Issues and Options

11.1 We have no comments at this time but reserve our position to consider specific policy proposals as part of subsequent stages of consultation.

12.1 On behalf our client’s we submit that the requirement to further explore and set out policies and deliver objectives related to sustainable transport and reducing the need to travel relates to underlying issues with the current Local Plan 2030, in terms of its foreshortened plan period and failure to secure allocations for the delivery of growth in the rural areas. 12.2 We support the Borough’s propose Site Selection Methodology in relation to those objectives that identify potentially significant positive effects associated with sites that are well-related to the existing settlement form and within walking distance to existing services and facilities. This also ensures that any new facilities provided for existing and future residents are accessible in terms of seeking to secure the wider benefits of development. The current position of deferring site allocations to Neighbourhood Plans in no way provides certainty that the site options selected will minimise the need to make journeys by car (either due to use of public transport or access by walking and cycling). 12.3 Revision to strategic policies and additional allocations provided as part of the Review of the Local Plan should ensure that opportunities to sustain and enhance the role of Key Service Centres and Rural Service Centres are maximised. This should also be supported by a review of the capacity for growth in order to deliver the requirements for development in each settlement. 12.4 This can be achieved as part of a ‘Dispersed’ spatial option, which the Council has previously determined as equally sustainable when considering levels of growth in the rural area. Greater weight should be given to recognise the cumulative benefits of growth in locations that contribute to meeting local requirements for sustainable development (in terms of accessible social and community infrastructure) and delivery of the Plan’s strategic priorities such as meeting the needs of education. This is the case for our client’s interests in both Sharnbrook and Oakley in terms of promoting safer and more sustainable access to existing education facilities and supporting future demands for growth. This should be reflected in the Council’s site assessment and site selection process.

13.1 The Council’s stated intention to update its evidence base in relation to environmental sustainability, open space and Green Infrastructure is supported. It was noted during the Examination of the Local Plan 2030 that neither the Council’s evidence base nor the strategy to defer site allocations to Neighbourhood Plans would ensure that these objectives would be met in full. There are various examples of sites previously assessed as part of the plan-making process that were identified as preferred allocation options and would contribute towards the Plan’s objectives for the natural environment but have not since been supported as allocations through the development plan (i.e. through the Local Plan 2030 or subsequent Neighbourhood Plans). 13.2 In updating its evidence base the Council should seek to ensure that the development plan brings forward allocations that satisfy future requirements for growth e.g. additional opportunities for sport and recreation. This is not achieved through the Local Plan 2030 where requirements are identified but meeting these is deferred to Neighbourhood Plans. There is a strong prospect that some Neighbourhood Plans will not deliver the type and location of sites that would secure optimum Green Infrastructure enhancements. 13.3 Where any requirements remain unmet, solutions should be clearly set out via the policies and allocations of the Local Plan Review. Specific allocations should be supported, particularly where this align with the Council’s spatial strategy and objectives for sustainable development and would provide for the additional requirement for housing growth in the period to 2030 and beyond. In this context, allocations to meet housing needs in full and deliver other priorities (such as Green Infrastructure) should not be deferred to the review of Neighbourhood Plans. 13.4 It is essential that the Council’s Infrastructure Delivery Plan (most recent version dated December 2018) is updated to reflect the requirements of further evidence, once available. This would address issues with the evidence for the Local Plan 2030 where the range of projects identified are typically non-specific with uncertainty over future funding to be provided by CIL/S106, given that allocations are not yet provided through the development plan. The lack of specific projects in rural areas does not reflect the overall priorities for development in the spatial strategy and demonstrates that aspects of the evidence base in relation to Green Infrastructure do not fully reflect the contents of the submission Local Plan. i) Land South of Odell Road, Sharnbrook and Land at Station Road, Oakley 13.5 Updates to the Council’s evidence base, including that relating to open space and playing pitches, would be welcomed as part of the Review of the Local Plan 2030. It was noted during the Examination of the Local Plan 2030 that the 2007 Open Space, Sports and Recreation Study (2007) was substantially dated and insufficient to fully assess requirements to be met as a result of future growth. 13.6 In relation to our client’s interests on Land East of Station Road, Oakley, the settlement is noted as being located in the ‘North Rural West’ parishes. The Lovell Road Sports Pitches are recorded as site ‘Oak8’ and acknowledged as ‘education playing fields’. Figure 4.19 records the surplus/deficit of supply and demand for pitches excluding school pitches and shows a substantial shortfall for the North Rural West parishes. However, one recommendation of the study is the future development and S106 obligations secure community use for facilities, citing Lincroft School as one example of this. 13.7 The existing use and management of the sports pitches available to specific groups and local teams on request therefore makes an important contribution to the deficit in supply identified in the OSSRS. However, this must be interpreted within the overall requirements of the BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 35 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission school itself, including increased pupil numbers and demand for the facilities. 13.8 Our client would therefore support a review of the current position to reassess the ongoing deficit in provision and seek to address this as part of the Review of the Local Plan 2030. This can be achieved as part of allocation of the Land East of Station Road for development to facilitate the relocation and enhancement of the existing Lincroft Academy Sports Pitches in order to support opportunities to deliver wide community benefits. 13.9 The Council has been provided with further evidence of our client’s land at Sharnbrook (School Approach / east of Odell Road), supported by a Landscape and Green Infrastructure Strategy. This demonstrates the availability of a suitable opportunity for delivery of relevant policy objectives through provision of a minimum 25ha of land to be managed for ecology and riverside park as well as opportunities to provide formal open space and playing pitch facilities. The proposed approach provides the ability to secure net gains in biodiversity and management of the relationship with the Felmersham Gravel Pits Site of Special Scientific Interest and areas of Flood Risk to the south of the site.

