Policy HOU10 Land at Bedford Heights, Manton Lane, Bedford

Comment

Representation ID: 9078

Received: 29/06/2022

Respondent: Mrs Cheryl Tiddeman

To summarise, in the section 2.1 of the Local Plan 2040, it states that "development will be sensitively planned to compliment the borough's natural environment" and "development will reflect each area's unique local character". I think this four-storey ‘block’ building located close to the road will be imposing and will not suite the area of its residential surroundings. Please consider a building which has two-storeys, is set further back from Brickhill Drive and has a pitched roof, and therefore will be similar to other residential buildings in the area.

Object

Representation ID: 9227

Received: 25/07/2022

Respondent: Mrs Carole Cunningham

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This development will create an additional burden on the volume of traffic on Brickhill Drive and Manton Lane, particularly at the peak commuting times. By building on what is currently a car park for Bedford Heights office workers, I am concerned that these people will park on Eagle Gardens, creating issues for access to homeowners properties. This was a frequent issue pre-pandemic, when there was a lack of car parking provision for Bedford Height employees.

I am additionally concerned about the statement about secondary school provision- there is no space for such a facility without destroying nearby green space.

Object

Representation ID: 9230

Received: 25/07/2022

Respondent: Mrs valerie kelly

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The area has already been developed over the past year, with a commercial site now fully operating with numerous heavy lorries using the main road at all times of the day. There are continuous tail backs of traffic in the morning and the evening. Permission was granted earlier in the year for the building of Rushmoor /St Andrews school, on land near the industrial estate. once this is operating traffic will again increase. Surely this area has been developed to its capacity, adding more houses, increasing traffic again will only increase problems.

Object

Representation ID: 9241

Received: 26/07/2022

Respondent: Mr Alan Smith

Legally compliant? No

Sound? No

Duty to co-operate? No

The area already has too many houses and the roads are queuing daily, despite new road impovments this year. The expansion of manton lane use has and does cause gridlock for the traffic, any additional will only add to this

The current car park at times is full and then users come into our roads,, eagle gardens and cause parking issues

The industrial complex and the hotel there would only be expanding in the future so i cannot see why the existing car park or even how that could be considered as future space for anything but the existing use

Object

Representation ID: 9247

Received: 26/07/2022

Respondent: Mr Oliver Richbell

Legally compliant? No

Sound? No

Duty to co-operate? No

Negative impact on surrounding areas and community orchard
Adverse impact on traffic congestion (during and after the construction phase)
The proposed site offers no tangible positives when there are already other potential sites around Bedford with greater available space that if utilised would not create the disruption, over-crowding and highways and traffic impact this plan will cause.

Comment

Representation ID: 9660

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy HOU10 is supported with reservations regarding the soundness of the policy.

The proposed development at the Land at Bedford Heights is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Verve Developments Ltd acquired the wider Bedford Heights site in 2014. Verve Developments Ltd have a long-standing objective of providing housing for those with specific housing needs as part of a longer-term legacy. A partnership has been formed with IMPAKT Housing and Support to provide a small scale development aimed at providing semi-independent housing with arm’s length support, along with some on-site communal facilities for those with housing needs.

The support for the principle of development identified by draft allocation HOU10 and supporting text at paragraph 4.64 is welcomed. Our client confirms that the area identified within the draft allocation boundary is surplus to requirements for car parking and alternative residential use in this location will not impact upon the operational requirements of the Bedford Heights site. However, our client does not support any suggestion that the area identified for allocation, or the extent of existing parking within this part of the site, should determine a capacity for development less than the 36no. units identified within its emerging proposals for development.

Draft Policy HOU10 is not positively prepared and not justified as it does not include a reference to the proposed capacity of the site (15 units) which is set out in Supporting Document 27 – Housing Trajectory. There is no recognition of different forms of developments (apartments) that could deliver a higher number of units on the site which would be a more effective and efficient form of development. Details of the 15no. unit capacity estimate are unsourced. They do not utilise the Council’s standard density multiplier of 30dph, based on the approx. 0.2ha site area, notwithstanding that our client would not agree with this assumption as it would fail to make best use of land within the urban area.

