2. Key Concerns Raised by the Inspectors

While I have raised the following issue before, I am not aware as to whether the Inspectors have considered the future situation during the course of their review of the local plan.

The point that appears not to have been covered in the Local Plan is the possibility of a road which might link the A6 tp A505, from the proposed roundabout on the A6 This proposed roundabout is to be build when developing the link road between the M1, Junction 11A to the A6.

In the Luton Local Plan, they have indicated a possible route where the land has been safeguarded but any such road would also have to pass through Central Bedfordshire. Why is such a possible road not indicated and planned for in the Local Plan for Central Bedfordshire? Do I assume that Central Bedfordshire has no such plan to built a link road to match the Luton Local Plan?.

As will be known, there has been, in the past, alternative proposals for a link road between A6 and A505, which would pass to the north of Warden Hill. This was indicated to be a preferred route. However, again, no such proposed road is shown within the Local Plan.

I would be grateful if this representation is submitted to the Inspectors.

I am responding to the above consultation as a member of the English Regional Transport Association(ERTA),which is a voluntary membership-based, pro-public transport improvement association which, subject to resources, seeks to advance towards better public transport across the English Regions.
ERTA Website: https://www.ertarail.com
I have a few concerns about the Local Plan:
1.There are several rail aspirations that should be included in your Council's plan.
- Station at Ampthill(previous station closed some 50 years ago)on Thameslink route from Bedford-London St.Pancras-Brighton
- Extend Bedford - Bletchley service(Marston Vale line all-stations)into Milton Keynes Central
- The East-West Rail Central Section should be a physically linked railway junction with East Coast Main Line at Tempsford, not a segregated railway and station interchange which puts a time-cost barrier to through services from south of Peterborough and north of Stevenage to Bedford and beyond.
-Recycle centre at Forder's Sidings linked by rail,which could be used for cars, fridges and and all wastes including incinerator ash.

2.Prologis Park,Marston Gate(by M1 J13) - this should be rail linked for deliveries/despatches,with connections to the East-West Rail Link

3.Roads:The following proposals should not go ahead - Oxford-Cambridge Expressway and A6-M1 Link Road.They would not solve traffic problems and in fact will bring in more traffic,which would be contradictory to your Council's commitment to reduce CO2 emissions;furthermore traffic increase will in turn increase air pollution which is already at critical levels.

4.Buses:The bus shelter in Flitwick along the A5120 Ampthill Road close to the railway station and backing on to the railway line should be cleaned up and up-graded with better information with Real-Time Information(RTI) or similar, and later buses linking Flitwick station and Ampthill.

Summary of the Consultation
1. Central Bedfordshire Council are in the process of consulting on the Central Bedfordshire Local Plan examination, seeking new evidence.

Background about the RHA
1. The RHA is the leading trade association representing road haulage and distribution companies, which operate HGVs as profit centres. Our 7,200 members, operating near to 250,000 HGVs out of 10,000 Operating Centres, these range from single-truck firms to those with thousands of vehicles. These companies provide essential services on which the people and businesses of the UK depend.
2. We proactively encourage a spirit of entrepreneurism, compliance, profitability, safety and social responsibility. We do so through a range of advice, representation and services, including training.
3. We would like to thank Central Bedfordshire Council for the consultation and the opportunity to comment on the issues raised.
General Comments
4. We have not previously responded to the Central Bedfordshire Local Plan and wish to make the following points.
5. Road Freight is vital for the economy. Before and during the recent pandemic 98% of all food, medicine and other essential goods were delivered by Road Freight. This sector continued operating seamlessly throughout the crisis keeping Central Bedfordshire operating. At the same time many other businesses were forced to use alternative methods.
6. We support the improvements made to the M1 in Bedfordshire and welcome the partnership working with Highways England to improve traffic flows, journey time and reducing congestion from the Strategic Road Network onto Local Authority roads and visa versa.
7. The Technical Transport Paper – Exam 114 – includes the need to examine existing transport networks. There is one reference to freight, no mention of HGV, yet these are the vehicles that supply and deliver goods to all businesses and dwellings throughout Central Bedfordshire, enabling Central Bedfordshire business.
8. Rail freight is mentioned and the modal shift from road to rail, we fully support multi modal transport. The reality is that roads can be constructed faster than rail infrastructure and roads are required for final mile delivery.
9. We know that 5% of Central Bedfordshire businesses are Road Freight orientated and employ a high proportion of the Central Bedfordshire population.
10. We can find no reference to the provision of more Lorry Parking, or driver facilities for rest and welfare. This issue causes significant problems in areas of high HGV usage, we estimate there is a nightly shortage of more than 11,000 spaces a night. A high proportion of those are in the South East and Midlands.
11. The Department for Transport, National Survey on Lorry Parking in 2017 identified the East Midlands Lorry Parking utilisation as Serious.
12. The 2019 Highways England, Lorry Parking Demand Assessment rated the three Central Bedfordshire lorry parks at Critical. There is a clear need in Central Bedfordshire for additional Lorry Parking.
13. HGV drivers must take statutory breaks and rest. Lay-by’s and HGV parking facilities are needed for HGV’s prior and post delivery in towns. If these facilities are not provided it is likely that drivers will be forced to drive until they can find a suitable place to stop. This causes unnecessary congestion and other environmental issues.
14. We would highlight the beneficial environmental aspects of Euro VI Heavy Goods Vehicles which by 2021 will account for more than 72% of the UK HGV fleet. There are no viable alternatively fuelled 44 tonne HGV available in the UK at present. These vehicles have a lifespan of 12 years and carry the same load as 21 Transit vans.
15. It is essential that these vehicles are considered in all planning requirements.
16. During the pandemic Central Government has encouraged Local Authorities to introduce measures which have resulted in loading and unloading bays being removed. These and other restrictions have prevented trucks from being able to deliver and collect goods from business and other premises.
17. Careful consideration must be given to the unintended consequences of implementing any restriction which force HGV to travel on extended routes, resulting in more congestion and air quality deterioration.

