Policy HOU12 South of Bedford area

Support

Representation ID: 9234

Received: 02/07/2022

Respondent: Bedford and Milton Keynes Waterway Trust

The B&MK Waterway Trust welcomes the emphasis that the draft Plan places on the Waterway Park as a strategic green/blue infrastructure project. In particular the Trust supports The South of Bedford Strategic policy area and the ambition to support the delivery of the Bedford and Milton Keynes Waterway Park as part of the green/blue infrastructure for the area. The Trust supports policy HOU12 especially the focus on enhancing natural capital by continuing to deliver the Forest of Marston Vale and enhancing the multifunctional green infrastructure network to provide the basis for distinctive place making.
The Trust strongly supports the proposal for a strategic place making framework to guide development across the South of Bedford policy area which will be adopted as a Supplementary Planning Document. The Trust would wish to be involved as a stakeholder in the preparation of the SPD. With regard to Figure 5, the concept plan for the South of Bedford area, the Trust considers that it flags up the opportunity to more closely realign NCN 51 along the route of the Waterway.

Object

Representation ID: 9331

Received: 28/07/2022

Respondent: Mr Eric Benton

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Insufficient justification for the"urbanisation" of this area

Comment

Representation ID: 9396

Received: 29/07/2022

Respondent: Bedfordshire Local Nature Partnership

We welcome this approach. For resulting development to truly deliver against this policy it must be genuinely environmentally led. This must be fully reinforced through the SPD. This opportunity to demonstrate how an environmentally-led policy can lead to high quality, sustainable development and must be delivered against in full. Looking forward, this should be the model for the whole of the borough (and beyond) as standard within a Local Plan.
We strongly suggest for it to be an "Arc leading new settlement" that development must deliver against all Arc Environmental Principles, including a minimum of 20% Biodiversity Net Gain.

Object

Representation ID: 9410

Received: 29/07/2022

Respondent: O&H Land

Agent: Varsity Town Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Sustainable, rail based growth is a real possibility in the area to the south west of Bedford even without the enhancements being talked about by East West Rail Co. The development strategy should continue to focus on this area but recognise the potential that already exists along the Marston Vale Line.

Comment

Representation ID: 9471

Received: 29/07/2022

Respondent: Anne Dorber

"Upgrading existing (active travel) routes to bridleway status" results in cyclists sharing the same space with pedestrians, which is less safe for walkers due to the risk of collisions, so may produce no increase of foot traffic. Unsurfaced bridleways also suffer rutting and may become difficult to negotiate by walkers in wet weather/winter.

Object

Representation ID: 9563

Received: 20/07/2022

Respondent: English Regional Transport Association

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Policy HOU12 Development will take environment-led approach approach by commitment to deliver the Forest of Marston Vale and enhancing the green infrastructure. This must include the minimum 30% tree cover which aims to become carbon-neutral by 2030 and cyclepaths off road between your various towns.
The eastern and southern expansion of Wixams will include the new station, plus bus services (see re rep Policy DS2{S})

Object

Representation ID: 9593

Received: 29/08/2022

Respondent: Urban & Civic plc

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

• U&C acknowledge and have no objection to the inclusion of allocations, focused upon the existing urban areas, where impacts and mitigation can be addressed largely within the bounds of the Borough. These allocations are therefore capable of being proven to be deliverable within the terms of the NPPF. The new settlement allocations are not, however, capable of being regarded as deliverable, having been assessed as the most sustainable option for longer term growth and allocated on the basis that they have potential to be served by East-West Rail. The Infrastructure Delivery Plan indicates that East-West Rail is


an infrastructure project which ‘is required’ over the Local Plan 2040 period, to meet the needs arising from planned growth (IDP, paragraph 7.2.1). It is not a nice to have. Yet, the new settlements are
allocated without any policy controls upon the timing or phasing of development relative to infrastructure and are not contingent upon the delivery of East-West Rail or other significant
infrastructure. Without such obligations, the Policy allows for development in advance of or even without the firm commitment of East West Rail or other significant infrastructure. Delivery without this infrastructure would make the new settlements location far less sustainable and would not be justified by the evidence base as it stands.

