this already ongoing problem (as it has been established as a local police priority to monitor the situation) will make this unmanageable.

The loss of agricultural land will be immensely significant as I understand that the site comprises of Grade 2 agriculture land, which is considered BMV and accordingly to national policy should be protected from significant, inappropriate and unsustainable development proposals, such as this one. In addition, there is an abundance of wildlife in these areas which will be disrupted and completely lost.

There is also no guarantee that this proposal will remain as only 200 houses, once planning permission is granted, there are several opportunities for the developer to vary planning conditions, whether that be adding more houses, or moving the placement of those houses, which will be completely out of keeping with the Elstow village area.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10333

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Elstow has seen change of a massive scale in recent years. There is the development of Progress Way/Hillesden and Abbeyfields estates [which quadrupled the number of residents living in Elstow], the huge Interchange Retail Park, which is expanding further with the B&Q and M&S additions, whilst the access road is nowhere near suitable. The development of the A421 bypass split the village and the construction of the BP station and hotel simply added to the police crime list. There have been a number of infill developments within the village with more in the “pipeline”, including the old school site. There is also the park and ride, the massive Health Care Logistics/Audi complex, in addition to the large retirement complex.

Apart from the re-location of the school to its current site, and increased size, in Abbeyfields, there has been no increase at all in the facilities in the parish as a result of these changes, in fact there's been a decrease following closure of the Swan pub, a middle school, and shop at Peartree View.

There has continued to be significant increases in through traffic and their speed in the village, to the disadvantage of local residents, and clearly this would increase if further development were to come to Elstow or the surrounding area.

Elstow is a rural community, which is vitally important to retain, through securing its rural feel by maintaining a large number of green spaces, such as through strategic gaps between settlements and important views into the surrounding open countryside.

Site EMP5 earmarked for ‘a modern research campus-style development, primarily for research and development with elements of manufacturing, warehousing and distribution’ in terms of local context does not sit naturally alongside a linear rural settlement.

Site HOU5 earmarked for residential use sits a substantial distance from any existing rural settlement, in fact being quite detached from the Elstow community.

Both EMP5 and HOU5 are not sensitive to the local landscape and setting which will be detailed greater below.

Current Local Planning Policy applicable to Elstow

Elstow has always been recognised as being unique in all previous framework and development strategy documents. This is even documented in the Borough Council's planning framework document, Allocation and Designation Local Plan 2013 which in Section 15 deals with the urban area boundary and local gaps. Policy AD42 specifically deals with coalescence between settlements and the importance of local gaps, aiming to prevent ‘coalescence between the urban area and nearby villages'. This 2013 Plan document has not been superseded by the adoption of the more recent Local Plan 2030 strategy framework document, so it is important to be aware of the policy as it is still relevant.

Furthermore, Policy AD42 (Local Gaps) with its supporting text clearly sets out that:
'In this respect local gaps will be protected, not only from development that would lead to a physical joining of settlements, including that which might normally be considered to be

acceptable development in the countryside, but where possible also from an increase in levels of activity which would reduce the distinction between leaving one settlement and arriving in another. This policy takes account of the principle that the essential feature of the gaps can be purely the absence of development and activity rather than necessarily its landscape quality.'

Paragraph 15.9 goes on to also explain that the policy “also takes into account that local gaps are generally narrow and limited in extent such that any development could seriously affect their openness and could be seen as contributing to visual or physical coalescence. The appropriate width of a local gap is likely to be no more than 1 mile (1600 m) in extent and may be much less.”

This is further reinforced by the reference that recognises Elstow

2.37 The settlement of Elstow can be considered in two parts (apart from the area south of the A421 which has been considered earlier in this project as a potential addition to the urban area). The northern part comprises an historic core along the High Street and around Elstow Abbey, together with later areas of housing along West End and at Bunyans Mead on the east side of the High Street. Most of the development in this area is currently within a defined settlement policy area. Open land separates this northern part from other areas of development to the west and east, however to the north it immediately abuts development within the main part of the urban area.

2.38 The southern part, between Elstow Brook and the A421 comprises development which primarily fronts Wilstead Road. This area does not currently have a defined Settlement Policy Area. Open land separates it from other areas of development to the west and east.

