Plan for submission evidence base

Comment

Representation ID: 9954

Received: 25/07/2022

Respondent: Barton Willmore

The duty to cooperate was introduced by section 33A of the Planning and Compulsory Purchase Act 20041 and the Localism Act 2011. It places a legal duty on local planning authorities, county councils and prescribed public bodies to work together on strategic cross boundary matters.
Paragraph 27 of the NPPF states that in order to demonstrate effective and on-going joint working, one or more statement(s) of common ground should be produced, and these should be made publicly available throughout the plan-making process.
However, the published duty to cooperate statement advises that the Councils neighbours and partners are yet to have sight of the detail contained in the plan’s policies and they do not know which sites are proposed for allocation.
In order to be considered ‘positively prepared’ and ‘effective’ (in accordance with the tests of soundness set out at paragraph 35 of the NPPF), a statement of common ground should be provided, documenting the cross-boundary matters being addressed and progress in cooperating to address these. This should be made publicly available to ensure transparency.

Comment

Representation ID: 9956

Received: 25/07/2022

Respondent: Barton Willmore

In summary, whilst support is provided for the overall strategy of directing growth to accessible locations, we consider that in order to be considered ‘sound’, the housing trajectory for a greater proportion of housing should be directed to urban areas other than Bedford, such as our Site at Rushden Road. The North Northamptonshire Joint Core Strategy 2011-31 (adopted July 2016) recognises Rushden as a Growth Town (the highest tier of settlements) and defines its ‘spatial role’ as “to provide the focus for major co-ordinated regeneration and growth in employment, housing, retail and higher order facilities serving one or more districts”. Furthermore, the East Northamptonshire Local Plan Part 2 identifies Rushden as a growth town, which will provide the majority of new housing and employment development during the plan period, through a new sustainable urban extension. This is considered to demonstrate the suitability of Rushden as a location for new development.
Several additional changes are proposed to the BBLP2040, based on the Local Plan tests of soundness (NPPF, Paragraph 35) and we respectfully request that these are considered going forwards.

Comment

Representation ID: 10347

Received: 29/07/2022

Respondent: Barton Willmore

5.1 Paragraph 4.21 of the Submission Local Plan states:
“An Infrastructure Delivery Plan (IDP) has been prepared to support the Local Plan 2040. It identifies the infrastructure required to meet the level of growth anticipated in the borough in a sustainable manner. The document covers all types of infrastructure from transport and mobility hubs to waste water and supply, energy to schools, health to policies and fire services. The IDP identifies the infrastructure projects that will be required to meet the needs arising over the local plan period.”
5.2 The IDP has been prepared by AECOM and was published in May 2022 as part of the evidence base for the emerging Local Plan. The IDP identifies the infrastructure required to meet the level of growth anticipated in the Borough. This includes sections on both Primary and Acute Healthcare.
Primary Healthcare
5.3 Section 6.5 ‘Primary Healthcare’ makes reference to the BLMK CCG’s April 2021 publication, Our Commissioning Strategy 2021-2024 and the separate Our Primary Care Strategy.
5.4 In looking forward at planned projects, the IDP sets out the emerging model for integrated health and care hubs. Paragraph 6.5.25 identifies five planned hubs, including:
“North Bedford Primary Care Hub, Health Village site, Kimbolton Road, Bedford (pre-2026, work in progress, £7.08 cost, NHS capital available in principle).”
(We assume £7.08 million)
5.5 Paragraph 6.5.38 provides cost information for three of the identified projects, including:
“North Bedford Primary Care Hub, Kimbolton Road, Bedford: £7.0m (assume funded – NHS capital available in principle).”
5.6 Paragraphs 6.5.39-40 provide an estimate of project costs, and also set out an alterative approach to estimating costs based on the ‘NHS Healthy Urban Development Unit Model’ which is based on 199 sqm per GP and £3,130 per sqm. The findings are set out in Table 6.14 (page 169), resulting in a cost of approximately £17m for 28 full-time equivalent GPs over the period to 2040.
Acute Healthcare: Hospitals
5.7 Section 6.6 ‘Acute Healthcare: Hospitals’ includes hospitals and specialist care services, including mental health care. Paragraph 6.6.3 explains that the Trust acts as the provider of acute healthcare in Bedford Borough and the BLMK CCH commission acute healthcare from the Trust, acting together as partners within an Integrated Care System (ICS).
5.8 Paragraphs 6.6.18-22 refer to the Trust’s Clinical Strategy and wider plans for estate development over the next 15 years.
5.9 Paragraph 6.6.29 refers to cost information for three identified projects:
• “The estimated cost for the redevelopment of Shires House for inpatient mental health facilities is £60m.
• The estimated cost to deliver an additional operating theatre is approximately £6.8m.
• Electrical infrastructure upgrades will cost approximately £3.4m, although associated works represent Phase 1 of a larger infrastructure development programme.”
5.10 Paragraph 6.6.34 provides information on funding and states that
• “Funding for a new operating theatre is mostly yet to be secured, although £1m has been secured from an allocation received from the Department of Health and Social Care as part of COVID-19 recovery monies Funding for electrical infrastructure upgrades has been secured via the NHS.”
5.11 In summary, this section of the IDP concludes (paragraphs 6.6.39-40):
“Bedfordshire Hospital Trust is formulating a Clinical Strategy and a Development Control Plan for Bedford Hospital involving a variety of capital projects. These include, at the South Wing Site, additional operating theatres, additional outpatient capacity, additional inpatient beds, and a progressed car parking and access strategy. At the North Wing site, planned investments include the development of a primary care hub, a joint scheme between the CCG and BHT...
”Costs associated with the full programme of works at Bedford Hospital are not yet available. However, acute healthcare equipment, technologies and infrastructure are high cost, and the overall programme of works of Bedford Hospital is likely to cost tens of thousands of pounds.”
5.12 We would like to clarify that the latter reference should be to “hundreds of millions” rather than tens of thousands. Significant investment is required.
5.13 The Trust has been happy to engage with AECOM in their work preparing the IDP 2022. The IDP helpfully references the Trust’s emerging strategies and associated projects. We would caveat that the IDP represents a ‘snap shot’ in time, and priorities and funding opportunities/constraints will change over time.
5.14 The Trust will seek to work closely with the Council and other partners, sharing their emerging plans for the South and North Wing sites to ensure the ongoing delivery of essential healthcare to support growth and development in Bedford and the wider area during the forthcoming plan period.

