Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 10077

Received: 28/07/2022

Respondent: Milton Keynes Borough Council

Thank you for consulting Milton Keynes Council on Bedford Borough Council’s “Local Plan 2040: Plan for Submission”. We welcome the consultation which is an important stage in delivering a plan-led strategy for the borough. Recognise that there are strategic issues of cross-boundary significance, notably housing, transport and employment land for warehousing. There has been ongoing engagement between the two authorities in taking forward preparation of our respective planning policy frameworks. This has involved regular cross-boundary meetings and engagement on the relevant supporting evidence base.
Milton Keynes is a regional service centre as a destination for work and leisure for communities living in Bedford and further east along the A421 corridor (and planned EWR rail corridor). Having considered the Local Plan 2040: Plan for Submission, and those documents made available alongside it, we do not raise any objection in relation to these matters. We note that a number of concerns and comments raised in our response to the draft plan stage in February 2021 have been addressed through the final spatial strategy, amendments to the plan, and further evidence base work.
Housing and Transport Strategy
As with the draft plan, we are happy to see that the Local Plan 2040: Plan for Submission is seeking to meet the Local Housing Need (LHN) for the period to 2040 in full.
Our main interest lies in how the different spatial options may affect car-based trips to Milton Keynes versus trips made by other modes (principally rail-based). The effects of different strategies on how people living beyond Milton Keynes may travel to Milton Keynes for work or leisure could have consequential impacts on infrastructure provision within Milton Keynes.
Several options were assessed and put forward through the draft plan stage. The chosen spatial strategy in the Local Plan 2040: Plan for Submission constitutes a combination of new settlements and allocations to the south and east of Bedford centres upon potential new rail stations, the A421 and/or East West Rail corridors, and urban densification primarily within Bedford. This strategy represents a more consolidated spatial pattern of growth compared to some of the more dispersed options contained in the draft plan. This is supported as it is likely to result in fewer car-borne trips with potential impacts on the Milton Keynes road network.
To assess the potential for cross-border transport effects we have reviewed the supporting document ‘BBTM Model Assessment of Local Plan 2040 Preferred Strategy’, May 2022. In particular, the Iteration 5 results appear to represent most closely the chosen spatial strategy of the Local Plan 2040: Plan for Submission. We have also considered the Infrastructure Delivery Plan: Transport, Final Report, May 2022.
We note these reports include some minor adjustments to the land allocations and infrastructure, when compared to earlier iterations in the draft plan, and use Bedford Borough Council’s most up to date 2018-based version of their transport model. It is not expected this model would represent Milton Keynes in detail, and the published reports show only a small area of Milton Keynes in the various traffic flow, junction delay and volume over capacity maps. Therefore, we only have limited information about the impact that the Local Plan 2040: Plan for Submission, and its suggested mitigation measures, would have on the wider Milton Keynes borough. As such we have, where possible, isolated Reference Case vs Local Plan comparisons in 2040 to look at the traffic impact of the plan on our eastern boundary, and the incremental effect of the suggested mitigation.
The modelling shows only a minor impact on the Milton Keynes junctions immediately to the west of the M1 between J13 and J14 when comparing ‘2040 reference Case’ with ‘LP2040 without mitigation’. The main difference near Milton Keynes is a modest increase in A421 traffic through Central Beds to Junction 13 and the M1. The small differences in flows between ‘with mitigation’ and ‘without mitigation’ shows that mitigation in Bedford borough would have little effect on this A421 increase. However, the mitigation does lead to slightly increased levels of traffic to/from Milton Keynes Borough on the A422 and A428 in the peaks, and junction delays and volume over capacity ratios in Milton Keynes. However they are not considered significant and the main impacts are due to reference case growth rather than new growth contained in the Local Plan 2040: Plan for submission.
It would be informative to understand the assumptions underlying the traffic generation represented in the modelling. The Infrastructure Delivery Plan indicates that East West Rail Connections Stages 2 and 3 and Wixams and Stewartby Hardwick new Stations are included either as committed, planned, or informed by the modelling analysis. As stated in our previous response, it is not clear how the new services have been represented and the extent to which these changes affect the mode share of travel and contribute to the lower level of car traffic between Bedford borough and Milton Keynes. Also, we note that, within the reference case, neither Marston Gate Expansion nor MK East (now with outline permission) have been included as significant external developments. However, the effects of these developments are already well understood through existing modelling and, in combination with the small additional effects of the Local Plan 2040: Plan for Submission, are unlikely to result in significant impacts.