Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 10497

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management objects to the proposed vision and objectives. Hallam considers that the vision could be more spatially relevant and provide a meaningful context for the emerging themes, and objectives. In this context Hallam considers that the plan fails to be positively prepared, justified and effective.
Hallam consider that the vision is important for setting the context for the spatial strategy, which in itself must be able to demonstrate how the vision will be delivered. Hallam, in this context also objects to the spatial strategy which is considered to omit key elements of the most sustainable or deliverable option of those considered as set out in the Development Strategy Topic Paper.
According to the Development Strategy Topic Paper, the proposed spatial strategy is based on the variants of Option 2. Hallam considers that the spatial strategy is unlikely to realise each of the opportunities for sustainable development and investment identified both within and without the Option 2 Development Strategy. Equally, an overemphasis on a single theme, and rejection of other sustainable development opportunities, places additional risks in relation to delivery of homes and infrastructure – the prospect of which has been given secondary rather than primary consideration. Maximising and not just meeting basic delivery aspirations should be a leading factor in the identification of the preferred option.
Hallam welcomes the commitment in the vision to “enable the creation of strong, safe and resilient local communities in environments that facilitate healthy and independent living for all”. However this vision is not then carried through in the remainder of the vision statement – in particular in the geographic focus that is set out. In this context Hallam is concerned that the omission of further spatial detail may undermine the effectiveness of the Local Plan.

The desired outcome and focus on sustainable neighbourhoods implies sustainable developments in Bedford and Kempston and in other sustainable communities with strong sustainable credentials but this is not in the vision. In particular Hallam considers that the vision should include a focus on Bedford and Kempston and should embrace related settlements adjacent to the town which are well connected and be further enhanced through modest investment. While the vision highlights the planned outcome of the new town centre railway hub with direct links to Oxford and Cambridge, neither the plan nor the subsequent proposed policies identify and seek to realise the opportunities for delivering sustainable growth that this brings – especially in limited number of nearby locations with direct multimodal transport links to the hub. An example of just such a location is Clapham immediately to the north east of the Bedford Railway hub.

Object

Representation ID: 10498

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst Hallam Land Management supports the overall intent of Policy DS1(S) there are pertinent questions to be raised in whether the principles set out under A) i and A) iii can be fully met due to the proposed spatial strategy set out in Policy DS2(S), levels of stepped housing growth proposed in Policy DS3(S) and distribution of growth in Policy DS5(S).
In this context, Hallam is deeply concerned that the spatial strategy, by omitting key sustainable development options, will not fully achieve the Borough ambitions for resources and climate change and in this context will be unsound for not being positively prepared, justified or effective. A key reason is that the full potential for growth in locations that are well related to Bedford is not being fully recognised – the strategy being based on a preferred option that favours locations that are either less well related to Bedford or physically connected.

Object

Representation ID: 10499

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management objects to the proposed spatial strategy in Policy DS2(S), which is based on a preferred option, as set out in the Development Strategy Topic Paper that focusses narrowly on variants of Option 2, whilst rejecting the alternatives or elements presented in Option 1 and 3-7 and its variants. Attached to these representations, is a note prepared by Hallam’s Transport Consultants: Brookbanks, that considers the transport effects and issues arising from the preferred spatial strategy option – as reported in the Evidence Base.

Hallam considers that the spatial strategy, if it is to fully meet the tests of soundness, needs to be based on a soundly identified preferred option that is more reflective of a balanced and appropriately weighted approach in planning for sustainable development across the Borough. In this regard, Hallam considers that the strategy must include an appropriate combination of the wider options that have been identified and assessed with due weight given to those that can create, or contribute towards, a balanced and sustainable spatial strategy.

The proposed spatial strategy, although positive in focus towards Bedford, notwithstanding the constraints of the A6 corridor, exclude opportunities for development at an appropriate scale to support existing communities that have the greatest potential to contribute to growth objectives in a sustainable way - aligned with requirements of paragraph 23 of the NPPF. There are also doubts as to whether the spatial strategy would be able to provide sufficient capacity, in isolation, for growth, certainly around rail station locations, provide opportunities for maximising sustainable accessibility to Bedford and along the East West Rail corridor.

