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

Support

Representation ID: 8507

Received: 02/09/2021

Respondent: Bedfordshire Police

Bedfordshire Police (BP) welcomes this opportunity to assist Bedford Borough Council with the
preparation of the Local Plan 2040. This stems from our desire to work in partnership with the Council
to ensure that development growth is designed to promote safety, as well as being supported by the
infrastructure necessary to guarantee the security of the new communities and places created by it.
This is why these representations are supported by an updated Bedfordshire Police Infrastructure Plan
(August 2021) (BPIP); the first edition of which was submitted to the Council in April 2020. The purpose
of this being to explain the police infrastructure implications and costs associated with the development
growth now being envisaged for the Borough.
By way of ensuring that these representations are as concise as possible, we only respond to those parts
of the new Local Plan that directly concern the aforementioned priorities of BP:

Support

Representation ID: 8508

Received: 02/09/2021

Respondent: Bedfordshire Police

BP welcome and support the references to growth being supported by appropriate infrastructure and
designed to create safer places. However, the Vision would benefit from a much clearer commitment
to creating a safe, secure and low crime environment for all in the Borough. This would ensure
consistency with the following:
 Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July
2021) (NPPF);
 Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and
 Section 17 of the Crime and Disorder Act 1998 (as amended).
In view of the above, BP propose the following amendments to the Vision:
Good design and supporting infrastructure will help to improve quality of life and to create safer,
more secure, low crime, vibrant and more sustainable places, both in the urban area of Bedford and
Kempston and in the surrounding village communities.
Theme 4: Better places – Page 14
Although BP welcome the aim of creating a safe built environment, it would be significantly
strengthened through direct references to Secured by Design and reducing crime. In doing so, it would
being Theme 4 into much closer alignment with:
 Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July
2021) (NPPF);
 Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and
 Section 17 of the Crime and Disorder Act 1998 (as amended).
Furthermore, National Planning Practice Guidance (NPPG) is very clear that:
‘Planning provides an important opportunity to consider the security of the built environment, those
that live and work in it and the services it provides.
Section 17 of the Crime and Disorder Act 1998 (as amended) requires all local, joint and combined
authorities (as well as National Parks, the Broads Authority and the Greater London Authority) to
exercise their functions with due regard to their likely effect on crime and disorder, and to do all
they reasonably can to prevent crime and disorder. Crime for these purposes includes terrorism.’
Paragraph: 009 Reference ID: 53-009-20190722
Revision date: 22 07 2019
‘Good design that considers security as an intrinsic part of a masterplan or individual development
can help achieve places that are safe as well as attractive, which function well, and which do not
need subsequent work to achieve or improve resilience. However good security is not only about
physical measures and design, it requires risks and mitigation to be considered in a holistic way…
‘Good design means a wide range of crimes from theft to terrorism are less likely to happen by
making committing those crimes more difficult.’
Paragraph: 010 Reference ID: 53-010-20190722
Revision date: 22 07 2019
This has been expanded on by the National Model Design Code (July 2021) (Parts 1 and 2), which makes
the following points:
 Page 32 – Paragraph 63 (iv) – Safety and Security – ‘All schemes should aim to create a safe and
secure environment and provide a sense of security for all users. Where development is for or
has potential for a significant concentration of people schemes should also consider appropriate
and proportionate security measures.’
 Page 61 – Paragraph 144 – Secured by Design – ‘Neighbourhoods need to be designed to make
all people feel safe and to reduce the incidents of crime in accordance with the recommendations
of Secured by Design which includes guidance for housing, commercial space, schools, hospitals
and sheltered accommodation. Support and advice is available from the police through a network of Designing Out Crime Officers (DOCOs) across the UK. Secured by Design advice
incorporates proven crime prevention techniques and measures into the layout and design of
places and spaces.
In view of all of the above, BP requests that the following amendments be made to Theme 4:
‘Theme 4: Better Places – Developing high quality, well-designed, beautiful, safe and low crime
places for all to use and enjoy.
Objectives:
Support and create a high quality, inclusive and safe built environment that values local landscapes
and settlement character. This environment will experience low incidences of crime through the
application of Secured by Design. It will also be one where the historic environment is conserved
and enhanced to enable enjoyment by all.

