Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Support

Representation ID: 8744

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

1.1 These representations have been prepared by Barton Willmore LLP on behalf of the Bedfordshire Hospitals NHS Foundation Trust (“the Trust”). These representations respond to the Bedford Borough Council (BBC) Local Plan 2040 Regulation 18 consultation, specifically the Draft Plan: Strategy Options and Draft Policies consultation document (June 2021).

The Bedfordshire Hospitals NHS Foundation Trust

1.2 The Trust is a key stakeholder within Bedford, providing essential healthcare provision to the population of the town and the wider area from their established sites at South Wing (Kempston Road) and North Wing (Kimbolton Road). In addition to their role as healthcare provider, the Trust is a major landowner and employer within the Bedford area.

1.3 Bedford Hospital merged with the Luton and Dunstable Hospital in April 2020 to become the Bedfordshire Hospitals NHS Foundation Trust. The merged Trust aspire to provide high quality care to the population of Luton, Bedford, Bedfordshire and further afield. Core services on both sites will remain, such as Accident and Emergency (A&E), maternity and children’s services.

1.4 The Trust is part of a regional integrated care system – Bedfordshire, Luton & Milton Keynes (BLMK) ICS. BLMK ICS is made up of commissioning groups, local authorities, Acute Trusts, Community Trusts, Mental Health Care Providers and Ambulance Trusts who all have a health footprint across BLMK. A number of regional priorities have been agreed and continue to be delivered. They include illness prevention and health promotion and the provision of high quality primary, community, social and secondary care. A number of the priorities link to capital development, including proposed construction at Bedford Hospital.

1.5 The clinical strategy is an evolving document, responding to local health needs and population health requirements, as well as regional and national strategy and best practice.


Engaging with the emerging Local Plan 2040

1.6 We appreciate that the Local Plan 2040 will be a partial update, focused on the Development Strategy and delivery of growth; town centre and retail policies; and some updated development management policies (paragraph 1.14).

1.7 The provision of high quality healthcare is essential to the growth of the Borough, highlighted particularly during the recent Coronavirus Pandemic. Ongoing investment and development of Bedford’s healthcare infrastructure, including the Hospital’s sites, is therefore an important objective looking forward over the next 20 years. As set out within this Representation Report, we consider that this objective should be more explicitly acknowledged within planning policy. In land use planning terms, we believe that the development and improvement of the Hospital’s sites warrants their specific identification and allocation as a ‘Special Policy Area’.

1.8 The Trust is keen to engage with the Council in the emerging Local Plan. We note from paragraph 1.45 that BBC plans to prepare an ‘Infrastructure Delivery Plan’ alongside the site allocations. The healthcare and social infrastructure aspects of this would be particularly relevant to the Trust, and we would be happy to discuss any matters in further detail.

1.9 This Report is submitted in response to the formal public consultation and relates specifically to the Draft Plan: Strategy Options and Draft Policies consultation document (June 2021). Section 2 of this report provides comments on the Vision and Objectives; and Section 3 relates to the Growth and Spatial Strategy Options. Section 4 relates to Site Allocations and Sections 5 and 6 provide further information regarding both the South Wing and North Wing sites. Section 7 provides comment on relevant Development Management Policy, and Section 8 sets out a summary of our Representations, and the conclusions.

Support

Representation ID: 8745

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

1.8 The Trust is keen to engage with the Council in the emerging Local Plan. We note from paragraph 1.45 that BBC plans to prepare an ‘Infrastructure Delivery Plan’ alongside the site allocations. The healthcare and social infrastructure aspects of this would be particularly relevant to the Trust, and we would be happy to discuss any matters in further detail.

Object

Representation ID: 8746

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

2.1 The Draft Plan’s ‘Vision’ is set out at paragraph 2.1, which states that its purpose is to demonstrate the focus and direction of the Local Plan.

2.2 The second paragraph of the Vision states that by the end of the plan period “well- planned growth supported by appropriate infrastructure… will enable the creation of strong, safe and resilient communities in environments that facilitate healthy and independent living for all.” However, there is no specific reference to healthcare infrastructure and we are of the view that this is an important element that should be included within the Vision.