14.1 Policy provision to encourage new sports and leisure facilities and community facilities is welcomed in principle and is central to the Plan’s objectives for healthy and safe communities. We urge the Council to address these objectives as part of the Review of the Local Plan 2030 through provision for development opportunities not supported within the existing development plan. 14.2 National Planning Practice Guidance states that to ensure health and well-being necessitates taking account of the current and projected health status and needs of the local population, including the quality and quantity of, and accessibility to, healthcare and the effect any planned growth may have on this (ID: 61-046-20190315). Responses in terms of policy may including making provision to improve the quality and quantity of existing services and addressing barriers to health and well-being, as well as supporting the use of Health Impact Assessments to consider application proposals. 14.3 It is fundamentally unsound for the Council to state that its existing policies including those dealing the provision of Green Infrastructure are up-to-date. This conclusion is undermined by the Council’s acknowledgement of needing to plan for significant increases in the housing requirement as well as reviewing spatial strategy options. Further, currently there is no certainty that sites will be identified through Neighbourhood Plans to provide relevant facilities. 14.4 As illustrated below, specific additional allocations should be specifically supported on the basis of their deliverability – for example land such as our client’s interests at Oakley. i) Land East of Station Road, Oakley 14.5 Our clients’ interests East of Station Road, Oakley demonstrate that accommodating flexibility in levels of growth is essential for the soundness of the Plan and securing sustainable development in Oakley. This site offers a clear opportunity for the delivery of sport and community infrastructure for the wider benefit of local residents. 14.6 This demonstrates that the Local Plan should support the allocation of sites that would ensure the policy’s objectives are achieved. The findings of the Council’s Sustainability Appraisal and consideration of options for the current Local Plan supported conclusions that this site, and Oakley as a Rural Service Centre, is a sustainable location and would satisfy relevant criteria in Policy 101 and Policy 102. Furthermore, the opportunity is supported by Sport England and would address an identified local need. In order to be effective, the Local Plan should actively look to secure opportunities that would secure delivery of policy objectives. 14.7 It should be reiterated that the overall site is both contained and physically and visually well related to the built-up area of Oakley and is not perceived as open countryside. Its development would not thus intrude into open countryside nor extend beyond the already existing confines of the development form of the village (See masterplan). 14.8 The development, in addition to facilitating the provision of new sports/recreation facilities and an integrated campus for Lincroft Academy (and for wider community use), would provide for circa 200 dwellings and also offers a unique opportunity to resolve existing congestion and parking issues arising from the school and through traffic along Station Road. The scheme proposed by Bedfordia Developments Ltd and Sharnbrook Academy Federation will deliver a new purpose-built distributor road running north-south through Oakley with reconfiguration of Station Road to prevent through-traffic and ease current parking and traffic issues predominantly associated with the Lincroft Academy. 14.9 Bedfordia Developments Ltd have already set out an approach for a more strategic scale of BE5542P (Bedfordia Developments Ltd) Review of the Bedford Local Plan 2030 Issues and Options Consultation Questions - Response Report 37 08.23.JG.BE5542P LP 2030 Review Consultation Response Document obo Bedfordia Developments Submission development that would see the delivery of a self-contained campus (both primary and secondary on the same site) and with scope to accommodate the expansion that is required of the Academy under planned growth, as well as securing land and third party funding to properly relocate and upgrade existing facilities. 14.10 This proposed approach is consistent with the Council’s objectives for healthy communities and can be facilitated as part of the Review of the Local Plan 2030 in terms of reconsidering Oakley’s role as that of a Key Rural Service Centres and reviewing the distribution of the housing requirement in the period to 2030 and beyond.

