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

Object

Representation ID: 5960

Received: 08/09/2021

Respondent: Staploe Parish Council

This should include a more accurate survey of the agricultural land grades – particularly in the areas where larger sites are proposed for development. Soil and agricultural land is an important consideration according to the NPPF.

Object

Representation ID: 5961

Received: 08/09/2021

Respondent: Staploe Parish Council

BBC have concluded that Twinwoods creates such a traffic problem at the Clapham Road/Manton Lane junction in Bedford that it is not a suitable development site as the developer has not proposed a solution to the congestion at that junction. I believe that conclusion is incorrect and that previously there have been some proposal put forward!
• The transport model starts with the 2018 base year model previously developed and then adds to that the growth identified by Bedford Borough Council in the adopted local plan to 2030 and includes the mitigations (traffic schemes) that are planned to happen by 2030. This then creates the reference case at year 2030, against which the different development scenarios to 2040 and to 2050 are compared.
• One of the measures of the impact the developments will have on the highway network, is the Junction-Volume Capacity Ratio. This shows how congested the junctions will be – so a figure of 100% means that the junction is fully utilised, i.e. congested, leading to delays at that junction.
• Tables 3.15 (for 2040) and 3.16 (for 2050, but incorrectly titled for 2040) show the Junction-Volume Capacity Ratios for the PM peak Hour in 2040 and 2050 for the unmitigated and mitigated Twinwoods scenarios. The 4 lines for the Clapham Road/Manton Lane junction as follows: (Extracts inserted here.)
• You will see that the black boxes denote 100% or more Ratio – i.e. the junction is completely full (on 3 of the 4 legs) and congested.
• The report at paras 3.5.21 and 3.5.22 states:
• 3.5.21 Table 3.9 to Table 3.16 highlight that there is forecast to be significant delays and congestion issues at the Clapham Road / Manton Lane Junction, particularly in the PM Peak hour. These forecast delays and high volume-capacity ratios are present within the 2030 reference case, with volume-capacity ratios forecast to be above 100% on three out of the four arms at this junction. These high forecast volume capacity ratios are maintained or are forecast to worsen in the 2040 and 2050 forecasts including the proposed Twinwoods and / or Colworth developments.
• 3.5.22 As part of the forecasting assumptions for the reference case (see Table 2.2), an improvement scheme at this location, which provides a dedicated left-turn lane for Clapham Road southbound traffic to Manton Lane and the part-signalisation of the roundabout, is included. Further mitigation at this location was considered as part of this study to alleviate the forecast congestion, but due to the constraints at this location (such as existing buildings and Bedford Modern School) no further mitigation has been proposed as part of this study.
• The junction is already completely full at 2030 before any new developments or the addition of an east west rail station in Bedford Town Centre. Therefore this is a Bedford Borough Council problem that will already happen due to the growth in the adopted Local plan 2030 (1500 new homes all north of Bedford which will impact the A6 by 2030). Bedford Borough Council will have to solve this – not the developers of Twinwoods but a development at Twinwoods might contribute some infrastructure funding to help mitigate the problems on the A6
• It should be noted that when Twinwoods (Brownfield site) is included the Junction-Volume Capacity Ratios increase (on 3 of the 4 legs) from 100% to between 101% and 105% which is negligible in the overall scale of the issue.
• Para 4.2.9 concludes :
• 4.2.9 Significant forecast delays and capacity constraints are forecast at the Clapham Road / Manton Lane roundabout in northern Bedford, primarily in the PM Peak hour, both in the reference case and with the inclusion of the proposed developments and mitigation measures. The reference case includes improvements to this junction; however, further mitigation at this junction to alleviate the forecast congestion has not been proposed as part of this study due to the physical constraints at this location. Without further capacity improvements or measures to reduce the forecast traffic at this location, the forecast congestion at this junction is likely to be a constraint on the delivery of growth along the A6 corridor to the north of the borough.
• This demonstrates that this is not a new development issue, but an existing issue that Bedford Borough Council will have to solve before 2030 – particularly in view of the fact that all traffic wanting to access the new East West Rail Station from the north of the Borough will need to use the A6 to reach the station in central Bedford.
• 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.
100 word summary
Development north of Bedford has been ruled out because of the capacity constraints on the A6. However, the traffic studies conducted already show that the capacity on the A6 will be exceeded when you include the existing development planned for Local Plan 2030. Since then Bedford Borough Council have specified that the new East West rail station must be in Bedford town centre so the issues on the A6 need to be resolved even without further development north of Bedford. Therefore infrastructure funds from a new development could contribute to this.
In addition the AECOM transport modelling is fundamentally flawed.

Object

Representation ID: 5962

Received: 08/09/2021

Respondent: Staploe Parish Council

• 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.
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

Representation ID: 5963

Received: 08/09/2021

Respondent: Staploe Parish Council

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.
No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.

