1.27

Showing comments and forms 31 to 55 of 55

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 6890

Received: 15/09/2021

Respondent: Master Corey T Farmer

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7020

Received: 17/09/2021

Respondent: Mr Robert Tusting

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7071

Received: 09/09/2021

Respondent: June Coles

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7118

Received: 09/09/2021

Respondent: Stephen Coles

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7198

Received: 17/09/2021

Respondent: Mr Peter Knight

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7285

Received: 01/09/2021

Respondent: Miss Laura Jones

Representation Summary:

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7495

Received: 03/09/2021

Respondent: Mr Jonathan Hambleton

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7604

Received: 01/09/2021

Respondent: Miss Nicola Tagg

Representation Summary:

Please refer to my detailed response to 1.25 above.

1.27 100-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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7651

Received: 01/09/2021

Respondent: Mr Simon Goodship

Representation Summary:

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.
SEE SECTION 2.4.3 OF THE NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.
The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.
Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.
Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.
If larger new settlements are the only realistic option then they should be centred on transport hubs such as a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7746

Received: 22/09/2021

Respondent: Mr Michael Thompson

Representation Summary:

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.
SEE SECTION 2.4.3 OF THE NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7807

Received: 03/09/2021

Respondent: Mr Emilio Meola

Representation Summary:

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7845

Received: 03/09/2021

Respondent: Mr Mark Ibbett

Representation Summary:

a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.

1.27 Bedford Borough Transport Model Local Plan Assessment Summary Report – AECOM
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.
SEE SECTION 2.4.3 OF NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.
The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.
Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.
Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.
If larger new settlements are the only realistic option then they should be centred on transport hubs such as a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 7949

Received: 24/09/2021

Respondent: Ms Lorraine Jewell

Representation Summary:

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.

PARAGRAPH 2.4.3 OF NEW SETTLEMENT WEST F WYBOSTON DOCUMENT

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8007

Received: 24/09/2021

Respondent: Mr Larry Gooch

Representation Summary:

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.

PARAGRAPH 2.4.3 OF NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8113

Received: 03/09/2021

Respondent: Dr Emma Thompson

Representation Summary:

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.

(see paragraph 2.4.3 of New Settlement West of Wyboston document.)

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8152

Received: 03/09/2021

Respondent: Mr Ross Thomson

Representation Summary:

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.

(see paragraph 2.4.3 of New Settlement West of Wyboston document.)

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8191

Received: 03/09/2021

Respondent: Mrs Bernadette Yockney

Representation Summary:

The transport model used by AECOM is fundamentally flawed because the model has not been validated / calibrated (particularly with respect to public transport), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8250

Received: 03/09/2021

Respondent: Mr Daniel Francis

Representation Summary:

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.

(see paragraph 2.4.3 of New Settlement West of Wyboston document.)

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8294

Received: 03/09/2021

Respondent: Miss Erin Francis

Representation Summary:

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.

(see paragraph 2.4.3 of New Settlement West of Wyboston document.)

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8439

Received: 03/09/2021

Respondent: Mr Theodore Cassell

Representation Summary:

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.

see paragraph 2.4.3 of New Settlement West of Wyboston document.

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8609

Received: 13/09/2021

Respondent: Mr Henry Zwetsloot

Representation Summary:

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.
[PARAGRAPH 2.4.3 OF NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT]
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.
The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.
Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.
Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.
If larger new settlements are the only realistic option then they should be centred on transport hubs such as a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8768

Received: 29/09/2021

Respondent: Staploe Parish Council

Representation Summary:

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.