No change is observed in the evidence base or the outcome of the existing plan – that existing well connected and well served settlements represent highly sustainable options for development. Specifically, the spatial strategy should not preclude sustainable development opportunities to the north of Bedford that are able to capitalise on the investment to be made in East West Rail and improving connectivity to Bedford station – rail related potential is not limited to the south of the town and Bedford station is as, or more, accessible from the north – more so with enhanced sustainable transport links, potentially including the A6 corridor as a focus for infrastructure investment (i.e. more frequent bus services and physical walking and cycle links) which would be more reflective of the objectives set out in paragraph 104 of the NPPF and policy in paragraph 105 of the NPPF. Moreover, as summarised in the attached note prepared by Brookbanks, the particular focus of the Preferred Strategy on the A421 and to the south of Bedford is shown to result in the most significant transport effects in terms of junction delay and volume to capacity ratios, consequent upon the strategy, to be concentrated within the A421 corridor and to and in the southern part of the town of Bedford.

Hallam, therefore, considers that the spatial strategy should not rule out opportunities for continued development at Key Service Centres, particularly to the north of Bedford which is otherwise avoided. It should actively encourage sustainable development at Clapham – the settlement most closely associated with Bedford and the investment in the Bedford Transport hub.

Other than the levels of growth committed to in the plan that are carried forward from the Local Plan 2030, the growth of Key Settlements is likely to rely on windfall development without any additional allocations that would allow meaningful growth at an appropriate scale to support these settlements over the remaining 10-year period – the assumption being that growth will be directed ONLY to the south of Bedford and the Little Barford new settlement. In Hallam’s view, the approach suggested does not fully accord with paragraphs 60 & 68 of the NPPF, certainly in terms of the amount, type and location of sites that are to be brought forward both before and after 2030.

Such an approach will fail to realise sustainable investment in those existing communities and their infrastructure. Indeed, the opportunities that do exist to invest in sustainable transport, both for new and existing communities to the north of Bedford, should be identified and supported through the transport and growth strategies of the plan. As identified in the attached note prepared by Brookbanks, options to include some development to the north of Bedford were largely rejected on the basis of the potential impacts arising from new settlement scale growth at Twinwoods or Colworth. No assessment was made of the potential of more limited opportunities for growth focuussed on well located locations closely linked through sustainable modes to Bedford – most notably at Clapham. The fact that the Council considers mitigation opportunities in the A6 corridor to be insufficient to support major scale development at Twinwoods or Sharnbrook, does not mean that there are not opportunities to be realised through lesser scale sites (than Twinwoods or Sharnbrook) in sustainable existing communities – served directly by high quality sustainable transport infrastructure – locations that are implicitly sought by paragraph 105 of the NPPF.

In this context, Hallam considers that the spatial strategy should combine elements of the wider discounted options (1 & 3-7) to best achieve the scale of growth that is likely to be required. Such an approach would better align with the NPPF and allow the site to better meet the soundness tests of being consistent with national policy and in turn allowing the plan to become sound in terms of being more effective, justified and positively prepared.

Hallam considers that elements of discounted options have a part to play if the housing numbers are to be met in capacity terms, more so in the current submission draft given the increase in the annual housing requirement, and in securing an appropriate geography of opportunities and in helping meet the deliverability gap that is implied by the stepped housing trajectory relying on the significantly stepped up delivery of housing growth with the allocations of large scale new communities or settlements later in the plan period.

Hallam also considers that the spatial strategy must enable a robust trajectory of delivery to come forward. In practice, Hallam have suggested that this will require the identification of additional opportunities at settlements that have the potential and capacity for growth (as evidenced by SHLAA and call for site submissions that are positively assessed), certainly for the shorter to medium term which, in turn, should better balance the rate of supply across the plan period and allow for sufficient lead in times to bring strategic allocations forward in a way that is well coordinated with the delivery of strategic infrastructure. Housing monitoring data demonstrates that rates of housing delivery are already consistently above the rate of provision proposed in the housing trajectory.

