Policy HOU11 Land at Bedford River Valley Park

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Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9394

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

Representation Summary:

We support the policy and its objectives, for which the proposed masterplan would be essential. We recommend that the objectives place even greater emphasis on delivery of Forest of Marston Vale objectives and targets, and include an objective around enhanced Biodiversity Net Gain, given the 'flagship' nature of this site for both the Forest and the borough.

Full text:

We support the policy and its objectives, for which the proposed masterplan would be essential. We recommend that the objectives place even greater emphasis on delivery of Forest of Marston Vale objectives and targets, and include an objective around enhanced Biodiversity Net Gain, given the 'flagship' nature of this site for both the Forest and the borough.


Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9494

Received: 29/07/2022

Respondent: Woods Hardwick Planning Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

See full representations as these cannot be summarised in 100 words.

Full text:

The Bedford River Valley Park (BRVP) Landowners comprised of, Bedford Borough Council Estates, Connolly Foundation, Forest of Marston Vale, Peter Bennie Ltd, Southill Estate and Tarmac Trading Ltd (“The BRVP Landowners”) strongly support the principle of Policy HOU11 Land at Bedford River Valley Park as a fundamentally sound part of the spatial strategy of the BBLP 2040. The delivery of the enabling development and the water sports lake it would facilitate is highly important to the soundness of the Plan and its vision for the Borough. It is positive to see confirmation of the Council’s commitment to delivering this project at paragraph 4.73 of the BBLP 2040.

Whilst wholly supportive of the principle of this policy, the BRVP Landowners do have some focused objections on certain aspects of it. These are explained in detail below, along with suggested amendments to the policy wording to overcome them, including introducing clarity on the broad number of homes to be delivered as part of the enabling development and deleting or amending certain requirements of the policy.

The suggested modifications do not fundamentally alter the thrust of Policy HOU11, but will ensure that it is positively prepared, justified, effective and consistent with national policy. They should be read in this context.

The principle of enabling development at the site to facilitate delivery of the water sports lake permitted through application BC/CM/2003/33 is well established through the existing allocation for mixed-use development under Policy AD23 of the Allocations and Designations Plan (ADLP) 2013.

The BRVP Landowners put forward the clear case for residential-led mixed-use development as part of a new policy to replace AD23, which also picks up other changes in circumstance since it was adopted as part of the ADLP, in their submissions made in response to the Issues and Options consultation on the BBLP 2040 and the Call for Sites. These submissions included a “Vision” for the enabling development and water sports lake, articulating the approach to delivering a sustainable new residential development with associated facilities, such as a local centre and a school, in an attractive parkland environment and alongside the new water sports lake it would facilitate.

Representations were also made at the Regulation 18 stage in the BBLP 2040’s preparation. These submissions on the Regulation 19 BBLP 2040 should be read alongside all of the previous representations made by the BRVP Landowners.
Support for the Principle of Development.

The BRVP Landowners are entirely supportive of the principle of the allocation of residential-led mixed-use development at the site to include, housing, education, open space and recreational uses, including the water sports lake and strategic green infrastructure. This represents an excellent opportunity to provide sustainable new homes alongside exceptional leisure and amenity enhancements as part of an attractive new parkland.

The location has already been determined to be a sustainable one for new development by both the Council and the Inspector who examined the ADLP, demonstrated through the existing allocation (AD23). Pedestrian and cycle connections to existing Rights of Way and the SUSTRANS network are possible, providing sustainable links to Bedford. It is also close to the A421, a key east – west transport corridor through the Borough.

The identification of growth at BRVP is also supported by the conclusions of Sustainability Appraisal, which assessed that there would be ‘mostly positive effects’.

The enabling residential-led mixed-use development would facilitate the creation of the water sports lake as part of wider multi-functioning green and blue infrastructure in the BRVP, providing a significant benefit to local residents and at a regional level. This benefit is acknowledged and was accepted when enabling development was first allocated in the ADLP.

