Policy HOU17 Land at College Farm, Shortstown

Object

Representation ID: 9134

Received: 22/07/2022

Respondent: Mrs Frances Baylis

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Shortstown has endured more than it’s fair share of development. The infrastructure just isn’t there to support further growth and development on arable land seems inherently flawed and will be devastating for local wildlife.

Object

Representation ID: 9144

Received: 23/07/2022

Respondent: Mrs Jennie Diston

Legally compliant? No

Sound? No

Duty to co-operate? No

It is shortsighted to be endlessly building houses with no long term plan of how we can ensure that we have enough fields to farm. The countryside and wildlife is being destroyed by our endless demand for more of everything. It does not support the need to reduce carbon emissions and save the planet. It is a joke for Shortstown to be classed as a key service centre, there are a couple of small shops and fish & chip shop!

Comment

Representation ID: 9216

Received: 01/07/2022

Respondent: Jackie Bell

We live at XXX Shortstown, which is roughly in the middle of the street, our garden face the farm, where you are proposing to build 1000 dwellings plus a school, and social hub. We went to the Village Hall a few weeks ago, and again this week we went to The Harper Centre, to try and find out more, about the proposed plans.

Our concerns are:-
1 We and our neighbours DO NOT want a school or playground/playing fields/play area being directly behind us, our road being a Cul de sac is extremely quiet. Houses being built, we cannot object to.

2 The other concern we have is The A600, even though it is 30 MPH from Cotton End down to our roundabout, it is a very narrow well used road, with lorries connecting from A1M to M1 and vice versa. If you build 1000 new homes, there will be at least 1000 extra cars using The A600, as there are already 2 schools, and people commuting to and from work, congestion will build up. as will the noise level, especially in the summer months when windows are open. It will effect our quality of life.

Object

Representation ID: 9249

Received: 27/07/2022

Respondent: Met Office

Agent: Mr Adam Kindred

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Please refer to separate representations. Given the proximity of this site to the Cardington research site, new major development in this location could have impacts on near-surface temperatures, winds and humidity (albeit dependent on wind direction) both during and post construction. As such, there is a strong likelihood that proposed development in this location could make measurements taken at the Cardington research site significantly harder to use scientifically due to increased complexity in their interpretation, thus affecting core Met Office operations.

Object

Representation ID: 9286

Received: 27/07/2022

Respondent: Mr Jonathan Pelham

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

I disagree with the plan for Shortstown expansion to the west. This is green belt agricultural land and Shortstown is already struggling to cope with the large amount of houses added to it which have caused various problems traffic through the A600 bottleneck to the A421 with its accident blackspot being only one of many.

Object

Representation ID: 9295

Received: 27/07/2022

Respondent: Mrs Gina Karavias

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Once the latest development has completed, 1493 new houses will have been added to the Parish since 2014. Shortstown doesn't have the key resources for this amount of houses and adding more will make it worse.

Overdevelopment of the area is taking away any character and will impact the quality of life for those who live in the area.

The A600/A21 junction is saturated and additional housing will only add to this.

Object

Representation ID: 9296

Received: 28/07/2022

Respondent: Mrs Jennie Diston

Legally compliant? No

Sound? No

Duty to co-operate? No

Please refer to the response received from the Shortstown Parish Council, I support their response. There has been considerable building in Shortstown in recent years, the impact of which has not yet been seen. The A road through Shortstown is already very busy and any incident/roadworks in the area bring access out of the village towards Bedford/A421 to a halt. The small village centre should not be classed as a key service centre, it is not. The additional housing already impinges on the hangers, any further building may stop their use in the future.

Object

Representation ID: 9305

Received: 28/07/2022

Respondent: Mrs Frances Baylis

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Over the last few years Shortstown has been targeted for massive development. Between 2014 and March 2021 901 houses have been built in the parish. When the Cardington Airfield development to the north of the sheds has been completed, another 592 houses will have been added. Once that is complete that will be 1493 houses added to the parish since 2014. While the development of RAF Cardington did include a notional village centre this has been slow to develop and Shortstown is still severely deficient in key services for the level of households now within the parish.

Object

Representation ID: 9338

Received: 28/07/2022

Respondent: Mrs Frances Baylis

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Over the last few years Shortstown has been targeted for massive development. Between 2014 and March 2021 901 houses have been built in the parish. When the Cardington Airfield development to the north of the sheds has been completed, another 592 houses will have been added. Once that is complete that will be 1493 houses added to the parish since 2014. While the development of RAF Cardington did include a notional village centre this has been slow to develop and Shortstown is still severely deficient in key services for the level of households now within the parish.

