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

Object

Representation ID: 8775

Received: 29/09/2021

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: 8776

Received: 29/09/2021

Respondent: Staploe Parish Council

This is an important statement for the Council. Staploe Parish Council 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) and Eaton Bank (new site submitted 2nd Sept). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes 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), 931 (Top Homes) and Eaton Bank (new site). The parish of Staploe is the epitome of intrinsic character and beauty, and it is considered that there are valued local landscapes that would be eroded by such urbanised development. Accordingly, the ‘draft vision’ can only be taken at face value if it is not upheld.

Object

Representation ID: 8777

Received: 29/09/2021

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: 8778

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council 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.
3.4 100 word summary
Staploe Parish Council 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: 8779

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council had understood that delivery had to be constant ie. approx. the same number per year. We 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: 8780

Received: 29/09/2021

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.

Object

Representation ID: 8781

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council did not agree that this consultation was sound or fair. We 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.”

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.

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.

3.11 100 word summary
Staploe Parish Council 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: 8782

Received: 29/09/2021

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.

SEE TABLE PARAGRAPH 2.4.3 OF NEW SETTLEMENT WEST OF WYBOSTON DOCUMENT

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

3.12 100 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: 8783

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council believe that the summary leaflet sent round to all houses in the Borough is flawed in that it does not make it sufficiently clear that other options can be selected or proposed, it does not distinguish between Little Barford or Dennybrook (site 977) and it doesn’t make it clear that the 2,500 homes at Dennybrook would be the first phase of a 10,800 home development. This is a fundamental flaw which we believe undermines the value of the responses to this consultation.

Object

Representation ID: 8784

Received: 29/09/2021

Respondent: Staploe Parish Council

Staploe Parish Council proposed in response to the Issues and Options Paper that the more appropriate growth strategy would be to apply a dispersed growth strategy (grey option), targeting housing and employment growth attached and within existing settlements and along transport corridors. Such a strategy would negate the need to build on the wider ‘open countryside’ attributed to the Parish of Staploe and align with the parish’s submitted objections to being classified as “Urban Growth”.