It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.

TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.

For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.

As part of the Bedford Borough Transport Model documents it is quoted that average departing trips are 20 to 25 vehicles, which may be below the trip rates assumed as part of a detailed development assessment. The extract below is taken from the New Settlement West of Wyboston document. [Extract inserted here.]
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.
The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node.
AECOM may claim that some of the departing trips will be internal and therefore will not cross cordon line however taking the 125 departing vehicle trips associated with 2,500 dwellings scenario; 20% of these departing vehicles are considered not to be leaving the area. This percentage decreases further if the worst case number of dwellings is being considered, i.e. 10,150 dwellings. It has previously been highlighted that the AECOM model has not be validated / calibrated and now given the apparent significant under valuation of the likely vehicle trips that will be generated, it is clear that the assessment of the capacity of junctions and the highway network is fundamentally flawed.

The significant undervaluation of generated vehicle trips could be argued by AECOM as being a reduction due to the impact of the public transport. However, the proposed new railway stations associated with the East West Rail Link are located to the east of the A1, which is significantly far enough away for the Dennybook development to be considered to not directly serve it without requiring a vehicle car trip to be generated. In this scenario it more likely that occupiers of Dennybrook (site 977) dwellings will continue their journey by car as opposed to transferring onto rail.

Given this all of the assessments undertaken by AECOM to determine the rerouting and vehicle km travelled for any scenario are highly unlikely to be representative.

Town planning principles are that new development should be centred on and around existing sustainable urban area where local infrastructure exists and allow residents to travel using public transport to serve the development which can be easily extended.

If larger new settlements are the only realistic option then they should be centred on transport hubs such as new railway stations, cycle tracks and footpaths, guided bus routes so that they become the heart of the community and the de facto mode of travel. Locating a new settlement on the edge of town / out of town where the transport hub is also not well connected leads to a disjointed sustainable public transport which will always be second best to car travel.

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

Object

Representation ID: 5964

Received: 08/09/2021

Respondent: Staploe Parish Council

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.

No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.

It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.

TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.

For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.
As part of the Bedford Borough Transport Model documents it is quoted that average departing trips are 20 to 25 vehicles, which may be below the trip rates assumed as part of a detailed development assessment. The extract below is taken from the New Settlement West of Wyboston document. [Extract inserted here.]
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.

The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound vehicle used by the AECOM model, assuming they have loaded it per node. Also Dennybrook will definitely by very heavy car reliant due to location and lack of transport links.

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.
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

Representation ID: 5965

Received: 08/09/2021

Respondent: Staploe Parish Council

The Transport Modelling undertaken by AECOM in support of the strategic options in the Draft Local Plan 2040 is fundamentally flawed for the following reasons.

No validation or calibration of the traffic model has been undertaken which is not in keeping with Department for Transport WebTAG guidance.

It is assumed that the Bedford Borough Transport Model was undertaken using Saturn, which was the model of choice for the Bedford Town Centre modelling project in 2015. In this case, Saturn cannot directly Model Public Transport therefore it is assumed that the engineers have made some significant assumptions with respect to public transport and trips being used, which have not been validated or calibrated.

TAG unit M1.2 introduces the National Trip End Model (NTEM). It includes forecasts of population, households, workforce and jobs over 30 years which are used in a series of models that forecast population, employment, car ownership, trip ends and traffic growth by Middle Layer Super Output Area (MSOA). The NTEM data set can be viewed using the TEMPro (Trip End Model Presentation Program) software. TEMPro estimates of trip ends at any level below aggregate regions (e.g. MSOA, district, or county level) are subject to uncertainty and should not be used as constraints in matrix development process without verification and possible adjustments. No uncertainty log was prepared which is a recommendation of WebTAG modelling guidance.

For direct use in matrix development, trip rate information estimated from household survey data should be considered instead to underpin trip end estimates at zone level. There is a risk that model may not be realistic or sensible due to the error around the model parameters used, or limitations in the extent to which the model can represent human behaviour. Therefore, before using any mathematical model, it is essential to check that it produces credible outputs consistent with observed behaviour. This is usually done by running the model for the base year (either the current year or a recent year), and:
• comparing its outputs with independent data (validation);
• checking that its response to changes in inputs is realistic, based on results from independent evidence (realism testing); and
• checking that the model responds appropriately to all its main inputs (sensitivity testing).
Five types of data can be collected and used to inform most models:
• data on the transport network, including the physical layout, number of lanes, signal timings, public transport frequencies and capacities;
• counts of vehicles or persons on transport services, links or at junctions;
• journey times;
• queue lengths at busy junctions;
• interview surveys, in which transport users are asked to describe trips either through household travel diaries or intercept surveys (e.g. roadside interviews, public transport onboard interview surveys.
These types of checks have not been undertaken to validate / calibrate the model.
AECOM have derived trip ends using CTripEnds for a number of journey purposes. Expanding synthetic trip ends produced by CTripEnd to the local zoning system is considered to be subject to significant discrepancies from observed especially if validation and the calibration exercise has not been undertaken.
It is also important to note that strategic models are not designed for use in a scheme specific assessment. For such an assessment it is recommended a revised forecast model would be produced from a recalibrated base year model using additional and more recent data and targeted to reflect a more specific geographical focus of resources and modelling effort.
As part of the Bedford Borough Transport Model documents it is quoted that average departing trips are 20 to 25 vehicles, which may be below the trip rates assumed as part of a detailed development assessment. The extract below is taken from the New Settlement West of Wyboston document. [Extract inserted here.]
It is unknown what scenario of Dennybrook (site 977) development that the above “20 to 25 outbound car vehicle trips in the AM peak hour” relate to, however an outbound TRCS residential trip rate is somewhere between 0.23 to 0.33 vehicles per dwelling.

