Policy HOU16 Land at East Wixams

Comment

Representation ID: 9687

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of listed buildings nearby at Duck End and Wilstead. These include All Saints Church, listed at grade II* and a variety of grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
A Heritage Impact Assessment has been prepared for the site which focuses on built heritage. This provides a useful analysis. The HIA makes a number of helpful recommendations. These include:
• Retention and incorporation of existing historic landscape features
• Careful consideration of layout scale and massing to reduce impact on heritage assets
• Landscape buffer and set back around John Bunyan Trail
• Create viewing corridors to grade II*Cardington Hangers as prominent landmark on the skyline
• Lower density and scale of development around Duck End to sustain the existing character of the lane
• Incorporate elements of the local vernacular to retain the local distinctiveness of the area
We recommend that these measures should be included in the policy wording.
Whilst we broadly welcome criterion xii it should be expanded to include the specific mitigation recommended in the HIA.
We welcome criterion xiii.

Comment

Representation ID: 9731

Received: 26/07/2022

Respondent: Historic England

The final category of sites include those sites where an HIA has been prepared but the recommendations from the HIA have not been incorporated into the policy
wording for the site.
These include sites HOU1, EMP4, HOU13, HOU14, HOU15, HOU16, HOU17, HOU18 and HOU19. We suggest including a diagram for HOU6 to illustrate the
extent of open space,
It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide ‘a clear
indication of how a decision maker should react to a development proposal’.
Planning Practice Guidance Paragraph: 002 Reference ID: 61-002- 20190315Revision date: 15 03 2019 also makes it clear that, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development.’
Historic England’s Advice Note on Site Allocations HEAN3 includes a section on site allocation policies at paragraphs 3.1 – 3.2. It states, ‘The level of detail required in a site allocation policy will depend on aspects such as the nature of the development proposed and the size and complexity of the site. However, it ought to
be detailed enough to provide information on what is expected, where it will happen on the site and when development will come forward including phasing. Mitigation and enhancement measures identified as part of the site selection process and evidence gathering are best set out within the policy to ensure that these are
implemented.’
Therefore, should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
In these cases, please ensure that the policy wording is amended to include the recommendations from the HIA. It is helpful if the recommendations are also shown
on a diagram in the Plan.
Without the completion of this evidence base, some sites are not justified and so are not sound. Furthermore, without suitable amendments to policy wording, some
of the policies are not effective and so are not sound.

Comment

Representation ID: 9737

Received: 29/07/2022

Respondent: Daren Maskell

Agent: Robinson & Hall LLP

1.0 Policy HOU16 Land at East Wixams

1.1 Policy HOU16 criterion (i) requires preparation of a masterplan and design code to be completed prior to and submitted with any planning application and to accord with the South of Bedford strategic framework. This framework will be detailed further in an SPD and as there is no indication as to when this SPD will be adopted there is a real risk that development in the South of Bedford area will be delayed.

1.2 Site-specific design codes could take several months to develop and if there is a delay in the South of Bedford SPD this could push back submission of applications and housing delivery substantially. We therefore suggest that the policy is more flexible and allows design codes to come forward either as part of an outline application or prior to the submission of the first reserved matters application, as is experienced in other local authority areas.

1.3 With respect to HOU16(i), we acknowledge the merits of consultation with the Meteorological Office to ensure the proposals minimise or mitigate any adverse effects on relevant sensitive receptors. The Met Office in this case is a non-statutory consultee. It should be noted that the Met Office’s Cardington facility is not a formally safeguarded site as defined by the following Directions that make provisions for such sensitive sites:
• Town and Country Planning (Safeguarded Meteorological Sites) (England) Direction 2014; and
• Town and Country Planning (Safeguarded aerodromes, technical sites, meteorological technical sites and military explosives storage areas) (Scotland) Direction 2016.

1.4 The facility does not appear on the corresponding Safeguarded Zones Map on the Met Office website (https://www.metoffice.gov.uk/services/business-industry/energy/safeguarding) and therefore it is understood not to benefit from any additional planning protection.

1.5 It is therefore important that the consultation process undertaken is proportionate to the status of the Met Office facility and that the delivery of land East of Wixams is not unduly delayed.

1.6 Paragraph 4.87 of Policy HOU16 states that “The proposals will complement the existing development at Wixams and provide additional facilities and infrastructure including schools and an employment hub to cater for a range of flexible employment uses.”

1.7 However, we note that Policy HOU16 itself does not contain references to an employment hub or any local centre that is likely to be required given the scale of the development proposed. We consider that this should be addressed in the policy.

1.8 In addition, given the significant role that the site will play in terms of delivering additional services, education and employment provision – in combination with enhanced vehicular and pedestrian linkages to the new railway station at Wixams – we are of the view that every effort should be made to deliver this site as early in the Plan period as is feasible.

1.9 Criterion (iii) of Policy HOU16 states that the development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan.

1.10 The Council has identified that development of the land at East Wixams would relate to a number of improvements to the pedestrian, public transport and vehicular road network. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 on the wider south of Bedford road network, we are of the opinion that a ‘Monitor and Manage’ approach should be adopted, in conjunction with the wider and more extensive improvements to widen A421 between A421/A6 and A421/A603 Cambridge Road.

