Question 11
11.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.
12.0 QUESTION 11 – MODAL SHIFT AND SUSTAINABLE TRANSPORT 12.1 On behalf our client’s we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 12.3 Revision to strategic policies and additional allocations provided as part of the Review of the Local Plan should ensure that opportunities to sustain and enhance the role of Key Service Centres and Rural Service Centres are maximised. This should also be supported by a review of the capacity for growth in order to deliver the requirements for development in each settlement. 12.4 This can be achieved as part of a ‘Dispersed’ spatial option, which the Council has previously determined as equally sustainable when considering levels of growth in the rural area. Greater weight should be given to recognise the cumulative benefits of growth in locations that contribute to meeting local requirements for sustainable development (in terms of accessible social and community infrastructure) and delivery of the Plan’s strategic priorities such as meeting the needs of education. This is the case for our client’s interests in both Sharnbrook and Oakley in terms of promoting safer and more sustainable access to existing education facilities and supporting future demands for growth. This should be reflected in the Council’s site assessment and site selection process.
12.1 On behalf our client’s we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 12.3 Revision to strategic policies and additional allocations provided as part of the Review of the Local Plan should ensure that opportunities to sustain and enhance the role of Key Service Centres and Rural Service Centres are maximised. This should also be supported by a review of the capacity for growth in order to deliver the requirements for development in each settlement. 12.4 This can be achieved as part of a ‘Dispersed’ spatial option, which the Council has previously determined as equally sustainable when considering levels of growth in the rural area. Greater weight should be given to recognise the cumulative benefits of growth in locations that contribute to meeting local requirements for sustainable development (in terms of accessible social and community infrastructure) and delivery of the Plan’s strategic priorities such as meeting the needs of education. This is the case for our client’s interests in both Sharnbrook and Oakley in terms of promoting safer and more sustainable access to existing education facilities and supporting future demands for growth. This should be reflected in the Council’s site assessment and site selection process.
12.1 On behalf our clients we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 12.3 Specifically, in relation to the Council’s spatial options, greater weight should be given to site options providing for A421-based growth. As acknowledged in the Council’s list of advantages for this strategic option the A421 corridor provides sustainable links to a wide range of employment opportunities. In terms of modal shift the corridor already benefits from intercity public transport links connecting major settlements within the Oxford-Cambridge Arc with other sustainable settlements such as Great Barford. Specifically, the route of the X5 provides direct connections east towards Cambridge. Journeys on the same route can be continued west beyond Bedford, including access to the major employment hub in Central Milton Keynes. Services are accessed from the close to the heart of the village via stops at the Golden Cross on the Bedford Road/Roxton Road crossroads and thus in very close proximity to our client’s site. 12.4 This means that modal shift objectives are particularly relevant in the case of site options such as our client’s Land at Willoughby Park, which also relate well to existing services and facilities in Great Barford and would contribute to the provision of new, accessible, social and community infrastructure. Greater weight should also be given to sites within a single ownership, supported by comprehensive Masterplan proposals, that illustrate the absence of constraints to delivery of the benefits identified. 12.5 The cumulative benefits of growth in this location in terms of contributing to meeting local requirements for sustainable development and delivery of the Plan’s strategic priorities should be reflected in the Council’s site assessment and site selection process.
9.1 The consultation document sets out sensible suggestions such as safe and green cycleways, dedicated busways or more innovative transport systems and modes. However, what it does not recognise is the importance of locating development in the correct locations which will in turn encourage people to make greater use of sustainable modes of transport. 9.2 Placing development near to sustainable transport nodes, or developing new transport nodes and interchanges, will make it more attractive for residents to use those methods of travel. Proximity to existing services and facilities, particularly those such as schools, is effective at discouraging car use and encouraging walking and cycling. 9.3 Similarly, improving connectivity between these various locations for non-vehicular means of travel will encourage the use of transport methods other than the private car.
Free car parking with regular, free and clean sustainable transport to and from bus and railway stations and local rural areas. More parking on site at Bedford Station and build the long promised station at Wixams. Reliable, regular fast train service to and from London. More safe routes for cyclists and walkers to link existing communities together. Accessibility and genuine costs must be determining factors.
High-frequency, easy to understand and comfortable public transport and a cycle and pedestrian network that is safe, affordable and enjoyable to use to use.
As set out in the answer to question 5 above, the need for investment in new cycle ways is considered to be particularly important.