Nothing chosen

2.1 We broadly agree with the scope of the local plan review, as was instructed by the local plan Inspector. It is very important that the Council plans for sufficient housing and other uses to meet needs over a local plan period longer than that in the adopted plan (which now has less than ten years to run).

2.2 We broadly agree with the draft vision. However, it could be strengthened by more specifically referring to East-West Rail in terms that it can provide a stimulus for new growth by virtue of the ability to introduce a new station that serves a new community. 2.3 It would also be beneficial for the vision to be accompanied by specific Local Plan objectives.

Nothing chosen

3.1 Whilst we agree that an end date of 2040 is probably the shortest period that can be planned for with regards to national policy (paragraph 22 of the NPPF requires a minimum 15-year period from adoption), we think the Plan could logically look longer term, principally because Bedford is a key area for growth, and because of its location in the OxCam Arc which means Councils should be thinking suitably long term to maximise these benefits. 3.2 We would suggest that the plan looks to 2050, in line with the time horizon of the OxCam Arc vision. This gives the Council headroom to plan for a bold vision over a sufficient period of time to see the benefits of growth and not be hampered by a plan period and associated housing and jobs figures which would be extended incrementally through Local Plan Reviews every five years. 3.3 The recent local plan examination of Uttlesford District Council1 is a clear reminder that it is important to align how a plan looks forward with the ambitious growth options that it has to consider. 3.4 The Uttlesford Inspector’s letter to the Council dated the 10th January 2020 was concerned that its Garden Community approach predetermined the development strategy long beyond the plan period and as such noted it was unduly inflexible (see paragraph 113). This risk would have been mitigated by extending the plan period. 3.5 Given new settlements are an almost inevitable ingredient in Bedford’s future, and that they will deliver over a longer-term period, it is important the Plan provides an appropriate time horizon to frame their consideration. Whilst we favour a longer plan period (e.g. to 2050), if a 2040 period is retained, it is important that the Council tests the longer-term options with reference to the implications beyond that plan period, reflecting the PPG (ID:61-060). 3.6 t is worth noting that a longer plan period (e.g. to 2050) would not demand the same level of detail be provided throughout the period; by way of example, the NPPF requires a minimum 15-year plan period but para 67 imposes a mandatory requirement for housing land supply only for the years 1-10 and where possible years 11-15. The PPG (at ID: 68-020) makes a similar observation. 3.7 Planning for more than the minimum local plan period gives Bedford the opportunity to think and plan big, through a considered long-term strategy which will deliver the most benefits and can be appropriately justified within the plan period. The Delivery of TwinWoods 3.8 The TwinWoods Garden Community can deliver around 6,000 homes by 2050. It is anticipated that delivery could begin as early as 2024/25 with delivery of c.3,500 homes by 2040. The scale of the TwinWoods Garden Community provides not just housing but allows for the provision of significant other benefits and infrastructure including up to 4,000 job opportunities, supporting community facilities and services, strategic and local transport infrastructure.