1.11 The implementation of the proposed transport infrastructure and in particular the suggested widening of A421, should not prejudice either the commencement or the full occupation of dwellings on the Site. The adoption of a ‘Monitor and Manage’ approach would therefore be consistent with the current views of both National Highways and BBC, and any future highway scheme to improve various junctions along A421 should also be assessed as part of the more extensive proposal by National Highways.

1.12 For the above reason, there is opportunity for East Wixams to come forward earlier than anticipated in the Council’s stepped trajectory under Policy DS3(S) and this would go some way to addressing the shortfall in housing supply earlier in the Plan period.

1.13 Currently, the trajectory shows the first homes on East Wixams occurring in 2029/30 due to the timing and need for upfront transport interventions. We can advise that new homes could be delivered as early as 2025/6 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

1.14 Criterion (xv) requires “delivery of a low carbon and environmentally resilient development that is adaptive to and resilient to climate change.” There are no specific targets suggested as part of this objective and therefore we would question its relevance to the policy and whether it is required in light of other similar policies in the draft Plan, such as Policy DS1(S) Resources and Climate Change.

Object

Representation ID: 9764

Received: 27/07/2022

Respondent: Mr David Stone

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I wish to strongly object to the proposals to the building of over two thousand homes shown in the plan as “Wixam’s Extension,” which would have devastating consequences for the residents of Wilstead. I have lived in the village since 1978 and my two sons also live here with their families in Wilstead. In this time, I have seen considerable increases in the developments in the village, but also the huge complex at Wixam’s, still to be completed. There has been no increase in the local facilities, no doctor’s surgery, pressure on the local school, small post office and a few shops. The main roads are totally unsuitable for the present traffic flow particularly vehicles travelling through the “rat run “at Cotton End Road leading to the A6 and A421 bypass.
The proposal to build more houses on the two new Wixam’s developments would seriously encroach on the rural nature of Wilstead, which is already under severe pressure. As already stated, the village is not a key service centre and therefore unsuitable for major development. The merging of our village is an extremely backward step, consequences being harm to our local heritage, threat to the green spaces, wildlife, rural landscape, footpaths, and recreation. These examples are not exhaustive and in our local area the developments at Cotton End, Stewartby & Shortstown are also adding further pressure to Wilstead.
I can only describe the proposals as the destruction of Wilstead which will be surrounded by hundreds of houses without serious thought of the lack of amenities and infrastructure to support the increase in population in the hundreds.

Object

Representation ID: 9766

Received: 27/07/2022

Respondent: Lola Stone

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I wish to strongly object to the proposals to the building of over two thousand homes shown in the plan as “Wixam’s Extension,” which would have devastating consequences for the residents of Wilstead. I believe the plan has named ‘Wixam’s’ wrongly as the land proposed for building is in fact part of Wilstead. This has proved to be very misleading for residents.
I have lived in the village since 1968. I live here with my husband, my son’s, and their families. In this time, I have seen considerable increases in the development of the village, not all of which has been negative. However, over recent years little thought has been given to the historic rural nature of the village. Wilstead is not a key service centre and should not qualify for major development.
When Wixams was first developed there was an agreement that the villages would not merge. There would be distinct separation by green space to allow our rural identity to remain. Protect our green space, views, and wildlife habitats.
The risk of flooding is significant as proposed building is in place on the flood plain.
To date there has been no increase in the local facilities, no doctor’s surgery, pressure on the local school, and a small post office. Bus travel is inadequate and unreliable.
The main roads are totally unsuitable for the present traffic flow particularly vehicles travelling through the “rat run “at Cotton End Road leading to the A6 and A421 bypass. Anybody who visits the village during school times is met by chaos.
The proposal to build more houses on the two new Wixam’s developments would seriously encroach on the rural nature of Wilstead, which is already under severe pressure. As already stated, the village is not a key service centre and therefore unsuitable for major development. The merging of our village is an extremely backward step, consequences being harm to our local heritage, threat to the green spaces, wildlife, rural landscape, footpaths, and recreation. These examples are not exhaustive and in our local area the developments at Cotton End, Stewartby & Shortstown are also adding further pressure to Wilstead.
I can only describe the proposals as the destruction of Wilstead which will be surrounded by hundreds of houses without serious thought of the lack of amenities and infrastructure to support the increase in population in the hundreds.

Object

Representation ID: 9780

Received: 27/07/2022

Respondent: Mr Marc Abbott

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I am opposed to the plan for 2100 homes to be built in “Wixams South and Wixams East” sites that are actually in Wilstead!

Considering the actual size that Wixams will eventually become, I do not understand the need to build on green land around Wilstead. The infrastructure is already struggling to cope with what is currently here. The roads are in a terrible state, trying to get to Bedford is a nightmare because the roads can’t cope with the constant flow of HGVs thanks to the amount of industrial warehouses/units that have been built in Wixams.

The schools are already at capacity, there are no additional amenities being proposed like a doctors surgery, dentist etc. There are only proposals for yet more houses that are not affordable.

The proposed houses will disrupt life for the people that already live here, not to mention the wildlife that will be displaced and destroyed. Wilstead should be left as a village and not eventually overtaken by the Wixams development.

In the last few years we have had a new estate built on the back of Whitworth Way, which has cause the crime rate to increase, including a drugs raid on one of the houses.

