Policy HOU8 Land west of Police Headquarters, Woburn Road, Kempston

Comment

Representation ID: 9674

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the grade II listed Sailors Bridge Cottages lie to the south east of the site. Any development of this site has the potential to impact upon the heritage asset and its setting.
We understand that there is no heritage impact assessment for the site. Given the proximity of the grade II cottages we recommend you prepare a brief, proportionate HIA. The recommendations of the HIA should then be used to inform the policy wording.
We welcome criteria v and vi.

Comment

Representation ID: 9717

Received: 26/07/2022

Respondent: Historic England

For some sites, there does not appear to be an HIA and yet there are heritage issues that need to be addressed.
These include sites HOU2, HOU8 and parts of HOU14.
In these cases, please prepare a proportionate HIA prior to EiP and use the recommendations to inform policy wording.

Support

Representation ID: 10119

Received: 29/07/2022

Respondent: Office of the Police and Crime Commissioner for Bedfordshire

Agent: Bidwells

I write on behalf of my client the Police and Crime Commissioner for Bedfordshire in response to the Bedford Borough Council Regulation 19 Local Plan Consultation.
My client would like to express their support for the draft plan which includes the identification of their site ‘Land adjacent to Police Headquarters, Woburn Road, Kempston’ as allocation HOU8. My client confirms that this site remains available for development and is deliverable in the short to medium to term to support the ongoing requirement for homes in the area. In this representation I will identify key matters of note in the emerging plan and will seek to highlight areas which I consider require further attention.
It is evident in both the Development Strategy and Site Selection Topic Paper and the Sustainability Appraisal that, throughout the evolution of development strategy and consideration of different development options, growth in and around the urban area was considered to be the most sustainable development typology.
It is stated in the Development Strategy and Site Selection Topic Paper that:
‘In relation to the broad components of growth, the sustainability appraisal found that the first component - within the urban area - performed best. It was likely to have a more positive effect than the other components, particularly in relation to reducing carbon dioxide emissions, promoting town centres, encouraging physical activity, providing for residents’ needs and access to community services, and reducing the need to travel and promoting sustainable modes of travel. It was likely to have fewer negative effects than any of the other components of growth, although the limited availability of land within the urban area could act as a constraint on business growth.’
This approach is in keeping with the principle of sustainable development which is at the heart of the National Planning Policy Framework (NPPF) (2021).
Specifically, paragraph 11a of the NPPF states that: ‘all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects’ (emphasis added).
Paragraph 120d of the NPPF also states that planning policies should ‘promote and support the development of under-utilised land and buildings’ and paragraph 124 supports ‘development that makes efficient use of land’ drawing attention to ‘the availability and capacity of infrastructure and services’.
My client’s site is located within the urban area of Kempston, in close proximity to a wide range of services and public transport links, and represents a sustainable site option as per the above NPPF policies. The Call for Sites process has highlighted that there are a limited number of available sites within the urban area and it is therefore essential that the Council prioritise those sites which have been put forward as being available as allocations moving forward, where they can be considered suitable for development.
Site HOU8 is currently identified as an Urban Open Space under Local Plan Policy AD43, which is a policy constraint to development. This can be amended through the review of the Local Plan and we agree with the conclusion set out in the Call for Sites Assessment which states that ‘The site is suitable for development for residential and open space uses. Whilst it is designated as an urban open space, the reasons for its designation can be retained alongside development and the delivery of publicly accessible green space will be a significant benefit to the area.’
The site is also in public ownership and paragraph 121 of the NPPF states that ‘Local planning authorities, and other plan-making bodies, should take a proactive role in identifying and helping to bring forward land that may be suitable for meeting development needs, including suitable sites on brownfield registers or held in public ownership, using the full range of powers available to them’.
My client considers that the approach to identifying suitable development land in the urban area and the prioritisation of such sites as allocations has been properly evidenced and, in accordance with the requirements of paragraph 35 of the NPPF, represents a sound approach within the Local Plan.

Object

Representation ID: 10482

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.