2.40 From this analysis, in terms of visual attachment it can be seen that the selected areas within the northern part of Elstow are distinct from the selected area south of Elstow Brook. The northern part is itself varied, with the Bunyans Mead area very similar in density, built form and type of building to the nearby built-up area, with both having a suburban feel. Conversely, the West End and High Street areas are quite different from nearby built-up areas to the north and east. The historic core of north Elstow, around Church End and the High Street retains a village- like character consisting largely of closely spaced individual dwellings in the High Street and a distinctive open character around Church End and Abbey Close. Nevertheless, this is only a small part of the current settlement and overall the northern part of Elstow can be considered to be primarily suburban in character.

2.41 The southern part of Elstow is completely different from the built-up areas to the east in terms of density, built form and type of building. It has a distinctly rural-like feel.

The extracts above show that Elstow manages in its current form to retain its rural nature. Paragraph 2.44 goes on to highlight: Looking at the land use and character of the open land in the northern part of Elstow, to the west the open land is used for agriculture between the Abbeyfields road and the A6. Between Abbeyfields road and the settlement the open land is variously rough grassland, woodland and mown grass. The character therefore changes from being distinctly rural in the west to becoming more managed and enclosed closer to the settlement.

Focusing on the policy wording, it would therefore be totally contradictory to place HOU5 in this pocket which is described as being a distinctly rural part of the village.


The AD41 Policy document goes on in Paragraph 2.47 to detail that the southern part of Elstow can be considered to be rural-like in terms of visual attachment. It would therefore be totally contradictory to place EMP5 in this area which is described as being rural and also contains ribbon like development along Wilstead Road which runs alongside the EMP5 site boundary.

During the preparation of the document previously known as Local Plan 2035, which went on to be adopted as the Local Plan 2030, at no point did it include any intended changes to the Urban Area Boundary policy AD41.

Located on Bedford Borough Council's Development Plan documents webpage is a link to the Bedford Borough Local Plan 2030 document that was adopted on 15th January 2020. On Page 189 of the document, it clearly shows that AD41 are current.
SEE ATTACHMENT

development of 34 houses at Village Farm, which is along Wilstead Road. The application was recommended for refusal by Borough Officers. This again re-enforces the supporting planning policy reasons as to why these areas are so important in terms of Elstow's character and history. Below is the extract from the 2015 report prepared by Planning Officers:

The Urban Gap was identified in the Urban Area Boundary Review as a means of preventing coalescence and to contribute to the separate character and identity of the settlement. The quality of the landscape is not considered in the designation of an Urban Gap. Whilst the Urban Area Boundary Review states that the green spaces cannot be considered countryside due to being surrounded by development, it does identify this particular area of Elstow as having a rural-like character, which is contributed to by the historic farm buildings that front onto Wilstead Road. It notes generally that the Urban Gaps in this area provide a separation between the historic core of Elstow village and the more suburban character of more recent surrounding development.
The proposal does not allow for the retention of any green corridor to the northern Urban Open Space, occupying as it does the entire space between the rear of the buildings on Wilstead Road to the west and Elstow School to the east. The proposal includes an area of open space between the southern and northern parcels, but this does not address the reasons for the Urban Open Space and Gap designations. The site assessment that was completed as part of the Allocations and Designations Local Plan acknowledged that the site would represent

