Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
3.16
Representation ID: 8040
Received: 24/09/2021
Respondent: North Northamptonshire Council
In respect of spatial options, firstly the Draft Plan appears to have moved away from the ‘Brown’ and ‘Red’ options that would have had the most potential negative impacts on North Northamptonshire (NN). The four preferred options set out in the Draft Plan are centred around Bedford town and the A421 with nothing presented further north towards the NN boundary in the vicinity of the A6. Growth around Bedford town and the A421 would have significantly less cross-boundary impacts on NN in comparison with the other previously considered options.
It is noted that since the publication of the Issues and Options consultation Bedford Borough Council (BBC) have developed the Bedford Borough Transport Model (BBTM) which has been used to test options initially put forward and to therefore inform the preferred options presented in the latest plan.
The production of the BBTM is welcomed and it is noted that the modelling has shown that the preferred options presented in the Draft Plan are those that result in the least impact on the highway network compared to the others tested. This modelling including testing of the option at Colworth Garden Village (CGV), which when tested concluded that any new settlement(s) in this location would result in significant congestion and delay on the A6. More detailed observations on the BBTM are outlined in the North Northamptonshire Council (NNC) Highways comments, which are set out overleaf.
As mentioned, the Plan’s move away from exploring options of significant development at CGV, Rushden and areas around the A6 to the north of the BBC authority area, means there are likely to be fewer significant implications for NN. This is not only in terms of impacts on traffic and congestion on the highways network, but also with regard to other issues previously identified such as coalescence with Wymington, sustainable transport routes and impacts on Green Infrastructure corridors and the SPA, the latter of which will help reduce the impact of wider growth. Natural England (NE) are becoming increasingly concerned regarding functionally linked land to the SPA. There is a need to understand the interaction with the SPA and surrounding land as well as the impact from visitors. Officers from NNC and BBC are engaged in proactive discussion with NE regarding the SPA and it is considered that the move away from growth close to the NN border is likely to release some pressures on it.
Conversely, the absence of any significant development towards the NN boundary would negate the need for a new railway station at Wymington Loop. As per the North Northamptonshire Joint Planning Committees (NN JPC) response to the Issues and Options consultation a new deliverable station here could have presented future opportunities that may have benefitted NN in light of Policy 17 of the JCS North Northamptonshire’s Strategic Connections which identifies investigating the longer-term potential for a railway station at Irchester. Notwithstanding this, it is noted that page 29 of the Development Strategy Topic Paper suggests that there is an ‘absence of currently deliverable railways stations’ within this location.
Despite the above, given the greater housing need in BBC due to the increase on its Local Housing Need (LHN) consideration will need to be given to future iterations of the Plan, particularly when it comes to the allocation of housing sites. It is noted that the annual housing requirement for BBC will increase from 970 dwellings p/a to 1,275 dwellings p/a and therefore, discounting existing commitments, the new local plan will need to allocate land for a minimum of 12,500 dwellings. It will be important for NNC to continue to engage with the BBC Local Plan 2040 as it progresses through the plan-making process to consider whether any potential future housing allocations may be of significance to NN due to their proximity to the authority boundary.
It is recognised that the BBC Local Plan 2040, Draft Plan is still in its early stages in terms of its development and there is still scope for it to change. Notwithstanding this, current proposed growth options illustrated within this consultation are considered to no longer present NN with any significant negative implications with regards to potential cross-boundary issues. On this basis NNC supports the alternative development scenarios presented.
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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
1.26
Representation ID: 8041
Received: 24/09/2021
Respondent: North Northamptonshire Council
It is noted that since the publication of the Issues and Options consultation in August 2020, Bedford Borough Council have developed the Bedford Borough Transport Model (BBTM) (a multi-modal transport model), to test the proposed Local Plan development scenarios for forecasts in 2030, 2040 and 2050. The results of this scenario testing has been used to inform the preferred options presented.
