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Local Plan Central Council Priory House Monks Walk Chicksands Shefford SG17 5TQ

29th August 2017

BY EMAIL Dear Sir/Madam,

CENTRAL BEDFORDSHIRE DRAFT LOCAL PLAN CONSULTATION – HOSPITAL, ROAD, STEPPINGLEY, BEDFORD, MK45 1AB On behalf of our client, NHS Property Services Ltd (NHSPS), who are the landowner of this site, we wish to make representations, in respect of the above site, to the Draft Local Plan. These representations are accompanied by a Site Location Plan attached at Appendix 1. In addition, at appendix 2, please find a completed Call for Sites form.

In April 2013, the Primary Care Trust and Strategic Health Authority estate transferred to NHSPS, Community Health Partnerships and NHS community health and hospital trusts. All organisations are looking to make more effective use of the health estate and support strategies to reconfigure healthcare services improve the quality of care and ensure that the estate is managed sustainably and effectively.

In particular, NHSPS’s Property Strategy team has been supporting Clinical Commissioning Groups and Sustainability and Transformation Plan groups to look at ways of better using the local health and public estate. This will include identifying opportunities to reconfigure the estate to better meet commissioning needs, as well as opportunities for delivering new homes (and other appropriate land uses) on surplus sites emerging from this process.

By way of background, local health commissioners are currently developing a strategy for the future delivery of health services in this area. This will involve the release of certain NHSPS landholdings which are no longer required for the delivery of health services.

Should any part of the subject site be declared as surplus to the operational healthcare requirements of the NHS (decision expected within 5 years), it should be considered suitable for alternative uses including a range of residential accommodation, depending on the needs of the local community. The subject site is considered available, suitable and deliverable within the period 5-10 years. a. Site Context

The site is located to the north west of , the fifth largest settlement in Central Bedfordshire. The site measures approximately 2ha. The site currently accommodates Steppingley Hospital, associated buildings and surface parking. The site is situated within the Green Belt.

The site is bound by open fields to the north, and west (beyond Fordfield Road). Froghall Road bounds the site to the south, beyond which a mixed use development comprising up to 400 new homes, up to

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Iceni Projects is the trading name of Iceni Projects Limited. Registered in No. 05359427 4,400 sqm of employment floorspace within class B1 and B2 as recently been constructed. In addition, directly opposite the site there is an area designated for open space and recreational land.

The site is located 1.5km from Flitwick Train Station and Flitwick High Street. Flitwick provides a range of services and facilities including:  Tesco supermarket – 1.35km  A library – 1.4km  Schools – 1.1 – 1.8km  A village hall – 1.5km  Flitwick Leisure Centre – 380m

Ampthill is located 2km north east of the site, providing additional services and facilities, to further support redevelopment of this site.

In this regard, the subject site benefits from a highly sustainable location with direct access to local services and amenities on the edge of the existing settlement of Flitwick. b. Contributing to the Housing Need

The draft Local Plan proposes the delivery of a minimum of 20,000 new homes. It is not clear from the emerging policy whether this will meet the full Objectively Assessed Housing Need which needs to be confirmed by the Council and demonstrated in full in the supporting evidence base to ensure the soundness of the Local Plan. Furthermore, there is a commitment to deliver some of Luton’s current identified ‘unmet need’ within Central Bedfordshire. The plan seeks to deliver this housing need through:

 Strategic extensions close to Luton’s urban edge; or

 Moderate extensions to existing villages and towns with good connectivity and access to services.

In order to meet this need, the Council acknowledges that the release of Green Belt land must be considered in the context of the wider objectives of the Local Plan and the pursuit of sustainable development (Para 9.2.1).

The draft Local Plan identifies that there is a need to strike an appropriate balance between removal of sites from the Green Belt to meet housing pressures from neighbouring authorities while maintaining local character and its role in preventing coalescence.

Paragraph 9.2.4 acknowledges that:

“Our Green Belt settlements have seen very limited development in the past due to the presence of Green Belt, and it is considered that some growth is needed here in order to maintain their sustainability and ensure continued provision of services and facilities.”

Furthermore, within the draft Local Plan, Flitwick is identified as a Major Service Centre, providing a focus for employment, shopping and community facilities for the local community and surrounding rural communities.

The site falls within Growth Area A. The draft Local Plan looks at growth in the rail corridor between Luton and Flitwick, which this site falls within. This objective seeks to concentrate growth along key transport corridors, promoting sustainable development in an area that has seen little growth due to Green Belt restrictions.

The Spatial Strategy includes options for concentrating moderate growth in the rail corridor between Luton & Flitwick, therefore promoting sustainable development in an area constrained by Green Belt.

2 c. Loss of Community Use

Policy HQ2 of the emerging Local Plan states that development which proposes the change of use or loss of land and buildings which are currently or were previously a community infrastructure use will be resisted. Permission will not be granted for change of use unless the applicant can prove that:

 The use no longer serves the community, and significant evidence is provided to demonstrate that it is surplus to requirements and there is a lack of need for any other community uses at the facility; or

 The loss would be replaced by equivalent or better provision either on site or at an appropriate accessible location; or

 Evidence is provided which satisfactorily demonstrates that the use is no longer financially viable, and all reasonable efforts have been made to sell or let the premises for a community use at a reasonable price for at least 12 months.

As detailed above, the local health commissioners are currently developing a strategy for the future delivery of health services in this area.

To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate code requires that any property to be disposed of is first listed on “e- PIMS”, the central database of Government Central Civil Estate properties and land, which allows other public sector bodies to consider their use for it.

The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver health services from modern and fit for purpose facilities is crucial. Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are provided, and that the estate is fit-for-purpose, additional protection through planning policy should be unnecessarily in relation to public healthcare facilities.

Therefore, if all/part of the site is declared as surplus to the operational healthcare requirements of the NHS by health commissioners, this should be considered sufficient to satisfy Policy HQ2. d. Site Suitability

As set out above, the site is located within the Green Belt. Given the built form on site, the site constitutes previously developed land within the Green Belt. It is considered, that when assessing the function this site performs within the Green Belt, it is very low. Accordingly, when reviewing release of land from the Green Belt, it is sites such as this which should be considered first.

Taken into account the sites location, and the recent, large scale, mixed use development to the south of the site, it is considered that redevelopment of this site would respect the surrounding area.

The site is bound to the north and east by open fields, creating a distinct restriction to development beyond the existing built form. Given this, the location of the site, and the surrounding land use, this should overcome concerns regarding future development coalescing with Ampthill. e. Summary

As detailed above, it is considered that the redevelopment of Steppingley Hospital, would contribute to the Council’s Housing Need. This site presents an excellent opportunity for a moderate extension to an existing town with good connectivity and access to services.

Should all/part of the subject site be declared surplus to the operational healthcare requirements of the NHS (decision expected within 5 years), it should be considered suitable for alternative uses

3 including a range of residential accommodation, depending on the needs of the local community which may include provision for the elderly.

The site falls within the Green Belt but is evidently previously developed land. In addition, redevelopment of this site would adjoin the existing town of Flitwick and recent Froghall Road development, without the need for significant infrastructure. The subject site is considered available, suitable and deliverable.

I trust that these representations provides the Planning Authority with sufficient information to consider this for residential development within the forthcoming Local Plan.

We would request to be kept informed of future stages of the Local Plan preparation. If you require any further information, please contact the undersigned (email: [email protected] Tel: 0203 435 4213) or my colleague Sophie Hardy (email: [email protected] Tel: 020 3435 4217).

Yours sincerely,

Leona Hannify DIRECTOR

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