development into an open space that provides a buffer against coalescence, a point backed up by the reason for the Urban Open Gap designation. In its present form the proposed development would conflict with the rural “feel” of the area. It would effectively remove the green corridor linking in to urban open space in the north as well as the gap between the suburban development of Abbeyfields and the more rural feel of Wilstead Road and it is considered that this compromises the purpose of the Urban Open Space and Urban Gap. - 83 - Heritage Issues.
Section 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 imposes a statutory duty on LPAs to have special regard to the desirability of preserving listed buildings, their settings and any features of special architectural or historic interest they may possess; and preserving or enhancing the character or appearance of a Conservation Area. Saved Local Plan Policies BE11 (setting of Conservation Areas), BE21 (setting of listed buildings) and Policy CP23 of the Core Strategy reflect those duties. Chapter 12 of the NPPF sets out the Government's national policies on the conservation of the historic environment. The site lies to the southeast of the designated Elstow Conservation Area and the Grade I listed Hillersdon Manor, also a Scheduled Monument. There are numerous listed buildings along Wilstead Road, including Acacia Cottage, Village Farm and curtilage listed barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse, all listed Grade II.
Part of the significance of these listed buildings is their historic interest. The character of the road, including both the settings and contexts of the above heritage assets, is the semi-rural nature of this ribbon development. This road distinguishes the change in character on entering and leaving Elstow Conservation Area. Therefore, the retention of the semi-rural character of this area is important both to the context of the Elstow Conservation Area and the setting of the identified listed buildings.
A development of 34 dwellings on the site would undermine the semi- rural character of this area and would thus create a much more urban setting to the identified listed buildings. The semi-rural setting of Village Farmhouse and associated traditional agricultural buildings is important to the historical development of the original farm complex and further erosion of the setting would be considered harmful to this identified significance. Two access points into the development have been proposed, in particular that adjacent to Village Farm barns has the potential to over formalise this area through the hard landscaping required. This could further undermine the semi-rural character of the settings of the identified barns and Village Farmhouse. The historical significance of the ribbon development pattern along Wilstead Road would also be further undermined by the infill of land to the rear of the properties to the east of Wilstead Road.
The Conservation Officer therefore advises that that the application would fail to preserve or enhance the setting of the identified listed buildings.

The proposed development site is located in an area of cropmarks comprising a number of ring ditches and linear features some of which have been previously investigated both as part of the bypass investigations and also the school to the east. The investigations identified remains of Late Neolithic/Early Bronze Age ring ditches, an Iron Age settlement, and settlement from the Saxon through Medieval period also. In addition to this the HER records the presence of a possible small Quaker burial ground within the site, traces of gravestones are recorded as being visible possibly as late as the 1950s in local newspaper articles.
In conclusion, the proposed built development would result in a significant incursion into the urban open space and gap which would be harmful to the character and appearance of the area. The development would also undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick

Cottage and Lynn Farmhouse. It would thus fail to meet the statutory duty under s66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to preserving the setting of listed buildings.

RECOMMENDATION: Refuse Permission for the following reasons:-
1. The proposed built development would result in a significant incursion into the urban open space and gap which would erode the visual break between the historic core of Elstow village and the more suburban character of more recent surrounding development and result in the loss of the green corridor linking in with the urban open space to the north. The development would therefore compromise the purpose of the urban open space and urban gap and be harmful to the character and appearance of the area, contrary to saved Policy BE30 (i) of the Bedford Borough Local Plan 2002; Policy CP21 (iii, vii) of the Core Strategy and Rural Issues Plan 2008; and Policy AD43 (viii, ix) of the Allocations and Designations Plan 2013.
2. The proposed development, by virtue of its scale, siting and layout would undermine the semi- rural character of the area and would thus create a much more urban setting which would be detrimental to the setting of the Grade II Listed Buildings at Acacia Cottage, Village Farmhouse and barns, 193 Wilstead Road, Merrick Cottage and Lynn Farmhouse. The development would therefore be contrary to saved policy BE21 of the Bedford Borough Local Plan 2002 and policy CP23 of the Core Strategy and Rural issues Plan 2008.

Summary

This clearly shows that the allocation of HOU5 and EMP5 are in breach of the Borough Council own planning policy, that aspects of Elstow and its immediately surrounding open countryside must be protected in order to retain its character, setting and separate identity.

Whilst the Parish Council have made their desire very clear on multiple occasions to Planning Policy Officers, to see greater protection for all local green and open space areas within Elstow that lay between the various ribbon areas of the village. It is understood that there is no intention for the Urban Area Boundary to be changed that affects Elstow parish, however, policy AD41 makes it clear what a rural community Elstow is.

Also referenced on the above diagram is Policy AD42 which also remains relevant regarding Local Gaps.

The above planning policies remain in situ, valid reasons as why development in Elstow would contravene the existing policies.