9.1 The consultation document sets out sensible suggestions such as safe and green cycleways, dedicated busways or more innovative transport systems and modes. However, what it does not recognise is the importance of locating development in the correct locations which will in Arrow Planning on behalf of AWEL LOCAL PLAN REVIEW ISSUES AND OPTIONS CONSULTATION 7 turn encourage people to make greater use of sustainable modes of transport. 9.2 Placing development near to sustainable transport nodes, or developing new transport nodes and interchanges, will make it more attractive for residents to use those methods of travel. Locating jobs near to existing settlements and homes and new/growing developments, as well as near to existing railway stations will encourage residents to commute by foot, cycle, bus and rail, rather than the car. 9.3 Similarly, improving connectivity between these various locations for non-vehicular means of travel will encourage the use of transport methods other than the private car.
Notwithstanding the potential for a new railway station, it will be important to consider sustainable transport links between North Northamptonshire and Bedford Borough, notably on the A6.
9.1 On behalf our client’s we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 9.2 We support the Borough’s proposed Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 9.3 Revision to strategic policies and additional allocations provided as part of the Review of the Local Plan should ensure that opportunities to sustain and enhance the role of smaller settlements are maximised. This should also be supported by a review of the capacity for growth in order to deliver the requirements for development in each settlement. 9.4 This can be achieved as part of a ‘Dispersed’ spatial option, which the Council has previously determined as equally sustainable when considering levels of growth in the rural area. Greater weight should be given to recognise the cumulative benefits of growth in locations that contribute to meeting local requirements for sustainable development (in terms of accessible social and community infrastructure) and delivery of the Plan’s strategic priorities such as meeting the needs of education. This should be reflected in the Council’s site assessment and site selection process.
1.39. The provision of new and enhancement of pedestrian and cycle routes to local facilities and accessibility to public transport are clearly ways in which we can encourage the greater use of sustainable modes of transport through the Local Plan. 1.40. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.41. New development on larger sites can and should be required to deliver new public routes which link with existing footpath and bridleway networks. 1.42. New developments should also be required to deliver Electric Vehicle Charing points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles. 1.43. More generally considerations should be given by the Council to ensuring that residential and employment uses are comprehensively plan and located adjacent to each other so as to maximise internal trips. 1.44. Large scale developments in particular can play an important role in influencing people’s behaviour given its scale of infrastructure.
1.37. The provision of new and enhancement of pedestrian and cycle routes to local facilities and accessibility to public transport are clearly ways in which we can encourage the greater use of sustainable modes of transport through the Local Plan. 1.38. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.39. New development on larger sites can and should be required to deliver new public routes which link with existing footpath and bridleway networks. 1.40. New developments should also be required to deliver Electric Vehicle Charging points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles. 8 PHILLIPS PLANNING SERVICES LTD 1.41. The provision of dedicated charging stations for EV ‘s along the A421 would also encourage a change in people’s behaviour by providing greater convenience and enable movement along the corridor in more sustainable vehicles. A lack of dedicated charging stations on main routes continues to be a bar to use of EV’s for longer journeys. 1.42. The Estate have made submissions as part of the Call for Sites process highlighting the availability of land for allocation as an EV charging facility.
1.29. The provision of new and enhancement of pedestrian and cycle routes to local facilities and accessibility to public transport are clearly ways in which we can encourage the greater use of sustainable modes of transport through the Local Plan. 1.30. In particular, enhancing pedestrian and cycle connectivity, and delivering improvements in safety on routes is important. 1.31. New developments should also be required to deliver Electric Vehicle charging points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles.
1.29. The provision of new and enhancement of pedestrian and cycle routes to local facilities, and accessibility to and frequency of high quality public transport are clearly ways in which the Borough can encourage the greater use of sustainable modes of transport through the Local Plan. 1.30. In particular, enhancing pedestrian and cycle connectivity into a network across the Borough of consistent high quality, and delivering improvements in safety are important. 1.31. New developments should also be required to deliver Electric Vehicle Charging points as part of the standard design of new homes and business premises to encourage the shift from petrol and diesel to electric vehicles.