Nothing chosen

4.1 We support two options, Orange - East–West Rail northern station growth and Red - New settlement-based growth. We can see obvious strategic connectivity benefits of Orange – which would give TwinWoods direct east-west links - but Red too is a strong feasible option for delivering housing growth in a sustainable way. 4.2 The TwinWoods site can play a key role in the development of either of these strategies through the creation of a sustainable new Garden Community. 4.3 In general terms, we agree that the strategy for the plan will likely combine one or more options. We consider that TwinWoods – as a new community capable of providing 3,500 homes by 2040 (and 6,000 by 2050) – can exist alongside a number of other development locations identified. Potential Location Options and their pros and cons 4.4 Below we appraise the alternative options in broad terms, using the Council’s already identified pros and cons to structure the response. We provide summary text on each of the options below. (SEE ATTACHMENT FOR TABLE 4.1 - APPRAISAL OF OPTIONS 4.5 We support the orange and red potential locations for growth as they both use large scale developments to address significant growth in Bedford. There was a broad consensus through the recent local plan 2030 process that a Garden Community is the most sensible long-term solution to meeting housing needs in Bedford; the new ingredient is the potential to combine this growth on the East-West rail route north of Bedford. 4.6 Compared to other Garden Community locations, TwinWoods is deliverable. It provides re-development of a partial brownfield-site, with all land in the control of the promoters. Furthermore, there are still outstanding issues with other options, including the significant noise constraints posed by Santa Pod Raceway to the delivery of a new settlement at Colworth. 4.7 TwinWoods would also incorporate the latest thinking on sustainable development into a new community at the outset, with a potential train station, bus services, walking and cycling at the core of the design. With a train station the character of TwinWoods would be based – at least in part – on a community that benefits from on-site employment and in Bedford but would also be attractive to those with employment or connections to business locations across OxCam Arc. A scheme without a station would be more a self-contained sustainable settlement in its own right with its own jobs, shops and services and with local connections to Bedford and as a market town for surrounding villages. There is also the benefit of existing and proposed employment provision to the north of the site at Thurleigh Airfield, providing further opportunities locally to the site. 4.8 However, TwinWoods would not meet all of the housing needs of Bedford and it is considered that a strategy which also looks at other potential locations for development would be required, particularly for beyond 2030, including the development of brownfield sites, development in smaller settlements if there is demand, and densification of urban sites in Bedford could all play a part in meeting needs. The Sustainability case for TwinWoods 4.9 Creation of a new settlement such as that at TwinWoods is an excellent opportunity to grasp the latest trends in travel and design to prepare for current and future attitudes, instead of designing for the past. One of the many things that the COVID-19 pandemic has taught us is that some of the old ways and travel habits are not necessary moving into the future. This development is designed to be a catalyst for future living which prioritises health, well-being and climate change, and creates liveable communities above all else. 4.10 The old fashioned Predict & Provide (P&P) way of accommodating traffic is making way for the newer Vision & Validate (V&V). V&V places greater importance on sustainable mobility in line with the Council’s planning aspirations. 4.11 Instead of predicting a demand and trying to make it fit, a coordinated approach with BBC is sought from the outset to start with the vision, then to define what the vision will allow. In this manner traffic will be a function of road space, and it will be this available road space that eventually dictates demand. 4.12 This vision is anticipated to ultimately define the movement characteristics of new users of the proposed TwinWoods settlement. 4.13 More and more people are re-realising the merits of community interaction, for both the mental and physical health benefits. When it comes to mobility therefore, this is encouraged at a local level, should this be allowing picking up of parcels from the ‘can I do it online and get it delivered’ as well as for leisure and living. This is the 20-minute town concept. SEE ATTACHMENT FOR FIGURE 1.1 THE 20-MINUTE TOWN CONCEPT 4.14 This means that every typical day to day facility will be accessible within 20-minutes by active travel and for able bodied people, and readily accessible by active travel or other means for people with disabilities. 4.15 By design therefore, the majority of local movement will be by classic mobility – two feet and two wheels. This will be enhanced by e-bikes and other transport initiatives, as well as an internal 20mph speed limit so that where cars share these corridors the intention is that they are in an environment designed to prioritise people movement and supporting the hierarchy of road users where pedestrian movement is paramount followed by cycling and public transport. 