This allocation would make a significant contribution to the achieving the BBLP 2040’s vision for the Borough and to the 4 ‘Themes’ set out under it. Specifically, as already noted, it would enable delivery of a water sports lake within the wider BRVP, securing new multi-functional green and blue infrastructure in line with Theme 1. It would also deliver a strategic leisure facility in a location adjacent to the urban area contributing to Theme 2 by allowing for easier access.

The BRVP Enabling Development proposal would incorporate a new primary school in line with Theme 3. It also provides an excellent opportunity to create a beautiful new place alongside the water sports lake, in an attractive river valley landscape and environment, in accordance with Theme 4.


The BRVP Landowners control all of the land required to deliver the enabling development and the water sports lake. They have all signed a Delivery Statement, which has been submitted to the Council, together with an updated Viability Appraisal, demonstrating the deliverability of the overall scheme.

Whilst the BRVP Landowners are seeking some modifications to the draft Policy (HOU11), the overarching aspiration for the BRVP is wholly supported and achievable.

Focused Objections

Absence of a Housing Target

At present the wording of Policy HOU11 provides no indication of the anticipated amount of housing to be delivered as part of this scheme. This is also not provided by Policy DS5(S), which identifies an overall target of 1,500 dwellings to be achieved in the strategic sites adjacent to the urban area, of which BVRP is one, but does not clarify the quantum anticipated from each site.
As noted in the focused objection to Policy DS5(S), this approach is considered too high level and provides insufficient certainty over what is expected from the development of this allocation site. The BRVP Landowners consider that the target from the proposed enabling development should be approximately 1,000 dwellings to reflect the work undertaken by the BRVP Landowners on site capacity having regard to constraints and appropriate densities across the allocation area, this includes the land use budget and density plans shared with the Council. That also ties in with the estimated capacity in Table 9 of the Development Strategy Topic Paper (May 2022).

To aid clarity and for effectiveness, this target should be included in the wording of Policy HOU11. It can be expressed as an approximate or indicative capacity in order to provide sufficient flexibility to respond to the detailed master planning of the site which may identify the opportunity for a slightly different quantum. However, inclusion of an indicative anticipated housing figure in the policy would provide the necessary certainty to the BRVP Landowners, future developers of the scheme. local residents and stakeholders.

Requirement for a Masterplan and Design Code SPD

As currently drafted the wording of Policy HOU11 (Criterion i.) requires the preparation of a masterplan and design code by the Council, to be prepared in conjunction with the BRVP Landowners, developers, stakeholders and local community, and these will need to be adopted as a SPD.

The BRVP Landowners are supportive of the requirement for development of the site to be comprehensively master planned with an associated design code. This is especially important if it is phased and constructed by different developers and will ensure a high quality development comes forward that responds to the unique setting and opportunities at the site, whilst also taking account of sites constraints.

On the latter point, the BRVP Landowners have already undertaken considerable technical work, both in respect of the water sports lake, which has the benefit of a lawfully commenced detailed planning permission, and also in the area identified for the enabling development. That has informed the initial master planning work carried out to date, including the land use budget and density plans that have been shared with BBC.

Whilst the Council’s aspiration for a masterplan and design code to be prepared as a SPD is understood, the BRVP Landowners are of the view that this is not required for two key and interrelated reasons.

Firstly, it is not considered necessary for the masterplan and design code to be incorporated in an SPD that is then adopted by the Council. The same level of information, i.e. a detailed masterplan and design code, could be provided with, and approved as part of, a future planning application for the site. The BRVP Landowners have no issue with these being prepared in collaboration with the Council and a suitable level of community engagement taking place as part of that preparatory process. Requiring the masterplan and design code as part of the application material in this way would save considerable time by avoiding an unnecessary separate layer of document approval with associated formal process.

Previous experience of masterplan SPDs is that their preparation, consultation and adopted processes are a timely exercise. Securing early delivery from this site is particularly important when the Council is proposing a stepped trajectory (Policy DS3(S)) and is therefore unlikely to meet its local housing need calculated using the standard method in the early years of the Plan, as the site could make an important contribution to the overall housing need of the Borough. It is also important in respect of facilitating the delivery of the water sports lake and associated green infrastructure at the earliest opportunity.