• Furthermore, the new settlement allocations are made without any consideration for the implications or the likely scale and location of development within close proximity, but outwith the Bedford Borough boundary. This includes, but is not confined to, additional development proposed along the A421 (for example options emerging through the South Cambridgeshire Local Plan) and in immediate proximity to Little Barford, at Tempsford. Tempsford is a highly sustainable location for substantial growth, which will be considered through early plan review in Central Bedfordshire.

Comment

Representation ID: 9633

Received: 29/07/2022

Respondent: Savills

Agent: Savills

The Crown Estate has submitted comments encouraging community and stakeholder engagement in the preparation of the SPD ‘strategic placemaking framework’ in order to expedite agreement and adoption of the document and so as not to delay delivery of sites allocated for development to the South of Bedford.

Object

Representation ID: 9643

Received: 29/07/2022

Respondent: Arnold White Estates Ltd

Agent: Arrow Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

4.1 For the reasons set out earlier in this response, AWG strongly supports the principle of
the South of Bedford Area as a focus for environmental-led and sustainable growth.
However, for the reasons set out below, AWG considers the focus of the Plan and Policy
HOU12 on the delivery of an “innovation hub” at Kempston Hardwick to be unsound.
This fails to recognise the importance of other sectors and locational advantages of the
south of Bedford area and the Kempston Hardwick site, particularly for industrial and
logistics uses. The overreliance on innovation uses also poses a threat to the delivery of
the overall employment and economic needs of the area. Furthermore, the proposed
mix of uses, density and quantum of housing is likely to lead to a shortfall in housing
across the HOU12 area. This is considered in more detail below.
4.2 AWG support the principle of Policy HOU14 and the proposed new settlement at
Kempston Hardwick. Cloud Wing set out, in detail, their comments in respect of the
Vision, and Policy HOU12 (south of Bedford Area) and these representations should be
read in conjunction with that submission.
4.3 The strategy of focusing growth on the south of Bedford area (Policy HOU12) is
supported by AWG. However, AWG find that the approach taken to allocating sites and,
in particular, the quantum of development allocated on certain sites, is not justified nor
consistent with national policy, for the following reasons.
4.4 Firstly, the Local Plan does not put dwelling numbers against allocations HOU13,
HOU15, HOU16 and HOU17. The Policy must be amended to do so that there is a clear
understanding and expectation as to the quantum of development that the Plan is
proposing in these locations.
4.5 Upon review of the Stepped Trajectory Topic Paper (April 2022), numbers have been
proposed against these sites as follows:
HOU13: 500
HOU15: 300
HOU16: 1800
HOU17: 1000
4.6 What is not evident from the evidence base or the Local Plan, is the approximate
developable areas and thus whether these are realistic densities. Upon examination of
the Policies for each site, and the Figures in the Local Plan which accompany each, the
only way to achieve all the Policy requirements, in particular the amount of open space
and green infrastructure, would necessitate very high densities on most of these sites
(c. 50/60+ dph).
4.7 There is no evidence accompanying the Local Plan which justifies this approach; the
HEDNA does not identify such a high requirement for small (1-2 bedroom homes) which
a high density would lead to, nor is there market evidence supporting housing demand
for such a high quantum of small units in these locations.
12 Pre-Submission Local Plan Consultation Response ● APL–251
4.8 This is likely to lead to future applications which either decrease the number of homes,
resulting in unmet need (in terms of overall quantum and/or mix) and possibly nondelivery
of key infrastructure. Alternatively, it may lead to non-delivery of green
infrastructure due to pressures to deliver housing numbers.
4.9 The quantum for each allocation is not based on a proportionate or robust evidence
base and are therefore not sound.
4.10 To make the Local Plan sound, additional allocations are therefore necessary to make
up this shortfall in numbers. Doing so would have the further benefit of addressing the
stepped trajectory shortcomings as set out in Section 2 of these representations.
4.11 AWG supports the principle of the allocation of the land at Kempston Hardwick for
development. However, for the reasons set out in detail in Cloud Wing’s
representations, Policy HOU14 proposes insufficient employment land on the parties’
land at Kempston Hardwick. AWG also has significant concerns over the overreliance
and inappropriate emphasis on delivery of innovation uses at the site, which do not
appear to be justified and pose risks to the delivery of economic needs and the overall
effectiveness of the Plan. The allocation should state “employment uses”, rather than
specifically identifying innovation uses.
4.12 AWG is also concerned by references in the draft Plan and its supporting evidence
which suggest that development at Kempston Hardwick and other strategic sites would
only be able to come forward post-2030 following the delivery of East-West Rail and
completion of various highway improvements, which in turn appears to be driving the
Council’s proposed approach to a stepped housing trajectory.
4.13 For the reasons set out in detail at paragraphs 6.9 to 6.69 of Cloud Wing’s
representations, a larger amount of employment land, including industrial and logistics
uses, could start to be delivered earlier than 2030. The site is already a suitable location