4.16 TwinWoods will include residential, employment, education, leisure, and open space development, connected by sustainable travel corridors, to provide a community and place which is accessible to all by a range of transport modes. The expectation on this basis is that TwinWoods could contain circa 70% of all journeys within the site across the day. 4.17 The ways in which ‘Mobility as a Service’ can be delivered on the site are as follows. This is not a definitive list and will develop as changing trends and innovations become available, and as the design of the TwinWoods evolve. • Mobility Hub – Primary and secondary comprising a community concierge team and mobility facilities; • Work Hubs – ‘coffee shop’ experience for those working remotely; • Virtual Mobility; • Active Travel Corridors; • Bike Sharing – including e-bikes; • Car Club; • Carpooling; • Demand-responsive Transport; • Electric Vehicles, including self-drive electric pods; • Connected Automated Vehicle (CAVs); and • Personalised/ Area-Wide Travel Planning SEE ATTACHMENT FOR FIGURE 1.2 MOBILITY HUB EXAMPLE 4.18 n addition to the package of measures above, opportunity to deliver a bus operated Park & Ride in the vicinity of the site (and north of Bedford) has been investigated. This would have a positive impact on residents and seek to reduce the demands on the A6 corridor and assist in more efficient operation of this highway infrastructure. 4.19 Furthermore, as per the Orange option, there is potential to provide a new rail station north of Bedford, on the new central section of the East-West Rail line between Oxford and Cambridge. This is being investigated and would provide a useful addition to the site’s extensive transport offering. The biggest advantage of a new station is as a parkway out of town transport hub for people currently using the A6 to travel into Bedford, who may be catching the train to London, or working in Bedford itself. This station is likely to intercept a notable proportion of traffic from the A6, thus reducing congestion into Bedford Town as well as opening up the region to access further afield to Oxford and Cambridge (and in between) sustainably. The details on how rail services from this station would operate are a point of discussion currently between the key stakeholders, to develop the best offering for the local area as well as the site. Comparison with Existing Towns 4.20 TwinWoods is designed to be a desirable place to live and work, to create communities and maximise social inclusion. With 6,000 – 7,000 homes and a population of up to 16,500 people, t will be a town in its own right. Any town of that size will sustain its own services and amenities and employment. 4.21 To give life to this, existing towns of a similar scale are considered below to provide useful real examples of how communities of the scale of TwinWoods can avoid being dormitories. Given these are existing towns, established in varying settings over time, a new Garden Community at TwinWoods would improve upon aspects such as ensuring all new homes are suitable for home working, providing local facilities, community interaction, and transport systems. Hence, it is intended that the transport habits at TwinWoods improve upon these existing examples. 4.22 We have identified a number of towns of broadly comparable scale across the greater South East that might be benchmarks for sustainable travel patterns: • St Ives • Lewes • Henley on Thames • Thame • Bourne • Petersfield • Marlow • Haslemere • Oxted 4.23 These towns have been selected in the first instance based on population size, which is congruent to that expected at TwinWoods. An analysis of the travel patterns of each town and how comparable to the proposed town at TwinWoods is provided below. 4.24 Table 4.2 shows the distance that residents of the reference towns travel to work based on 2011 Census data. This is the only relevant data available and it should be noted that it is now nine years old, and also only reflects journeys to work which form only a minor proportion of trips made during the road network peak period. Therefore, this only provides an indication of trip patterns, and does not represent trips for education, retail or leisure purposes which are usually less car dependent particularly in a post-COVID-19 world. Of note, the proportion of the population working at home is typically in the 15-20% band; one might expect this to have increased since 2011, and to have done so markedly over recent months. 4.25 The table below also shows the percentage of employed residents that work within 5km of home, thus indicating a level of containment within the town, as well as the percentage of those who travel to London for work (considered relevant given TwinWoods’ and Bedford’s relationship to London). SEE ATTACHMENT FOR TABLE 1.2 DISTANCE TRAVELLED TO WORK 4.26 In terms of distance travelled to work, St. Ives is the most comparable to the targets of TwinWoods, with 68% of employed residents working within 5km of home (including working from home). There is a high level of people living and working within the town and also a considerable proportion of people working from home. Only a quarter of the employed population work further than 10km from the site, and this is the lowest of all assessed towns. 4.27 Bourne has a lower proportion of residents working within 5km of home, however 33% of these work within 2km of home (second highest to St. Ives). This indicates that whilst working from home is lower than other locations, the propensity for internalised trips within the town is high. 4.28 Oxted and Haslemere have the lowest proportion of people working within 5km of each respective town (38% and 42% respectively). This is possibly due to the high levels of residents that work within London (37& and 16% respectively). Indeed, the number of residents working within London is far higher than the other towns considered. This doesn’t mean that travel at these towns however is unsustainable, only that the self-containment of these towns is far lower than the likes of St. Ives and Lewes for example. 