The ‘proposed use’ details within the Council’s HELAA Assessment Form (ID:7412) do recognise the suitability of flatted development in this location (30 units) and the evidence base is therefore inconsistent with details of capacity within the Housing Trajectory or Plan for Submission, albeit the HELAA fails to fully reflect the unit mix and associated capacity for emerging proposals at the site.

Two rounds of pre-application engagement have been undertaken on the proposed development of bespoke affordable housing development. Ongoing discussions and dialogue have taken place to discuss issues relating to technical comments and design aspects.

A project exhibition was hosted on the Bedford Heights site on 28th April 2022, which provided all residents with the opportunity to review the scheme and raise concerns / questions. A consultation website was also launched to allow comments to be made. Discussions have also been taking place with the Council’s Housing Team.

The proposed development of 36 affordable housing units (1-bed) is a carefully designed, sustainable development.

The Key Principles of the development set out in the draft Policy are commented on below:

i. Preparation by the applicant of a masterplan and design code to be complete prior to and submitted with any planning application and to pay particular attention to the adjacent noise sources, layout and massing of the site having regard to its elevated location;

We support the principle of supporting information to demonstrate how the design of the site has evolved and full consideration has been given to key constraints of the site. The proposed development of the site by IMPAKT Housing & Support will be fully supported through a Design and Access Statement. The size of the development site is considered to be quite small for such a specific requirement for a Masterplan and Design Code and is not justified. The planning application will be prepared in accordance with national policy and best practice on design in the absence of a Local Planning Authority design code.

ii. Access from Brickhill Drive;

We support that the proposed development should provide an access from Brickhill Drive. The proposed development utilises the existing car park access from Brickhill Drive.

iii. Provision of safe pedestrian and cycle links to adjacent networks;

We support that the site should have provision of safe pedestrian and cycle links. It is well located in a sustainable position for nearby services and facilities.

The proposed development is located on an area of existing car parking. This is lightly used with significant spare capacity in the immediate and wider surrounding Bedford Heights areas.

Covered and secure and short stay cycle parking will be provided in line with Council requirements. The quantum of car parking will reflect IMPAKT Housing & Support’s experience of developing and managing similar affordable schemes through the UK. Electric vehicle charging and DDA compliant spaces will be provided in line with Council guidance.

iv. Landscaping on and around the site to soften the interface with the adjacent car park;

We support the provision of landscaping to soften the development. This is proposed to be incorporated as part of the scheme currently being prepared.

v. Financial contributions towards secondary school provision;

This requirement appears to have been applied to most of the draft housing allocation sites within the Local Plan.

Support Document 16 – Bedford Infrastructure Delivery Plan, Section 6.2 covers Secondary Education. This looks at the demand for secondary education to 2040 and makes reference to the Bedford Borough Council (2013) Planning Obligations Supplementary Planning Document that assumes there are 21 secondary school aged children for every 100 dwellings built. Within paragraph 6.2.21 reference is made to small sites being required to make CIL or S106 payments to help fund the extension of existing schools or to fund the creation of a new school in the vicinity. There is no specific reference to the type of housing developments proposed and is therefore not justified or positively prepared.

In this case the proposal is for 36 1-bed dwellings which will generate no school age children and will therefore not generate a need in secondary education infrastructure terms. The policy is not flexibly worded to allow for consideration of a range of sizes of dwellings and the different requirements of these in terms of school age children. In accordance with the proposed saved Policy 33 of the Bedford Borough Local Plan 2030 there would be no adverse impacts to secondary education required to be mitigated through the proposed development of the site in accordance with the proposed 36, 1-bed dwellings and would therefore not meet the statutory tests set out within the CIL Regulations 2010 echoed in paragraph 57 of the NPPF (2021). The draft policy criterion is therefore not consistent with national policy.

vi. Delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change;

We support this key principle and the applicant for the development has aspirations for it to be one of the highest performing developments within Bedford in respect of sustainability, adopting a fabric first approach and extensive use of renewable technology.

vii. Early engagement with Anglian Water is required in order to identify connection to water network infrastructure

We support this principle and technical liaison will take place with the applicant’s drainage engineers to establish connections and adequate provision is made for water supply and surface and foul water disposal.

Comment

Representation ID: 9676

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets within the site boundary. Bedford Cemetery, a grade II registered park and garden lies to the south of the site but due to the intervening development, the development of the proposed site is unlikely to have an impact on the significance of the park and garden.

Object

Representation ID: 10484

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.