for employment growth. It is accessible by public transport and would be capable of
supporting early delivery of infrastructure improvements including improvements to the
surrounding highway network (i.e. the package of improvement works to Junction 13 of
the M1 and the junction of the A6 and A421 which have been developed in detail
through discussion with Highways England as part of the outline planning application for
the Bedford Business Park) and deliver sustainable transport improvements (i.e.
improvements to pedestrian and cycle accessibility and public transport).
4.14 Residential development, meanwhile, can come forward in advance of much of the
necessary infrastructure. The land at Elms Farm (considered below) is one such location
where homes can be delivered early, without the requirement for strategic
infrastructure.
4.15 On this basis, the Plan and draft Policy HOU14 risks unnecessarily delaying delivery of
housing and job growth in a sustainable, suitable location and failing to meet economic
needs in the short-term.
4.16 AWG supports the principle of mixed-use development and the allocation of the land in
HOU14 as a strategic allocation for growth in Bedford Borough. For the reasons set out
above, the quantum of employment development should be increased, and the loss of
residential development can be made up through allocating additional land which
directly adjoins the HOU14 area.
13 Pre-Submission Local Plan Consultation Response ● APL–251
4.17 In this context, AWG’s view is that it is entirely inappropriate for development at the
site to be delayed until late in the plan period and for the policy to prevent permission
being granted until such time that a Supplementary Planning Document has been
prepared by the local authority. Whilst we agree that further work would be required to
develop a robust Infrastructure Delivery Plan for the site and support the Council’s view
that development at Kempston Hardwick should be landscape-led and of high-quality
design, underpinned by an appropriate masterplan, the proposed approach has the
potential to delay and undermine delivery of development early in the plan-period. The
Policy should, therefore, be amended to allow flexibility for the landowners/ developers
to prepare their own masterplan and design code, in accordance with paragraph 129 of
the NPPF.
4.18 The detailed criteria set out in Policy HOU14, the concept plan and the infrastructure
identified in the Infrastructure Delivery Plan and Transport Strategy would also need to
be reviewed, updated, and amended, as appropriate, to reflect changes to the quantum
and mix of residential and employment development proposed in response to our
comments earlier in this response.
4.19 The next section of these representations puts forward a case as to one such location
for growth within the southern parishes, which would deliver growth in accordance with
Policy HOU12, on a site which has erroneously been discounted from the site selection
process
4.20 These remainder of these representations focus on an area of land, known as Elms
Farm, which is partly included and partly excluded from Policy HOU14.
4.21 As set out earlier in this response, Elms Farm is located in a sustainable location,
adjacent to Woburn Road, Manor Road, and the roundabouts on Fields Road. It is a
gateway location at the key entrance to the HOU14 allocation area when travelling from
the west and along the A421, and is, therefore, a prime location for a high-quality
development as part of this wider allocation.
4.22 The land at Elms Farm does not appear to have been assessed by the Council, despite its
location and the fact that part of the site is included within the HOU14 area. Whilst the
site has not previously been put forward through the Call for Sites process, it is in a
sensible and logical location for development.
4.23 Planning Practice Guidance (PPG) Housing and economic land availability assessment
paragraph 11 (reference ID: 3-011- 20140306) states:
“Plan makers should not simply rely on sites that they have been informed about but
actively identify sites through the desktop review process that may have a part to play
in meeting the development needs of an area.”
4.24 Neither the SA, nor any other evidence base document, make any reference to any such
action having taken place.
4.25 HOU14, instead, is presented with an arbitrary boundary through the middle of a field
partly within the Elms Farm premises. Instead, the boundary for HOU14 should be
extended to Manor Road and Woburn Road, as a logical and clear permanent boundary
for the allocation.
4.26 This would increase the amount of land available for residential development,
contributing to the housing shortfall identified earlier in this response. Moreover, as the
14 Pre-Submission Local Plan Consultation Response ● APL–251
Elms Farm site adjoins the roundabouts on Fields Lane and is a gateway site, it can
deliver early and also contribute to the housing trajectory, similarly responding to the
stepped trajectory point.
4.27 The land at Elms Farm, is readily available, in single ownership from a company with a
proven track record of delivery.
4.28 The Local Plan evidence base finds that this location is a logical and appropriate location
for residential development; The Site would accord with the development strategy for
BBC and would deliver housing in a sustainable location, as advocated in the NPPF.
4.29 As currently drafted, the Local Plan is unsound as it is not justified based on the
evidence base, nor is it effective given it will create an arbitrary boundary, leave an area
of land that is not practical for modern day farming, and will fail to deliver sufficient
housing to meet identified needs.
4.30 The boundaries for HOU14 should therefore be amended and the allocation must
include the land at Elms Farm to make the Local Plan sound.