4.29 Table 4.3 highlights the key statistics of each reviewed town, showing information regarding population, employed population and the most local major roads. SEE ATTACHMENT FOR TABLE 1.3 KEY STATISTICS 4.30 The statistics provided at Table 4.3 are from the 2011 Census, and as such the population is likely to be higher and older, as a result of an aging population and further developments being undertaken in many of these towns. The population of TwinWoods is expected to be in the region of 16,500 residents, which is likely to be comparable to the majority of the sites which have been reviewed, with the exception perhaps of St. Ives and Oxted. In the case of these towns it might be expected that there is less potential for containment of trips, as the critical mass needed to achieve this is more difficult to attain. However, as demonstrated this is not the case at St. Ives. 4.31 There is a possible correlation shown in these tables between convenient access to major roads, and distance travelled to work. For example, St. Ives and Henley on Thames show some of the lowest average distances travelled to work and are not situated close to strategic road links. Inversely, Oxted is located within convenient access with the M25 and on London’s mass transit network, resulting in the least amount of local containment for work trips. 4.32 The mode split for journeys to work for each town (Census 2011) are presented at Table 4.4. A proposed conservative mode split for the TwinWoods development has been included for comparison purposes. For clarification, “Other” modes of travel include Underground, Taxi, Motorcycle and “Other Method of Travel”. It is based on a scenario including the East-West Rail Station (Orange Option) 4.33 The mode split for TwinWoods is a conservative estimate at this time and refers to external trips rather than all trips. Considering all trips (internal and external), the likely sustainable travel movements are expected to be over 50% and closer to that for St. Ives. Walking and cycling trips in particular will be far higher for TwinWoods when considering internal site trips. SEE ATTACHMENT FOR TABLE 1.4 JOUNEY TO WORK MODE SPLIT 4.34 Whilst TwinWoods has the highest proportion of cycle trips to work, when compared with the other towns, it is the only town which will provide a cycle share scheme which will include e-bike sharing. 4.35 The mode splits shown above for each town reflect the distances travelled for work. For example, St Ives has one of the lowest car driver mode split with 48%, and the highest walking mode split with 38%. This suggests that many of those travelling shorter distances to work within St. Ives itself are choosing to walk to work. The converse is observed at Oxted where the car driver mode split is also low (49%) but the train mode split is high (34%). This is evidently the effect of its location on the outskirts of London and is suggestive of a commuter town. 4.36 The proposals at TwinWoods will seek to more closely reflect the travel patterns of St. Ives and Lewes where there appears to be a high level of self-containment (at least for journeys to work), and many walk to work over short distances. The wider travel patterns when trips for other purposes are considered are hence expected to be even more socially inclusive, meaning that many trips will remain contained within the towns themselves. Vision & Validate 4.37 The approach for TwinWoods is not new. Vienna adopted a ‘vision and validate’ approach in the 1990s. Cardiff Council followed the same tactic for their LDP in 2014. Stevenage Borough Council also adopted the same strategy for its LDP in 2017. Transport for the North adopted a ‘vision and validate’ approach also in 2019. In addition, a number of recent appeal decisions (Hartford 2013 and 2019) have supported just this approach of ‘vision and validate’- Inspectors appear to understand and accept this method of planning and assessment. 4.38 New developments across the UK are now adopting this type of approach also in varying degrees, which is policy compliant. Some examples include the following: • Gilston Garden Town • Waterbeach, Cambridgeshire 4.39 At Wintringham, St Neots and Gilston, Vectos has secured broad agreement to the levels of internalisation (circa 60% - 65%). The more detailed points of delivery and providing for this vision are now being worked through. In agreement with the Council, network modelling is being used to show what percentage of trips by sustainable modes is “needed” rather than what road building should be delivered to accommodate additional traffic demand. The focus is on sustainable growth rather than traffic growth, delivering a vision for the future. This is the core principle of the vision and validate approach. 4.40 At Waterbeach, a varying internalisation or containment factor has been applied to each journey purpose. 48% of commuting trips, 88% of education trips and 61% of retail, personal business, and escort trips. The internalisation of commuting trips at Waterbeach is not considered extreme, and broadly is in line with the internalisation rates of local existing towns of similar size in the area. The proposed land use mix within the new town development offers significant opportunity for internalisation of trips within the site by providing key new facilities in easy reach of residents. 4.41 The internalisation factor for Wintringham has been set at 8.93% for commuting trips, 44.8% for education trips and finally 25% for shopping trips. No internalisation factor has been used for other journey purposes. While the internalisation appears to be relatively low, the site is not as large as Waterbeach or Gilston, with a total of 2,800 dwellings and little employment proposed on site. The development is located a short distance from Cambridge, and it is likely that several trips will be made on the A428 to the east. 4.42 On a larger scale, some examples of local authority adoption of the ‘vision and validate’ approach are provided in the following paragraphs. 