Object

Representation ID: 5919

Received: 08/09/2021

Respondent: Mr Tom Tagg

The comments for Options 2b, 2c and 2d FAIL TO IDENTIFY the negative issues arising from the inclusion of new settlements, i.e.:
• Greener: The loss of high quality agricultural land for Wyboston/Dennybrook is not identified. The negative impact on air quality because of the greater need to travel by private car is not identified (but is for the same settlements in options 3a, 3b, 3c, 5 and 6).
• More accessible: The fact that Wyboston/Dennybrook is not a development near to a rail station is not identified. It is not recognised that the dispersal of growth to new settlements is likely to increase the need to travel and trip lengths significantly. This is unlikely to be by walking, cycling or public transport meaning that there is likely to be a significant increase in private car use. But this is identified for the same settlements in options 3a, 3b, 3c, 5 and 6?
• More Prosperous: The fact that Wyboston/Dennybrook is 12 miles from Bedford and its residents will use St. Neots to the detriment of Bedford fails to be recorded. A bland statement of “The effect on town centres is uncertain.” is insufficient. Yet for the same settlements options 5 and 6 note that “Town centres will not benefit as the benefits of growth are dispersed away from the urban area.”
I can only conclude that the summary comments in this table are MISLEADING in respect of options 2b, 2c and 2d. If these have informed the strategy for these options to become BBC’s emerging preferred options, then BBC need to URGENTLY RECONSIDER their emerging preferred options.
3.28 and 3.29 High level transport conclusions:
As noted in items 1.23-1.27 (AECOM transport models) above the conclusions in these two paragraphs are seriously FLAWED, notably, inter alia, as follows:
• The model significantly underestimates the numbers of vehicles leaving the Wyboston/Dennybrook development in the AM peak hour. The conclusion in 3.28 that “…the forecast impacts of the proposed development at Dennybrook are not significant in terms of generating additional delays and congestion on the highway network.” is INCORRECT and cannot be relied upon.
• The note in 3.28 that “Twinwoods and Colworth – the assessment highlighted significant forecast delays and congestion at the Clapham Road / Manton Lane roundabout to the north of the Bedford urban area, particularly in the PM Peak hour (17:00 to 18:00), both with and without the proposed mitigations which is an issue for both developments as the modelling shows up to six minute delays at this junction.” is an INCORRECT SUMMARY. THIS ISSUE ARISES IN THE 2030 REFERENCE CASE with the developments allocated in the current Local Plan and planned highways mitigations, before any new developments (e.g. Twinwoods and Colworth) are considered. When they are considered they add little to the congestion at this junction. A solution to this junction congestion issue needs to be found by BBC by 2030, irrespective of any local plan 2040 proposals by developers north of Bedford on the A6.
• The resulting conclusions at 3.29: “The main area where additional mitigation is not identifiable is on the A6 approach to Bedford from the north. In the absence of currently deliverable railway stations at either location which might make an impact, the capacity issues here are too great to allow further development on the A6 (north) corridor such as the new settlements proposed at Twinwoods and / or Colworth.” ARE INCORRECT. This is a 2030 issue that BBC have to solve, irrespective of any local plan 2040 proposals by developers north of Bedford on the A6.
I can only conclude that these conclusions are MISLEADING and if these have informed the strategy for the dismissal of developments north of Bedford and the selection of BBC’s emerging preferred options, then BBC need to URGENTLY RECONSIDER their emerging preferred options.
THE ABOVE ISSUES HAVE BEEN CARRIED FORWARD INTO THE CONCLUSIONS AND RECOMMENDATIONS IN PARAS 3.32 TO 3.41, AND THEREFORE THESE ARE INVALID AND NEED TO BE REASSESSED.