Comment

Representation ID: 9683

Received: 26/07/2022

Respondent: Historic England

We welcome the Councils intention to prepare a strategic place making framework for the major growth proposed in the area to the south of Bedford. We suggest an additional bullet point in the section to read:
• Protection and enhancement of the historic environment

Comment

Representation ID: 9712

Received: 29/07/2022

Respondent: Cloud Wing UK Ltd

Agent: Avison Young

Cloud Wing strongly support the principle of the South of Bedford Area as a focus for environmental-led and sustainable growth. However, for the reasons set out in other sections of these representations Cloud Wing considers the focus of the Plan and Policy HOU12 on the delivery of an “innovation hub” at Kempston Hardwick to be unsound. This fails to recognise the importance of other sectors and locational advantages of the south of Bedford area and the Kempston Hardwick site, particularly for industrial and logistics uses. The overreliance on innovation uses also poses a threat to the delivery of the overall employment and economic needs of the area.

Comment

Representation ID: 9746

Received: 29/07/2022

Respondent: Mr Kevin Levvit

6. The land to the east of the A6 in the area noted in the plan is not, to my knowledge, WIXAMS – it is WILSHAMSTEAD.
7. Yet to see the Central Bedfordshire Council Local Plan 2040 but the already proposed development to the south of Wrest Park along the east side of the A6 would suggest there is a longer term plan to join Bedford and Luton in one long ribbon development with few green spaces in between.

Object

Representation ID: 9784

Received: 29/07/2022

Respondent: BDW Trading

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Our comments should be read within the context of our responses to the vision and objectives and Policy DS2(S) Spatial Strategy.
We consider that Policy HOU12 is not sound on the following tests under paragraph 35 of the National Planning Policy Framework (NPPF):
a) Positively prepared – the plan does not propose a strategy which contains sites within a strategy capable of delivering the area’s objectively assessed needs as a minimum.
b) Justified – the strategy in the plan is not appropriate taking into account the reasonable alternatives which is more of a focus on Bedford Town and Kempston and sites that can be well-connected to these existing urban areas.
c) Effective – the strategy is not effective due to the uncertainty over deliverability of proposed allocations.
d) Consistent with national policy – we simply consider that the plan is not capable of being considered to deliver sustainable development as required under the NPPF because of the proposed spatial strategy and the proposed site allocations.
The proposed policy is overly reliant on East-West Rail despite there being significant decisions yet to be made on this infrastructure proposal. By pushing ahead with this consultation prior to any definitive progress on East-West Rail there is danger that the spatial strategy including the approach to south of Bedford will unravel.
The locations of proposed sites do not relate well to one another in terms of accessibility and connectivity, and instead rely on higher order settlements such as Bedford, Kempston and Wixams. If the overarching strategy is based on East-West Rail connectivity, this only really relates to the sites with good accessibility to the stations, these being some of the western located sites.
We have explained in our response to the proposed vision, objectives and spatial strategy overall that we consider the tests of soundness have not been met. Land at Box End, west of Bedford is well related to the urban area of Bedford and Kempston and performs well in sustainability terms being to the south west within the broad area defined as ‘South of Bedford Area’ within Figure 5. This land is being promoted by BDW Trading Limited, which includes Barratt Developments, for sustainable and deliverable development. Masterplanning for the site includes land with potential for around 1,150 dwellings, a primary school and a community hub thereby creating a sense of community and potential for some trips to be internalised within the development.
Barratt Developments are a 5-star (the top level) home builder as awarded by the HBF customer satisfaction survey 2022 and previous years. Barratt Developments measure its socio-economic impact (more information can be provided) and recently won the RESI Awards Large Developer 2021.
As the land at Box End performs so well but is inexplicitly omitted from the proposed sites within the South of Bedford Area, there is a vulnerability in the approach which is not sound.
We have concerns regarding he deliverability of the sites within the South Bedford area. The reasoning of which is contained within the response to Policy DS2(S).
We suggest a review of the evidence base and strategy which would lead to a need for more land for housing-led development including identification of land at Box End, west of Bedford.