SECTION 5: COALESCENCE

The Parish Council can not reiterate how this aspect of the Local Plan as proposed allocations on multiple sides within and adjacent to Elstow are closing in, which bring increased worry over the rural village being totally engulfed. It is fundamental to safeguard the rural historic nature of Elstow that it is does not become lost into Bedford and end up as an urban suburb.

There really needs to be a distinct difference between Elstow village and Bedford (to prevent "coalescence") with the urban town, as well as between the very distinct communities of Elstow, Wilstead, Wixams, Cotton End and also Shortstown so that their historically separate identities are preserved. The potential size of major development would threaten the very heritage of a vil­lage that is described in the Domesday Book.

The existing very stretched parish of Elstow would not tolerate further development on its edges without these developing into separate, isolated, communities in themselves, or necessitating car journeys to the centre. This is a concern to the Parish Council, as well as Elstow residents who have first hand experience of some of the challenges that developing like this already have. It has taken a number of years to integrate Abbeyfields, a new area of the community in with the older part of Elstow village. Growth in the wrong parts of a rural community will be damaging for not just the short term, but also for future generations to come.
SEE ATTACHMENT

Figure 12 Key Diagram, Page 83 in the consultation sets out an overview of proposed develop­ meant for housing and employment sites. It shows a clear distribution of allocations heavily around the area south of the A421 now being defined as the South of Bedford Policy Area. However, the marking of the map again is misleading in how it represents the sites as it places Wixams and Elstow on the section of the map on the same side of the A6.
SEE ATTACHMENT

This is factually incorrect and is inaccurate.

Showing vague, poorly located blobs of roughly where allocations are is not helpful. Having spent more time looking at local policy maps relating to Elstow parish it has shown the clear is­ sue with the allocations EMP5, HOU5, HOU15, HOU16 and HOU17 in terms of coalescence. It has already been raised there is noticeable development closing in on Elstow and looking at the local maps it is really evident, please see below.

The Parish Council feel that there needs to be more done to protect the parishes otherwise it will be one large swathe of development.

Map 8 in Policy 52 Changes to the Policies Map shows the level of coalescence.
SEE ATTACHMENT

This will lead to the areas highlighted by the red arrows which are vulnerable, and them being lost along with the rural village identity of Elstow.

SECTION 6: HISTORIC BUILDINGS AND HERITAGE ASSETS

The Parish Council feel it is important to outline some vital, important local factors, which will enable the lnspector(s) to be more aware of the issues within the parish when reviewing poten tial sites. In addition to the Conservation area, historic architecture of both Moot Hall and Elstow Abbey Elstow has a rich and diverse historic environment comprising archaeological remains, historic buildings, settlements and important local landscapes.

Elstow is proud of its heritage and has a conservation area, as identified on the map below which can be found on the local authority website at the following link

https://bbcdevwebfiles.blob.core.windows.net/webfiles/Files/CA Elstow.pdf

SEE ATTACHMENT
HOU5 abuts the conservation on two sides, effectively enclosing the conservation area. Any proposed allocation on this site at HOU5 will detrimentally impact this uniquely re­ cognised designated area. Absolutely, any level of development will significantly harm and risk the historic heritage assets.

There are numerous buildings which are within the area allocated, who would have there setting impacted not just in terms of local landscape or environment but many would also become im paired with a limited sight line being available to the listed asset.

The Parish Council would like to reference Appendix A which clearly illustrates the high number of heritage assets, please see attached Appendix A Elstow_CAA_FINAL LOCAL PLAN EPC 2022. The document can also be found at:
h ttps://bcdevwebfiles.blob.core.windows.net/webfiles/Files/Elstow_CAA_FINAL.pdf

With such rich evidence of so many historically recognised assets in close proximity, but in particular with Elstow Abbey, Moot Hall being adjacent/so close to the proposed site boundary, it is reasonable that these, and their respective settings, are afforded the highest level of protection and preservation. There is also clearly evidenced on the site assessment submissions by the land agent for both HOU5 and EMP5 there are a number of significant buried archaeological as- sets and standing assets within both site boundaries. Therefore, any such allocation will result in irreplaceable damage to the asset setting.