Of particular concern, the overreliance on a small number of policy options, and the rejection of others (e.g. rural service centres) is in effect a U Turn in the policy directions proposed in the Plan. From the adopted Plan, where Rural Service Centres (for instance) were recognised as highly sustainable locations for, and a focus of growth, the 2040 proposed submission draft appears to effectively preclude further development at such locations. The consequence of such a profound shift in policy direction (in relation to Rural Service Centres and indeed other development options (whether positive or negative)) is to gravely increase the risk of a major discontinuity in the delivery of the new homes that are so urgently required and, also, in the delivery of infrastructure in the Plan area. Just by way of example, existing planned expansion at Clapham in the adopted Plan will generate the need for a 1FE school yet provision is required to be made for a 2FE primary school which is the aspiration of the education Authority and which would best benefit the community. The about turn in the policy and the absence of any continuity in the commitment to rural service centres and Clapham suggests that there is little prospect of the 2FE school being delivered.

Of those locations identified for more strategic scale development along the A421 and East West Rail corridor, account should also be taken of cumulative delivery rates in the context of the scale of delivery being planned in Bedford Borough but also in Central Beds and other adjoining locations such as those that will be served by the A421 and East West Rail corridor. Some flexibility or tolerance may be required with anticipated delivery timescales. Such uncertainties and a requirement for contingencies translates into a more balanced and critically an adaptable and flexible focus that embraces additional foci for growth and in particular looks also towards the north of Bedford.

Whilst considering that a multi-faceted strategy will be required, Hallam considers that a substantial emphasis must continue to be placed in and around the edges of Bedford and therefore, emphasises for clarity, that this must extend beyond the 0.5 miles of the urban area boundary to include the most immediate neighbouring settlements that have significant potential to benefit from enhanced sustainable connections with Bedford, its town centre and railway station. To some extent, growth beyond 0.5 miles of the urban areas is reflected in the spatial strategy with housing allocations to the south of Bedford, and in this context, the north of Bedford also offers good potential which is not being fully recognised. An example in this context is Clapham. Clapham is a positive example of a settlement that will support further growth around Bedford. It lies some 3.5km from the Town Centre and Railway Station, has the potential for improved connectivity with public transport and walking and cycling infrastructure to complement improvements at the A6 Gateway (being delivered under the Transporting Bedford 2020 Project). Delivery of the Great Ouse Way, which completes a western bypass of the A6 arguably, in relieving traffic pressures on the Shakespeare Road and Ashburnham Road sections of the A5141, provides an additional opportunity for transforming this corridor into a more pedestrian and cycle focussed route – thus lock in the full benefits of the Great Ouse Way.

Furthermore, Clapham becomes even more sustainable as a location as investment takes place in Bedford Town Centre and in the Bedford Midland Station and rail services. There are substantial opportunities for synergy between new homes at Clapham and the enhancement of the social and environmental and quality of life characteristics of the community, particularly through the enhancement of public transport services and physical walking and cycling infrastructure.

Relative to Clapham, some identified sites for growth to the south of Bedford do not offer the same opportunities for maximising multi-modal connectivity – key barriers to active travel being, in some instances, the A6 western bypass of Bedford and Kempston and the A421 corridor.

For instance, and in comparative terms:

• Land allocated at Gibraltar Corner (HOU13) is proposed in a small settlement that lies west of the A6 - services and facilities have to be accessed by crossing the A6 (albeit via a cycle and pedestrian underpass). The site being some 5km from Bedford Town Centre and the railway station is more distant than Clapham.

• Land South and East of Wixams (Allocations HOU15 & HOU16) forms a location for housing growth to the south of Bedford, east of existing growth at Wixams. Delivery of this site will be reliant on infrastructure investment to provide good accessibility and the delivery of wider supporting community infrastructure. Hence, delivery is likely to require be longer lead in times not least in relation to the required infrastructure. Again the site is some 5km from Bedford Town Centre and railway station, and opportunities for multi-modal connections are more limited and is likely to require significant investment. Relative to Clapham, the A421 corridor is a key barrier to improving connectivity for sustainable modes.