Object

Representation ID: 9826

Received: 25/07/2022

Respondent: Roger Gould

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Reference: Paragraph 4.87 of LocalPlan2040
I object most strongly to any development in this area (SG1 in the above diagram). It was designated to be a strategic gap between Wilstead and Wixams in order to preserve their different identities.
Even more important is the likely detrimental effect any development will have on the habitat of the Newt reserve.
[See attachment]

Object

Representation ID: 9830

Received: 28/07/2022

Respondent: Mrs Joy Levitt

Legally compliant? No

Sound? No

Duty to co-operate? No

I am against the 2040 Local Plan of 2100 new homes for the “Wixams Extension” for the following reasons:
1. South of Bedford has had more than its fair share of house building – i.e. Wixams and Cardington developments
2. Neither of these developments have had sufficient infrastructure – especially in regards to doctors and dentists, etc
3. The new developments in the 2040 plan are incorrectly labelled as “Wixams Extension” but are within Wilstead parish boundaries. This would treble the size of the current village and implies a lack of clarity and attention to detail from the Planning Department.
4. People live in Wilstead because it IS a village – not a town – and clearly would rather it remain so.
5. The A6 is a very busy and in parts dangerous road as it is; more housing will have a negative impact. The A600 is not such a busy road but is not suitable for higher volumes of traffic. It is single carriageway throughout.
6. There is much development being proposed along the A^ near Barton-Le-Cley and Silsoe – Central Bedfordshire Council jusrisdiction. It is likely that in the future all these ribbon developments will mean that Luton and Bedford will be joined, with little or no countryside between.
7. We are fortunate to have foxes, badgers, muntjac and fallow deer visit our garden; all this wildlife comes from the area and direction of the planned buildings. We need to preserve what wildlife we can.
8. This volume of building does not make the area a pleasing one in which to live. It is particularly difficult to employ GPs as they are able to find far nicer areas to live in.
9. We are in a drought area in the country. More housing requires more water which is unsustainable, with current environmental issues.

Object

Representation ID: 9837

Received: 28/07/2022

Respondent: Mr Peter Tansell

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bedford Local Plan response (east of Wixams)
I have lived in Wilstead for over 50 years and I originally chose to live here because of it's close knit rural village community. It strikes me that the building proposals will override this and our village will be consumed in the the larger sprawl that is Wixams. The Village identity would be lost once we get swallowed up by Wixams. These houses are not in Wixams. They are within the parish boundaries of Wilstead. Is this a deliberate attempt to mislead?

Your assumption that Wilstead is a key service area is false. We do not have a doctor's surgery in the village. Most villagers travel 8 miles to the surgery in Ampthill. We have a poor bus service. Two buses and hour and both arriving within 10 minutes of each other. There no east to west service. We have one village school and Wixams has a primary and secondary school. The latter has not been included in the Wixams quota. Some of the facilities claimed by the Borough, have in fact been provided by the hard work of villagers who raised funds to facilitate them. The bowls club was funded by and built by a group of villagers in the 1980's and the allotments have also been maintained through local interest.
We have already had substantial building of new houses in recent years and they have stretched village resources. The school has been hard pressed to accommodate the new influx of pupils. In my experience, school building follows after house building and there will be a huge demand for school places when our school has already had difficulties offering places to our current population. The volume of traffic around the village, especially at school times has increased and parking is chaotic at times. The new developments have not provided enough spaces to park and parking on pavements and grass verges is now commonplace. Any further substantial housing development would only make this situation worse. The proposed development is out of proportion with the existing size of our village and road use would be vastly increased putting further strain on our roads and causing poorer air quality.
We have concerns currently about traffic along Cotton End Road which is used as a cut-through for journeys from A6 and A600. Speeding is a real problem even after the installation of speed signs. Volume of traffic on this road will increase considerably if a large new development is allowed.
I have served on the village P3 walking group and have volunteered with the upkeep and maintenance of all the village paths. I object to having a large conurbation adjoining our pubic rights of way. Buildings which are adjacent to these paths restrict the rural aspect that walkers expect when using our paths. The 2100 new dwellings would have a huge impact on our unspoilt rural countryside and the homes of substantial wildlife.
I am totally opposed to these proposals and I hope they are refused.

Comment

Representation ID: 9841

Received: 28/07/2022

Respondent: Mr Roger Mant

Whilst appreciating the need for housing I am concerned about the expansion of Wixams towards Wilstead. In particular the area showing 1800 houses to the East of Wixams and the A6 and is being called the Wixam’s Extension.
This is also in the area/boundary currently allocated to the Wilstead Parish Council.
One can only assume that the desire is to swallow Wilstead up.
Also this is prime farming land and with this country needing to think seriously about home grown produce. Is this a wise move.

The subsequent increase in traffic and the current use as a cut through to the large warehousing facilities near wixams, this is taking away the rural atmosphere of this popular village.
Living on Cotton End Road for over 40 years I can only say that too many think it’s a racetrack being so straight. 6 accidents we know of in the time here, the good fortune being no one has been seriously injured. Average speed camera’s are a necessity with the extra traffic that is merely using the village to get from the A600 to the A6

Shortstown has its houses and 1000 more to be added there.
Land South of Wixams is 300 houses. Looking at the map, then Wilstead will soon be completely swallowed up.

Wilstead is not a keyservice centre and should not qualify for such a development.

We do not have a Doctors Surgery at all and such an increase is going to put a huge requirement on the area.

