Policy HOU9 Land at Chantry Avenue, Kempston
Bedford Borough Local Plan 2040 Plan for Submission
Representation ID: 9675
Respondent: Historic England
There are no designated heritage assets within the site boundary or nearby.
Bedford Borough Local Plan 2040 Plan for Submission
Representation ID: 9749
Respondent: Hubbell Limited
Agent: Aragon Land and Planning
Kempston has the largest concentration of employment sites is around Bedford/Kempston with 74 sites and 1052 Ha of employment land. This site will see the stock of employment land reduced by 1Ha, in other words a minimal change to the overall supply.
This is a site which has been derelict for many years and is having a considerable negative impact on the local environment. This in turn is impacting on investment and suppressing the quality and character of the local environment.
The allocation is supported in principle with some changes.
This site in terms being Previously Developed Land, within the Settlement and its most sustainable location is a priority for development having regard to NPPF and the NPG.
These sites can make a welcome and quick contribution to housing sites and will compliment the supply of housing sites provided in the local plan.(NPPF para 69-73).
4.63. This submission is supported by a Noise Assessment and a layout plan 12.008 200N which provides acoustic fencing, a flatted development on the eastern side demonstrating the key design objectives at mitigating any possible noise harm. The wording in 4.63 should be revised to support the advice in the NPG to follow the wording seeking good acoustic design guidance. All the acoustic evidence shows a good standard of amenity can be created and a further acoustic benefit is extended to the existing dwellings to the North of the allocated site. This is a planning advantage which can be weighed into the balance of the decision.
The policy outlines the key principles, and this includes a master plan and design code. This can be achieved, but the site is fairly modest and a masterplan may not be required and the applicant may seek a detailed layout rather than a masterplan.
The dwelling types can be mixed, although no details are given as to what mix is required or reasons for the request. It is therefore unclear as to what mix is required or sought
The enclosed transport assessment identifies very little off site highway improvements,
It needs to be remembered the previous vehicular actively from the employment use is likely to change in nature, but the off-site improvements are likely to be limited.
A flood risk assessment is enclosed and shows the preferred strategy.
It will be possible to support the delivery of a low carbon development; Resilience can be designed in where reasonable and where measures can be identified.
The indent on live work units should be updated to reflect the need for houses to be resilient to changing work patterns and facilitate home working.
Bedford Borough Local Plan 2040 Plan for Submission
Representation ID: 10483
Respondent: Bedfordshire Police
Agent: West Mercia OPCC
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
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.