Object

Representation ID: 9007

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Highways Capacity and Development to the North of Bedford
3.1 TwinWoods is not a shortlisted site for the emerging 2040 Local Plan review. The reason for this appears to be almost solely due to traffic capacity issues at the Manton Lane/Clapham Road/A5141 roundabout on the A6, in north Bedford, as it is perceived through the Bedford Borough Transport Modelling (BBTM) results alone. In addition to TwinWoods, development of any other sites north of Bedford appears to have effectively been ruled out with no exceptions based on highway capacity grounds. There is no apparent consideration of measures to overcome these concerns through reallocation of roadspace, nor the opportunities to be gained through implementing policy compliant Garden Village principles central to the development of the TwinWoods proposals.
3.2 Vectos has undertaken a detailed review of BBC’s highways evidence, especially the modelling, this is appended to this consultation response at Appendix 1.
3.3 However, stepping back, we consider that the approach BBC has taken to its 2040 Local Plan site selection process is an incorrect one. It is not policy compliant in the context of the Climate Emergency declared by BBC, as it follows a ‘predict and provide’ approach to traffic capacity that ignores mobility as a whole, contrary to leading transport guidance. This guidance, amongst many other things, includes a commitment to embed transport decarbonisation principles in spatial planning and across transport policymaking and accelerate modal shift to public and active transport (Department for Transport paper – Decarbonising Transport published in July 20215).
3.4 The recent changes to the NPPF 2021 make moves in a similar direction including reference to the 17 Global Goals for Sustainable Development at paragraph 7, the need for plan making to promote sustainable patterns of development to align growth and infrastructure with improving the environment and mitigation climate change (paragraph 11a) and planning for larger scale development needing to be supported by necessary infrastructure and facilities including a genuine chose of transport modes (paragraph 73). A more minor change includes reference to planning policies aiming to achieve healthy, inclusive and safe places through the use of attractive, well-designed, clear and legible pedestrian and cycle routes.
Vision & Validate or Predict & Provide in Planning Policy
3.5 Vision & Validate (V&V) is an expression coined to represent current planning policy expressed in the NPPF. The labels have been applied to distinguish the approach from the discredited and abandoned, except in particular circumstances, Predict & Provide (P&P) which has been used in the BBTM evidence.
3.6 V&V embraces masterplanning, planning and transport. The constant threads, and highest priorities, are climate, health and economy (NPPF paragraph 8). In contrast, P&P was commuter traffic focussed (traditional morning and evening peak hours), and its highest priority was providing convenience for those that would prefer to drive at the busiest times. V&V is an inward out approach to decide, or establish, the vision for what is desirable, and design to achieve that.
3.7 The recently published DfT Paper ‘Decarbonising Transport’ (July 2021) endorses the V&V approach:
“We recognise that the Government has a role in helping Local Planning and Highways Authorities to better plan for sustainable transport and develop innovative policies to reduce car dependency. We need to move away from transport planning based on predicting future demand to provide capacity (‘predict and provide’) to planning that sets an outcome communities want to achieve and provides the transport solutions to deliver those outcomes (sometimes referred to as ‘vision and validate’). We will continue to work with MHCLG to identify how we can best support local authorities to develop innovative sustainable transport policies as part of the planning process, how this can be used to better assess planning applications, and better monitor local transport outcomes to deliver on our ambitions for sustainable transport use6.”
3.8 When it comes to considering traffic, there is a fundamental difference in thinking between national planning policy as it now is, and P&P as adopted by BBC’s approach to it’s Plan. In real life, traffic is a function of available roadspace. At busy times, increasing road capacity generates traffic, and reducing road capacity reduces traffic. Capacity is a tool. This can be seen by observed effect throughout the country. It is no coincidence that gridlock never occurs on a regular basis. A good example is in London, where since 2000 road capacity has been reduced across all areas, with a reduction of 30% in the Central Area. Research from the EU CREATE report, also reported in TfL’s Travel in London Report no. 9 states:
“Research as part of the CREATE project has found that in London over the last ten years up to 25% of road space on key routes in London has been reallocated from private vehicle to cycling, walking or public transport infrastructure. However average journey time / congestion today is broadly the same as ten years ago. This has been achieved whilst accommodating 7 million more journeys today (all modes) per day (increasing from 24m to 31m). This capacity has been unlocked thanks to the modal shifts. This shows that efficient reallocation of road space can unlock capacity for more journeys, accommodating population and economic growth, whilst keeping congestion constant.”