2.20 The ability to walk, cycle or access public transport is dependent on where new homes are built with regards to their proximity to services and facilities. Beauchamp Park is ideally located to the west of Bromham where new residents will be within walking and cycling distance of existing services and facilities within the village. With the ever-increasing need for new homes in the Borough it is essential that sites in demonstrably sustainable locations, like Beauchamp Park, come forward without delay. The application has now been with the Council for almost a year and there is still no date for it to go before the planning committee with an officer recommendation of approval. Similarly, the application to the east of MGH’s site (LPA ref. 17/02242/MAO) was submitted in 2017 and officers were originally given delegated powers to approve the application in October 2019. This application was not determined until late August 2020. It is essential that the Council invests in its development control teams to ensure that applications for sites that are allocated, or about to be allocated, are approved without delay.
11.1 O&H consider convenience as one of the driving factors to encourage people to make greater use of sustainable modes of transport. 11.2 To achieve this, new development needs to be located near sustainable modes of transport i.e. close to railway stations such as Stewartby and Kempston Hardwick. 11.3 O&H consider the existing rail network in the Borough including local stopping stations at Stewartby and Kempston Hardwick will play a valuable complementing role to East-West Rail once it is complete. 11.4 The Council needs to locate future development in the initial years of the emerging Plan period around these local stopping stations until East-Rail is complete and operational. This approach will ensure local residents make the best use of the existing sustainable modes of transport until the wider network is operational. 11.5 O&H responded to the Authority’s ‘Call for Sites’ consultation on 14 August 2020 to put forward five sites that are completely within O&H’s ownership which could be developed during the emerging Plan period. 11.6 Of the sites promoted by O&H, Broadmead Farm, CP Farm and Land at Kempston Hardwick are all well situated to take advantage of the existing rail network in the Borough and create an environment which encourages local residents to make greater use of sustainable modes of transport.
The Borough Council needs to substantially increase investment in high standard footways/cycleways linking existing communities together, integrating new development and coordinating with other sustainable modes of transport.
12.1 It is vital that sustainable travel provides a ‘joined up’ approach to encouraging people to use more sustainable modes of transport. Although this may not be possible for all journeys, providing people with a realistic alternative to travel by car is vital to the success of embedding a model shift. 12.2 By strategically placing larger employment areas in accessible locations, it would be possible for any operator of this employment site to prepare a travel plan which would consider where employees live and how they can access their place of employment. It is anticipated that this would be developed as part of the planning application and could be linked to any permission through a legal agreement.
As set out in the answer to question 5 above, the need for investment in new cycle ways is considered to be particularly important.
11.1 It is vital that sustainable travel provides a ‘joined up’ approach to encouraging people to use more sustainable modes of transport. Although this may not be possible for all journeys, providing people with a realistic alternative to travel by car is vital to the success of embedding a model shift. 11.2 The recent changes to work and travel patterns born from the Covid 19 pandemic has demonstrated that trip numbers can be reduced, and many people do not need to travel as much for work in particular. It also saw a dramatic decrease in the use of trains and buses. In addition, changes to our shopping patterns have been experienced. Allowances must be made to ensure a flexible approach to sustainable modes of transport allowing for unforeseen changes and technological advancements.
Priority parking for (pure) electric vehicles with easy access to high power/ rapid charging. Free buses on very limited, high volume routes, eg Wixams to town centre, but that may interfere with attracting operators for the broader network.
43. Please see our response to Question 5.
We would love all the above to be put into policies that would enable it to happen.
As a rural Parish, our obvious concerns relate to the provision of a reliable bus service. The answers provided to Questions 4, 5, 6, 7 and 8 already respond to the question in the generality but ultimately the Council will only be able to encourage the use of sustainable modes of transport if it is provided, widely available and at an affordable cost.
It is our view that the Local Plan, whilst acknowledging to an extent the public rights of way network within the Borough, does not give enough recognition to these as an important leisure amenity as opposed to a transport facility. The bridleway and byway network in the Borough is used by horse riders and carriage drivers largely for leisure and for exercise (of both the rider/driver and the horse). It is an important resource for the physical and mental wellbeing of these equestrians, and indeed their horses. Policy 95 is welcomed in that it addresses the importance of the public rights of way to the residents of the Borough, and point iv) in particular is welcomed by the Society. However, we would ask that two additional paragraphs be added to this policy: • There should be no net loss of public rights of way as a result of any particular development • Public rights of way should retain their existing surface or improved surface suitable for all users of the rights of way and should not be tarmaced or converted into roads This latter point is of particular concern to riders and drivers who use the extensive network of bridleway and byways in and around the proposed Colworth Garden Village. The current masterplan would see much of this network being integrated into the Village access and estate roads. This is not, in the Society’s view, appropriate and we would wish to see these equestrian routes remaining available as soft riding/driving surfaces for horses. We do appreciate that the masterplan is an outline only and that detailed planning considerations will apply in due course but nonetheless we ask that the nature of public rights of way surfaces be addressed in this important policy document. There is no mention of horse-riding within Section 5 of the Plan - research undertaken by University of Brighton and Plumpton College and published in British Horse Society Health Benefits of Horse Riding identified that horse riding is moderate level exercise that is especially well placed to play a valuable role in initiatives to encourage increased physical activity amongst women. (A copy of the report can be obtained from http://www.bhs.org.uk/enjoy-riding/health-benefits ). Whilst we accept that horse riding is rarely seen as transport these days (apart maybe from the odd ride to a pub or café), the importance of horse riding as a form of exercise for many of the rural residents of the Borough should not be ignored.
