Object

Representation ID: 6218

Received: 09/09/2021

Respondent: Peter Coles

Staploe Parish Council did not agree that this consultation was sound or fair. We responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or under utilised land. Our whole parish is classed as open countryside for planning purposes. Our three tiny hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.

We believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots which are already under pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here to make sustainable travel choices – we have one bus on Thursday and it would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would not improve viability of retail and leisure in Bedford Borough. People would go to St. Neots.”

We still feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.

In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses: Number of respondents = 315
• 222 were from within the borough – out of a total estimated population of 174,687. This is a pitiful 0.12% response rate
• 93 were from outside the Borough or did not give a postcode
• 53% were from individuals.

Top areas for numbers of responses:
• Bedford 46
• Sharnbrook 23
• Staploe 18 (a 6% response rate which was 50 times the Borough average)
By contrast – no other areas were in double figures. This brings into further question the validity of the consultation. We believe Bedford Borough Council should be arguing for an extension of time such that the Local Plan 2030 remains “in date” for another year to enable proper consultation, to allow the East West rail route to be announced and for the Oxford Cambridge Arc to decide about development corporations.

3.11 100 word summary
Staploe Parish Council believe that the Issues and Options consultation was invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2).
We would also call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.
A rail based growth strategy policy may be required if growth is to be located around rail.

3.12 Following the 2020 consultation, the Council commissioned consultants to assess the likely effects of four development scenarios on traffic flows in the borough. That work is published as the evidence base document Bedford Borough Transport Model Local Plan Assessment Summary Report (see Table 1). The report explains that four spatial scenarios, chosen for highway testing purposes, were assessed and it provides a high-level comparison of spatial growth scenarios looking at seven key transport metrics and identifies the mitigation measures that would be required by each scenario. The report offers a comparison between scenarios. More detail on these scenarios is included in the Development Strategy Topic Paper.

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.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

As part of the Bedford Borough Transport Model documents it is quoted that average departing trips are 20 to 25 vehicles, which may be below the trip rates assumed as part of a detailed development assessment. The extract below is taken from the New Settlement West of Wyboston document.



It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.
The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.
Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.
Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.
If larger new settlements are the only realistic option then they should be centred on transport hubs such as a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.