Staploe Parish Council consider that the dispersed growth strategy is still applicable which would include housing growth to existing serviced settlements, plus A421 transport corridor and rail growth, as well as the proposed new settlement of Little Barford (option 2b, in part). Such a strategy would provide 13,085 dwellings, including at least an additional 10% allowance for growth to small and medium scale housing sites associated with the existing key and rural serviced settlements. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor.
In support of a dispersed growth strategy, it makes clear at Paragraph 68 of the NPPF that the Council’s Local Plan should identify a supply of housing covering ‘years one to five, specific developable sites or broad locations for growth, for years 6 – 10 and, where possible, for years 11 – 15 of the plan’. Paragraph 69 goes on further to state that ‘Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.’ The development around existing served settlements would provide for these small and medium sites, which could deliver early in the plan period negating the reliance of large urban extensions and new settlements which inevitably are built out towards the end of the plan period, and potentially beyond. It is noted within the Settlement Hierarchy (September 2018) that the main urban settlement of Bedford/Kempston provides the most services, employment, public transport and facilities, and it is therefore where additional urban development should be focused. In addition to this, further sites can be allocated to key and rural serviced settlements as identified in sections 3 and 4 of the Settlement Hierarchy report, which identifies six key service centres and 10 rural service centres. Further development in and around these settlements would support existing services and facilities. It is also noted that the report is currently being reviewed. Staploe Parish Council would like to highlight that our parish has always been classified as open countryside in the settlement hierarchy so we are surprised that we are now deemed suitable for large scale development and would like to know what has changed.
In terms of windfall development, this would be identified over and above any proposed allocations to existing serviced settlements. The Small Sites Topic Paper (June 2021) notes that the windfall requirement for Bedford Borough Council is 2,250 dwellings over the plan period. BBC have identified through the topic paper that this figure would be exceeded by 920 over the plan period, contributing positively to delivery. Whilst windfall cannot be entirely relied upon, the growth strategy outlined at paragraph 3.7 can provide for a quantum of development that is over and above that of the required housing need. It should also be noted that Bedford Borough Council easily exceeds the NPPF requirement of 10% development on small sites through windfall sites.
The proposed rail corridor development for option 2b identifies around 5,500 dwellings for the areas of Kempston Hardwick, Stewartby and Wixams. Applying the ‘low option’ to the rail corridor would reduce the development pressures along this corridor. However, it should be noted that applying the additional new settlement of Little Barford would add an additional 3,085 dwellings in the ‘rail corridor’. The preference of Little Barford as a new settlement will mean that the proposed East West rail Station to the south of St Neots will provide for a truly sustainable form of development where there is a choice of sustainable modes of public transport – adhering to the strategic objectives of the Council and the draft Local Plan. The site at Little Barford has better connectivity to the existing settlement of St Neots and to the existing mainline station than Dennybrook (site 977). This settlement at Little Barford would enable access to a large number of services and facilities, including existing employment which would reduce the need to travel by car. In addition, the timing for the East West rail connection between Bedford and Cambridge is due to commence in 2025. This could potentially align with the delivery of Little Barford. Future masterplanning for the Little Barford settlement could join up with detailed track alignment and station location for the East West rail station. St Neots already has planned expansions to the east at Loves Farm and Wintringham Park and Little Barford would align with this strategic expansion. In contrast any development at Dennybrook (site 977) would form part of the first phase of a large new town of up to 10,800 homes in an entirely rural, unserviced location.
In terms of the proposed settlement at Dennybrook (site 977) (site land west of Wyboston), this ‘new settlement’ does not provide a suitable alternative. This proposed settlement provides for around 2,500 homes. It is located very close to the existing settlement of St Neots and Wyboston and entirely engulfs the existing hamlets of Honeydon and Begwary. It appears to offer very little separation causing potential coalescence which is against Council policy. Although close to the settlement of St Neots in distance, the A1 currently marks the clear and defined boundary to the urban area the roadway being the dominant feature in the landscape that creates a hard transition to the rural area. The Dennybrook proposal would disrupt this and represent ’urban sprawl’ of built form crossing the A1 into the rural area beyond. This new settlement would also be car dependent with limited access to the wider road network due to the existing narrow roads. There is poor connectivity in terms of a choice of sustainable modes of transport, including the train. Further details in respect of the proposed development at Dennybrook are addressed in the site assessment for Dennybrook (site 977).
It is evident that 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.
Another option may be a new settlement of 2,500 homes at Twinwoods or Colworth. The Parish Council believe that the problems on the A6 north of Bedford are going to need to be resolved anyway in order to support the housing development proposed in the 2030 plan and for residents to access the east west rail station in the centre of the town. We believe that development of a new settlement of up to 3,000 homes at Twinwoods (site 883) or Colworth (site 1002) could provide the infrastructure funding to support improvements to the A6 which have long been needed and provide residents with access to the east west rail station in Bedford. A northern parkway station could be considered in future to provide sustainable transport for those in the north of the Borough. Twinwoods would include a significant proportion of brownfield land and Colworth includes lower quality (grade 3) agricultural land and so would comply with the NPPF requirement to utilise brownfield land or lower quality agricultural land before high quality agricultural land (greenfield land). These sites would also support Bedford Town Centre. Colworth was the site supported in the 2035 plan which was later reviewed. The A6 was not considered sufficiently problematic to prevent this site being adopted – the site was dropped because it was difficult to mitigate against the noise from Santa Pod. We therefore find it hard to understand why the A6 is deemed such an insurmountable problem now.

3.17 100 word summary
Staploe Parish Council consider that option 2b with a new settlement at Little Barford is the best option. The East West rail station south of St Neots will provide a truly sustainable form of development at Little Barford. It will be better connected to the new station than Dennybrook. The latter does not provide a suitable alternative – too far from the rail station, risk of coalescence, good agricultural land. Our second preference if Little Barford were deemed unsuitable would be Twinwoods at Thurleigh as a significant part of the site is brownfield land. See above and site assessments for reasons.