Object

Representation ID: 9880

Received: 28/07/2022

Respondent: Mrs Nicola Penfold

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I vehemently object to this part of the plan

Like many residents of Wilstead, we moved here over 25 years ago for the village and rural lifestyle. This has been slowly eroded over the years through development and the current proposals will put the final nail in the coffin for the village.

We need to ensure that open spaces, villages, wildlife and the countryside are kept intact as much as possible to maintain quality of life for us and future generations.

With the large development of Wixams, there should be no need for any development within the Parish of Wilstead, which must retain its identity and not be “swallowed up” by Wixams or Shortstown.

One major consideration is the traffic. Over the last few years the traffic in the village has increased dramatically (most of which appears to be cut-through traffic) and parking near the centre of the village near the school/Post Office is almost impossible for a large part of any weekday. This will get even worse if the new proposals go ahead as there are no alternative routes and a complete lack of public transport options. Also, the roads into and out of Bedford are seeing an increase in traffic volume, particulary on the A6, and this will become significantly worse if this development goes ahead. This will have a major negative effect on air pollution and the environment as well as making journey times into Bedford even worse than they are now.

Comment

Representation ID: 9888

Received: 28/07/2022

Respondent: Mr Michael Penfold

I strongly object to this part of the plan

Wilstead should not be classified as a key service centre as it has no GP/Doctor provision within the village itself, the bus service is appalling.

Wilstead is a rural community and current residents have chosen to live in a rural rather than urban community and any large-scale housing development would adversely impact the rural nature of the village.

There must continue to be a distinct gap between the village and other communities such as Wixams, Elstow & Cotton End so that the historical identities of all of these areas can be preserved.

Any substantial development would have a major impact on the look of Wilstead and would be out of character with the current properties in the village

The transport infrastructure supporting Wilstead is very poor with no bus service at all along Cotton End Road. Building further houses in the village would result in more through traffic and car ownership as there is no feasible alternative available. The village could not cope with any further increase in traffic without there being risk of serious accident or injury, particularly outside the school/post office and the garage at the crossroads. The average speed cameras and speed censors in the village appear to have had no impact of the high speeds seen regularly through the village.

Any large-scale housing development would adversely impact the rural green infrastructure of Wilstead and would seriously affect the ready access to the open countryside that is currently available in many parts of the village.

Object

Representation ID: 9902

Received: 29/07/2022

Respondent: Hollins Strategic Land

Agent: Emery Planning

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy HOU15 Land south of Wixams and Policy HOU16 Land at East Wixams
5.33 The site is located to the east of the A6 and the existing Wixams development. Figure 8 shows this to be a disparate allocation of three residential parcels one of which (HOU15) is a logical extension to the village. The other two parcels (HOU16) are on the opposite side to the A6 and the largest parcel is a standalone development. In the Settlement Hierarchy Wixams scores 55 points whereas Wootton scores 92 points. Despite this clear difference Wootton has not been allocated. As with HOU13 residents will rely on vehicular connections to more sustainable locations.
5.34 The spatial strategy and distribution of development in the Plan requires a fundamental change and greater concentration of sites adjacent to existing settlements. At present Policy DS5(S) is not justified when utilising the evidence base, is not in accordance with national policy and is not effective in delivering housing needs in the most sustainable locations.

Comment

Representation ID: 9915

Received: 28/02/2023

Respondent: Anthony Hare

HOU 16 - East Wixams
Also, what Elstow residents do urgently need are the current detail plans for the 1800 East Wixams homes (approx equal to half the original Wixams housing) which will possibly need to come considerably further north to the point of being just across the Harrowden brook close to our Moss Lane and South Avenue in Elstow [The various different plans for that site show its northern boundary ever closer to Elstow, particularly if housing is increased over time] and which I am sure those Elstow residents are totally unaware of. The Elstow Parish Council organised a residents Local Plan drop in meeting on 26 July 2022 and nobody from those 2 roads was aware of the East Wixams/College Farm housing plans.

Comment

Representation ID: 9918

Received: 29/07/2022

Respondent: Mrs Barbara Rigg

Building another 1,800 houses at Wixams extension will double the size of Wilstead village which the village cannot support. There is no doctor, facilities, shops or school to provide for the added homes and families and Wilstead will lose its village status it so supports.
These extra homes need to be relocated.

Support

Representation ID: 10017

Received: 27/07/2022

Respondent: Shortstown Parish Council

Shortstown Parish Council has reviewed your draft local plan 2040 and after careful consideration have the following comments. In the proposed 2040 Local Plan there are several options proposing further development within Shortstown parish but due to the high levels
of development that Shortstown has already seen further housing beyond what has already been built would risk Shortstowns rural character, further diffuse its small and fragile centre, and risk the future of the historic airship sheds and Cardington airfield.
Policy HOU16 development on land east of Wixams
This proposes a cycle link to Shortstown/Cotton End that would be close to the North end of Shocott spring and would be an ideal cycle route to Wixams station(when and if that happens). Ideally it would connect to the existing right of way between Sefton Fields and
Shocot Spring and/or with the cyclepath on the A600. Shortstown greatly needs rights of way for walking and cycling to the east towards Elstow and Wixams. Ideally to connect to the Bunyan trail and enable greater opportunity for travel on bicycle of by foot for residents of the borough.