Support

Representation ID: 8512

Received: 02/09/2021

Respondent: Bedfordshire Police

It is stated that 25,500 dwellings will be required for the period 2020 to 2040, of which 12,500 will need
to be provided by the new Local Plan.
Much of the development will be on open fields, which by definition place little demand on the police
and other emergency services. By contrast, once the population is living at these sites, there will be
significant and on-going demands upon the emergency services permanently.
When looked at from purely a policing perspective, there will be a very big increase (relative to current
rates) in crime and demand (comparable with existing rates in the Borough) from new residents for
policing services across a wide spectrum of support and intervention as they go about their daily lives
at the various sites and across the Borough. This applies whether they are victims of crime or witnesses
to it, involved in car accidents for example, or require the police for some other reason.
These additional crimes, anti-social and public safety/welfare incidents will translate into the following
day-to-day impacts upon BP:
 Additional calls and responses per year via the police control centre.
 Attendance to additional emergency events within the developments and Borough each year.
 Additional non-emergency events to follow-up with public contact each year.
 Additional recorded crimes in the developments and Borough
 Additional anti-social behavior incidents each year within the new developments and Borough.
 Demand for increased patrol cover.
 Additional vehicle use.
 Additional calls on police Airwaves system.
 Additional use of the Police National Database (PND) systems to process and store crime records
and intelligence.
 Additional demands for deployment of mobile CCTV technologies.
Additional demand for use of ANPR technologies.
 Additional demand for local access to beat staff from local neighbourhood teams.
 Additional policing cover and interventions in all the areas described when considering staffing
functions above and for additional accommodation from which to deliver these.
The above explains why it has been necessary to prepare the enclosed BPIP, which should be read in
conjunction with these representations. This is because it identifies and evidences the infrastructure
that will be required by BP to deliver effective policing services to the four potential growth options.
Hitherto BP has absorbed the impacts arising from development and population growth in the Borough
without seeking mitigation from the planning system. As explained and evidenced in detail in the BPIP,
this situation cannot continue as BP does not have the resources or capacity to do so. Further
development growth without any form of mitigation being provided will simply lead to a steady
degradation of BP’s ability to deliver policing services. This is a situation true of the education and health
authorities for example and applies to the emergency services as well.
The methodology used in the BPIP to calculate the police infrastructure impacts arising from the
development growth options has been endorsed by the National Police Chiefs’ Council. It has been
found to be sound by the Secretary of State 12 times and the Planning Inspectorate 31 times following
planning appeals. The most recent decision is dated 12 August 2021. This confirms that the
infrastructure requirements specified by BP are directly related in scale and kind to the development
growth options.
It is noted that the public consultation draft is concerned with seeking responses as to which of the four
options the Council should progress. Whilst BP are a neutral party when it comes to this decision, we
strongly recommend that when detailed planning policies are eventually prepared in relation to the
chosen option, they should set-out the infrastructure required to support it. This should include police
infrastructure in accordance with the detailed evidence and findings presented in the enclosed BPIP.

Support

Representation ID: 8513

Received: 02/09/2021

Respondent: Bedfordshire Police

BP welcome and support the statement in paragraph 5.4 that key issues for the town centre include
managing the night-time economy to reduce disturbance and make the area safer.