Object

Representation ID: 9898

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU12 South of Bedford area
5.31 We have significant reservations on how land has been allocated in the south of Bedford area where priority has been given to new settlements and extensions to less sustainable settlements, with such extensions likely to more than double the size of the existing communities. This has been chosen over extensions to more sustainable settlements for example Wootton. It is clear that HOU13 and HOU14 will rely on Wootton for services and facilities but journeys are likely to be by car. Extensions to Wootton would promote shorter journeys by alternative means such as by foot and cycle.

Comment

Representation ID: 10010

Received: 29/07/2022

Respondent: Wates Developments

Agent: Boyer

Wates supports the principle of proposed Policy HOU12. As indicated in our comments on draft Policy DS2, it is clear that the SA and other evidence base documents confirm the sustainability benefits of growth within the A421 transport corridor and provide strong support for a strategy of rail-centric development. Wates also agree that East West Rail presents a particular opportunity to create higher-density and walkable communities, which are less reliant on travel by private motor vehicle.
7.2 In this context, draft Policy HOU12 finds support in NPPF paragraph 73, which at part (a) requires the consideration of opportunities presented by existing or planned investment. Likewise, paragraph 73 part (b) requires that larger developments be of a scale that achieve the critical mass necessary sufficient to support services and employments opportunities, whilst also offering suitable connectivity to established settlements. This is indeed already occurring at Wixams, which is designated as a Key Service Centre.
7.3 Another justification for the overarching policy, as set out in the ‘South of Bedford Topic Paper’ (April 2022), is that it is necessary to provide a comprehensive approach to the ongoing renewal of Stewartby, Kempston Hardwick and Wixams. This necessitates the coordinated delivery of new infrastructure improvements to road and rail networks (as detailed previously in these representations). Such an approach aligns with the requirements of NPPF paragraphs 11(a), 20, 22 and 73 specifically, and NPPF Section 9 more broadly.
7.4 Draft Policy HOU12 also provides a coordinating framework to enable environmentally led regeneration, through the Forest of Marston Vale. This is necessary to provide an effective response to green / blue infrastructure constraints and opportunities in the area. For example, the watercourses and lakes within the Stewartby and Kempston Hardwick area (a legacy of historic brickmaking) have the latent potential to promote regeneration, address surface water flooding issues and promote strategic biodiversity enhancements. This is supported by NPPF Sections 14 and 15.
7.5 Whilst Wates supports the overarching principle of Policy HOU12, a number of points regarding the detail of the policy, as well as the supporting text and relevant evidence base document. Wates therefore objects to the policy as presently worded but considers that the policy can be made sound through appropriate modifications.

Support

Representation ID: 10037

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Paragraph 4.77 sets out the Vison for the South of Bedford Area. Policy HOU 12 sets out the policy requirements for the Area. Figure 5 defines the boundary of the Area. The Southill Estate owns land at Pear Tree Farm Elstow, which is identified as a draft allocation for a science and innovation park (Policy EMP 5) and the site falls within the South of Bedford Area. The Pear Tree Farm site is identified for a high value science and innovation park, primarily research and development with elements of manufacturing, warehousing and distribution.