• Land at Shortstown (Allocations HOU17 & HOU18) forms a continued expansion of development at this new settlement which has the benefit of infrastructure investment and new local facilities. At some 4-4.5km the distance is slightly further than Clapham. However multi-modal connectivity, particularly for cycling is limited.

The comparative sites above, their relationship with Bedford, certainly in terms of their connectivity merits, underscores the potential of Clapham in being equally or indeed more advantageous as a location for growth in a location proximate to Bedford. The effective exclusion of even limited housing growth to the north of Bedford in close proximity to it – has the effect of adding to the transport impacts to the south and in the south of the town as a result of the preferred spatial option. An appropriate scale of development at Clapham already capitalises on strong and planned sustainable transport links with the potential to enhance them further. It is in this context that the preferred strategy, in not allowing for additional growth at Clapham, a settlement that has the demonstrable capacity to expand, is fundamentally flawed for achieving sustainable growth, certainly in the context of paragraphs 104 and 105 of the NPPF and also providing for a wide mix of sites, as suggested under paragraph 68 of the NPPF. That there remain substantive highly sustainable development opportunities at Clapham is evident from the technical assessment work carried out by Aecom in support of the Clapham Neighbourhood Plan. The Aecom evidence base concluded that there were additional, unallocated, sites at Clapham (for at least 500 dwellings) that were entirely appropriate for development performing at least as well, if not better, than sites allocated for through the previous Adopted Local Plan and made Neighbourhood Plan.

The potential for Clapham to accommodate future growth and being well connected to Bedford, whilst being distinct as a settlement, is evidenced by Hallam’s submissions in response to the Call for Sites. Equally highly sustainable options such as at Clapham presents the opportunity for the Borough Council to encapsulate a Greater Bedford element in the Local Plan and for this to be expressed as a key part of its spatial strategy and also the Local Plan vision and related policies such as for the timing of housing growth and its distribution. As outlined above, the level of ambition in the forthcoming plan will have to be high and should be so. The Council is not able to fall back on piecemeal solutions but needs a comprehensive approach. A Greater Bedford element to the plan, including the urban areas and immediate connected settlements would reflect that ambition and provide a positive framework for investment and early delivery.

The Development Options Topic Paper, in referring to the sustainability appraisal of the broad components of growth, considers the urban area component of the preferred options (including the rejected variants of Option 1, which would play a key role in a wider strategy) to perform best and then considers the adjoining urban area component to perform almost as well. In this context it follows, in Hallam’s view, that growth in immediate neighbouring settlements to the Bedford Urban Area such as Clapham are also capable of performing just as well as what is currently considered to be the adjoining urban areas, and the locations for growth currently proposed to the south of Bedford, with enhanced sustainable connections in the form of frequent public transport services and active travel routes. In this context a limit to identifying opportunities for growth to within 0.5 miles of the urban area boundary is considered arbitrary and not necessarily reflecting functional relationships. In practice, existing settlements such as Clapham are arguably better located than sites in the immediate adjoining area, as described above, where patterns of existing development and transport corridors including the A6 western bypass and A421 are likely to constrain opportunities for development that can fully exploit and enhance sustainable transport corridors.

In Hallam’s view the definition of the adjoining area should be broadened to include the most immediate settlements that are able to be well connected though relatively modest infrastructure investment that encourages sustainable movement. In essence, this approach begins to reflect elements of Options 3b and 3c, 4, 6 and 7, insofar that the focus is extended to those smaller settlements that are immediately adjacent to Bedford and have the potential to benefit from enhanced sustainable connectivity.

An added benefit of securing an appropriate level of growth in those smaller settlements, particularly those adjacent to Bedford, would also be to support local services. Key Service Villages such as Clapham with additional development has the potential to support and enhance the offer of local services, including community facilities and local retail. These benefits are particularly important for people who do not have access to a car. A greater reliance of access to local services and facilities have been underpinned recently by the changes to working and living patterns arising through the Covid-19 pandemic. The benefits are also well aligned with paragraph 73, objective b) in the NPPF. Furthermore, with regard also to paragraph 73, objective a) in the NPPF, Clapham offers the potential to accommodate additional development that can support the co-ordinated improvement of existing infrastructure. With much of the hard infrastructure in place Hallam envisages improvements involving enhancements to transport corridors into Bedford to the railway station to access East West Rail and the town centre to reinforce its vitality and vibrancy, fully exploiting the benefits to be maximised by the recent opening of the Great Ouse Way which, in effect, completes a western bypass around Bedford.