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10340

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

SECTION 8: POLICY HOU5 ABBEY FIELD WEST OF ELSTOW, AND POLICY EMP5 LAND
AT PEAR TREE FARM, ELSTOW

General Issues applicable to both HOU5 and EMP5
The village is an established 'rat run' which is well documented, as traffic comes into the village travelling in huge volumes during peak times. The most popular route is from the A6 travelling in both directions, along Wilstead Road, onto the High Street, then West End, through to the Cow- bridge junction which even after numerous redesigns still suffers from monumental levels of congestion. There is also the Progress Way traffic flows which are significant as a popular route on the local network. The cumulative impact of both these makes highways a real issue in the local area throughout the week.

The popularity of Elstow Primary School attracts pupils from a wide area. It is located in Abbey- fields many travel to the school by car and on regular occasions cars are parked and there is total grid lock at the end of the school day. There has been a number of incidents in recent years involving pedestrians being knocked down. The school has been extended by two additional forms to create a primary school which has resulted in further pressure for parking. Elstow is rightly proud of its local environment, wildlife and heritage assets found throughout the village.

The abundant wildlife along Elstow Brook, in the meadows along Abbeyfields through to its in- famous connection to John Bunyan. The Parish Council have a range of resources evidencing this which all act as further proof that Elstow is a unique parish. To change the setting of these world renowned connections that really are at the centre of Elstow would be devastating.

As mentioned earlier within this response, Elstow sits in a very rich local landscape, any development would impact negatively, in particularly in regards of visual impact. For example any cur- rent open spaces or green areas in the parish, if development were to be sought then it would have a visual intrusion on either the John Bunyan Trail, Cardington Air Sheds or Elstow Abbey. In addition to this, there is the heritage asset of the Medbury medieval village earthworks.

Much work, effort and volunteer time has gone into improving and strengthening the visual appearance of the village. The manicured grass at the Playing Field, the award winning Abbey- fields Roundabout Group with their colourful floral displays, through to the popular tourist attraction destination of Moot Hall. Growth within a community evolves over many years, it is a concern of the Parish Council that if both these sites were allocated then they would not sit naturally in the village setting.

In recent years, Elstow has seen a significant change in the local landscape in terms of flooding and drainage. Reports of issues with watercourses within Elstow have not only become more noticeably frequent but also more wide spread, these have been reported to and followed up by the Internal Drainage Board as well as the Environment Agency. Also there needs to be consideration the different, but exceptionally characterful parts of Elstow which differ greatly. For ex- ample, the area off Wilstead Road, around South Avenue has no street lights, there is a strong sense within that community that if this were to change it would totally alter the setting.

HOU5 ABBEY FIELD WEST OF ELSTOW
SEE ATTACHMENT
Precedent
A huge concern for the Parish Council, shared by the residents are regarding the issue of precedent if there were to be any allocation of housing on this site. Once a site has been included in an accepted strategic growth document it allows a principle of development being acceptable. At this point it then relies on the local planning process as a site goes forward with a planning application. Having left the inspection process it then falls to BBC as the local planning authority to implement the planning policy set out in the Local Plan 2040, and in reality the site bound­ary for HOU5 is extensive and could clearly take a much larger development.

The landowner and their agent have been working together for multiple decades regularly presenting housing proposals in various different parts of the village. The Parish Council will continue to challenge these alongside the HOU5 allocation in order to safeguard the historic and uniqueness of Elstow.

Subsidiary planning policy Document 52 titled 'Changes to the Policies Map' Page 18 shows the HOU5 within the whole parish setting, as illustrated below with the red hatchings. The area within the marked red arrows below is the part of Elstow known as Abbey Fields, this diagram is to highlight the size of Abbeyfields and the size of the HOU5 in that the site could take a significantly higher number of dwellings which has been set out in the Call for Sites supporting docu­mentation supplied by the land owner and their agent. Again, a real concern for the Parish Council and Elstow residents.