Object

Representation ID: 10028

Received: 27/07/2022

Respondent: Mr Neil Robertson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I wish to formally object to the planned 2,100 new houses ie Land South of Wixams (300 houses) and Land East of Wixams (1,800 houses) that are part of the Bedford Borough Council Local Plan 2040. These developments are within the Wilstead Parish although they have been shown in the draft Local Plan as a “Wixams Extension”, which means that the Plan itself is inaccurate and could be misleading for residents when assessing the plan. There are a further 1000 homes proposed for Shortstown, which are next to the Wilstead Parish Boundary.
I have serious concerns about the detrimental impact that this large-scale development will have on the environment.
These are my main concerns:
1. The loss of over 400 acres of rural countryside, affecting numerous species of wildlife.
2. Loss of village identity.
3. Increase in pollution and traffic congestion.
4. Lack of sufficient public services.
5. Loss of food producing farmland.


Thank you for your consideration of the points I have raised as my objection to the planned housing developments in Wixams/Wilstead.

Object

Representation ID: 10031

Received: 27/07/2022

Respondent: Sheila Mousley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

THE NEED FOR HOUSING/SUSTAINABLE DEVELOPMENT
I object to the size of the community trebling in size. This is far too high. AT present the infrastructure is insufficient not enough GPs, bus services, post offices, general shops to accomodate 27,100 houses. I moved here as I wanted to live in a village and not an urban sprawl.
The proposal does not represent sustainable development.
TRAFFIC/TRANSPORT
I have huge concerns regarding traffic travelling on A6 towards Bedford and Luton. At present I experience congestion at roundabouts coming up to A421 and approaches to Interchange Park, more houses more congestion.
Cycling is not realistic as there are no continous pathways people can use on the approach to Bedford.
I object to having to put up with heavy construction traffic in this area for the rest of my life.
UNSPOILT COUNTRYSIDE
I object to the area outside the SPA which is designed as green space area between the settlements being built on. This should be left for food production, wildlife preservation and walks.
I cannot support these plans in their present form I hope my objections are listened to.

Comment

Representation ID: 10064

Received: 28/07/2022

Respondent: Avison Young

Proposed development sites crossed or in close proximity to National Grid assets:
Following a review of the above Development Plan Document, we have identified that one or more proposed development sites are crossed or in close proximity to National Grid assets. Details of the sites affecting National Grid assets are provided below.
Electricity Transmission

Policy HOU16 Land at East Wixams
Asset Description - 4VK ROUTE (TWR 378A - 476): 400Kv Overhead Transmission Line route: EATON SOCON - WYMONDLEY MAIN 1

Gas Transmission
Gas Transmission Pipeline, route: ST. NEOTS TO LITTLE BARFORD

To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Grid wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Grid on any Development Plan Document (DPD) or site-specific proposals that could affect National Grid’s assets. We would be grateful if you could check that our details as shown below are included on your consultation database:

Object

Representation ID: 10092

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Likewise for this proposed planning policy, in addition to the Parish Council objecting to the proposed allocations for the overriding planning policy reasons set out above, the Parish Council wish to highlight in particular for this site, concerns about the development area as illustrated on Figure 8.

The location of this site is a real concern as it sets total precedent for high density estate development east of the A6 within Wilstead parish. For many years land that side of the A6 and the village road into Wilstead has been put forward for planning, and refused, rightly so. Such an allocation with Policy HOU16 would have a significant knock-on effect.

The proposed Settlement Policy Area for HOU16 also extends a long way eastwards, again a concern given the large land masses along Cotton End Road in Wilstead which have received planning applications for housing development in the past. Whilst they have been refused previously, it does bring concern that this allocation could set a precedent.

The Parish Council also feel it is important to highlight specific areas of the associated planning policy which if the site remains allocated, must be amended prior to Secretary of State scrutiny.

Overall, the two largest areas marked on Figure 8 identified for potential housing development are situated a considerable distance away from the A6. Figure 8 clearly shows that development abuts the A6 fully on the western side. It seems more logical and natural, that the third potential development area currently located on the south west corner of the proposed allocated site, is moved upwards to be in line with the larger two masses as depicted by the red arrow below. Alternatively if this revised location is not acceptable, being then situated in a Flood Zone it should be removed altogether.

Equally for this Policy HOU16 site the Council feel in light of the landowner/site agent representations within the ‘Call for Sites’ process it is clear the site can hold significantly more than the 1800 proposed allocation. Given recent experiences of sites that have come forward, the Parish Council are mindful it is often the wish of the developer when bringing a site forwards to place as many houses on as possible, to maximise revenue output. It is therefore reasonable that if this site remains included that it must have written into the strategic policy robustly a definite number of houses, alongside the key earmarked open space areas to act as a strategic buffer. Without this change and inclusion within the policy there is no safeguard or protection for the site to not be fully developed and given the site has capacity to hold enough for a new town this is really a concern for the Parish Council.

Again the Parish Council feel that Policy HOU16 wording is not clear enough on a number of important factors that must be stated within the overarching policy if this site goes forward. There are again too many ‘loose’ words which during the development of Wixams resulted in so many expectations not being met, alongside the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and many ultimately never were delivered.

Paragraph 4.87 makes no reference of the site within Wilstead parish or its proximity to Wilstead, these omissions are not acceptable.