In the context of tackling climate change, locating new development in immediate settlements adjacent to Bedford offers the potential to create the critical mass necessary to support and enhance public transport services with increased frequencies to enable them to become modes of choice. Similarly, development can support investment in active travel infrastructure, better supporting the objectives of paragraph 104 of the NPPF and in turn paragraph 105.

The co-ordinated growth of settlements within a ‘cycle-shed’ of Bedford, as a key part of the overall strategy provides an opportunity for capturing value from new developments alongside access to funding for sustainable transport infrastructure to invest in cycleways – including corridor improvements for continuous links (e.g. wider pavements, on road facilities). Such an approach would contribute significantly towards the England’s Economic Heartland’s Transport Strategy and align with Bedford Boroughs’ own transport principles – in terms of improving public transport networks and local connectivity and accessibility through active travel.

The approach aims to complement the focus toward strategic locations/settlements to the south and west of Bedford, insofar that Clapham has similar, if not more advantageous strengths in being close to Bedford and being better connected, as demonstrated above.

Furthermore, a rationale in the current adopted development strategy is apportioning growth to Key Service Villages to support the provision of new Primary Schools with a scale of growth sufficient to support the delivery of 1 form of entry accommodation, is at odds with the Borough’s Council’s position (as set out in its paper for Education Provision for the Local Plan 2030) that new primary schools should by preference be for 2-3 forms of entry. It follows in this context that allocating further development to Key Service Villages would enable for the delivery of primary schools that are of an operationally efficient and preferable size (i.e. 2-3 forms of entry).

Object

Representation ID: 10500

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management supports the approach to the level of housing growth required, which as a “starting point” is set at 1,355 dwellings per annum and represents a significant uplift from the Local Plan 2030 requirement of 970 dwellings per annum. The level of growth also represents a further increase from the 1,275 dwellings per annum identified in the Draft Plan Strategy Options and Draft Plan consultation (see para 3.2).

In context, however, of the scale of uplift required and significant challenges in terms of housing delivery, Hallam objects to the proposed stepped trajectory, which is considered to be inappropriate for achieving an even and consistent level of housing delivery to meet the Borough’s housing needs. In this context Hallam considers that the plan does not meet the tests of soundness.
The amount and timing of housing growth example suggested in the Policy seeks to provide for 27,100 new dwellings with the delivery of 970 dwellings per annum until 2024/25 then stepped to 1,050 dwellings in the period 2025/26 – 2029/30 and then 1,700 dwellings per annum from 2030/31 until 2039/40. The stepped trajectory equates to a significant uplift in housing delivery, first by a modest 8.2% after 2024/25 and then by a substantial 61.9%after 2030/31. It builds in the postponement of measures to meet immediate need, and it increases substantially the level of risk built into the plan since the effects of any under-delivery of stepped housing requirements on housing need would be greatly exacerbated. There would be little opportunity to redress any under-delivery in the highly stepped targets at the end of the plan period.
Evidence, in Bedford Borough Council’s interim Housing Monitoring Report 2020-21 demonstrates that rates of housing delivery from 2015/16 to 2020/21 have ranged between 964 dwellings per annum and 1,359 dwellings per annum but overall, have supported the delivery of housing at an average rate of 1,192 dwellings per annum – well above the 970 dwellings per annum planned for up to 2024/25 and the 1,050 per annum planned for up to 2030.
Hallam considers that planning for a rate of delivery constrained to 970 dwellings in 2020/21-2025/26 and with just a modest increase to 1,050 to 2029/30 would be a constraint to growth, well below current delivery rates. With a lack of planned deliverable sites that could be brought forward sooner, a reduced rate will create a significant cumulative underbuild towards 2030/31. Such an approach, in turn, is likely to undermine wider growth and planning objectives. Failing to plan adequately for a sufficient supply of sites to come forward in the short and medium term, in the face of current higher delivery rates, and with sites in sustainable locations that are available to come forward if they are allocated, runs counter to paragraph 68 of the NPPF. Planning for lower rates will frustrate and provide no incentive to deliver sustainable development and growth opportunities in the early years of the Plan.

