1.25

Object

Representation ID: 3801

Received: 26/08/2021

Respondent: Mr Paul Woolmer

The proposed Dennybrook development is flawed on so many levels.
Environmentally it will bring chaos to small local lanes which in many cases cannot be widened without major impacts on local residents & wildlife.
The overall infrastructure is already inadequate with no mains sewerage, inconsistent electrical supply, very poor broadband & mobile phone connectivity.
The development would make St.Neots a much busier centre, to the detriment of Bedford town.
The rural nature of the site would encourage car usage, which is completely to opposite of government policy.
There are much better sites which apparently for political reasons have been ignored.

Object

Representation ID: 3803

Received: 26/08/2021

Respondent: Mr Paul Woolmer

The proposed Dennybrook development is flawed on so many levels.
Environmentally it will bring chaos to small local lanes which in many cases cannot be widened without major impacts on local residents & wildlife.
The overall infrastructure is already inadequate with no mains sewerage, inconsistent electrical supply, very poor broadband & mobile phone connectivity.
The development would make St.Neots a much busier centre, to the detriment of Bedford town.
The rural nature of the site would encourage car usage, which is completely to opposite of government policy.
There are much better sites which apparently for political reasons have been ignored.

Object

Representation ID: 3806

Received: 26/08/2021

Respondent: Mrs Gerardine Meola

This is flawed. 20 - 25 vehicles leaving AM going north from settlement west of Wyboston - a development of phase (1) 2,500 homes up to 10,000+ homes 2050 is unrealistic.

It does not take into account the nature of the current road network north; B roads, single track roads, no paths, instances no verges.

Widening of these roads would change their intrinsic character they should remain open countryside - not be urbanised.

Roads to the north of in the urban area of St Neots already have mini roundabouts, traffic calming measures and schools.

No Duty to Cooperate evident.

Object

Representation ID: 3907

Received: 28/08/2021

Respondent: Mrs MARGARET TURNER

The Transport model document quotes average departing trips are 20 to 25 vehicles in am peak hour. this relates to 0.23 to 0.33 vehicles per house This seems quite ridiculous on development of 10800 houses. The proposed new railway station is to the east of the A1 and is unlikely to be reached by commuters other than by car. If larger new settlements are the only way forward they should be focused around the railway stations.

Object

Representation ID: 3954

Received: 29/08/2021

Respondent: Mr Mark Potts

The transport model used by AECOM is fundamentally flawed because the model has not been
validated / calibrated (particularly with respect to public transport), a strategic model has been used
incorrectly and the data has not been tested. AECOM have significantly undervalued the number of
vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a
significant reduction in car use. Therefore we believe that if a new settlement is required it should
be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway
station.

Object

Representation ID: 3984

Received: 29/08/2021

Respondent: Mrs Sharon Woolmer

The proposed Dennybrook development is fundamentally flawed in so many ways.
The current infrastructure is already inadequate with no mains sewerage, inconsistent electrical supply, very poor broadband & mobile phone connectivity.
Environmentally it will cause massive disruption to small local lanes, none can be widened without major impacts on local wildlife, farming & residents.
There are no public services, cars would be the only option which goes against Government policy.
The development would not benefit Bedford, St.Neots would be the natural choice for shopping etc.
There are much more suitable sites currently which for political reasons are being ignored.

Object

Representation ID: 3992

Received: 29/08/2021

Respondent: Mr Keith Turner

The Transport model document quotes average departing trips are 20 to 25 vehicles in am peak hour. this relates to 0.23 to 0.185 vehicles per 100 houses This seems quite ridiculous on development of 10800 houses. The proposed new railway station is to the east of the A1 and is unlikely to be reached by commuters other than by car. If larger new settlements are the only way forward they should be focused around the railway stations

Object

Representation ID: 4140

Received: 30/08/2021

Respondent: Mr paul giles

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 4160

Received: 30/08/2021

Respondent: Mrs MARGARET TURNER

The transport model used by AECOM is fundamentally flawed because the model has not been
validated / calibrated (particularly with respect to public transport), a strategic model has been used
incorrectly and the data has not been tested. AECOM have significantly undervalued the number of
vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a
significant reduction in car use. Therefore I believe that if a new settlement is required it should
be at Little Barford. My second choice would be Twinwoods with a guided busway or parkway
station.

Object

Representation ID: 4187

Received: 30/08/2021

Respondent: Mrs Gail Browning

How can the model predict that only 20 – 25 cars would be moving in the morning rush hour from 10800 houses? To travel to the proposed new railway station, cars would be needed as it is too far to walk or even cycle. This would be the same for travelling to Bedford. A large new settlement should be focussed much nearer to the railway station/town.

Object

Representation ID: 4229

Received: 30/08/2021

Respondent: Mrs Gerardine Meola

Too complex to fully understand.

Concerned referring to 10,000+ houses 2050, we are being consulted on 2500 houses 2040 only. 10,000 + house is a town.