The Metrological Research Unit at Cardington is referenced, having tried to better understand the impact this has on the site, in terms of planning policy, this is not clear. It would be reasonable for such an item considered to be so significantly important to be mentioned in the planning policy that somewhere there is clarity on what such a reference actually means along with the types of mitigation that will need to be factored in. The reference is made in both paragraph 4.87 as well as Policy number i. so it must be an important item.

Item iii. references transport improvements are required, in fact the development is dependent upon it. Again the policy wording is insufficient and unclear, this needs to be defined.

The Parish Council feel that there needs to be more included with the Transport Assessment point number iv. it seems illogical that a site for 1800 houses has less requirements stipulated in the associated policy than Policy HOU15 which is to have 300 houses. Surely as a bare minimum the four bullet points contained within HOU15 should be referenced in HOU16. Along with, as mentioned previously, the local authority needing to have higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport. As highlighted in the above section, all such development activity should be mandated to have localised, on-site generation to mitigate the impact of the site by ensuring renewable energy is used in the local transport and heating solutions from the point of breaking ground and beyond.
In item vi. it talks of ‘provision of a mobility hub’, this needs to be defined in more detail as otherwise becomes just a piece of land that is allocated but has nothing of any useful benefit on it. Infrastructure is critical to ensuring a community can grow.

Again there needs to be more robust wording in items vii. viii. ix and x and education infrastructure. Previous issues as outlined already with empty spaces for facilities to be built when infrastructure needs to be available to support the community before it grows.

Item xii. makes reference to preserving and enhancing heritage assets and their setting, ‘including assets located in Duck End. In Policy HOU15 this statement referenced ‘and Wilstead’, it appears inconsistent that there has been no reference of Wilstead which contains 23 listed buildings that will need protecting.

It is also noted that there is no policy wording as in Policy HOU15 stating ‘submission of a wildlife and habitat survey with appropriate mitigation and enhancements.’ The Parish Council request this must be included if the site is taken forwards, it is an extraordinary omission given Policy HOU16 is adjacent to a community woodland area in Duck End which also has a designated area for Great Crested Newts - very much a protected species.

The Parish Council would like to reiterate the concern with this allocation with regard to its close proximity to the Duck End part of the village. The boundary abuts this unique setting of dwellings which are all of historic value. The houses along the western side of Bedford Road will have their outlook changed forever, so this reiterates the importance to protect those views as much as possible by moving or removing the proposed development area identified on the map above by a red arrow.

Object

Representation ID: 10129

Received: 29/07/2022

Respondent: Miss Anna Skoyles

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

I object to the plan for 1800 new homes in ‘east Wixams’. The proposed development is not actually in Wixams but in the parish of Wilstead.
There is a valuable greenfield site that separates Wilstead and the Wixams. This needs to be kept so that the Wilstead and Wixams do not merge in to one huge residential area with no green spaces. The areas of Kempston Hardwick, Shortstown, Wilstead, Wixams and possibly Houghton Conquest would just be one huge development with no countryside.
There is currently no doctors surgery in Wilstead or Wixams and the plan does not include any plan for this.
The A6 is an very busy road already, particularly during rush hours and school runs times. This causes a jam on the road heading in to Bedford by Cow Bridge traffic lights, sometimes as far back as the turn for Elstow at the A6 roundabout. Getting out of Wilstead on to the A6 by car is very difficult with constant traffic on the A6, the proposed development would increase traffic and make this issue much worse. Plus, there will be even more pollution from more road use, adding to climate change and lessoning air quality for Wilstead residents.
Wilstead is already used as a commuter through road, with speeding cars on A6 and A600 and there is an issue of daily on street parking, on Cotton End Road in particular, where cars park on the blind bend causing an obstruction. This proposed development would make things much worse. Cars and other larger vehicles speed through the main roads in Wilstead every day, causing noise, pollution and traffic problems.
Wilstead should not be designated as a KSC but as a rural service centre. the data used for Wilstead’s rating is very outdated e.g. there is just one shop/post office, no GP surgery, the number of residents is overstated and Wilstead has very little public transport with no buses running on Cotton End Road and only 2 an hour from Luton Road.
Nowhere else in the borough are there 2 KSCs in such close proximity to each other. The 1800 proposed new houses are planned to be built very near to a new wood that has been created near Duck End Lane, Wilstead and this would interfere with the peaceful nature intended by planting a new woodland.

Comment

Representation ID: 10170

Received: 29/07/2022

Respondent: Mrs Elsie Hare

HOU 16 - East Wixams
Also, what Elstow residents do urgently need are the current detail plans for the 1800 East Wixams homes (approx equal to half the original Wixams housing) which will possibly need to come considerably further north to the point of being just across the Harrowden brook close to our Moss Lane and South Avenue in Elstow [The various different plans for that site show its northern boundary ever closer to Elstow, particularly if housing is increased over time] and which I am sure those Elstow residents are totally unaware of. The Elstow Parish Council organised a residents Local Plan drop in meeting on 26 July 2022 and nobody from those 2 roads was aware of the East Wixams/College Farm housing plans.