Object

Representation ID: 9355

Received: 28/07/2022

Respondent: Mrs Sylvia Lorenzo

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Over the last few years Shortstown has been targeted for massive development. Between 2014 and March 2021 901 houses have been built in the parish. When the Cardington Airfield development to the north of the sheds has been completed, another 592 houses will have been added. Once that is complete that will be 1493 houses added to the parish since 2014. While the development of RAF Cardington did include a notional village centre this has been slow to develop and Shortstown is still severely deficient in key services for the level of households now within the parish.

Object

Representation ID: 9445

Received: 29/07/2022

Respondent: Mr Stephen Rutherford

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

This and other developments in the plan create an 8 mile x 2 mile urban area to the south of Bedford.
If done well it will be a very big pleasant suburb. If done badly it will be a series of estates with small gaps of farmland in between.
Either way, very significant areas of countryside disappear.

Object

Representation ID: 9591

Received: 29/07/2022

Respondent: Sarah Gallagher

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I am the Borough Councillor for Eastcotts and have been a resident of Shortstown for 26years
I oppose the Development at College Farm
Over the past few years Shortstown has been targeted for massive development. Between 2014 and March 2021 901 houses have been built in the parish.
When the Cardington Airfield development to the North of the sheds has been completed another 592 houses will have been added. Once that is complete that will mean 1493 houses will be added to the parish since 2014.
Shortstown, Cotton End and Harrowden all have their own identity and are individual, distinct communities. That would be eroded by this proposed development. Harrowden is currently classed as a hamlet, for example and development such as this in its vicinity could bring that into question.
The A600 is the only route into Shortstown and Cotton End and is the same route to exit.
Residents of Shortstown young, old and vulnerable and disabled cross over the A421 using the dumb bell roundabout crossing points. Traffic entering the A421 stop at the pedestrian crossing but when traffic is exiting the A421 residents put their lives at risk with vehicles speeding up towards the crossing point no consideration has been given to the safety of the pedestrian and cycle users crossing at this point with the proposed development the traffic is undoubtedly going to increase.
In the past 6 months alone there have been a number of accidents which have caused the A600 in this vicinity to close and traffic be diverted through to Cardington or through Wilstead this causes severe disruption.
With the current increase in the population of Shortstown and with almost every household having 2-3 vehicles, the Iconic Sheds being used for filming and for music productions the increase in HGVs and vehicles on the A600 has been immense. The A600 is struggling now to cope with the additional vehicle movement. This is without the College Farm Development.
Public Transport
Many residents of Shortstown rely on buses to get to work and school this in recent months has had a service stopped in Shortstown creating overcrowded buses. No consideration has been given to what the bus companies can realistically provide

Comment

Representation ID: 9688

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 including Cardington number 1 and number 2 sheds, both listed at grade II* and several grade II listed buildings at Harrowden. The impact on the historic airfield setting is also important. Any development of this site has the potential to impact upon these heritage assets and their settings.
The open space around the sheds was of critical functional importance and contributes to their significance as heritage assets. The massive scale of the sheds within the open space of the flying field and the surviving landscape beyond speaks to the function of the buildings and combine to make the sheds extraordinary structures that dominate the landscape to the south of Bedford acting as local landmarks.
The Masterplan drawing shows that a large proportion (roughly half) of the development would be sited to the west of the existing settlement, where there is no discernible spatial relationship with, or uninterrupted views of the hangars.
However there would also be a significant amount of development to the south of Shortstown and directly opposite the west doors of the hangars, which would is likely to have some effect on some medium and longer distance of the hangars, affecting, to some extent, the way in which these heritage assets are experienced and appreciated. Very careful attention to layout and siting of development will be critical here, as well as massing and building heights, in order to minimise impact.
A Heritage Appraisal has been prepared for the site. It focuses on built heritage, in particular the Cardington sheds. It does not consider the listed buildings in Harrowden.
The Heritage Appraisal considers the issue of views to the sheds and suggests that that southern portion of the site is left open to retain these views. This is reflected in the concept plan at Figure 9 which is welcomed However, it should also be referred to in the policy, perhaps at criterion viii. Additional wording could read ‘open space in southern portion of the site to retain important views to Cardington sheds’.
We broadly welcome criteria xii and xiii but again suggest that reference is made to the need to maintain open space and key views to the sheds. We also suggest that the design of the development as well as the open space and landscaping will also be important and should draw on its historical aviation context for inspiration. This should be included in the policy wording.

Comment

Representation ID: 9732

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: 9916

Received: 28/02/2023

Respondent: Anthony Hare

HOU 17 - College Farm Shortstown
To reiterate the pointst said at HOU16 above. What Elstow residents do urgently need are the current detail plans for the College Farm and given the serious concerns for further expansion.