2.3 The fourth paragraph of the Vision briefly makes reference to the transformation of “brownfield sites on the western side of the town and south of the river”, the latter of which we assume relates to the Policy 14 Area including some of the South Wing site and wider car parking land etc, in the Britannia Road area. Again, we are of the view that explicit reference to the Bedford Hospital sites should be made within the Vision, as these are key locations for development and improvement during the local plan period.

Object

Representation ID: 8747

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

2.4 The Draft Plan sets out four ‘Themes’ that are intended to reflect the Vision, as follows:

• Theme 1: Greener;
• Theme 2: More accessible;
• Theme 3: More prosperous; and
• Theme 4: Better places.

2.5 Under each theme, there are a number of objectives.

2.6 Theme 3’s objectives include:

“Deliver the necessary social infrastructure to support growth in both the urban and rural areas of the borough.”

2.7 We recommend that specific reference to ‘healthcare’ is included within this objective, as follows:

“Deliver the necessary social and healthcare infrastructure to support growth in both the urban and rural areas of the borough.”




2.8 Theme 4’s objectives include:

“Achieve a borough where everybody has appropriate access to high quality health and social care, as well as everyday essential services and community facilities where social and cultural wellbeing are supported, enabling all residents to lead healthy and independent lives.”

2.9 We support this objective, including identifying access to high quality healthcare as an essential aspect of the development of “high quality, well-designed and beautiful places for all to use and enjoy” (Theme 4).

Object

Representation ID: 8748

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

3.1 We appreciate that the Draft Plan consultation is a focused review, including the following key elements as set out in paragraph 3.7:

• determining how much employment land needs to be planned for,
• how many homes need to be provided across the plan period,
• what infrastructure would be needed to support this growth and
• what, in the context of the vision and objectives outlined earlier in the document, is the appropriate spatial strategy for the plan.

3.2 The Trust does not have any specific comments in relation to the levels of employment land and housing numbers, or in relation to the ‘Growth Strategy’ options in regard to where in the Borough this growth should go. However, in relation to “what infrastructure would be needed to support this growth” (third bullet point) the Trust would again like to highlight the importance of healthcare infrastructure.

Object

Representation ID: 8749

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

3.3 We note that the presentation of the four growth options (Options 2a-2d) is followed by the ‘Transport Strategy’ at paragraphs 3.18-3.25. There is no section of the Chapter that addresses wider infrastructure needs and specifically what infrastructure is required to support the proposed growth (as in third bullet point). In addition to transport, we consider that there should be a consideration of what other infrastructure is needed to support growth during the plan period, including healthcare infrastructure and the specific development of the Bedford Hospital North and South Wing sites. Indeed, it is worth acknowledging that whilst the development of both sites will be undertaken in line with the clinical strategy and to ensure the ongoing provision of excellent healthcare within a high quality hospital environment, the redevelopment of parts of the wider South Wing site is likely to be necessitated by the proposed East West Rail (EWR) project.

Object

Representation ID: 8750

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

3.4 Whilst the delivery of EWR is mentioned at paragraph 3.22 as one of five actions within the sub-national transport strategy, there is no acknowledgement in the Draft Plan of the significant implications that the implementation of the project will have on some sites within the Borough. Whilst we appreciate that EWR remains an emerging proposal, with the April - June 2021 consultation including some ‘Preferred Options’ for the route, the ramifications of the project’s delivery will be significant for many landowners, operators and residents in the Borough. Even if the detailed locations and sites for change remain too uncertain to specify on a Policies Map at this stage, we believe that the land use


planning implications of the EWR project should at least be acknowledged in the emerging Local Plan 2040.

3.5 There is much uncertainty regarding the EWR project, and considerable opposition within some groups. Whilst there is a danger of any comments being politicised, and the Local Plan should remain focused on committed schemes, we believe that the Draft Plan should make acknowledgement of the EWR project and set out the Council’s objectives at the local level.