4.43 Cardiff Council (CC) plans to deliver 40,000 new homes and 45,000 new jobs in the next plan period with traffic levels remaining unchanged from 2014 levels. In order to achieve this CC has set out a vision for what is required to deliver future growth in a sustainable way, which includes a 50:50 sustainable mode split for all journeys in the city, and a break in the link between economic growth and traffic growth. 4.44 To promote walking, cycling, public transport, shared transport and sustainable living, the LDP includes policies to deliver walking and cycling infrastructure (Policy T1); strategic rapid transit, bus corridor enhancements and wider improvements to the city’s bus network (Policy T2); Transport Interchanges (Policy T3); and a Regional Transport Hub (Policy T4). 4.45 In Stevenage the mobility strategy which underpins the Local Plan steers away from the historic, and now contra-policy, predict and provide car commuter peak as a proxy for transport and mobility. Instead of prioritising road building schemes to satisfy a theoretical short-lived car commuter demand, the strategy is to design for and prioritise mobility as a whole. It is to create even more attractive choice in movement than already exists, committing funds to physical improvements to the higher capacity cycle network, which can be up to seven times more effective in terms of unit road space compared with car use, invest in public transport and make huge inroads in influencing behaviour by significant funding of new measures to promote and use the mobility options that already exist and will improve. 4.46 To inform the strategy, Stevenage Borough Council (SBC) reviewed why people were undertaking journeys (journey purpose), origins and destinations of journeys, and by what mode these journeys could, and SBC would like, to be undertaken. SBC placed a high priority on active travel. For the purposes of the Local Plan and beyond, SBC planned on the basis that the proportion of travel by active travel will increase, that commuter peak car demand will remain broadly static, and therefore that the proportion of travel by car driver will decrease. 4.47 The strategy is to further encourage this shift through the creation of an active travel /car differential whereby it is more attractive to cycle for short journeys than drive. This is the vision SBC would like to deliver and the vision SBC is planning for. The outcomes of this vision were assessed in a model.

4.48 The proposals at TwinWoods complement growth in the area, and the combination of local and strategic infrastructure benefits all users, existing and new. Infrastructure proposed within the development will continue beyond to ensure full integration with the communities in and north of Bedford. 4.49 The need to travel is reducing more and more as technology advances and virtual working, shopping, and socialising becomes easier and more prevalent. As such there are certain decisions made before even choosing to step out of the front door. These can be summarised as: • Can I do it online? • Can I do it online and get it delivered? • Do I need to travel, and if so can I do it locally and in a sustainable way? SEE ATTACHMENT FOR FIGURE 1.3 NEED TO TRAVEL DIAGRAM 4.50 On choosing to travel, the design of the site becomes paramount to influencing and allowing for a range of sustainable travel choices. 4.51 Transport is now the third question after ‘can I do it online’ and ‘can I do it online and get it delivered’. The third question then becomes ‘if I have to travel, how can I do it locally and sustainably’. This will be the focus of the masterplan design at TwinWoods. 4.52 Infrastructure should begin therefore with enabling virtual mobility, followed by providing for classic travel (2 legs/2 wheels), then by mass transit (rail and bus), shared travel (DRT and car sharing/pooling, and with facilitating convenient car travel at the bottom of the hierarchy. 4.53 With consideration to providing all of these modes, the key to growth is the seamless transfer between each mode. TwinWoods can achieve this be it rail to cycle, walking, bus etc, or bus to these modes, or car to rail via the Mobility Hub and designing in the travel modes early in the masterplanning and design stages. 4.54 It is considered that the infrastructure required to enable growth in Bedford Borough should be cognisant of this hierarchy. The focus for growth should begin with reducing the need to travel (fast broadband, 4G/5G) and sustainable travel, and not a position where growth is only enabled through building more highway which would induce supressed demand. 4.55 Bedford Borough Council’s Local Transport Plan (2011) states the following vision for transport in Bedford Borough: “To create a transport system in which walking, cycling and public transport are the natural choices of travel for the majority of journeys because they are affordable, healthy, convenient and safe alternatives to the private car”. 4.56 A clear aspiration of Bedford Borough is therefore in accordance with this hierarchy of travel modes. 4.57 At TwinWoods the key transport related infrastructure is focused on providing for the community, it succinctly comprises walking and cycling corridors, development designed to be accessed by bus, a potential rail hub, and a key sustainable travel corridor between the site and Woodlands Park in north Bedford. This could be a dedicated bus and active travel corridor, or simply an active travel corridor offering a direct and high-quality route to Bedford, linking to the existing infrastructure there. Other external links have been investigated to allow full permeability and connectivity with existing communities surrounding TwinWoods. 