In summary, the South of Bedford Area is based on an environment led approach to development, and includes green infrastructure, access by sustainable modes of transport including rail, delivery of existing and proposed new settlements, and employment. The South of Bedford Area is consistent with Paragraphs 105 and 106 of the NPPF, in terms of directing significant development to locations that are or can be made sustainable, supporting the delivery of sustainable modes of transport, and providing a mix of uses including housing, employment and green infrastructure.

The draft allocation for a science and innovation park at the Pear Tree Farm site would contribute directly towards the vision for the South of Bedford Area, including by delivering employment, support for Forest of Marston Vale, and green infrastructure.
The South of Bedford Area is supported, and no changes are required to Policy HOU 12.

Comment

Representation ID: 10079

Received: 28/07/2022

Respondent: Savills

Agent: Savills

Savills (UK) Ltd are instructed to respond on behalf of our client, The Crown Estate (TCE) to the
current consultation into the Reg.19 Submission version of the Bedford Borough Local Plan 2040.
Our clients have noted the preferred spatial strategy is to focus future growth of homes and
employment into the area to the south of but close to Bedford. They are supportive of this
sustainable approach to focus growth on the A421 transport corridor which is properly evidenced in
the Sustainability Appraisal. It is also noted that the Bedford Infrastructure Delivery Plan allows for
the Gibraltar Corner site to come forward without reliance on any prior off site infrastructure being
committed or delivered. These representations are made in relation to policies HOU12 and HOU13
accordingly.
The importance of an overarching vision for the area where significant growth and change are
proposed is recognised and the approach taken in proposing policy HOU12 is supported. We see it
as vitally important to the successful delivery of the growth and associated infrastructure that
landowners and developers are involved in the process of preparing the strategic place making
framework. It is also important that early progress is made to engage all partners in the shaping
and detail of the proposed supplementary planning document, so as to allow the process to flow
into preparation of site specific masterplans and design codes as described in subsequent policy
allocations. TCE would urge that sufficient resources are made available by the Local Planning
Authority to ensure the timely preparation of these documents so that the bringing forward of much
needed new homes is not delayed. TCE welcomes the opportunity to engage in this process in the
coming months.
In terms of policy HOU13 TCE is pleased to see that delivery of sustainable development at
Gibraltar Corner has been recognised and that an allocation is proposed. We would confirm that TCE land remains available and deliverable and we support the delivery of a sustainable mix of
uses in this location, including housing, education and strategic green and blue infrastructure
improvements. Because of the scale of the proposal and the fact that not all of the proposed
allocation is within a single ownership or control we agree with the proposed approach of the
preparation of a masterplan and design code. Given the policy objectives to match new homes with
necessary community and green infrastructure it is vital that a partnership approach be taken to the
design and agreement of a masterplan and the appropriate mechanism for sharing of the costs and
benefits of the infrastructure to be delivered.
We would expect that the masterplan process would be used to identify the extents of land required
to deliver the supporting infrastructure in consultation with landowners and the community and that
the Council does not see the indicative land use areas on their proposals plan at Figure 6 of the
Plan as being necessarily fixed at this stage but allowing for further refinement during the
masterplan process. It would be prudent to amend the wording of Policy HOU13 to allow for the
submission of a planning application before the final approval of the masterplan, as later stages of
this process could take place in parallel, allowing the earlier implementation of the development.
The Gibraltar Corner Vision Document (Annex 1) demonstrates how a sustainable new
neighbourhood can be delivered on TCE landholdings and we look forward to building on this work
alongside the adjacent landowners, the community and the Council as part of the masterplan SPD.
Further technical investigations have been ongoing in recent months and the Crown Estate
proposes that the area of the allocation be extended southwards to enable the incorporation of a
second access option off Bedford Road, as illustrated on the attached vision document. It had
previously been thought that ridge and furrow remains would preclude this access option however
further archaeological work suggests that ridge and furrow remains are not present on the area
immediately south of the allocation boundary, enabling a second access option to be incorporated.
Initial technical work also indicates the additional access would meet highway visibility and
geometry requirements. The option of a second access will provide improved sustainable travel and
connectivity opportunities.
In summary, this representation-
1 supports the strategy and evidence underpinning the allocation of the land at Gibraltar
Corner
2 encourages stakeholder engagement in the early preparation of SPD and masterplans
3 supports the early delivery of housing on the site which is not constrained by major
infrastructure requirements and seeks a minor change to policy HOU13(i) to allow a
planning application to proceed in parallel with adoption of a masterplan
4 seeks an amendment to the boundary of the allocation to allow a second vehicular
access to be provided

Comment

Representation ID: 10095

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

It is recognised by the Parish Council that development has to go somewhere in Bedford Borough but the policy of concentration of proposed development South of Bedford has to be accompanied by exhaustive investigation into, and subsequent close monitoring of, the infrastructure to support it.