3.6 It is important that strategic-level plans, including new infrastructure and transport projects, support the delivery of healthcare and facilitate good access to healthcare services. The Trust is seeking to work closely with Bedford Borough Council to ensure the establishment of both an integrated sustainable transport strategy for the Hospital and a shared vision for the ‘Land south of the River’ (designated for future redevelopment under Local Plan Policy 14). Likewise, the Trust is seeking to engage with the EWR Company, to ensure that the EWR project will deliver local benefits in addition to strategic opportunities.

Object

Representation ID: 8751

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

4.1 The Draft Plan seeks feedback on the 430+ sites that were submitted to them during the 2020 Local Plan Consultation.

4.2 We note that the focus of these sites is on their potential for housing development. The Trust does not have any specific feedback on any of the individual sites that have been proposed for housing. However, we are proposing the identification and allocation of the Bedford Hospital sites (North and South Wings) as ‘Special Policy Areas’.

4.3 There are two key reasons why the Hospital sites should be allocated on the Policies Map in this way:

• The Hospital sites play a fundamental role in the delivery of essential and high- quality healthcare to the population of Bedford Borough and beyond. As noted in previous sections of this Representation, healthcare infrastructure is a crucial element in supporting the delivery of growth. The Trust’s clinical strategy will require the development and improvement of both sites during the forthcoming plan period, and this change should be supported by the Council’s local land use planning policies.

• The South Wing site is very likely to be impacted by the emerging EWR project, and the need to plan for change is therefore imperative. The South Wing occupies a constrained and land-locked site, with limited opportunities for physical expansion. Indeed, the land between the Hospital and St Johns Station would likely have comprised the best location for intensification and future development (and some of this area is now identified under EWR Option 1 for the relocation of Bedford St Johns Station, closer to the Hospital). The Trust needs to safeguard the ongoing and future viability of the Hospital and will also need to ensure operational continuity during any construction works. This requires foresight and careful planning, including looking at different spatial options and their land use planning implications.

4.4 We are of the view that a ‘Special Policy Area’ (SPA) policy approach would be appropriate in relation to both the North and South Wing sites. The remit and scope of this form of allocation would need to be set out in the emerging Local Plan 2040. We present our considerations, below.




‘Special Policy Area’ Allocation

4.5 In some local plans, ‘Special Policy Areas’ are designated for strategic sites where major development is proposed during the forthcoming plan period.

4.6 Barton Willmore LLP has experience of this policy approach being followed by Chelmsford City Council, in respect of their Local Plan (adopted May 2020). Chelmsford Local Plan identifies six SPAs, crucially including Broomfield Hospital under SPA1. We provide the relevant extracts from their Local Plan at Appendix 1, for your ease of reference.

2.10 We believe that a similar rationale for allocating these SPAs would apply to that set out in the Chelmsford Local Plan:

“The SPA designation enables the operational and functional requirements of these facilities or institutions to be planned in a strategic and phased manner. The SPA sites are shown on the Policies Map.

The key objectives are to:
• Enable Special Policy Areas to be planned in a strategic and phased manner
• Ensure future development reflects the operational and functional requirements of the Special Policy Areas
• Ensure future development minimises the impact of development on their surroundings, sites important for nature conservation, wildlife and heritage assets
• Strengthen access to the sites by sustainable modes of transport and minimise traffic pressures on local roads
• Achieve high quality design”

(Chelmsford Local Plan 2020, paragraphs 7.363-7.364)

4.7 A specific policy (or policies) should be included within the Bedford Local Plan 2040, setting out the Council’s support for development proposals which support the role, function and operation of the North and South Wing sites.


4.8 Supporting text should also be provided, setting out the significance of Bedford Hospital as an important medical facility and providing a brief description of the North and South Wing sites, their key characteristics and constraints in land use planning terms, and the changes envisaged during the plan period (including the emerging clinical strategy as well as the EWR project). Further details on both sites are set out in Sections 5 and 6 of this Representation Report, including site plans.

4.9 We would be keen to discuss matters further with the Council, including the wording of policies and supporting text and the detailed boundaries for site allocations.

5.0 SOUTH WING SITE

The Site

5.1 The Bedford Hospital South Wing Site is located circa 1km southwest of Bedford town centre, as shown by the Site Location Plan at Appendix 2. It lies to the south of the River Great Ouse and southwest of the Bedford St John’s Railway Station. The Hospital’s main buildings lie to the southeast of Kempston Road, southwest of Britannia Road and the northwest of the A6 Ampthill Road. These buildings provide clinical, clinical support and non-clinical support functions. To the northeast of Britannia Road, the wider Hospital site includes non-clinical support buildings and car parking areas.

