Policy HOU15 Land South of Wixams

Object

Representation ID: 10299

Received: 29/07/2022

Respondent: Wixams Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Wixams Parish Council wishes to make the following comments with regard to the current proposals in the Local Plan 2040 for development of the sites named as Wixams East and Wixams South.
Infrastructure:
We believe that the current infrastructure is insufficient to support additional development so close to Wixams. There has been poor infrastructure delivery to date at Wixams, with a delayed station and town centre and a lack of local GP services. Any additional development without sufficient infrastructure to support it will create additional challenges for Wixams residents. The proposal to extend Wixams goes well beyond what was originally envisaged for the development.
Traffic and Highways:
Wixams currently lacks suitable pedestrian crossings and has seen a number of accidents with children hit by cars. There are currently significant HGV movements through WIxams as a result of local depots and warehousing. Additional housing so close to the existing Wixams development will add further pressure on local traffic and potentially put pedestrians at risk. An additional 2100 dwellings is likely to add over 4000 additional vehicles, putting huge pressure on the A6 and surrounding roads
Loss of green space and environmental impact
We are concerned at the potential loss of green space along the east side of the A6 and to the south of WIxams. Currently there is a clear divide between the villages of Wixams and Wilstead. However, the proposed development looks like it will result in a major loss of green space, with a result that the two separate villages will start to merge into one, as a continuous sprawl of development, with no clear delineation between the villages.

Object

Representation ID: 10338

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

SECTION 5: COALESCENCE

The Parish Council can not reiterate how this aspect of the Local Plan as proposed allocations on multiple sides within and adjacent to Elstow are closing in, which bring increased worry over the rural village being totally engulfed. It is fundamental to safeguard the rural historic nature of Elstow that it is does not become lost into Bedford and end up as an urban suburb.

There really needs to be a distinct difference between Elstow village and Bedford (to prevent "coalescence") with the urban town, as well as between the very distinct communities of Elstow, Wilstead, Wixams, Cotton End and also Shortstown so that their historically separate identities are preserved. The potential size of major development would threaten the very heritage of a vil­lage that is described in the Domesday Book.

The existing very stretched parish of Elstow would not tolerate further development on its edges without these developing into separate, isolated, communities in themselves, or necessitating car journeys to the centre. This is a concern to the Parish Council, as well as Elstow residents who have first hand experience of some of the challenges that developing like this already have. It has taken a number of years to integrate Abbeyfields, a new area of the community in with the older part of Elstow village. Growth in the wrong parts of a rural community will be damaging for not just the short term, but also for future generations to come.
SEE ATTACHMENT

Figure 12 Key Diagram, Page 83 in the consultation sets out an overview of proposed develop­ meant for housing and employment sites. It shows a clear distribution of allocations heavily around the area south of the A421 now being defined as the South of Bedford Policy Area. However, the marking of the map again is misleading in how it represents the sites as it places Wixams and Elstow on the section of the map on the same side of the A6.
SEE ATTACHMENT

This is factually incorrect and is inaccurate.

Showing vague, poorly located blobs of roughly where allocations are is not helpful. Having spent more time looking at local policy maps relating to Elstow parish it has shown the clear is­ sue with the allocations EMP5, HOU5, HOU15, HOU16 and HOU17 in terms of coalescence. It has already been raised there is noticeable development closing in on Elstow and looking at the local maps it is really evident, please see below.

The Parish Council feel that there needs to be more done to protect the parishes otherwise it will be one large swathe of development.

Map 8 in Policy 52 Changes to the Policies Map shows the level of coalescence.
SEE ATTACHMENT

This will lead to the areas highlighted by the red arrows which are vulnerable, and them being lost along with the rural village identity of Elstow.