Object

Representation ID: 10245

Received: 29/07/2022

Respondent: Wilstead Footpath Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU16 Land East of Wixams.
The Wilstead P3 Footpath Group object to this proposed development (HOU16) on the grounds of its impact on the numerous Public Right of Way in Wilshamstead Parish which would be effected by this proposed development, i.e. Wilstead Footpaths 12, 13, and Wilstead Bridleways 14 (part of the John Bunyan Trail), and to a slightly lesser extent on Bridleways 11 & 15.
Background. The Group with assistance from Bedford Borough Council (Rights of Way dept and Councillor Graeme Coombes (Ward Fund)) and Wilshamstead Parish Council monitor and help maintain all of the Public Rights of the Way in the Parish including the five Public Rights of Way listed above. They survey all the paths every two months and where necessary cut back overgrowth and maintain the surface of the Footpaths and Bridleways as well as installing furniture such as kissing gates, culverts and waymark posts.
The purpose of this work is to provide accessible off road routes in the countryside not only within the village but also to provide good connectivity with neighbouring communities. These five Public Rights of Way form part of a network of important recreational routes, linking Wilstead with Elstow, Cotton End, Haynes and east to Wixams and Houghton Conquest.

Object

Representation ID: 10265

Received: 29/07/2022

Respondent: Central Bedfordshire Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

HOU16 - Land East of Wixams
10.16 Central Bedfordshire Council objects to this allocation on the basis of our transport concerns as detailed above.
10.17 The submission plan identifies that the proposed allocation forms part of the wider South of Bedford Area, it is however, unclear how many homes would actually be delivered within the allocation.
10.18 HOU16 is proposed to be located to the east of the A6 and the existing Wixams development. It is noted that the proposed policy states, ‘The development is dependent on the delivery of transport improvements which will need to be secured before development can take place in accordance with an agreed Infrastructure Delivery Plan’ and that ‘Traffic mitigation (will be required) for the existing roundabouts off A6 to accommodate the new development;.
10.19 Without further details as to the nature of the transport mitigation required, and the concerns identified at paragraphs 6.4 and 6.5 above, it is impossible to fully understand potential impact and implications upon Central Bedfordshire. The Council therefore at this time, cannot support this proposal.
 
10.20 However, if transport implications can be resolved and the allocation is retained within the plan, due to the cross boundary nature of the Wixams site as a whole, coordination between CBC and Bedford will need to be ongoing to ensure the area as a whole is delivered cohesively. In these circumstances, CBC would welcome early engagement in relation to the proposed SPD for the site.
10.21 CBC and BBC will also need to look at wider cross-boundary issues, including an access strategy and particularly treatment of the A6 junctions and extension of bus routes to create a network for the wider Wixams site.

Object

Representation ID: 10300

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: 10335

Received: 29/07/2022

Respondent: Elstow Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

P roposed Allocations Objections
Substantial development has been included in the Local Plan document with EMP5 and HOU5 both within Elstow parish. On review of Document 52 Changes to the Policies Map it further highlights the encroachment from Policy HOU16 Land at East Wixams in particular. In light of this very sizeable allocation, the Parish Council is also mindful of the large allocation for Policy HOU17 Land at College Farm, Shortstown which will be addressed as well in this response as it virtually adjoins HOU16.

If HOU16 and HOU17 allocations were taken forwards as strategic growth options by the local authority, they would most likely consist of estate-type development which would be out of character with the rural, multi-age and mixed style of the current range of dwellings and rather worryingly create a broad swathe of dense development in the immediate area.

In addition for site HOU5 if it were to be developed it would be mean it would be totally neces- sary for people to have to travel by car into other communities, as these resources are not nearby in light of the isolated location of the pocket of housing.

 Schooling (insufficient places available locally)
 Shopping (local store cannot supply the range of goods required)
 Health facilities (limited locally)
 Onward bus or train travel (limited services, considerable travel time due to insufficient highways network capacity)

P olicy HOU16 Land at East of Wixams
In addition to the Parish Council objecting to HOU5 and EMP5 proposed allocation for the plan- ning policy reasons set out above, the Parish Council wish to highlight in particular that for HOU15 for this site, the detrimental impact in terms of coalescence with Elstow village, in partic- ular the South Avenue part of the village.

The location of this site is a real concern as it sets total precent for high density estate development east of the A6 within Elstow parish. For many years land that side of the A6 and the village road into Elstow has been put forward for planning, and refused, rightly so. Such an allocation with Policy HOU16 is going to have a significant knock on effect.
The proposed Settlement Policy Area for HOU16 also extends a long way eastwards, again a concern given the large land masses nearby in Elstow which have received planning applications for housing development. Whilst they have been refused previously, it does bring concern that this allocation could bring precent.

The policy wording makes a brief reference to a long term buffer between Wixams and Elstow, however, this is not reflected in Figure 8 of the consultation document within the site boundary. This is concerning as in many other site maps illustrating proposed allocations there has been distinct reference already included of important areas identified as key open spaces even at this strategic level. Such safeguarding of areas can be included at this stage of the Local Plan, again this omission is concerning for the Parish Council.

Equally for this Policy HOU16 site the Council feel in light of the landowner/site agent represent- ations within the ‘Call for Sites’ process it is clear the site can hold significantly more than the 1800 proposed allocation. Given recent experiences of sites that have come forward, the Parish Council are mindful it is often the wish of the developer when bringing a site forwards to place as many houses on as possible to maximise revenue output. It is therefore reasonable that if this site remains included that it must have written into the strategic policy robustly a definite number of houses, along side the key earmarked open space areas to act as a strategic buffer. Without this change and inclusion within the policy there is no safeguard or protection for the site to not be fully developed and given the site has capacity to hold enough for a new town this is really a concern for the Parish Council.