3.9 P&P looked at it a different way. It made the judgement that a notional forecast of traffic would come what may, and because of that it needed to be accommodated, often by road building. This was self-fulfilling and is one of the reasons why P&P can now be the antithesis of national planning policy in delivering sustainable development. Indeed, there is no expression in the NPPF which promotes P&P, but promotes an approach that has been characterised by the phrase V&V which includes a commitment to mitigating climate change and specifically, the need to provide a genuine choice of transport modes in supporting new settlements, i.e. not just expecting and modelling for unsustainable car-based journeys. Liveable neighbourhoods and sustainable transportation modes need to be built into the design of a large-scale development to comply with the NPPF.
3.10 Even before the latest changes to the NPPF, there have been clear examples of this interpretation.
3.11 In 2013, the Inspector for the Hartford, Cheshire West and Chester, Hartford and School Lane Section 78 Inquiries included in his determination that “it is not the aim of policy to protect the convenience of commuting car drivers”. The decision was called in by the Secretary of State, who agreed with the Inspector’s conclusions and recommendation and allowed the Appeals for a total of 650 homes7.
6 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 158
7 Appeal References: APP/A0665/A/12/2179410 & APP/A0665/A/12/2179374
3.12 In 2016, Stevenage Borough Council submitted a Mobility Strategy in support of its Local Plan, and with the agreement of Hertfordshire County Council as highway authority. The strategy explained that it steered away from the historic and contra policy P&P, and that instead of prioritising road building the strategy was to prioritise mobility as a whole. It assumed no peak period traffic growth beyond the designed capacity of the network, taking into account some pinch point works, focussing its infrastructure funding on more sustainable means of movement. The Local Plan Inspector endorsed this approach8.
3.13 In 2016 Cardiff County Council promoted a 50:50 approach to traffic in Cardiff. It built a traffic model and loaded it with traffic forecasts for a Local Development Plan growth of about 40,000 homes and 40,000 jobs, and, by design, no new road infrastructure except where it provided bus priority. They removed traffic from the model until it ‘functioned’. They assumed that traffic levels would only exist up to the limit of the network (the capacity of the network determines the traffic volume) and then determined what the movement mode split would be in Cardiff for all movement demand to be satisfied, coming up with the expectation that by the end of the Plan period the mode split would be 50:50.
3.14 The V&V approach is unequivocally set out in the Garden City principles (which the NPPF para 73 c directs the reader to) and endorsed by the industry bodies including the Department for Transport (Decarbonising Transport – A Better Greener Britain), the Royal Town Planning Institute9, the Chartered Institution of Highways and Transportation10, the Town and Country Planning Association11 and TRICS12.
3.15 Equally, these industry bodies explain that P&P is abandoned and is used to the detriment of planning better places.
3.16 It is not the case that V&V has no regard to traffic and traffic effects. There are circumstances where maximising road capacity is considered beneficial in planning, for instance in considering regional economic performance. There are also safety implications, particularly in respect of the strategic road network, such as motorway slip roads, where capacity is used for safety as opposed to convenience reasons.
3.17 Following the V&V approach is in accordance with national planning policy and, especially in light of the changes to the NPPF 2021, it is harder to justify how the P&P approach could achieve all the sustainability and climate change commitments of the Framework, and therefore risks the soundness of the Plan.
Highways, Placemaking, Health, Climate Change
3.18 P&P approach to transport planning places too much emphasis on individual travel rather than planning communities which are centred around active travel and public transport which facilitate the behavioural changes that are required for decarbonisation of the transport sector.
3.19 The promotion of 20-minute neighbourhoods is recognised in DfT’s Decarbonising Transport report (July 2021), which has an aspiration to “place cycling, walking and public transport provision at the heart of local plan making and decision taking for new developments” (page 158).