SEE PARAGRAPH 2.4.3 OF NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT

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

1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8803

Received: 28/09/2021

Respondent: Mrs Nicola Gooch

Representation Summary:

1.27 Bedford Borough Transport Model Local Plan Assessment Summary Report – AECOM
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 states
No site specific trip rates have been applied within this assessment of the proposed Dennybrook development, with trip rates defined within CTripEnd (the DFT's trip end model underpinning its National Trip -End Model (NTEM) forecasts ) adopted. These represent 'average' trip rates and in general result in around 20 to 25 outbound car vehicle trips in the AM peak hour, which may be below the trip rates assumed as part of a detailed development assessment.
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.
The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.
Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.
Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.
If larger new settlements are the only realistic option then they should be centred on transport hubs such as a new railway station so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.
1.27 100 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), the National Trip End Model (NTEM) should not be used below district / county level, no uncertainty log has been prepared, it doesn’t include household survey data, and the data has not been adequately tested. Strategic models are not designed for use in a scheme specific assessment. The latter requires a revised forecast model produced from a recalibrated base year model using additional and more recent data with a more specific geographical focus of resources and modelling.

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8929

Received: 01/10/2021

Respondent: Mr James Browning

Representation Summary:

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.
It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.
TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.
For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

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



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

Object

Local Plan 2040 Draft Plan - Strategy options and draft policies consultation

Representation ID: 8992

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Representation Summary:

Comments on transport modelling evidence– for full assessment see attachment (appendix 1)
64. The transport modelling evidence presented thus far is incomplete and, in its current form, is not a sufficient level of evidence upon which to base planning based decisions. It fails to identify a number of critical elements which will undoubtedly influence the decision making process.
65. It fails to acknowledge the limitations of the modelling software in terms of how it is calibrated, how simplistic mode shift and sustainable transport is considered, that the time periods are restricted to single hours and that it is based on an assumption that current travel movements will be reinforced by traffic growth.
66. There is a significant lack of consideration being given to sustainable and active modes within the development of a mitigation strategy.
67. There is a failure to distinguish between development specific impacts and those which occur as a result of the application of an additional 10 years of traffic growth.
68. The inclusion of 10 years ‘generic’ growth is, in itself, questionable as it makes it difficult to discern development specific impacts and means that the mitigation strategy derived through the modelling is one which can only reinforce existing travel patterns and exacerbate car dependence.
69. The exacerbation results from continuing to seek to provide capacity for predicted traffic movements all of which are based on a set of assumptions around growth and trip generation which have not, themselves, been suitably tested. By not assessing the sensitivities of conclusions to certain modelling assumptions it cannot be determined how critical to the plan any of the measures identified may be.
70. There is a failure to consider the relationship between development strategy and mitigation. No regard has been given, within the isolated scenario tests, to understanding which developments are likely to rely on or contribute towards different mitigation measures. Consistent application of certain measures across all scenarios means it is not possible to determine if a development is dependent upon a measure (as a series of measures are included from the onset rather than those which are essential for a development to be delivered). Similarly, where Reference Case mitigation is not yet fully funded or permitted it should be identified as such to ensure that the reliance on mitigation of differing levels of certainty is fully identified within the assessment work.
71. The strategic model is not, in isolation, a suitable tool upon which judgements about junction capacity can be made but this is not made clear within the reporting. More refined modelling should be undertaken in areas where capacity has been identified as a constraining factor. This refined testing should consider an approach which better reflects capacity (ideally Microsimulation but, as a minimum Isolated junction modelling). It should also test how sensitive these conclusions are to other factors such as the omission of the generic TEMPRO growth and/or peak spreading and retiming of trips to allow judgements on whether mitigation is essential or desirable (i.e. if a modest change in demand negates the need for a scheme then it can, at best, only be determined as desirable).
72. Further testing should be cognisant of what it is reasonable and realistic to expect each development to deliver by way of mitigation, uniform inclusion of certain measures which are not yet permitted and/or lack funding for full delivery obfuscates the identification of development impacts, specifically when considering different development specific allocation strategies. More critically, this fails to recognise that each development brings with it unique benefits by way of mitigation strategies, especially if a foundation of mitigation is assumed in each option regardless of wether it can be delivered. Larger developments have the ability to deliver more mitigation without adversely impacts viability but this has not been considered in the modelling to date.