We welcome that the transport model built includes the highway network in North Northamptonshire Council, to enable us to understand the distribution of forecast traffic flows from each of the development options tested and any impact on the highway network within North Northamptonshire.
The preferred options presented (Option 2a, Option 2b, Option 2c, Option 2d) all have an urban focus, with growth concentrated around the A421, railway based growth with various options around new settlements.
We note that the transport modelling shows that the preferred options result in an increase of forecast flows concentrated in the vicinity of Bedford with the least impact on the highway network relative to the other options tested. Moreover, the transport modelling concludes that mitigation should be achievable to mitigate the forecast flows to an acceptable level in highways terms but that there will be some congestion and delay.
We note that the transport modelling concluded that the Colworth and Twinwood new settlements resulted in significant congestion and delay on the A6 approach to Bedford from the north and that additional mitigation has not been identified to address this delay.
We also note that page 29 of the Development Strategy Topic Paper states that in ‘the absence of currently deliverable railway stations at either location which might make an impact, the capacity issues here are too great to allow further development on the A6 (north) corridor such as the new settlements proposed at Twinwoods and / or Colworth.’
Following careful consideration of the Bedford Borough Transport Model New Settlements and the A6 report we also note the following:
• A higher proportion of traffic from Colworth is forecast to travel north to Rushden than south to Bedford (to access the A14)
• Despite the increase in traffic flows, the transport modelling seems to suggest relatively minor impacts on the A6 junctions around Rushden compared to the 2030 reference case. Our transport modelling suggests that the A6 particularly south of Rushden is becoming constrained. A new settlement at Colworth would compound this.
• There is forecast to be some rat-running to use the A509 (and presumably on to Milton Keynes)
• We note that the trip rates used are average trips rates and may not represent the most robust worst case
• We note that the new station at Colworth has been included as a mitigation measure in the transport modelling for the A6 settlements, however the Development Strategy Topic Paper notes that this railway station is undeliverable. This therefore suggests that the traffic modelling may be underestimating the forecast flows on the A6 if the railway station is not a deliverable mitigation and as a result, the impact on the highway network.
• We note that a super cycle highway is proposed from Colworth to Bedford. The distance from Sharnbrook to centre of Bedford is around 9 miles, so this would be around a 45-minute cycle for the average person cycling, less with an e-bike. Further details on how many trips are expected to use this, the proposed route and its deliverability would be welcomed.
In light of the above, it is clear that the transport modelling has identified some unacceptable highway impacts of the new settlements proposed on the A6 corridor. We therefore support alternative development scenarios being taken forward that are able to be mitigated in highway terms.
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Local Plan 2040 Draft Plan - Strategy options and draft policies consultation
1.5
Representation ID: 8042
Received: 24/09/2021
Respondent: North Northamptonshire Council
The NN JPC response to the Issues and Options consultation suggested that consideration should be given as to whether an end date of 2050 for the new BBC Local Plan to align with the Arc would be beneficial. It is noted that the Draft Plan end date is still 2040, however it is recognised that para 1.5 of the Plan states “the Council’s view is that 2020 - 2040 is an appropriate time period for this plan. With a requirement now for five-yearly local plan reviews there will be sufficient opportunity to plan beyond 2040 once the regional planning context is clearer” and the context of the Arc is well considered throughout.
Within the context of the above, it is noted that the Arc Spatial Framework (ASF) sets out at para 5.3 of the ‘Creating a vision for the Oxford-Cambridge Arc’ consultation document that in parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself. In relation to this, it is also noted that an advisory panel for the Arc has been set up to explore potential opportunities for sustainable and economic growth in the Arc, with the Bedford-Cambridge area as its primary focus. From this, it is likely that the route of E-W rail between Bedford-Cambridge will be a potential location for new settlements, which will influence the longer-term development within Bedford Borough in future local plans. NNC will continue to engage in plan-making through the Duty to Cooperate to ensure ongoing consideration of cross-boundary issues.