Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10493

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.

Object

Representation ID: 10494

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

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;

• Bedford Borough Community Safety Partnership – Community Safety Partnership Strategic Plan – 2020-2023 – Vision; 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.

Object

Representation ID: 10495

Received: 29/07/2022

Respondent: Bedfordshire Police

Agent: West Mercia OPCC

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Bedfordshire Police’s previous representations recommended that the Local Plan’s Vision be amended to acknowledge the need to create a secure and low crime environment for all in the Borough. However, this was not done. Unless the amendment is made the Vision’s consistency with the following paragraphs of the National Planning Policy Framework (NPPF) is at risk:

• Paragraphs 8, 20, 35-37, 92 (b), 97 and 130 (f) of the NPPF (July 2021);

In addition, the absence of the requested amendment jeopardises support for the need for design measures and additional infrastructure to ensure safe, secure and crime free communities. Support for this viewpoint is provided by paragraphs 92 and 130 of the NPPF, which both state that planning policies and decisions should:

‘Create places…where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.’

Furthermore, paragraph 20 of the NPPD states that local planning authorities should plan for the provision of community and security infrastructure for their areas.

The above demonstrates that 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 also ensure consistency with the following:

• Bedford Borough’s Sustainable Community Strategy 2009-2021 – Section 5; and

• The following legislation and national planning practice guidance:

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 all due regard to their likely effect on crime and disorder, and to do all they reasonable can to prevent crime and disorder.

Paragraph: 009 Reference ID: 53-009-20190722
Revision date: 22 07 2019

It should be noted at this juncture that the ‘Bedford Borough Community Safety Partnership – Community Safety Partnership Strategic Plan – 2020 – 2023’ states that the critical objective is:

‘Tackling crime, disorder, anti-social behavior, drug and alcohol misuse and increasing perceptions about safety and well-being in our communities.’

Therefore it is essential that the Vision of the Local Plan accords directly with the above to ensure its delivery in the Borough.

More generally, the Local Plan’s Vision contains other aspirations such as sustainable development, being more attractive and greater prosperity. However these and other aspirations will not be achieved if those same developments and communities are not safe, secure and low crime.

Consequently, BP is not convinced that the Local Plan’s Vision as currently worded is compliant with Section 17 of the Crime and Disorder Act 1998 (as amended) or the other documents cited above. Therefore, BP considers the Vision to be ineffective, inconsistent with national planning policy and consequently unsound as currently drafted.