Conclusions As set out above we acknowledge that the Council has a significant task ahead to deliver a plan which can facilitate the delivery of a significant escalation of housing growth. To an extent this problem is partially a result of what we consider to be the Council’s unwillingness to prepare a more ambitious growth strategy as part of the adopted Local Plan 2030. By way of an example, in the event that our client’s land had been retained as one of the large urban extensions at the town it is likely that its delivery would have now progressed to the point that first completions on site could Bedford Local Plan Review – Issues and Options Submission on behalf of Manor Oak Homes 6 be expected within the next year. We urge the Council to take a more positive stance when identifying the spatial strategy of the next plan with a clear focus on delivery. On this basis, and recognising the availability of a site capable of accommodating an immediately deliverable residential-led scheme comprising 400 dwellings and land for a new primary school under the control of our client, we commend the Council to pursue a strategy which allows for growth on the urban edge of Bedford. Specifically, we recommend either the urban focused or dispersal options as a priority. An additional point that is covered by the I&O document but is not subject of a specific question is the housing target for the plan. Following the publication of the Government’s draft replacement standard methodology there is now greater clarity in respect of the level of growth that the Borough will be required to accommodate – between 13,000 and 15,000 additional homes. Once the final version of the formula is published, we urge the Council to run a further consultation seeking views on the housing target for the plan area specifically and how provision should be made for additional growth relating to the Oxford Cambridge Arc. As is made clear by the Inspectors overseeing the Local Plan 2030 the ability of the replacement plan to accommodate growth resultant of this strategy will be critical, particularly as the revised plan period is to run until 2040. We trust that the enclosed information is helpful and of a sufficient level to allow our client’s views to be taken on board at this stage. However, should you have any queries or require any further information to assist this process, do not hesitate to contact me. Otherwise, we look forward to continuing to engage with the emerging Local Plan Review process as it unfolds. Yours faithfully
Bedford Borough is well served by strategic transport corridors, with the A421/ east west rail corridor, and A6/ Midland Mainline corridor. It is noted that the proposed Plan vision highlights the opportunities that the new east/ west rail route will offer, in association with the Oxford to Cambridge Arc. However, East Northamptonshire Council would also highlight the potential for enhanced connectivity along the north/ south A6/ Midland Mainline corridor.
The town and country planning system has no control and little influence on the provision of public transport services, and relatively little direct influence on its use. Encouragement in the form of (for example) shelters, seats at bus stops and real time information is the responsibility of the providers. Nevertheless there is much that the planning system can do. First, it should provide for a distribution of development which will either encourage the greater use of existing public transport services or be on a scale which supports the provision of new services. However, we think the scope for the latter in these circumstances is limited, especially if the residual housing requirement is at the lower end of the range discussed in the Consultation Paper. Secondly, the Borough Council should in its engagement with applicants at both outline and reserved matters stages pay particular attention to layouts and other factors which encourage travel on foot and by bicycle. The land west of the A1 at Wyboston is ideally located to promote travel to St Neots on foot and by bicycle.
A sense of realism about the issue. To take just one example: electric cars. Leaving aside the fact that battery technology is flawed and what to do with millions of dead batteries is another (perfectly predictable) crisis just around the corner, the almost complete absence of charging points makes their use unrealistic for most people. If the BBC were serious about this as an issue it would have installed hundreds of charging points in all its car parks and not just the odd token few. This is an obvious example that in Bedford (and to be fair much of England) infrastructure has never remotely been adequate, and for the Plan to suggest that it will be in future invites scorn and disbelief.