4.58 Under the Orange Option, a new rail station is a potential proposal at TwinWoods, forming part of the East-West Rail line between Oxford and Cambridge. This will provide an excellent alternative to many car trips already on the network and reduce other potential new trips from the development site. This is therefore an important piece of infrastructure, however is not imperative to the success of the TwinWoods development, nor is it judged crucial to the growth of Bedford Borough. However, the dedicated link between the site and Woodlands Park is made even stronger in the case where a new rail station is provided. 4.59 Proposed as part of the TwinWoods development is a new A6 bypass of Milton Ernest and Bletsoe. This is an important part of the proposed infrastructure to provide relief to both locations, turning Milton Ernest back to a village. It allows for the delivery of the proposed development without further significant highway works. It is deemed crucial that infrastructure such as this is kept in proportion with the development proposed. 4.60 Mindful that infrastructure should remain proportional to development, it is uncertain exactly what form, nor when external mitigation would be appropriately introduced for TwinWoods in the future. For this reason, the development is ideally suited to a ‘Monitor and Manage’ approach which will sit alongside the Vision and Validate strategy. Monitor and Manage is the process for the delivery of key infrastructure associated with TwinWoods. 4.61 The ‘Monitor and Manage’ strategy will complement the development proposals and will comprise a detailed strategy that identifies potential mitigation measures, real-time targets for movement/mode split, reactive monitoring, and subsequent management. Management will take the form of implementation of the identified measures when and if they are needed only. This approach is justified where, as is the case here, forecasts reach further into the future. This approach has been accepted by the Secretary of State for Arkall Farm (1,000 homes) in Staffordshire.

5.1 We agree that more employment sites will certainly need to be allocated, but in determining which sites to allocate due regard should be had to opportunities to reduce unsustainable commuting patterns. TwinWoods as a new Garden Community can provide a broader economic role, not just a location for new homes. Through specific on-site employment space provision, as well as jobs generated through a whole range of uses including schools, shops etc, it is anticipated that TwinWoods could deliver 2,000 to 4,000 jobs, meaning people can live and work in TwinWoods. It would be a community in its own right and nor dormant to Bedford. Furthermore, the existing site currently provides jobs for 456 people, including part time staff and people currently working from home. 5.2 Thurleigh Airfield to the north of the site also provides existing employment opportunities, but also proposes significant employment expansion. The ‘40 Acre Site’ to the south of the airfield previously benefited from planning permission 00/01790/OUT for employment expansion. There are ongoing pre-application discussions regarding the redevelopment of the 40 Acre Site for employment use once more. This development would also provide employment opportunities for those living in the TwinWoods Garden Community a short journey to the north of the site. 5.3 TwinWoods is designed to be a community encompassing a highly attractive employment offering. The benefits of locating employment in this specific location are numerous and include; excellent propensity for internalisation or containment of trips within the site, close to a new town centre containing shops, schools, leisure facilities etc allowing for linked trips, possibility of a new rail station in close proximity, and excellent active travel links both within the site and to the employment facilities from outside of the site. 5.4 The COVID-19 situation has created a situation where people and businesses are learning that working from home on a daily basis is a viable option, something that may have been unusual prior to the crisis. From an employer’s perspective this could mean in the long run, more flexibility in working hours in the office, less days spent in the office itself, and this could open employers up to offering active travel and alternative travel incentives. As a result, the way commuting movement operates in the future may result in an extinguishment of the traditional peak periods for traffic, and business premises will benefit greatly from being integrated within a vibrant community such as that proposed at TwinWoods. 5.5 TwinWoods is already an established employment site and its location north of Bedford makes it a convenient commuting location for villages such as Clapham, Milton Ernest, Oakley etc. For example, from Clapham, the northern extent of TwinWoods is an approximate 15-minute cycle which is a convenient and attractive journey time. In particular this might offer a more attractive preferable journey than travelling into Bedford Town centre for some. 5.6 The TwinWoods proposals are therefore able to support growth in the borough by providing employment on a comprehensively designed site. Employment will be set up in the heart of the development and businesses will be thus be available to on-site residents within the 20-minute town concept, in any direction. 5.7 Additionally, an element of employment provision will be consumed by employees who permanently work from home. This is an expected outcome of the COVID-19 pandemic and certainly occurred prior to this and is now amplified. The on-site work hubs will offer the ideal ‘coffee-shop’ type environment for those who do work from home no longer need to work from a central or fixed office (full or part-time), and so it is considered that an element of employment is contained within the site outside of business premises to offer modern and attractive work hubs supported with necessary peripherals thus reducing the need to travel longer distances and making a positive contribution to the work-life balance.