The development scenario ranges from 2,500 dwellings to 10,150 dwellings. On this basis and using a 0.25 departure trip rate results in 625 to 2,538 departing trips all of which would be home based departure trips. The model assumes 5 loading zones which therefore means there could be 125 to 508 vehicles per loading zone. This is significantly higher than the 20 to 25 outbound 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.
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

Representation ID: 5966

Received: 08/09/2021

Respondent: Staploe Parish Council

I did not agree that this Issues and Options consultation was sound or fair. I agree with Staploe Parish Council who responded to question 4 as follows: “Staploe Parish Council object in the strongest terms to the suggestion in the brown option that our parish is a brownfield site or under utilised land. Our whole parish is classed as open countryside for planning purposes. Our three tiny hamlets are not even classed as a small settlement in the Local Plan 2030 definition (6.21) and we are therefore defined as open countryside. We feel that describing the brown option which would see the majority of our parish covered in a large scale, high density, urban development as using brownfield or under utilised land is very misleading. We believe this could compromise the validity of the consultation as those responding would logically propose development on brownfield or under-utilised land over greenfield sites.

We believe the pros and cons list for the brown option is very inaccurate for our parish. A large development in Staploe parish would not support services etc in Bedford – we are 13 miles away and people would use services in St. Neots which are already under pressure due to large scale development on the eastern side of the town. There would be very little potential for residents here to make sustainable travel choices – we have one bus on Thursday and it would require huge investment to improve public transport. This would not reduce the need for growth in rural areas – we are a rural area and it proposes building all over our parish. Development in our parish would not improve viability of retail and leisure in Bedford Borough. People would go to St. Neots or Biggleswade retail park.”

We still feel that this is a fair reflection that the issues and options consultation was flawed because it led people to believe that our rural parish was urban with underutilised or brownfield land which is very far from the case.

It is unusual to for a draft Local Plan to attempt a review of the strategic growth for the borough whilst at the same time reviewing certain planning policies that will support the Local Plan going forward. It may be through deciding the strategic growth of the borough that additional or existing policies need reviewing. For example, should the growth strategy employ a rail based growth strategy (e.g. new settlement at Little Barford linking to the East West rail station to the south of St Neots) then there may be a need for a specific rail based policy. Policy 90S of the adopted Local Plan identifies the infrastructure that may come forward as part of the Oxford-Cambridge Arc as well as supporting identified allocations. However, a separate rail based specific policy intervention may be required should the growth strategy around rail as a ‘sustainable’ form of growth be selected. Nevertheless, BBC need to be confident that the growth options identified within the draft Local Plan, or indeed any other suitable growth strategy that might be applied, reflects the current policies within the adopted Local Plan and those that are currently subject to consultation.

In addition, the issues and options consultation was conducted during the covid pandemic when it was not possible to meet more than 6 people outside. We believe this was reflected in the responses: Number of respondents = 315
• 222 were from within the borough – out of a total estimated population of 174,687. This is a pitiful 0.12% response rate
• 93 were from outside the Borough or did not give a postcode
• 53% were from individuals.

Top areas for numbers of responses:

• Bedford 46
• Sharnbrook 23
• Staploe 18 (a 6% response rate which was 50 times the Borough average)
• By contrast – no other areas were in double figures. This brings into further question the validity of the consultation. We believe Bedford Borough Council should be arguing for an extension of time such that the Local Plan 2030 remains “in date” for another year to enable proper consultation, to allow the East West rail route to be announced and for the Oxford Cambridge Arc to decide about development corporations.
100 word summary
I believe that the Issues and Options consultation was invalid. It represented growth in our parish as “urban growth” showing our whole parish as brown – urban land on brownfield or under utilised land. This is profoundly untrue. Our parish is entirely rural and classed as open countryside and is all utilised as high quality agricultural land (grade 2).
We would also call into question the effectiveness of the issues and options consultation as only 0.12% of the population responded.
A rail based growth strategy policy may be required if growth is to be located around rail.

