Object

Representation ID: 9006

Received: 03/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

“Given the highway constraints on the A6 north of Bedford (including both new settlements
KSCs and RSCs), the need to allow villages already planning development to assimilate
that growth, the more dispersed nature of the distribution of growth and the loss of focus on
EWR, these options do not perform as strongly.”

The Council’s claims regarding the level of impact generated by any level of development at
Key Service Centres and Rural Service Centres are not justified. The Council primarily relies on evidence of other components comprising part of these strategy options (particularly
‘New Settlements’ on the A6) as generating a significant element the highways impact on the
highways network.

The assumed impact arising from village-related growth specifically results from the first
stage of testing undertaking in the AECOM Transport Model. Paragraph 1.2.2 of the
Summary Report explains that this was only considered as part of testing of four general
development scenarios, relating to the ‘grey’ (dispersed) option providing no focus upon
strategic growth locations within the corridor:
“this scenario includes all sites identified as part of the Local Plan 2040 call for sites
consultation with the size of the proposed developments scaled uniformly to ensure that the
overall growth in the borough is considered to be in the likely range of the new Local Plan
housing and employment targets.”

This approach to testing bears very little relationship with the Council’s subsequent testing
of strategy options where the opportunity to focus some growth on the urban area and A421
corridor is not disputed. Levels of growth required to be tested under the ‘dispersed’ scenario
are materially higher than the relatively limited proportion of ‘village-related’ growth in Option
3c not otherwise associated with ‘east’ and ‘south’ corridor parishes. Moreover, the AECOM
testing of the ‘dispersed’ scenario has the same flaws as the Council’s testing of ‘villagerelated’
growth in the strategy options by opting for a ‘uniform’ or ‘one-size fits all’ approach
to levels of development at individual settlements. This overlooks where site-specific or
settlement-specific justification for site selection could reduce impact on the highway
network.
Upon beginning the process for identifying strategy options the Council has acknowledged
the need for subsequent Transport Modelling. This is set out at paragraph 1.4.1 of the
AECOM Summary Paper and includes additional testing of ‘New Settlement’ options on the
A6.
Our client has instructed Transport Consultants SDD to undertake a ‘Review of “Bedford
Borough Transport Model’, including the specific assessment of impact of New Settlements
on the A6. A copy is enclosed at Appendix 7.

The findings of the Review confirm:
• Beyond levels of committed growth to 2030 in the ‘reference case’ the AECOM
scenarios are based upon different levels of growth at Twinwoods and Colworth
only, and whether each / both sites are brought forward.
• No sensitivity testing has been undertaken whereby the two new settlements at
Colworth and Twinwoods do not come forward, and instead housing growth
development at other existing villages across Bedford Borough.
• There is no justification provided within the report as to why the focus of
assessment has been focused on the development at Colworth / Twinwoods only,
as opposed to assessing potential levels of ‘village-related’ growth in accordance
with Option 3c north of Bedford from a highways capacity perspective
• No assessment is provided of the dumbbell roundabouts off the A6 in the vicinity
of Oakley, nor the junctions with Highfield Road further north along the A6
• There is not specific testing of impacts and changes to the network resulting from
the deferral of site allocations to Neighbourhood Plans – specifically the need for
a new roundabout on the A6 required as part of the proposed Hill Farm
development.

It follows from the above that the Council’s conclusions for strategy options in the
Development Strategy Topic Paper and reasons for the selection of Preferred Options at
Paragraph 3.12 of the Consultation Document are not justified and not consistent with
national policy.

The Council has not only failed to justify that the impact of Option 3c on the highway network
would be severe but failed to begin preparation of Transport Modelling that would in any way
allow it to test a ‘hybrid’ approach to development in providing for an appropriate strategy.
The requirement for further testing is significant in terms of ensuring further site-specific and
settlement-specific testing of options maximises the potential to achieve benefits for the
highway network in accordance with paragraph 110 of the NPPF2021, for example:
• Assessing the opportunities to relieve congestion at Station Road, Oakley
associated with Lincroft Academy through provision of a new dedicated access
together with supporting sustainably located residential development within easy
walking distance of Primary and Secondary education in the village
• Promoting growth adjacent and well-related to the Sharnbrook Settlement Policy
Area, facilitating opportunities for the delivery of new and accessible services and
facilities (including a Primary School) within walking distance from existing
residents of the village in order to sustain and enhance its role.

This section of our representations (and supporting information at Appendix 6) confirms the
requirement to undertake further detailed testing of a ‘hybrid’ strategy option including an
accurate assessment of potential impacts on the highway network.