5.2 The South Wing site provides a range of essential healthcare services to the population of Bedford and beyond, including an Emergency Department, operating theatres, pathology, x-ray, inpatient wards and outpatient services.

Site Development

5.3 The Trust’s current clinical strategy requires the strategic estate development of the Bedford site over the next 15 years. This has been agreed by the Executive and includes:

a. Significant infrastructure development to support the corporate and national agenda and objectives to achieving net zero carbon. In terms of the physical estate, this will require significant infrastructure developments e.g. new sub stations, an energy centre, new efficient buildings, green space.
b. Additional operating theatres to accommodate increasing demand and to replace old, sub-standard theatre accommodation.
c. Additional outpatient capacity to accommodate the demand for secondary care services. This can be divided into accommodation for outpatients, diagnostics and ambulatory care.
d. Inpatient beds for elective day care to accommodate growth in demand and for acute admissions to accommodate demand for an ageing population.

5.4 The car parking and access strategy for the site must also be progressed. The outcome of this will ultimately require a new multi-storey car park on site, on Trust owned land between Britannia Road and the Danfoss site. The Trust currently lease around 1000 car


parking spaces on the Danfoss site from Arch Co 1. This is a short-term measure. Car parking provision and cycling facilities to support access to the Trust is a priority for the Trust. This links in with the Trust’s corporate objective to drive forward Net Zero Carbon.

Considerations

5.5 The South Wing Site benefits from an accessible, edge-of-centre location close to St Johns Railway Station. The Trust is keen to work with the Council to develop an integrated sustainable transport strategy, promoting walking, cycling and public transport modes. However, there is also a need to ensure safe and adequate car parking provision for those who need to use a private vehicle (and for emergency vehicles).

5.6 The main Hospital site and its associated support buildings to the northeast of Britannia Road lie within Flood Zone 1, whilst some of the car parking land closer to the railway lie within Flood Zone 2.

5.7 The South Wing site includes the Hospital Administrative Block and Children’s Ward Grade II statutory listed building.

5.8 The East West Rail Consultation 2021 proposes changes to the railway track alignment in the vicinity of the South Wing site, with Option 1 proposing the relocation of Bedford St Johns Station closer to the Hospital. Whilst this would have the advantage of improving accessibility to the Hospital via public transport, the proposals would result in an immediate impact on existing Hospital car parking provision. Options for car parking re- provision will need to be carefully considered.

5.9 South Wing occupies a constrained and land-locked site, with limited opportunities for physical expansion. Indeed, the land between the Hospital and St Johns Station would likely have comprised the best location for intensification and future development.

Proposed Allocation

5.10 We propose that the Bedford Hospital South Wing Site is allocated on the Policies Map and with a specific policy.

5.11 We propose the following wording for your consideration:


1 Arch Co is JV between Telereal Trillium and Blackstone who have a lease from Network Rail for all of their surplus land assets, primarily under bridge arch spaces.

POLICY SPA1 – BEDFORD HOSPITAL SOUTH WING SPECIAL POLICY AREA

The Council will support health related proposals which support the role, function and operation of Bedford Hospital’s South Wing Site and surrounding area. This includes significant infrastructure development to support achieving net zero carbon; the provision of additional operating theatres; the delivery of additional outpatient capacity and inpatient beds to accommodate demand; improving access, including through public transport, pedestrian links, cycle provision and car parking. The Council will work with the Trust and other partners in developing plans for the land between Britannia Road and the railway, including under Policy 14 Area and as may be necessitated by the emerging East West Rail project.


6.0 NORTH WING SITE

The Site

6.1 The Bedford Hospital North Wing site is located circa 1km northeast of the town centre in an accessible location, as shown by the Site Location Plan at Appendix 3.

6.2 The North Wing site is a health village for Bedford. It includes Gilbert Hitchcock House, Florence Ball House, Enhanced Services Centre, Shires House, Dental Care Centre, Archer Unit, Cedars House and Fountains Court.