Object

Representation ID: 10020

Received: 27/07/2022

Respondent: Shortstown Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We oppose the following policies.
Policy HOU17 Development at College Farm. Over the few years Shortstown has
been targeted for massive development. Between 2014 and March 2021 901 houses have
been built in the parish. When the Cardington Airfield development to the North of
the sheds has been completed another 592 houses will have been added. Once that is
complete that will be 1493 houses added to the parish since 2014. While the development of RAF Cardington did include a notional village centre this has been slow to develop
and Shortstown is still severely deficient in key services for the level of households now
within the parish. The Transport Model discussed in supporting documents shows the
A600/A421 junction is already forecast to be saturated and additional housing would only
make things worse. For this reason we would also object to large development within
the parish of Cotton End as that would also massively increase the strain on our limited
transport infrastructure.
The only data we could find via the DfT for traffic on the A600 is available at the following
URLs
Count point 77216 https://roadtraffic.dft.gov.uk/manualcountpoints/77216
Count point 81517 https://roadtraffic.dft.gov.uk/manualcountpoints/81517
Both of these points are on Tinkers hill on and the reason for changing ID is not known but they are both in approximately the same location. Discarding the estimated traffic numbers and plotting only those that were manually counted we can see that there has been
significant traffic growth on the A600. This is shown in the first figure. It is a reasonable conclusion that this significant increase in traffic coincides with and is caused by the recent housing increases in Shortstown. Given the very large site in Shortstown to the North East
of the two historic airship sheds which is at an early phase of construction additional large traffic growth is only to be expected.
(graph included in original submission)
As can be seen in the second included figure Shortstown has seen recent rapid change over
recent years and when the additional development to the North of the historic sheds is
included this pushes the developed area within the parish to roughly 25% of the parish.
This land use estimate was calculated using GIS software and creating polygons around
each development one at a time to allow both the area of each development to be calculated
and also to understand the cumulate area used for housing and its growth over time. The
data is available on request. The proposed College Farm and Shorts Park developments would completely change the character of the parish and ruin the future of the sheds and aireld for movie and airship use.
(graph Shortstown parish land use for Housing included in original submission)
Beyond that it is a reasonable conclusion from the existing growth in traffic and services demand we have seen College Farm would increase these problems still further and we have not yet even seen the full impact of developments that have already been approved.

Object

Representation ID: 10032

Received: 27/07/2022

Respondent: Mrs Janice Woodall

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

I would refer to the proposed plans for 900 new housing site across Shortstown fields - I object to the amount of new buildings which is slowly losing Shortstowns identity as a village - also the fact that agricultural land, that is used to grow wheat, is being used - especially when we need all the home grown produce we can create ourselves.

Comment

Representation ID: 10093

Received: 28/07/2022

Respondent: Wilshamstead Parish Council

The local community will be able to offer comments on this proposed allocation for significant growth, however the Parish Council feel it is important that within the Policy HOU17 wording it makes reference not just to Wixams but the detrimental impact and clear need for mitigation in Wilstead. Again Planning Policy Officers appear to have neglected Wilstead, yet any travel from Shortstown to Wixams will require movements through Cotton End and Wilstead, particularly down Cotton End Road in Wilstead.

Comment

Representation ID: 10171

Received: 29/07/2022

Respondent: Mrs Elsie Hare

HOU 17 - College Farm Shortstown
To reiterate the pointst said at HOU16 above. What Elstow residents do urgently need are the current detail plans for the College Farm and given the serious concerns for further expansion.

Object

Representation ID: 10336

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)

Policy HOU17 Land at College Farm, Shortstown
The local community will be able to offer comments on this proposed allocation for significant growth, however the Parish Council feel it is important that within the Policy HOU17 wording it makes reference not just to Wixams but the detrimental impact and clear need for mitigation in Elstow.

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: 10439

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 HOU17 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 held up. 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.
With respect to HOU17(i), we acknowledge the merits of consultation with the Met 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, by virtue of it being a neighbouring occupier. 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
•
• Town and Country Planning (Safeguarded aerodromes, technical sites, meteorological technical sites and military explosives storage areas) (Scotland) Direction 2016
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.
It is therefore important that the consultation process undertaken is proportionate to the status of the Met Office facility and that the delivery of College Farm is not unduly delayed.
Paragraph 4.88 of Policy HOU17 states that “Land at College Farm, Shortstown offers the opportunity for sustainable residential development which will also contribute to the wider South of Bedford area allowing sustainable transport and green infrastructure linkages with Wixams to the west and beyond, including to the Wixams and Stewartby Hardwick railway stations. The proposals will complement the existing development at Shortstown and provide additional facilities including a new Primary School.”
There is no mention in the policy of the need for any other additional facilities that might serve new residents and we think this should be addressed in the policy.
We have progressed our early plans for the site in consultation with the local community and following a public consultation in May this year respondents made clear that there is a desire for more services and facilities across Shortstown to meet the needs of the growing population. Aside from more education and healthcare provision, respondents at our public consultation event highlighted the following elements of infrastructure for enhancement across Shortstown in the future:
a) food store
b) pub or eatery
c) more frequent bus services
d) coffee shop & takeaway
e) gym
With a growing population, we consider there to be clear need for an additional local centre at the College Farm site, which is accounted for in our masterplanning. Currently, the draft policy does not include such provision within the development, which is a missed opportunity to balance the needs of the area and deliver more sustainable development in accordance with Chapter 8 of the NPPF (Promoting healthy and safe communities).
Criterion (xvi) 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: 10440