SEE ATTACHMENT
Viability
As already mentioned above there is a worry about this site allocation not being restricted to growth of up to 200 dwellings. The Parish Council have seen on multiple occasions in recent years and over time the strategies used within the local planning system in regards to planning gain to enable more houses and therefore more profit from a site. If the precedent is lost with the allocation then there would be further concerns about whether the site is viable with up to 200 houses on. The proposed location of development being restricted to the south west corner of HOU5 means all site infrastructure will be required at the furthest point of the site, therefore costing the most to implement. For example, building a highways access, connecting utilities etc which because of the increased distance to service the south west corner will cost significant more as it is the furthest location from any existing such local infrastructure.

This then enables through the local planning process for viability to be sited as a reason as why the site can not be delivered. More houses therefore being proposed with a the threat to the local authority that they may fall behind with their strategic housing need supply being delivered. This again leaves the site vulnerable over time.

Infill
Once the site infrastructure has been put in place, it leads to opportunities for this site within the Urban Area Boundary even with the special classification of Elstow being a historic rural village, it is highly likely that the site would in the life time of the Plan grow and the density of housing within the site if it were to grow would again bring a swathe of urbanisation and the risk of El- stow being submerged into Bedford Town.

Isolation
Communities take time to grow, this is a process that evolves over time. Elstow has had first hand experience of how when development comes it can not immediately be integrated into the local village. The proximity of the pocket of houses within the site is a great concern for the Parish Council and again Elstow community as it is effectively distinctly located well away from any exiting housing settlement and the village centre. In order to do anything it will require the in- habitants to have to get in their vehicle(s) to access services or facilities, this therefore does not feel like sustainable growth which is now the understandably favoured direction for growth.

Wildlife and habitat
Loss of wildlife, habitat, the wider ecological network, and valuable landscaping (trees and hedgerows), failing to conserve and enhance the natural environment, as required by the NPPF 2021. It is important to understand that there are protected species on this site such as red kites nesting.

SECTION NINE: MITIGATION MEASURES

The purpose of this section is to outline the Parish Council’s comments, having engaged with parishioners, to understand what mitigation measures would in their opinion be needed. The Parish Council would like to reiterate that these comments are being made without prejudice in terms of Policy EMP5 and HOU5 and should not be taken that the Parish Council support the proposed employment allocation but are following feedback from residents:

POLICY HOU5 ABBEY FIELD WEST OF ELSTOW

1. Ensure that Elstow Parish Council takes an active role and is fully engaged and identified as a key stakeholder in the preparation of the Masterplan.
2. Policy amendments to include clear, robust wording within HOU5 that states ‘the number of dwellings up to’, so the size of growth within this site is restricted.
3. Traffic management must be robust and measured given the ongoing issues Elstow has with speeding, volume of traffic and the use of the village highways network as a ‘rat run’ with large volumes of congestion stationary for long periods at peak flow times. Along with particular attention to the Elstow Primary entrance located on Abbeyfields Road which has a number of regular highways safety issues well documented.
4. Strong protection, with extensive mitigation measures for the numerous heritage assets as identified within the Elstow Conservation Area Management Plan.
5. Environmental considerations include tree/hedgerow planting; creation of wildlife opportunities.
6. Sensitive lighting that recognises the position of the site being some distance from any other settlement area.
7. Community assets created and enhancements to recreational facilities, local amenities, cycle paths, safe footpaths, safe access to the site.
8. Enhancement of PROW and bridleway networks.

Given that the sites’ developments are meant to be in a landscaped setting/environment, a significant proportion of the sites should therefore be identified for meaningful landscaping and enhanced opportunities for biodiversity net gain noticeably beyond the minimum requirements

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10419

Received: 29/07/2022

Respondent: Mr Parm Singh

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

• Existing wildlife in this area will be destroyed

• The beautiful landscape where we walk down most days will be destroyed including trees. Will not benefit our health as will prevent us walking down this beautiful area.

• Elstow village will be massively effected, which is a historic rural parish and really needs to be preserved.

• No consideration for traffic flow/generation, living on Melrose drive the traffic is disaster during school hours already whereby I cannot get into my own property, people parking on double lines, on my drive way, this development will just add to the problem, which has still not been addressed despite numerous complaints to the council since 2017!

• Highway Safety - this will cause more traffic coming in and out the estate, we already have issues with speeding through the estate and been requesting for average speed cameras throughout the estate

Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10479

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.