Site Development

6.3 In partnership with colleagues across the ICS, the Trust are a key player in leading strategic estate change to drive clinical service advancement which effectively aims to deliver primary care at scale, supporting patients to receive better quality care and ultimately improved health outcomes. There is a significant impact on social value bought about by this change programme.

6.4 The change programme alluded to above sees the transformation of primary care with GP practices brought together into primary care hubs, with clear alignment to and support from, secondary care (the Acute Trust).

6.5 The North Wing site is a health village for Bedford. Land ownership is varied and clinical service management is aligned to a multitude or organisations. The Trust owns one of the buildings on the North Wing site, Gilbert Hitchcock House, and delivers services from the Archer Unit.

6.6 In partnership with commissioners, the Trust are co-leading a strategic estate programme to enhance the delivery of primary and some secondary care from the North Wing site. An options appraisal is underway and one consideration is to extend the buildings to create additional healthcare capacity and deliver the opportunity to bring services together. This programme will see an increase in demand for healthcare services on the North Wing site.

6.7 Other projects underway on the North Wing site include the development of Shires House to create inpatient facilities for mental health services.




Considerations

6.8 The North Wing site benefits from an accessible location. The Trust is keen to work with the Council to develop an integrated sustainable transport strategy, promoting walking, cycling and public transport modes. However, there is also a need to ensure safe and adequate car parking provision for those who need to use a private vehicle (and for emergency vehicles).

6.9 The North Wing site lies within Flood Zone 1, and is therefore considered to be at a low risk from flooding.

6.10 The site lies within the Bedford Town Centre Air Quality Management Area (AQMA).

6.11 Shire House is a Grade II listed building which has also been significantly affected by fire damage. The site is not within a Conservation Area, but lies adjacent to the Bedford Conservation Area.

Proposed Allocation

6.12 We propose that the Bedford Hospital North Wing site is allocated on the Policies Map and with a specific policy.

6.13 We propose the following wording for your consideration:

POLICY SPA2 – BEDFORD HOSPITAL NORTH WING SPECIAL POLICY AREA

The Council will support health related proposals which support the role, function and operation of Bedford Hospital’s North Wing site and Bedford Health Village. This will involve a partnership approach towards a strategic estate programme to deliver enhanced healthcare provision from the site. Development will include the redevelopment of Shires House for mental health services, along with other building projects on other parts of the site.

APPENDIX 1 OF ATTACHMENT CONTAINS EXTRACT FROM CHELMSFORD LOCAL PLAN 2020

APPENDIX 2 OF ATTACHMENT CONTAINS HOSPITAL SOUTH WING SITE LOCATION PLAN

APPENDIX 3 OF ATTACHMENT CONTAINS HOSPITAL NORTH WING SITE LOCATION PLAN

Object

Representation ID: 8752

Received: 29/09/2021

Respondent: Bedfordshire Hospitals NHS Foundation Trust

Agent: Barton Willmore

7.1 The Trust does not have any comments except in relation to Draft Policy NE1,
Environmental Net Gain.

7.2 The principle of seeking biodiversity net gain is supported and is expected to be mandated nationally through the government’s Environment Bill. The policy text also accounts for circumstances where net gain on site may be particularly challenging and instead requires enhancement or creation of off-site habitats. However, we consider that further consideration needs to be given to scenarios where landowners do not own sufficient off- site land and may need to consider contributions through biodiversity obligations or credits as a last resort.

7.3 We consider that it is unclear what ’environmental net gain’ means in the context of this policy and if this requires more than ecological net gain measures. Paragraph 8 of the NPPF already defines the environmental objectives of sustainable development as protecting and enhancing our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy. ‘Environmental net gain’ could therefore encompass several features, potentially leading to confusion in the interpretation and application of this policy and ultimately its soundness. This will enviably lead to issue for decision makers when trying to apply the policy to developments.

7.4 The main focus of the policy appears to be on biodiversity and therefore we think the policy wording should be more closely aligned with this aspiration. The term ‘environmental net gain’ should be replaced with ‘biodiversity net gain’.