3.20 The policy approach, represented by the phrase V&V, is all encompassing. Traffic is not a subject in its own right, and neither is transport. There is an interaction between masterplanning, land
8 Report on the Examination of the Stevenage Borough Local Plan 2011-2031, Reference: PINS/K1935/429/6
9 Net Zero Transport (RTPI Research Paper, January 2021)
10 Better Planning, Better Transport, Better Places (CIHT, August 2019)
11 Garden City Standards – Guide 13: Sustainable Transport (TCPA, September 2020)
12 TRICS Guidance Note: On the Practical Implementation of the Decide and Provide Approach (February 2021)
use, landscape, economy, mobility, accessibility and traffic. Each affects the other, and there is an iterative procedure required before finalising on the best “place-based solution”13.
3.21 The V&V approach at TwinWoods has embraced this with provision of everything communities need in 20-minute neighbourhoods14, reducing the need for individual travel. The strategic modelling approach undertaken in the BBTM has not and does not. It appears to be a stand-alone traffic-based exercise with some adjustments made for limited mode shift. For this reason the modelling results are not appropriate to make planning decisions in isolation.
How has this impacted TwinWoods?
3.22 In transport modelling terms, the BCC approach to assessing TwinWoods does not look at the new settlement as a new self-sustaining town, but only as additional housing all attracted to Bedford and beyond. This is an archaic view of development, not reflective of what is proposed at TwinWoods, and contrary to BBC’s own visions and objectives.
3.23 In BBC’s ‘Strategy Options and Draft Policies Consultation’ (June 2021) document the Transport Strategy states (p.3.19-3.22):
“The basic premise for transport investment is that business as usual will not get us to where we want to be…
What this means is that in order to deliver sustainable growth; transport investment, travel behaviour and the way we think about moving around will need to change. The impact of continuing with current travel behaviour will have a detrimental impact on the very things that make the area successful…
Increased economic activity and growing populations, if left to continue in traditional patterns of movement and behaviour, will mean people spend longer on congested transport networks, the environment will be degraded, and quality of life expectations will not be met.
The EEH Strategy includes…
• Focus on decarbonisation of the transport system by harnessing innovation and supporting solutions which create green economic opportunities
• Promote investment in digital infrastructure as a means of improving connectivity, in order to reduce the need to travel
• Use delivery of East West Rail and mass rapid transit systems…
Champion increased investment in active travel and shared transport solutions to improve local connectivity to ensure that everyone has the opportunity to realise their potential” (emphasis added).
3.24 An allocation of a new settlement at TwinWoods would meet all of these objectives, and it could be argued that some sites selected in the draft Plan have not demonstrated this but instead rely on new strategic road infrastructure releasing highway capacity at a local level. Using the P&P
13 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 144
14 The 15 minutes-city: for a new chrono-urbanism! – Professor Carlos Moreno; https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 158
modelling results as a pass/fail for development on solely highway capacity terms is the antithesis of BBC’s own aspirations for sustainable growth.
3.25 In section 4.0 of these representations we note that the updated NPPF requires a 30-year vision for the Plan. It will be necessary for BBC to revisit its strategic choices to 2040 in light of the long term vision for the Borough which must recognise that over this longer period – if not by 2040 – there will be structural shifts in sustainable transport that render the current P&P approach underpinning the Plan out-of-date.
How can this be addressed?
Types of Model
3.26 The BBTM is a strategic model which has been designed for the purpose of analysing the traffic performance across the Borough for the 2040 Local Plan. This is a Saturn model and given its strategic purpose, it will ‘load’ traffic onto individual junctions in a manner which cannot occur in reality (i.e. this much traffic simply cannot exist within such a time period). The coarse nature of the software means it often overestimates traffic flows at individual junctions therefore and, when closely scrutinised, will forecast ‘chaos’ in this respect. It cannot be relied upon in isolation as a means of informing decisions around the operation of the highway network.