Received: 29/07/2022

Respondent: Gallagher Developments Group Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Criterion (iii) of Policy HOU17 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. Criterion (iv) requires submission of a transport assessment including measures to mitigate the impact of development on the local and strategic route network and to maximise opportunities for sustainable travel including provision of a mobility hub (criterion v).
Linked to this site specific policy, is strategic Policy DS3(S), which explains that housing provision across the plan period will need to be “stepped”; continuing at the same rate as it is for Local Plan 2030 for the first five years, with more significant growth post-2030 once critical infrastructure is delivered – in particular transport infrastructure. We have provided a detailed overview of the transport evidence that accompanies the Draft Plan in Appendix A of these representations.
Firstly, the Council should look to ensure that it seeks to meet housing needs consistently across the plan period and not unnecessarily pushing back housing delivery through the use of a stepped trajectory, as outlined in paragraph 68-021of PPG. The use of a stepped trajectory should be a last resort and preference should be given to meeting needs more consistently across the plan period where sustainable.
The Council has identified that development of the Site at College Farm would be directly supported by the proposed improvements to the junction of A421/A600, which includes the introduction of traffic signals on the northbound approach of A600 leading towards the southern roundabout of the dumbbell junction. Although it is recognised that some peak hour delay and congestion may be forecast in 2040 at that junction, 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.
The implementation of an improvement to the junction of A421/A600 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 the junction should be assessed as part of the more extensive proposal by National Highways to widen A421.
For the above reason, there is opportunity for College Farm 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 in the earlier plan period. Currently, the trajectory shows the first homes on College Farm occurring in 2028 due to the timing and need for upfront transport interventions on the A600/A421. We would argue that new homes could be delivered as early as 2025 without the need for major strategic interventions and therefore the trajectory should be amended to reflect these considerations.

Object

Representation ID: 10458

Received: 27/07/2022

Respondent: Conservative Group

Agent: Bedford Borough Councillor

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The 1500 houses on College Farm allied to the 250 hoses on the DVSA site at Shortstown also raises the issue of the inadequate infrastructure including the problems of the A600, school provision and health provision. It will again lead to a sprawling development, dependent on car use, that will links Shortstown and Old Harrowden and with implications for Coton End.

Comment

Representation ID: 10463

Received: 29/07/2022

Respondent: Shortstown Liberal Democrats

We are particularly concerned about coalescence with Elstow (and Cotton End) and request that the land between HOU17 and Elstow and Shortstown and Cotton End have a protected designation to avoid coalescence.

Following the recent consultation by Gallagher Developments at the Village Hall we received a lot of views from residents. Many did not welcome the proposal to develop this site.

Almost all of those who contacted me mentioned poor road infrastructure as a major concern:
• The A600 north and south of Shortstown is already heavily used and this proposes approximately 4,000 additional traffic movements per day (2 vehicles per house, each vehicle makes 1 journey out and 1 journey in per day), which the current road infrastructure cannot support.
• The additional traffic will lead to a lot of congestion and we saw recently with the A600 resurfacing work that any closure that is not catered for with reasonable alternative routes (? where would they be – there is just 1 road in and out) this could be catastrophic for emergency vehicles. When the A421 is shut for incidents it causes lengthy diversions through Shortstown.
• As an estimate there would 1,000 to 2,000 additional movements through Cotton End where children have to cross the already busy road to the primary school.
• Can there be a link to the A421 to the north?
• Risk of rat-running through residential areas in Shortstown.

Other concerns which we share:
• Lack of services for existing population e.g. GPs
• Lack of services – buses that run early in the morning and late at night
• Years of construction disruption including the construction traffic (HGVs)
• Coalescence
• Loss of a village feel
• Impact on wildlife and habitats
• Potential negative impact on Shocott Spring due to increase footfall, litter, dogs mess etc
• Loss of valuable farm-land
• Potential loss of light and privacy (due to over-looking) for homes in Evans Croft and Flintham
• School provision – should a secondary school be provided
• Proposed location of school need A600 could leader to traffic backing up on to the A600
• Play parks – two proposed are very small, would benefit from a play area for older children as in Wootton

Object

Representation ID: 10491

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.