An additional and related point is that the BRVP Landowners and their future developer delivery partners would, in any case, be better placed to lead on preparation of the masterplan, in full collaboration with Council, given the extent of knowledge already held on the site and the aforementioned work undertaken to date on constraints and opportunities. Any planning application prepared for the site would need to be accompanied by a masterplan anyway and the requirement for a separate masterplan as part of an SPD would double up on this. It is also commonplace for design codes to be submitted with planning applications, setting the design parameters future development must adhere to.

As such, the BRVP Landowners object to the current wording of criteria i. of Policy HOU11 and suggest that it is amended so that it requires a masterplan and design code to be included with any future planning application for the site and not that these need to be included in an SPD that is then adopted prior to submission of the application, which would unnecessarily delay delivery of the benefits from the scheme. If it is considered absolutely necessary for an SPD to be prepared, then the policy should be amended to state that this will be led by the landowners and their future developer partners in consultation with the Council, stakeholders and local residents.

Trigger for delivery of the water sports lake

Criterion ix. of Policy HOU11 requires delivery of the water sports lake before the completion of the 500th dwelling at the site.
The BRVP Landowners have a focused objection to this element of the Policy on the basis that a rigid trigger for delivery of the water sports lake imposed at this stage in the overall scheme could have the counter-effect of making the enabling works unviable. It is also unclear what basis the Council has determined the 500 dwellings trigger.

The Landowners are fully committed to delivery of the water sports lake, as outlined in the signed Delivery Statement submitted to the Council earlier this year. A Viability Appraisal accompanied the Delivery Statement and demonstrated the scheme to be viable, and the enabling development able to support delivery of the water sports lake.

That work reflects a point in time. The inputs into a Viability Appraisal can change as costs and revenues change over time, which illustrates the risk of imposing a fixed trigger too early in the process. It is therefore suggested that criterion ix is amended to require an updated Viability Appraisal be undertaken at the time the application is submitted with the benefit of the further technical work that will have been carried out at that stage, so that a trigger for delivery of the water sports lake can be agreed and included in the S106 Agreement. Without such an amendment the BRVP Landowners consider that this element of Policy is HOU11 is unsound as it is no effective.

The retention and appropriate reuse of Octagon Farmhouse and its outbuildings

Criterion xii of the Policy HOU11 requires the retention and appropriate reuse of Octagon Farmhouse and its outbuildings as part of the overall development.

Upon further interrogation of title information, it is apparent that Octagon Farmhouse and its outbuildings lie outside of the Bedford Borough Estates landownership and are not within the ownership or control of the BRVP Landowners. Consequently, they have no control over the future use of these buildings or ability to include them within the scheme. As such, this criterion will need to be deleted from Policy HOU11 if it is to be considered effective, as it is not deliverable.


Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9566

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

Willington Rowing Lake – Will sever both East-West trackbed and Sustrans cycleway, and also flood-plains.


Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9682

Received: 26/07/2022

Respondent: Historic England

Representation Summary:

The grade II listed Octogan Farmhouse lies within the site boundary. There are multiple other listed buildings in the surrounding area including the highly graded Stables and Dovecote (both listed at grade I and also scheduled) as many grade II listed buildings. There are also numerous scheduled monuments (the Stables and Dovecote as well as a number of barrows, mortuary complex and settlement site) along the river valley. Any development of this site has the potential to impact upon these heritage assets and their settings.
This is a large strategic proposal for between 700 and 850 dwellings and other mixed uses.
A heritage assessment has been prepared for this site. Recommendations include the retention and appropriate reuse of the Octagon Farmhouse, buffer to scheduled monument, and careful masterplanning for preservation and enhancement of other assets. These recommendations have been included in the policy which is welcomed.
We broadly welcome criteria xi, xii, xiii and xiv. The policy seems well defined and the policy criteria seem appropriate. However, we suggest that other scheduled monuments are added to the list at criterion xi.


Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10485

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.