At the moment the justification for development South of Bedford appears to be the future availability of Stewartby Hardwick and Wixams stations and the “easy” transport links to the A421.

However, the effect on A6 traffic has been poorly researched (e.g. it does not cover the increase in traffic likely from the Central Bedfordshire Local Plan which currently looks to be substantial in the northern part of that region) and the identified requirement for additional bus service, GPs, Primary and Secondary Schools and road improvements will require very substantial funding and, from experience at Wixams, unless very tightly monitored, will fail to meet the amounts required. This will result in compromises that will put extreme pressure on existing infrastructure which is already at capacity.

To concentrate on GP availability as one example : the GP to patient ratio is already extremely high. Wilstead Parish Council has attempted for 20 years to interest GP surgeries in the surrounding area to open new facilities in Wilstead or Wixams – without success. How it would be possible to recruit the 8 or more GPs required to support new developments in the Parish plus existing patients who can no longer be accommodated at the Ampthill surgeries due to Central Bedfordshire houses expansion is not explained.

In addition how is it planned to accommodate the extra traffic generated by the station at Wixams both in terms of existing road capacity and parking? Both are considered inadequate at present and will be made even worse by the proposed developments. Moreover, there have already been a number of children injured in the new Wixams development due to their existing issues with traffic. This remains a concern for the residents of Wilstead too, who already have a significant amount of through traffic coming from the A600 and which would likely increase with HOU17; people will most likely come through Wilstead and into Wixams for the new station as opposed to joining the A421 and the queues that already exist there at the Interchange intersection.

The new settlements proposed under different options of the draft Plan could have allowed for sufficient road infrastructure and parking from the start.

Comment

Representation ID: 10261

Received: 29/07/2022

Respondent: Central Bedfordshire Council

10. Site allocations
10.1 As noted above, CBC supports the use of urban, brownfield sites ahead of the allocation of greenfield sites. We therefore do not have any specific comments to make in relation to site allocations within the urban area of Bedford. We do, however, have comments in relation to the following proposed allocations.
Policy HOU12 - South of Bedford area
10.2 Central Bedfordshire Council objects to this proposal on the basis of our transport concerns as detailed above.
10.3 This is a significant expansion area to the south of Bedford which seeks to bring together and coordinate the delivery of various strategic sites. It is recognised that the area already contains a number of existing built areas and strategic allocations, however, the further expansion will likely have significant implications for Central Bedfordshire. Whilst it is a sensible approach to coordinate the delivery of growth in the area through this policy, we have signficant concerns about the overall impact of growth in this area on the road network, bearing in mind site allocations already committed within our own plan and therefore cannot support this proposal .These concerns are covered in detail in our review of the supporting transport modelling in sections 4 to 8 above.
10.4 It is noted that the Council proposes to prepare a Strategic Place Making Framework to guide development across the policy area which will be adopted as a Supplementary Planning Document. It is considered of paramount importance that if the proposed allocation is taken forward, Central Bedfordshire Council is engaged from the outset in the production of the Framework, to ensure that any impacts arising from the proposals on Central Bedfordshire residents, communities, serices and infrastructure, is identified and mitigation measures agreed prior to any development taking place.

Support

Representation ID: 10301

Received: 29/07/2022

Respondent: Natural England

Policy HOU12: South of Bedford area
Natural England notes that this policy will take an “environment led approach and focus on enhancing natural capital by continuing to deliver the Forest of Marston Vale and enhancing the multifunctional green infrastructure network”. We welcome this policy which seeks to create GI opportunities by linking a band of ancient woodland that is located to the west of Kempston, stretching south from Hanger Wood SSSI to Wootton Wood.
We also note that the council is preparing “a strategic place making framework to guide development across the policy area”. Natural England has provided comments on the Developing in the Forest of Marston Vale: Design Guide SPD, which can be found in our letter dated 27 July 2022 (our ref: 397525).

