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

Object

Representation ID: 8755

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council are very concerned that this call for sites initially showed Dennybrook (site 977) as a much smaller site beyond the boundaries of Honeydon. We were only informed in May 2021 (an astonishing 8 months after the call for sites closed) that the site boundary had expanded by approximately 25% to engulf the whole of the hamlet of Honeydon and Begwary. The new site showed many existing homes surrounded on all sides by housing estates. Therefore we believe that the call for sites was not conducted in an open and transparent manner. Residents only had one month to gather their thoughts about this enormous new development of up to 10,800 homes which engulfed their properties before the draft consultation opened. We do not believe this is a fair consultation for them. In addition, a new site of around 3000 homes at Eaton Bank in Duloe was submitted on 2nd September - the day before the consultation closed. Duloe Field (3420) was also added late. We do not believe sites submitted after the deadline should be considered, and certainly not without further consultation to consider additional comments that may be pertinent to the draft Local Plan going forward.

1.4 100 word summary

The site at Dennybrook expanded in area by around 25% after the call for sites closed to engulf the hamlets of Honeydon and Begwary. We were informed only 8 months after the call for sites closed about this expansion which left only 4 weeks for residents to consider this and seek advice before the consultation on the Draft Local Plan openened. Duloe Field (site 3420) and Eaton Bank in Duloe were also submitted after the deadline. We do not believe sites submitted after the deadline should be considered and certainly not very large sites submitted many months after the deadline.

Object

Representation ID: 8756

Received: 29/09/2021

Respondent: Staploe Parish Council

The plan appears realistic in the context of housing growth identified within the Council’s Objectively Assessed Housing Need (OAHN). However, 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.

1.5 100 word summary

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: 8757

Received: 29/09/2021

Respondent: Staploe Parish Council

The Oxford-Cambridge Arc identifies a delivery period of 2050. Bedford Borough Council 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.

Object

Representation ID: 8758

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council do not agree that there should be extensive new housing development in the Oxford Cambridge arc. Much of it is rural and with productive agricultural land which we believe should be retained. We believe that any large scale allocations over 2,500 homes should not be permitted until the Oxford Cambridge arc has developed its spatial strategy.

Object

Representation ID: 8759

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council believe it is important to map the soil (which forms part of the natural capital) and therefore the agricultural land grades much more closely as this is a key part of the National Planning Policy Framework. The agricultural land classification map published by Natural England presents a number of difficulties: it is only available at a scale of 1:250,000 and so it is not easy to identify individual parcels of land. The map states that it “represents a generalised pattern of land classification grades and any enlargement of the scale of the map would be misleading”. The webpage states that the map “is intended for strategic uses” and is not “sufficiently accurate for use in assessment of individual fields or sites and any enlargement could be misleading”. The map is based on old survey information and circumstances may have subsequently changed. The map does not differentiate between Grades 3a and 3b. Grade 3a is included in the NPPF’s definition of best and most versatile agricultural land (along with Grades 1 and 2). Of the larger sites as far as we can see Dennybrook (site 977) (along with all land in Staploe Parish) is all grade 2 land with possibly a bit of grade 1 near Wyboston. Great Barford and Colworth are largely grade 3 and Twinwoods is grade 2 but has a significant proportion of brownfield land. However, we believe Bedford Borough Council should commission a more detailed survey of the agricultural land quality in the Borough.

1.12 100 word summary

Staploe Parish Council believe it is important to map the soil (which forms part of the natural capital) and therefore the agricultural land grades much more closely as this is a key part of the National Planning Policy Framework. The agricultural land classification map published by Natural England is not sufficiently detailed. High quality agricultural land should not be used for development and therefore more detailed information is needed before decisions about site allocations are made.

Object

Representation ID: 8760

Received: 29/09/2021

Respondent: Staploe Parish Council

The scope of the Local Plan is broadly acceptable to Staploe Parish Council. However, 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.

1.14 100 word summary

If 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 growth policy.

Object

Representation ID: 8761

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council object to the presentation of the 4 options in the summary leaflet that residents received regarding the draft plan. There is just one small statement saying that other options are available in the summary leaflet and we believe this is misleading – most people will only respond based on the summary document and are unlikely to look up the alternative options.

We also object in the strongest terms to the fact that Dennybrook (site 977) (land west of Wyboston) is presented as a development of only 2,500 homes and it is not made at all clear in the summary leaflet that this is the first phase of a large town of 10,800 homes.

A number of our residents have told us that they believe they have to choose from the 4 options and that they believe Dennybrook would remain a site of only 2,500 homes based on the information they have seen in the consultation. This demonstrates that it is misleading.

It is stated in the Council’s Draft Sustainability Appraisal, dated June 2021 (DSA) that all spatial options have been assessed. However, options 2b, 2c, and 2d clearly identify two new settlements. In order to fully consider the social, economical and environmental impacts associated with these two proposed settlements, their impacts need to be assessed separately and fed into the draft SA. At present, the options testing within the draft SA are not accurate as a result. Accordingly, Bedford Borough Council have not robustly assessed the options, and therefore have not adequately evaluated the likely significant effects on the environment, contrary to The Environmental Assessment of Plans and Programmes Regulations 2004.

Staploe Parish Council would like to request that the decision about which sites to choose for development be made at full council with Borough Councillors being given the opportunity to vote on it before it reaches the “is it sound and is it legal” stage of the plan – regulation 19. We would ask that the decision is therefore not made by the Mayor of Bedford’s executive powers. We would also like to request that, where a Borough Councillor is conflicted due to a conflict of interests, an alternative Borough Councillor representing the same party is permitted to vote on the matter in their stead. Our Borough Councillor Tom Wootton is conflicted regarding the proposed site at Dennybrook (site 977) and we would like Councillor Moon to vote in his stead.

1.18 100 word summary

The consultation on the draft plan is misleading. It is not sufficiently clear that alternative options can be proposed other than the 4 presented. It is not made clear that the new settlement at Dennybrook would be the first phase of a development of 10,800 homes. The full impacts of Dennybrook and Little Barford as new settlements should be fed into the assessment of the options independently. Please make the decision re choice of sites in a full council meeting (not executive) and permit Councillor Moon to vote in place of Tom Wootton as the latter is conflicted re Dennybrook.

Object

Representation ID: 8762

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council will be commenting on site submissions in our parish, Little Barford (907), Twinwoods (883) and Colworth (1002). See comments under each of these site assessments.

Object

Representation ID: 8763

Received: 29/09/2021

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: 8764

Received: 29/09/2021

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. Staploe Parish Council believe that conclusion is incorrect.
• 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:
SEE TABLES 3.15 AND 3.16 OF BEDFORD BOROUGH TRANSPORT MODEL NEW SETTLEMENTS AND THE A6

• 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 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.

1.23 100 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.