Object

Representation ID: 10379

Received: 29/07/2022

Respondent: Judy Jacobs

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We object to this plan to build 300 homes in the countryside between Wilstead and Wixams. The following paragraphs explain the reasoning behind these objections.
Wilstead - Key Service Centre. We object to Wilstead remaining as a Key Service Centre. Whilst being a Key Service Centre was understandable prior to the development of Wixams, as Wilstead was separate from any other village in the area, the continuing growth of the town of Wixams means that Wilstead should now be designated a Rural Service Centre. Nowhere else in the Borough are two Key Service Centres separated by the width of a road (i.e. the A6). Oakley, a similar size village to Wilstead is a Rural Service Centre as it adjoins Clapham, a Key Service Centre. Currently the distance between these two communities is greater than Wixams to Wilstead and still Oakley is a Rural Service Centre.
Descriptions of Proposed Development. It is misleading to describe this site ‘Land South of Wixams, without mentioning its position relative to Wilstead. Such designation is likely to reduce any input / response to the Local Plan from those who it is likely to affect i.e. Wilstead residents.
Local Gaps. The Local Gap between Wixams and Wilstead is very important to prevent coalescence between them and must be preserved. This gap should include the area between this proposed development and Wilstead as well as that associated with HOU16 further up the A6 towards Bedford. The provision of a Country Park in the southern section of this site is welcome but will be of little benefit to all of Wilstead if access is only by walking across the A6.
Use of Prime Agricultural Land. It was understandable that when Wixams was created on the West of the A6 as it was mainly built on Elstow Storage Depot, a wartime bomb factory and subsequently a light industry site. This meant, following decontamination, homes on the site could be provided without taking up prime agricultural land.
In contrast HOU16 would be built on a large area of prime agricultural land currently used for food production.
Access. It is not clear what additional access routes to this development are proposed. Having a single road access causes problems especially if this road is blocked by roadworks or an accident. However an additional road northwards towards the main body of Wixams would mean going across one of the Wixams Greenways. The Southern Greenway was promoted as a green edge to Wixams thus forming a softer edge between it and the surrounding countryside. Driving a road through will not generate this green edge and will cut across the designated paths for horse riding, walking and cycling.
The provision of a Country Park in the southern section of this site is welcome but will be of little benefit to all of Wilstead residents if access is only by walking across the A6, thus discriminating against all but the most nimble. Alternative access should be provided possibly by a footbridge which would appear feasible as the A6 runs through a cutting where the current footpath crosses the A6.
A similar access problem arises where another footpath from Wilstead crosses the A6 further north. As well as being enveloped by the proposed housing, this footpath also crosses the A6 on the level near the proposed roundabout giving access to this development. It is never a good idea to have a foot crossing of a major road near a roundabout as all the drivers attention is concentrated on vehicles using the roundabout. The roundabout would also cause difficulties for pedestrians as approaching traffic would be hidden by the roundabout. An alternative mechanism for crossing this road should be provided.
Coalescence. There must be some protection against the creation of ‘South Bedford’ comprising of the joining up of the villages south of the A421 with each other and the town of Wixams, currently all separate communities.
Thousands of houses are proposed in an arc to the south of Bedford whilst in contrast there seems to be little planned for the A6 and East West Rail corridors north and north east of Bedford. Previously identified proposed developments to the north of the Borough seem to have disappeared in the Local Plan 2040
Summary. The proposed development is one of a series of developments proposed for the area south of the A421. There seems to be an imbalance of development compared with that proposed for the area north of Bedford.
Development in the current gap between Wixams and Wilstead would mean houses would be only a small field apart with the gap narrowing as the field goes northwards.
This development is isolated (in terms of accessibility, (i.e. one road in) but providing another route in would mean cutting across the Greenway, a multi user path design for horse riders, walkers and cyclists.
Alternative ways of crossing the A6 should be included in any permitted development.
Wilstead shouldn’t be a Key Service Centre. It is immediately next to Wixams which is also currently a Key Service Centre. Wilstead should be designated as a Rural Service Centre. Just naming the site South of Wixams or changing the parish boundary and letting it be part of Wixams doesn’t change the proximity of Wixams to Wilstead.

Object

Representation ID: 10489

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.

Object

Representation ID: 10505

Received: 29/07/2022

Respondent: Maralyn Napier

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I write to object to the following proposed developments on the following grounds:

1. BOTH developments are in Wilstead parish NOT Wixams, a separate parish. Wilstead has been identified as having no major developments in the Local Plan 2040.=

2. Wixams continues to be being developed between the A6 and Kempston Hardwick therefore there is still areas of brown site to be developed without using green sites.

3. Currently both Wixams and Wilstead suffer from lack of services such as health and have pressure on other services such as education. Any further development should factor in these particular health care as there is no direct bus service to the most popular surgeries in Ampthill or London Road, Bedford.

4. I object strongly to this cynical and misleading proposal. It would easily be suggested that Wilstead would lose its identity as a rural village and separate parish and be incorporated into Wixams and thus an extension of a Bedford sprawl.