Object

Representation ID: 10535

Received: 26/07/2022

Respondent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The duty to cooperate was introduced by section 33A of the Planning and Compulsory Purchase Act 20041 and the Localism Act 2011. It places a legal duty on local planning authorities, county councils and prescribed public bodies to work together on strategic cross boundary matters.

Paragraph 27 of the NPPF states that in order to demonstrate effective and on-going joint working, one or more statement(s) of common ground should be produced, and these should be made publicly available throughout the plan-making process.
However, the published duty to cooperate statement advises that the Councils neighbours and partners are yet to have sight of the detail contained in the plan’s policies and they do not know which sites are proposed for allocation.
In order to be considered ‘positively prepared’ and ‘effective’ (in accordance with the tests of soundness set out at paragraph 35 of the NPPF), a statement of common ground should be provided, documenting the cross-boundary matters being addressed and progress in cooperating to address these. This should be made publicly available to ensure transparency.

Comment

Representation ID: 10536

Received: 26/07/2022

Respondent: Barton Willmore

Site 896 Rushden Road
The Site is located on the southern edge of Rushden, 12 miles east of Northampton and 17 miles north of Milton Keynes. Rushden offers a range of shops and services, including convenience stores, supermarkets, pubs, primary schools a post office and medical facilities. Additionally, there is also a primary school and pubs in Wymington to the south. The Site is therefore considered to represent a sustainable location for residential development.
The Site is comprised of a number of agricultural fields and an area of existing allotments, and currently extends up to 30.8 hectares. Immediately to the north of the Site are existing properties in Rushden with a public right of way running along the Site’s northern boundary. To the east, the Site is bounded by residential development on Rushden Road as well as Rushden Road itself. Green Lane bounds the Site to the south, beyond which is agricultural fields. To the west are agricultural fields with an existing tree belt along some of the Site boundary.
The Concept Plan (shown within the Vision Document) provides an indicative vision and masterplan for the Site. Following dialogue with the Local Authority, information is provided within the Vision Document which illustrates how the Site could be successfully phased, with the first phase delivering approximately 5.7ha of residential development, alongside landscaping, drainage, infrastructure and community benefits such as public open space in line with the wider proposals.
The overall Concept Masterplan for the Site will retain and enhance existing hedgerows and planting across the Site including extensive new screening planting along the development edge. An integrated sustainable drainage system will be utilised with informal and formal open space accommodated within the development. The existing PRoW will be retained and enhanced to link into the wider network, and the existing allotments within the Site will be retained, with the potential for these to be expanded. The vision for the Site will assist Bedford in sustainably meeting the housing needs of existing and future residents.