Object

Representation ID: 5967

Received: 08/09/2021

Respondent: Staploe Parish Council

I note the following statements in the assessment:

1E.1.37 Conserve and enhance surviving historic field boundaries and restore hedges where possible in areas of former ancient enclosures, while retaining the open character of areas which were formerly open field land.

1E.1.38 Enhance the hedgerows consistent management and resist development that will result in further loss/fragmentation of hedgerows and hedgerow trees. Encourage the growth of new hedgerow trees to maintain landscape structure and connectivity.

1E.1.42 Conserve the character of the rural roads and limit urbanising influences – widening/kerbing and ensure that traffic management measures are sympathetic to the rural character.

Our Staploe Parish Neighbourhood Plan survey demonstrated that the peace and quiet, open countryside views and rural feel of our parish are of great value by myself and local residents and the key reason we purchased our property in Honeydon back in 2007, plus having the opportunity of e a small holding. In addition, our single track, often high sided lanes and roads are a distinctive local feature. Many have roadside nature reserves due to the rare plants present such as Bath Asparagus. The verges and hedges are cut as little as we can manage in order to maintain visibility and this has enhanced them as green corridors and added to the rural feel of the area. I also strong believe if this development goes ahead many of these protected habitats will be destroyed. Developing a large new town of Dennybrook (site 977) or other large sites in Duloe such as Cobholden, Manor Farm, Duloe Field, Flints Field and Top Homes may necessitate widening of these roads which would urbanise them and destroy valued hedgerows which is contrary to the comments in this landscape character assessment. We would also like to point out that our hamlets are very different to Thurleigh. Our three hamlets of Staploe, Duloe and Honeydon (including Begwary) are very sparsely populated often with large gaps between homes and usually only with houses on one side of the road. All have countryside views from their gardens. This is different from a larger settlement such as Thurleigh on which the Landscape Character Assessment appears to be modelling future development.
100 Word Summary
Our Staploe Parish Neighbourhood Plan survey demonstrated that the rural feel of our parish is greatly valued by residents. Our rural lanes are a distinctive local feature and many have roadside nature reserves. Developing a large new town of Dennybrook (site 977) or other sites in Duloe such as Cobholden, Manor Farm, Duloe Field, Flints Field and Top Homes may necessitate widening and urbanisation of these roads and destroy valued hedgerows - contrary to the comments in this landscape character assessment. Also, our hamlets are much more sparsely populated than Thurleigh (the model settlement given for our landscape type).

Object

Representation ID: 5968

Received: 08/09/2021

Respondent: Staploe Parish Council

I would like to point out that development should be focussed around Bedford Town wherever possible as this will support Bedford town centre.

Object

Representation ID: 5969

Received: 08/09/2021

Respondent: Staploe Parish Council

If we use numbers (2,1,0,0,-1,-2) to replace Bedford Borough Council’s “scoring” (++,+,0,?,X,XX) and assume that all criteria have equal weight, the options can be totalled and compared. Option 2a is best and scores 7. Option 6 is worst and scores -9.

The other points are of note:
1. Of the 15 criteria, 7 criteria have the same score for all options, so make no difference to the assessment. These include 2. Protecting and maintain biodiversity and 8. Landscape character.
2. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; Zero Carbon, which will affected by the proposed new train from Oxford to Cambridge as diesel. 15. Reduce travel/promote sustainable transport. So in reality, of the 15 criteria only 6 criteria make a difference. We do not believe this is reasonable or sufficient.
3. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider the true impact of new settlements (incl. Dennybrook (site 977)) on:
a. Promoting Bedford as a town centre – all options 2 and 3 score the same, but new settlements such as Dennybrook will push people to St. Neots, not Bedford. However this issue is recognised in options 4, 5 and 6.
b. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
c. Max development on brownfield/avoid loss of agricultural land – despite the loss of agricultural land at Wyboston being highlighted in the words, this is not recognised in the scoring of 2b and 2d as these are the same as 2a. Shockingly the words say for all options “Although most new development is likely to be on greenfield land” – it seems that Bedford Borough Council readily accept this and have made no effort to maximise use of their stock of brownfield land (eg. 70ha at Twinwoods) – contrary to the NPPF.
100 word summary
I’ve noticed that the scoring system used appears to score the same for 7 of the 15 criteria for all options including protecting a maintain biodiversity and landscape character. I believe the criteria / scoring system is insufficiently sensitive if it produces so little variation between the options. In the favoured options 2a to 2d, we believe that Bedford Borough Council have failed to properly consider / reflect in their scoring the true impact of new settlements (incl. Dennybrook (site 977)) on promoting Bedford as a town centre, landscape character, loss of good agricultural land and greenfield land.