Object

Representation ID: 10501

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam objects to the proposed distribution of growth, which is linked to concerns with the proposed spatial strategy in Policy DS2(S) and amount and timing of growth to be delivered expressed in Policy DS3(S). In this context the policy undermines the soundness of the plan.
Hallam considers that the proposed distribution is heavily skewed towards the Growth Locations on the A421 Corridor and with the potential for rail based growth. The overreliance is reflected in, and predicated upon, the stepped housing trajectory, which as a result of longer lead in times to allow for adequate infrastructure investment will result in rates of delivery well below the annual housing requirement of 1,335 dwellings until 2030/31. The primary objection is that this distribution of growth suggests a restriction in the supply of smaller sites, relying on those currently allocated to deliver housing below the average rates of delivery achieved over the last six years, which is evidenced to be at an average rate of 1,192 dwellings per annum (Bedford Borough Council Interim Housing Monitoring Report 2020-2021). Moreover it may be served to preclude the delivery of other highly sustainable options for contributing to the growth objectives of the Plan. In representations on Policy DS2(S)the clear case for the inclusion of Clapham within the Spatial and Distribution Strategy is made. Specifically, in particular the opportunity should be taken to accommodate additional numbers at the settlement or to redirect allocations from the south of the town where the overconcentration of allocations leads to the greatest impacts in terms of transport and infrastructure.
The NPPF, in paragraph 60, requires a sufficient amount and variety of land to come forward where it is needed. The NPPF later states in paragraph 68 that planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and viability. Consistent with Hallam’s rationale that underpins the requested modifications to the Policy DS2(S) Spatial strategy and Policy DS3(S).

Object

Representation ID: 10502

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Hallam Land Management objects to the proposed Policy for Essential local shops and public houses and their change of use.

The approach is not consistent with national policy (see paragraph. 93 c)) and no specific justification for it, that is consistent with national policy, is provided. Equally, what constitutes an essential service or facility is also not explained nor easily done – which types of shops – foodstore, nailbar etc. If the policy is to preclude a congregation of hot food or similar retail elements, then it should say that.

In the absence of the justifications set out above, Hallam suggest that the policy is deleted and not pursued.

Were the policy to be retained, Hallam considers that the requirements of ii) should only apply to be consistent with paragraph 5.27 if there are no alternative facilities, with regard to i), within 1,000 metres or that a broad range of facilities is available. We believe the requirements for ii) should only apply when i) cannot be met. Otherwise, Hallam considers the requirements of ii) would be too onerous if alternative essential services are available within the 1,000 metres distance threshold. That definition should also be widened to address the breath of services in communities rather than simply distance which is arbitrary.

Hallam also considers criterion iii) to be vague in terms of ‘similar uses’ and would welcome clarity on this term. Without such clarification the objective of iii), appears to overlap with the objectives of Policy TC9 which seeks to guard against the impacts of concentrating similar, albeit “Town centre uses”. Hallam in this context questions whether iii) is necessary. Should it be so, then Hallam would also request the criterion to clarify that test it to be applied to the proposed use.

Equally even if uses are viable, there are planning and other justifications, that would permit alternative uses or purposes and the loss of such a facility as a result of wider benefits achieved. This should be recognised in any policy.

Comment

Representation ID: 10503

Received: 29/07/2022

Respondent: Hallam Land Management

Agent: David Lock Associates

Hallam Land Management considers that the proposed Policy for Residential Space Standards set out in Policy DM6, whilst welcome, deserves expansion to encourage new developments to embrace the changes to working patterns with a housing offer that can facilitate choices to work from home, reflecting changes to working patterns arising through the Covid-19 pandemic. Offering a wider choice of homes that make provision for working from home would be beneficial in further reducing the need to travel and increasing support for local services and facilities.