Policy HOU18 Land at Former DVSA Site, Shortstown

Object

Representation ID: 9252

Received: 27/07/2022

Respondent: Met Office

Agent: Mr Adam Kindred

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Met Office broadly support this housing allocation, as it is recognised this development has been previously committed as part of the Bellway Homes New Cardington Fields development. Therefore, new development in this location should be subject to appropriate and effective engagement with the Met Office as part of achieving well-designed places in accordance with paragraphs 16 and 126 of the NPPF. Furthermore, effective engagement will help ensure new development does not place “unreasonable restrictions” on the Met Office’s existing operations in line with paragraph 187 of the NPPF.

Support

Representation ID: 9283

Received: 27/07/2022

Respondent: Mr Jonathan Pelham

Infill on brownfield site. Good use of otherwise awkward plot

Support

Representation ID: 9303

Received: 28/07/2022

Respondent: Mrs Frances Baylis

This policy would makes good use of a brownfield site currently surrounded by houses. The site is of limited size and so while it would create additional traffic load, compared to some other proposed sites it would be of a more limited and manageable amount.

Support

Representation ID: 9340

Received: 28/07/2022

Respondent: Mrs Frances Baylis

This policy would makes good use of a brownfield site currently surrounded by houses. The site is of limited size and so while it would create additional traffic load, compared to some other proposed sites it would be of a more limited and manageable amount.

Support

Representation ID: 9354

Received: 28/07/2022

Respondent: Mrs Sylvia Lorenzo

This policy would makes good use of a brownfield site currently surrounded by houses. The site is of limited size and so while it would create additional traffic load, compared to some other proposed sites it would be of a more limited and manageable amount.

Support

Representation ID: 9379

Received: 29/07/2022

Respondent: Gareth Adam, Homes England

Agent: Stantec

Homes England is supportive of Policy HOU18 Land at former DVSA Site, Shortstown.

Object

Representation ID: 9446

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.

This particular site pushes the edge of Shortstown almost to the edge of Cardington.
Most of this site could be returned to nature.

Comment

Representation ID: 9689

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the site lies immediately adjacent to the grade II listed Cardington Railway Station. It is also close to the grade II* listed Cardington sheds whilst to the east lies Cardington Conservation Area with its associated listed buildings (including the grade II* Howards House and grade II Registered Park and Garden to Howards House). Any development of this site has the potential to impact upon these heritage assets and their settings.
This site not quite as sensitive as HOU17 given that it is in an area where lots of other residential development has been approved in recent years. However, it is important that to ensure that development is grounded in a thorough understanding of the context and in particular the setting ,and ensuring that layout, siting, massing etc is appropriate so that development is in deference to the hangars.
A Heritage Appraisal has been prepared for this site. The appraisal makes a number of recommendations for the site including:
• Maintain channelled views between the station and hangers
• Retain vegetation and eastern and south eastern boundary of the site
• Sensitively placed built form with massing that does not compete with the hangers
These recommendations should be included in the policy wording.
We broadly welcome criteria vi and vii. We suggest adding the following after Conservation Area ‘and associated listed buildings and Registered Park and Garden’

Comment

Representation ID: 9733

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.

Support

Representation ID: 10015

Received: 27/07/2022

Respondent: Shortstown Parish Council

Shortstown Parish Council has reviewed your draft local plan 2040 and after careful con-
sideration 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.
We support the following policies found within it.
Policy HOU18 development of the former DVSA site. This policy would makes
good use of a brownfield site currently surrounded by houses and we would welcome the
developer to open consultation with us at the earliest opportunity. The site is of limited
size and so while it would create additional traffic load compared to some other proposed
sites it would be of a more limited and manageable amount.

Comment

Representation ID: 10464

Received: 29/07/2022

Respondent: Shortstown Liberal Democrats

As a brownfield site this site is a good candidate for development. It is a shame that it has come forward for development so late in development of land to the east of Shortstown as then it could have been more integrated into the overall design. Hopefully good design will ensure this site looks and feels like a part of the neighbouring development, not a separate afterthought.

Object

Representation ID: 10492

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.