Object

Representation ID: 10393

Received: 29/07/2022

Respondent: FCC Environment UK Ltd

Agent: Axis PED Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HOU 12 South of Bedford Area
Figure 5 Strategic Concept Plan – South of Bedford shows FCC’s Elstow South site within the middle of the area defined as ‘South of Bedford’. It is evident that the site, if allocated, can help to deliver the strategic objectives of the Local Plan. To the north east of the site is the allocation at Pear Tree Far (EMP5) and to the west is the Kempston Hardwick New Settlement (HOU14).
The Elstow site is sustainably located as it adjoins the Urban Area Boundary at its most northern point. A Site Context Figure was prepared to support representations made in 2021. This has been updated to reflect the additional / revised allocations within this plan. Figure 1 Rev A (enclosed) shows the site in relation to the Urban Area Boundary (UAB) and Settlement Policy Area (SPA).
The UAB is approximately 60m from the north-eastern corner of the site and the southern boundary of the site clearly adjoins the SPA. The site is also located adjacent to the proposed new settlement at Kempston Hardwick. As illustrated on Figure 1, the site is located within an area which has and will continue to experience considerable economic development. Figure 1 reflects the Strategic Concept Plan at Figure 5 of the Local Plan, the Elstow site is located within the middle of the South of Bedford policy area. Whilst the site sits currently outside of the UAB and SPA it is closely connected to both areas. The proximity of the site to other industrial uses, the UAB and SPA weighs heavily in the site’s favour for allocation.

Object

Representation ID: 10438

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy HOU12 states that the Council will prepare a strategic place making framework to guide development across the policy area which will be adopted as a Supplementary Planning Document.
The six matters that Policy HOU12 intends to build upon in the SPD include:
a) Landscape, natural capital and green infrastructure;
b) Internal and external connectivity and active and low carbon travel;
c) Environmental regeneration and remediation;
d) Strategic master planning and placemaking principles;
e) Approaches to governance and stewardship of community assets; and,
f) Infrastructure delivery in accordance with the Council’s Infrastructure Delivery Plan.
National planning guidance (008 Reference ID: 61-008-20190315) states that “supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance
on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan.”
In the case of Policy HOU12, the six matters of focus for the SPD include landscape, connectivity, environmental regeneration, placemaking principles, governance and infrastructure delivery. These are all relatively broad topics that are already guided by the Borough’s general development management policies or separate strategy-making bodies in the area (e.g. Internal Drainage Board). Examples of such policies and strategies are provided below:
• Forest of Marston Vale (Policy 36S and SPD),
• Bedford to Milton Keynes Waterway Park (Policy AD27)
• Placemaking and Design Principles (Policies 28S and 29)
• Environmental Net Gain (Policy DM7)
• Green Infrastructure, Landscape Character, Landscaping in New Development (Policies 35S, 37 and 38)
• Minerals and Waste Restoration (Policy 48)
• Pollution, Disturbance and Contaminated Land (Policy 47S)
• Water Resources and Flood Risk (Policy 50S, 92)
• Resources and Climate Change (Policy DS1[S])
• Impact of transport on people, place and environment (Policy 88)
• Marston Vale Surface Water Plan (IDB)
There is potential here for the SPD to duplicate what is largely covered already in other policies or strategies governing the area but if more innovative or ambitious targets are sought, these should be presented upfront in Policy HOU12 to ensure they meet national planning policy requirements and are tested at examination stage. This is particularly important given the large number of potential development sites affected by this strategic place making framework.
The South of Bedford area covers a large area of the Borough including eight parishes. All of the site specific policies for this area require applications to be accompanied by design codes that accord with the proposed SPD. As the SPD covers such a significant area and number of sites, its preparation and adoption will likely be complex and time consuming. This could hold up several development sites, threatening not only the timely delivery of development but also a significant amount of the Borough’s housing supply and new infrastructure. To avoid this situation, we would recommend that any specific policy objectives and guidance for the South of Bedford be written into Policy HOU12 and not left to an SPD.

Object

Representation ID: 10486

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.