Object

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

Representation ID: 5917

Received: 08/09/2021

Respondent: Mr Tom Tagg

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is FUNDAMENTALLY FLAWED for the following reasons:
• General: No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport guidance.
• 2.4.2 Despite employment land being allocated in the BBC options, AECOM have assumed that no employment has been assumed to be associated with the proposed developments. This underestimates the journeys of employees and delivery vehicles to/from the sites.
• 2.4.3 AECOM have not applied site-specific trip rates but have adopted trip rates using a DfT model (CTripEnd). This results in “around 20 to 25 outbound car vehicle trips in the AM peak hour,”. The Dennybrook development scenario options range between 2,500 and 10,150 houses. With a likely 2 cars per household, i.e. up to 20,300 cars, allowing only 20-25 cars is clearly a gross underestimate of the number of outbound car vehicle trips in the AM peak.
Given these, all of the assessments undertaken by AECOM to determine the rerouting, vehicle km travelled, junction delays and junction-capacity ratios for any scenario are highly unlikely to be representative.
2.4.4 Without detailed site access and the internal development network being unavailable, AECOM have assumed various access points onto Staploe Road. This road is at best narrow two lane but most of it is single width with passing places. This is a country/farm road totally unsuited to 20,300 cars accessing it and using it. AECOM take no account of this. The model therefore also fails to recognise the actual physical constraints present on the ground.
2.5.10 Proposes two additional mitigation measures. One measure is to add a roundabout at the Bedford Road/Roxton Road junction to replace the existing priority junction. However the model states that this is not needed until the 2040 scenario of 5,000 dwellings. This clearly demonstrates how the model underestimates and fails to recognise the actual issues on the ground – this is a minor junction and Roxton Road is a narrow country/farm road – this will be unsuitable for a few hundred new dwellings, not 5,000.
Table 2.6 lists additional mitigation measures proposed by AECOM. This includes the rerouting of the existing 905 Bedford-Cambridge bus service through the development site, exiting the A421 at the new interchange and entering St Neots via Bushmead Road. The roads though the development are minor country roads unsuited to these busses. The Bushmead road is dangerously narrow for busses and HGVs, and entry into St. Neots is past a busy primary school, in a 20mph zone with extensive traffic calming measures – all unsuitable for the bus route.
2.5.17 AECOM note that development of additional potential mitigation measures
has not considered any safety issues which may arise from additional traffic using minor roads in the vicinity of the proposed development, such as along Staploe Road. AECOM recommended that a review of these locations is undertaken as part of any future planning application to understand if highway improvements are required on safety grounds in and around the proposed development. This is too late – assessment of the many and significant safety issues highlighted above must be carried out before the Dennybrook development can be considered for inclusion in the Local Plan.
4.2.8 Concludes that there is remaining capacity at the key junctions. This conclusion is wholly unreliable due to the failures to correctly model, as detailed above and the failure to account for correct traffic numbers, the size, quality and safety of the existing local country roads, the Bushmead Road and impact of traffic restrictions when entering St. Neots.