Support

Representation ID: 8514

Received: 02/09/2021

Respondent: Bedfordshire Police

Whilst we support the provisions in Policies TC2, TC5 and TC9 that state proposals in town centres
should not lead to anti-social behaviour or other problems, the issue of the night-time economy would
be better addressed through a dedicated policy on the topic due to the complex issues involved. We
propose the following for inclusion in the Local Plan:
Policy TC?? – Evening and Night-time Economy Development
Developments that will deliver a safe and socially responsible evening and night-time economy in
the Borough’s town centres will be encouraged. A balanced mix of uses will be supported including
late-night shopping, theatres, cinemas, galleries, museums, cultural activities, cafes, restaurants,
bars and clubs.
No development must, individually or cumulatively, create an unacceptable impact on neighbouring
uses or the surrounding area by reasons of noise pollution, light pollution, anti-social behaviour,
crime, disturbance, traffic, littering or other side effects.
Developments associated with the evening and night-time economy should also seek to ensure
activity during the daytime where possible to avoid the clustering of ‘dead’ frontages.
5
Proposals linked to the evening and night-time economy will be expected to contribute towards
public realm enhancements, infrastructure improvements and emergency services provision in
order to ensure safety and security. Contributions towards public transport, toilet facilities and CCTV
for the benefit of the evening and night-time economy will also be encouraged.
Owners and operators of evening and night-time economy development will be expected to take
part in active management measures to help the public and emergency services in partnership with
the Council and other stakeholders.
Planning decisions will include conditions and legal agreements to deliver the above and secure
closing times where appropriate.
Including the above policy in the new Local Plan will ensure that this type of development is located in
appropriate places in the Borough. At the same time it will guarantee that the well-documented
negative side-effects of this type of development will be carefully controlled and mitigated to the
maximum possible extent.
The proposed policy also establishes a solid basis upon which public sector agencies, private companies
and other stakeholders will work together to coordinate the active management of this type of
development in the town centres.
In the experience of BP and other Forces around the nation, if this type of good quality planning policy
is not implemented, then delivery of evening and night-time economy development will simply equate
to a rapid rise in crime and antisocial behaviour levels in direct proportion to the scheme(s) being
delivered. An outcome nobody wants.

Support

Representation ID: 8516

Received: 02/09/2021

Respondent: Bedfordshire Police

As explained earlier in these representations, BP strongly advocate that Secured by Design (SBD) be
promoted by the relevant policies of the new Local Plan. In the same vein, the proposed Bedford
Borough Design Guide should do so as well.
This will ensure that developers properly consider the measures involved in designing out crime to
create and maintain a sustainable community in accordance with the following, as well as the National
Model Design Code (July 2021) (see above):
 Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the National Planning Policy Framework (July
2021) (NPPF);
 Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and
 Section 17 of the Crime and Disorder Act 1998 (as amended).
To give a brief summary of SBD, it is a long-running flagship initiative of the National Policy Chiefs’
Council (formally Association of Chief Police Officers). Its objective is to design out crime during the
planning process. It is a highly respected standard in the sector, supported by numerous public bodies
and professional organisations. SBD is therefore a vital guidance resource for planners. SBD was created
in 1989, is available online, regularly updated and consequently there is no danger of it ceasing to exist
during the lifetime of the Local Plan.
It should though be highlighted that incorporating SBD will not though negate the need for additional
police and other emergency services infrastructure in relation to new developments. Not least because
there is no statutory power under which police, fire & rescue and ambulance services could be reduced
because of a given scheme incorporating SBD.

Object

Representation ID: 8517

Received: 02/09/2021

Respondent: Bedfordshire Police

BP request that the forthcoming Infrastructure Delivery Plan incorporates in full the findings presented
and evidenced in the enclosed BPIP. This is because the delivery of policing services 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. If this does not take place, BP’s resources used for existing
communities in the Borough will have to be ‘stretched’ to serve the new ones being created. This will
lead to the risk of unacceptable dilution of policing service provision across the Borough.
The above negative outcome would contrast starkly with the basic expectation that when people move
into a new housing estate or other type of development, they expect to be protected by policing services
that can operate effectively and efficiently across the area concerned. This applies to all levels of
services, whether they ring 999 should the worst happen, or are simply benefitting from the reassurance
of day-to-day neighbourhood policing for example.
Underlying the above is the fact that 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 it will have on the present disposition of resources.
Delivery of policing in this respect is not just about responding to a crime or incidents, but also providing
other services such as community assurance, protecting the safety of children or vulnerable people and
preventing crimes from happening in the first place amongst many others.
We also want to make it clear that mitigating the impact of a given scheme on BP and other 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. Neither one alone can achieve this. As evidenced at length in
the enclosed BPIP, new infrastructure for the police will be required in many cases across the Borough
alongside design measures therefore.