Again the Parish Council feel that Policy HOU16 wording is not clear enough on a number of important factors that must be stated within the overarching policy if this site goes forward. There are again too many ‘lose’ words which during the development of Wixams resulted in so many expectations not being met, alongside with the limited local authority powers, it caused a lot of distress that facilities were not being progressed in a timely manner and many ultimately never were delivered.

Paragraph 4.87 makes no reference of the site within Elstow parish or its proximity to Elstow, these omissions are not acceptable.

The Metrological Research Unit at Cardington is referenced, having tried to better understand the impact this has on the site, in terms of planning policy, this is not clear. It would be reason- able for such an item considered to be so significantly important to be mentioned in the planning policy that somewhere there is clarity on what such a reference actually means along with the types of mitigation that will need to be factored in. The reference is made in both paragraph
4.87 as well as Policy number i. so it must be an important item.

Item iii. references transport improvements are required, in fact the development is dependant on it. Again the policy wording is insufficient and unclear, this needs to be defined.

The Parish Council feel that there needs to be more included with the Transport Assessment point number iv. it seems illogical that a site for 1800 houses has less requirements stipulated in the associated policy that Policy HOU15 which is to have 300 houses. Surely as a bare minimum the four bullet points contained within HOU15 should be referenced in HOU16. Along with, as mentioned previously, the local authority needing to have higher expectations and aspirations for further enhancements to the local network to maximise more sustainable methods of transport.

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: 10381

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 1800 homes in the countryside between Wilstead, Wixams and Elstow. 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 East of Wixams, without mentioning its position relative to Wilstead. ‘Land East of Wixams’ 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 gaps between Wilstead, Elstow and Wixams are very important to prevent coalescence between these communities and should be designated Local Gaps. These gaps should include the area between this proposed development and Wilstead as well as that associated with the proposed HOU15 to the west of Wilstead further down 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 could be provided without taking up prime agricultural land.
In contrast HOU16 would be built on an area of prime agricultural land currently used for food production.
Access. It is not clear what additional access routes to these pockets of development are proposed. Having a single road access to 1800 houses would cause traffic problems especially if this road is blocked by roadworks or an accident. However any such additional access from Wilstead would necessitate going through the remaining open countryside north of Wilstead impacting on the rural characteristic of the village . The newly planted Community Woodland was intended to help maintain this rural gap between Wilstead and Wixams. A new road would produce a large amount of additional traffic through the village as drivers seek to avoid the traffic congestion on the A6.
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. These are all separate communities and must not become a suburb of Bedford.
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
We very strongly object to the particular section of this proposed development between the A6 and Duck End Wilstead. This should be removed as this will produce the very coalescence the Landscape Enhancement Area (Wixams) was trying to avoid.
Education. It is noticed that the proposed secondary school is to have a nine form entry i.e. nine forms for each year group. Assuming 30 pupils per year this would suggest nearly 300 pupils per year for 1st to 5th forms plus 150 per year for each sixth form. This would give one child of secondary school age per household. Judging by Wilstead, a slightly smaller community, this would seem to be excessive. What would be the catchment area for such a school and how will they get to school?. With one entrance off the A6, pupils from outside the development won’t be able to walk or cycle to school, so traffic on the already congested A6 at school times will be made worse.

Summary. The proposed development is one of a series of developments proposed for the area south of the A421. One of these is (HOU17) 1000 Houses proposed a field away at Shortstown.
There seems to be an imbalance of development compared with that proposed for the area north of Bedford.
These proposed areas of development would compromise the current open space between Wilstead and Elstow bringing the built up urban area nearer to Wilstead at the cost of good agricultural land. It would also seriously affect off road connectivity between local communities for walkers, cyclists and horse riders.
The most western section of this proposed development will bring about the coalescence between Wixams and Wilstead and I strongly object to this part of the proposed development.
This whole HOU16 development is isolated (in terms of accessibility, (i.e. one road in) but providing another route to Wilstead would further impact on the open countryside to the north of Wilstead and bring additional traffic into Wilstead. Any such road would also encourage development along its route. Wilstead already has problems with rat running and speeding in the village.
Alternative ways of pedestrians & cyclists crossing the A6 must 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 this site East of Wixams or changing the parish boundary and letting it be part of Wixams doesn’t change the proximity of Wixams to Wilstead or the impact this development would have on Wilstead.

Object

Representation ID: 10457

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This will similarly result in the effective merger of two distinct communities, Wixams and Wilstead, and lead to a what is in effect a continuous area of development from Stewartby, Wootton, through Kempston Hardwick and Wixams to Wilstead, Elstow and Shortstown. It will be an uncoordinated and unstructured urban sprawl with no oval coherence, grossly inadequate infrastructure and again will be dependent on car use.

Comment

Representation ID: 10462

Received: 29/07/2022

Respondent: Shortstown Liberal Democrats

While this site provides the opportunity to improve active travel (cycling, walking, scooting) to the planned Wixams rail station (planning consultation just closed) that will be a stop on the Bedford-St Pancras line, there is a great danger of coalescence between Wixams and Shortstown which should be resisted.

Object

Representation ID: 10490

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.