3.27 A microsimulation model is more appropriate for the assessment of TwinWoods and an individual junction or corridor. This would allow for a more reliable analysis of the behaviour of vehicles at the Manton Lane roundabout by determining the most appropriate highway ‘interventions’. As a result of the greater detail in the model, the outputs are closer to reality than from a strategic model and capacity is more accurately reflected. It is therefore both adequate and proportionate to the task of developing policies for the allocation of TwinWoods in the new Local Plan. As such, its use complies with national policy and is sound in principle.
3.28 As different types of model they have different functions. They are both tools that can be used to inform the Local Plan and demonstrate the soundness of the Local Plan and selected sites, but in different ways. The results must then inform the planning decisions made, rather than dictate them as it appears has been done in Bedford.
3.29 The requirement for soundness is that the Plan should be prepared in accord with National planning policy (NPPF para. 35). NPPF para.31 says: “The preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.”
Alternative Mitigation
3.30 Despite the BBTM not being the correct tool to accurately forecast traffic impacts on specific junctions, BBC has used its results to rationalise what is, in effect, a moratorium on new development to the north of Bedford that will constrain the Plan beyond it’s Plan period and infect its 30-year vision now required by the NPPF.
3.31 The issues at the Manton Lane roundabout become ‘significant’ with the inclusion of an additional 10 years of traffic growth excluding potential 2040 allocation sites. The inclusion of this growth is questionable as it means that the mitigation strategy derived through the modelling is one which can only reinforce existing travel patterns and exacerbate car dependence by continuing to seek to provide capacity for predicted traffic movements. As identified, this is not in line with the direction of national (or indeed local) policy.
3.32 As new allocated developments come forward within Bedford the reality is that they will be developed in line with policy aspirations and will buck historic trends in travel patterns. In this case, congestion at the Manton Lane roundabout is unlikely to occur in the fashion predicted by the BBTM.
3.33 It is not evident that meaningful alternative measures (to road capacity enhancements) have been identified such as re-allocation of road space to higher capacity modes, and the supporting joined-up infrastructure to make these modes a viable form of travel. This is not tested in the BBTM. The below is an image extract from the document ‘Ticket to the future. 3 Stops to Sustainable Mobility’.
Mobility. Figure 3.1 Number of people crossing a 3.5 metre-wide space in an urban environment during a one hour period
Source: Ticket to the future. 3 Stops to Sustainable Mobility. UITP International Association of Public Transport, Brussels. 2003 based on Botma and Pependrecht Traffic operation of bicycle traffic. TU Delft 1991
3.34 Critically however, it is a questionable assumption that drivers will continue to load onto a junction that is operating at capacity without acting to minimise their own inconvenience. This is not realistic and hence excluding beneficial development on this basis is not in accordance with a balanced approach.
Development to the North of Bedford
3.35 TwinWoods is designed as an exemplar Garden Community which embodies the placemaking and transport principles of modern policy. The proposal is for a new town that consumes much of its own movement in the same way as an established town does, but better. It does this through careful design, accommodating those features which make liveable towns successful and futureproofing for emerging innovations.
3.36 The vast benefits of an allocation in this location appears to have been discarded in lieu of the BBTM results.
3.37 It is clear from a wide variety of national planning and transport policy that using highway capacity as a determining factor to new development is outdated, and not sustainable as we move towards the Net Zero targets set out to address the declared Climate Emergency in the UK.
It has been demonstrated that justification for closing north of Bedford to new development is flawed in the following ways:
• The function of the BBTM is not to measure individual junction effects, nor is it to be the whole determinant of site selection in the planning process;
• Alternative measures to increasing road capacity have not been considered, such as reallocation of roadspace to higher capacity modes, and facilitating a reduced need to travel in the first instance;
• Traffic and indeed transport is not an isolated topic in development selection;
• Highway capacity constraints are not a barrier to development, this follows a P&P methodology rather than a V&V approach as endorsed by DfT as well as other industry bodies.
3.38 Ultimately traffic is a function of roadspace; we design for what we aim to achieve; the Vision. People act to minimise their own inconvenience and thus in reality gridlock does not occur on a regular basis as people increasingly choose to work remotely, order shopping online, travel at a different time, change modes etc. When these principles are accepted by decision makers and the choice is as readily available as jumping in a car, highway congestion is no longer a barrier to the right development in the right location.