Nature of roads not taken into account just low vehicle movements?

Some roads north of new settlement are single track, no path, no verge or rutted verge and in keeping with open countryside so should not be urbanised.

No reference to Duty to Cooperate with neighbouring authority re its road network and access for vehicles from new settlement?

Object

Representation ID: 4244

Received: 30/08/2021

Respondent: Mr Fletcher Giles

The Transport model document quotes average departing trips are 20 to 25 vehicles in am peak hour. this relates to 0.23 to 0.33 vehicles per house This seems quite ridiculous on development of 10800 houses. The proposed new railway station is to the east of the A1 and is unlikely to be reached by commuters other than by car. If larger new settlements are the only way forward they should be focused around the railway stations.

Object

Representation ID: 4326

Received: 31/08/2021

Respondent: Miss Helen Leach

The Transport model document quotes average departing trips are 20 to 25 vehicles in am peak hour. this relates to 0.23 to 0.33 vehicles per house This seems quite ridiculous on development of 10800 houses. The proposed new railway station is to the east of the A1 and is unlikely to be reached by commuters other than by car. If larger new settlements are the only way forward they should be focused around the railway stations.

Object

Representation ID: 4358

Received: 31/08/2021

Respondent: Miss Helen Leach

The Transport model document quotes average departing trips are 20 to 25 vehicles in am peak hour. this relates to 0.23 to 0.33 vehicles per house This seems quite ridiculous on development of 10800 houses. The proposed new railway station is to the east of the A1 and is unlikely to be reached by commuters other than by car. If larger new settlements are the only way forward they should be focused around the railway stations.

Object

Representation ID: 4461

Received: 31/08/2021

Respondent: Mrs Lucy Crawford

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 4537

Received: 01/09/2021

Respondent: Mrs Kathryn Smith

See above

Object

Representation ID: 4622

Received: 01/09/2021

Respondent: Mr Melvyn Chase

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 4628

Received: 01/09/2021

Respondent: Mr Melvyn Chase

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 4683

Received: 01/09/2021

Respondent: Mr Joshua Zwetsloot

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. (para 2.4.3 of document inserted here).
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 new railway stations 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.
For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.

Object

Representation ID: 4862

Received: 02/09/2021

Respondent: Ms Tara Skey

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore I believe that if a new settlement is required it should be at Little Barford. My second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 4964

Received: 02/09/2021

Respondent: Mrs Julia Willison

The transport report for Dennybrook states there will be 25 cars outbound in the AM peak hour. This is ridiculous. 2500 houses will create far more outbound journeys. There is not a station within walking distance as the proposed EW rail station is too far to walk so therefore people will be using cars to get to the station.

Object

Representation ID: 4971

Received: 02/09/2021

Respondent: Mr Chris Giles

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 new railway stations 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.

For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.

Object

Representation ID: 5177

Received: 03/09/2021

Respondent: Mr Ian Francis

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated
(particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been
tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed
new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is
required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway
station.

Object

Representation ID: 5486

Received: 06/09/2021

Respondent: Mr Stuart Ledwich

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 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 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 new railway stations 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.
For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.

Object

Representation ID: 5581

Received: 06/09/2021

Respondent: Mrs Julie Kilby

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 new railway stations 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.
For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.

Object

Representation ID: 5631

Received: 07/09/2021

Respondent: Mr Phillip Yockney

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 5735

Received: 07/09/2021

Respondent: Miss Hannah Hambleton-Jewell

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 new railway stations 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.
For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.

Object

Representation ID: 5767

Received: 07/09/2021

Respondent: Mrs Gillian Tagg

• 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. (extract inserted here)
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 vehicles 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 Dennybrook 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 new railway stations 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.
For this reason, I believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, my second preferred option would be Twinwoods where I believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues, and it does not engulf a local existing settlement.
100-word Summary
The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore, I believe that if a new settlement is required it should be at Little Barford. My second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 5843

Received: 08/09/2021

Respondent: Mr Norman Hoy

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. (Extract of document inserted here)
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 new railway stations 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.
For this reason we believe that if a new settlement is required the preferred option should be Little Barford as it will be very close to the new East West Rail station and within walking distance of the current mainline station at St Neots. However, our second preferred option would be Twinwoods where we believe a parkway station and mitigations for the A6 can be provided towards the end of the plan period. Much of the site is brownfield land, there are no flooding issues and it does not engulf a local existing settlement.
100 word summary
The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), a strategic model has been used incorrectly and the data has not been tested. AECOM have significantly undervalued the number of vehicle trips. Dennybrook is too far from the proposed new E-W rail station to cause such a significant reduction in car use. Therefore we believe that if a new settlement is required it should be at Little Barford. Our second choice would be Twinwoods with a guided busway or parkway station.

Object

Representation ID: 5917

Received: 08/09/2021

Respondent: Mr Tom Tagg

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.