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

Object

Representation ID: 5970

Received: 08/09/2021

Respondent: Staploe Parish Council

This assessment was done in Nov 2020. There was significant flooding in Honeydon and St Neots in December 2020. There are 5 watercourses which run from Staploe Parish into the rivers just upstream of St Neots. I don’t believe that a development of up to 10,800 homes at Dennybrook (site 977) is appropriate and believe it would increase the chance of flooding.

NPPF 2020 states at 167. When determining any planning applications, local planning authorities should ensure that flood risk is not increased elsewhere.

We believe that Dennybrook (site 977) would increase the risk of flooding elsewhere and that this flood risk assessment should be updated to allow for this. It should also incorporate cross border effects ie. the assessment shows watercourses going from Staploe parish into St Neots but no indication is given that these would affect the flood risk in St Neots.

The methodology for preparing a strategic flood risk assessment was updated in Sept 2020 and the risk assessments became more stringent therefore this flood risk assessment is out of date and needs to be updated. There is no mention of flooding in Staploe and Honeydon. The brooks in both of these villages flood and I have the photo’s and videos to proof it. . No properties have been directly affected in recent years but the roads in both villages flood significantly about once per year and in December 2020 they were very close to flooding homes.
100 word summary
This assessment was done in Nov 2020. Honeydon and St Neots flooded in December 2020. There are 5 watercourses which run from Staploe Parish into the rivers just upstream of St Neots. A development of 10,800 homes at Dennybrook (site 977) would increase the chance of flooding in St Neots and Honeydon. NPPF 2020 167. The assessment should incorporate cross border effects on St Neots. The methodology for preparing a strategic flood risk assessment was updated in Sept 2020 increasing the stringency of risk assessments. Therefore this flood risk assessment needs to be updated.

Object

Representation ID: 5971

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:
4. 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.
5. Of the remaining 8 criteria where scores vary between options, 3 are effectively the same: 1. Air Quality; 3. Reduce CO2; 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.
6. 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:
d. 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.
e. Landscape character – all options score the same and the words fail to fully recognise the impact of new settlements on the existing landscape.
f. 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
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. We 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.

Object

Representation ID: 5973

Received: 08/09/2021

Respondent: Staploe Parish Council

What influence can a Neighbourhood Plan have on a strategic allocation? And will the development in a strategic allocation be CIL liable in the usual way or would it use section 106 money? Our Neighbourhood Plan survey conducted early in 2021 demonstrated that there was no support for extensive development in our parish. How can this be used to influence a strategic site?

Object

Representation ID: 5974

Received: 08/09/2021

Respondent: Staploe Parish Council

This is an important statement for the Council. I recognise the growth challenges faced by the Council, specifically when attempting to align with the Oxford-Cambridge Arc. That said, the Council’s statement would appear contrary should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes including protected wildlife that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.


2.1 100 word summary

The Council’s statement would appear contradictory should the proposed new settlement of Dennybrook (land west of Wyboston site 977) or the other large sites in the parish be taken forward. Other large sites are 997 (Cobholden), 455 (Manor Farm), Flints Field (930) or 931 (Top Homes). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes including protected wildlife that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld. We seem to have a significant amount of proposed houses developments on our parish compared to the rest of Bedfordshire, if you review all the call for sites above 455/930/931/997etc

Object

Representation ID: 5975

Received: 08/09/2021

Respondent: Staploe Parish Council

The current figures result in a 36% increase in the housing stock of the Borough in the space of 20 years which we believe is unreasonable and will profoundly affect the character of the Borough; large areas of which are currently rural. We believe the Borough Council should continue to campaign against such large increases.

Object

Representation ID: 5976

Received: 08/09/2021

Respondent: Staploe Parish Council

I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.


The plan period may be dependent on how strategic growth is applied within the current draft Local Plan. It states within Paragraph 22 of the National Planning Policy framework (NPPF) that ‘Strategic policies should look ahead over a minimum 15 year period from adoption…’. However, the same paragraph goes on to state that ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.’ It should be pointed out that Paragraph 221 of Annex 1 to the NPPF notes that ‘For the purposes of the policy on larger-scale development in paragraph 22, this applies only to plans that have not reached Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (pre-submission) stage at the point this version is published…’. On the basis that BBC have not yet reached the Regulation 19 stage, the Council may need to consider looking beyond the current plan period (2040) should there be the introduction of new settlements, for example.
In addition, the Oxford-Cambridge Arc identifies a delivery period of 2050. BBC consider that the draft Local Plan aligns with the Arc in terms of growth and infrastructure, though the two are currently misaligned in terms of timescales. It may be feasible, for example, for a dispersal development strategy to be applied which would align better with the timescales identified within the current draft Local Plan, and therefore accord with policies 22 and 221 of the NPPF. However, large urban extensions and new settlements may need to look beyond 2050, and this would align better with the Arc.
100 word summary
I believe that dependence on new settlements is a risky strategy as they are inevitably built out towards the end of the plan period, and potentially beyond and therefore we do not believe there should be too much dependence on large new settlements Where new settlements are to be built we believe they should be within walking distance of sustainable transport options ie. Little Barford.
Bedford Borough Council are considering new settlements and their plan has not yet reached the regulation 19 stage so if they do consider new settlements they should be planning at least 30 years ahead according to the NPPF

Object

Representation ID: 5977

Received: 08/09/2021

Respondent: Staploe Parish Council

I had understood that delivery had to be constant ie. approx. the same number per year. I believe it is important that there is no risk that the Borough could be perceived not to be delivering their housing targets thereby increasing the risk of speculative developments.

Object

Representation ID: 5978

Received: 08/09/2021

Respondent: Staploe Parish Council

Employment growth should be centred around the transport corridors and where there are sustainable modes of public transport and other sustainable choices such as walking or cycling. On this basis we believe that this should be provided adjacent to Bedford / Kempston urban area and NOT Dennybrook.

Object

Representation ID: 5980

Received: 08/09/2021

Respondent: Staploe Parish Council

I do not agree that this 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 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.”

I still feel strongly that this is a fair reflection that the issues and options consultation were 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.
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.
I 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: 5981

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), 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.