Final Comments
18. The RHA welcomes the opportunity to work more closely with Central Bedfordshire Council for the benefit of all Central Bedfordshire businesses and residents.

Members at Flitwick Town Council have reviewed the documents and feel that not enough effort has been put into the transport strategy or other infrastructure in Flitwick due to the amount of other developments in nearby Towns which do not currently support transport arrangements.

See attachment

It fails to address main problems arising from past developments needing resolution before helping more development on top. Duty of care to residents it needs to be paused to allow developments for which permission has been granted to be finished with required improvements to roads, water supply and sewage disposal completed.

PLEASE SEE ATTACHMENT

Please note SG19 cannot meet at present due to Covid but we communicate by e-mail and attached confirms views held by all committee members, A petition with 2300 signatures is with our MP Richard Fuller for action regarding the road network.

See attachments

I have just undertake a skim review of the forecast report and the LMVR prepared by Aecom and HE on your behalf.

I note that this work was started in April this year and completed in June while in Covid lockdown. It is based on a 2016 traffic survey base (over three years old) and projections for future traffic growth.

As you will no doubt be aware, traffic flows since Covid 19 have not been following the same patterns and trends as they did previously. The DfT have released several papers on this in the last few months as well as a call for data from transport professionals to chart the fall and rise of traffic flows across the country. These suggest we are now at 70% of pre Covid flows.

What is concerning is that CBC will be presenting the forecasting and LMVR as they stand to PINs, when I am aware from first hand experience that other councils in a similar position are waiting for post Covid conditions to allow them to undertake fresh traffic surveys to compare traffic flows. This will allow them to check their growth forecasts and allow for potential modal shift to walking and cycling. Potentially if CBC don’t follow this approach then your base data won’t be robust and PINs may decide again that the plan is unsound.

One for your transport planning team and consultants to consider.

I think several Local Authorities may be in the same boat in terms of the age of traffic model data, so PINS may need to take a view on this.

I believe traffic flows are now roughly at 85 to 90 of pre-Covid based on recent DfT comparisons, but we are in the summer holidays so it’s difficult to pin point exactly. There has been some recent news about potential errors in the NTEM in terms of forecasting which may skew growth, so that may also need a review:

https://www.transportxtra.com/publications/local-transport-today/news/66413/correct-model-s-trip-forecasting-errors-?etid=2404329&artid=66413

I am writing on behalf of the British Horse Society (BHS) a membership charity with over 112,000 members representing the UK’s 3 million regular riders and carriage drivers, in response to the current consultation on the Fareham Borough Local Plan. The BHS is the largest and most influential equestrian charity in the country, working to improve the lives of horses and their owners through its four core foundations of education, welfare, safety and access.
1. BACKGROUND TO OUR COMMENTS
Nationally, it is estimated that there are 3.5 million people in the UK who ride or who drive a horse-drawn carriage. Hampshire has among the highest densities of horse ownership in the country (source: former National Equine Database). We estimate that 220,000-270,000 are employed in equine industries and the equine industry is estimated to be contributing at least £7 billion each year to the local economy, mainly through goods and services supplied by small businesses such as feed merchants, vets, farriers, trainers, saddlers, etc.
Road Safety is a particular concern to equestrians, who are among the most vulnerable road users. Between November 2010 and March 2019, the BHS received reports of 3,737 road incidents, in which 315 horses and 43 people were killed. Research indicates however that only 1 in 10 incidents are being reported to the BHS; in 2016-17 alone, 3,863 horse riders and carriage drivers in England and Wales were admitted to hospital after being injured in transport accidents. (NHS Hospital Episodes Statistics).
The BHS actively campaigns to improve road safety by making motorists aware of what to do when they encounter horses on the road (see https://www.bhs.org.uk/our-work/safety/dead-slow – we recommend taking a few minutes to watch the ‘Dead Slow’ virtual reality film for an impression of how vulnerable equestrians are in proximity to cars and lorries).
Because of the difficulties that equestrians encounter on roads, they avoid using them wherever possible. Road use is often unavoidable, however it is simply because people have nowhere else to exercise their horses. The main off-road access available to them is the network of Rights of Way (RoW). England and Wales have over 140,000 miles of RoW, but only 22% of this network is available for horse riders (who may only use routes designated as Bridleways and Byways) and a mere 5% to carriage drivers (who only have access to Byways). An additional factor is that the network is fragmented, and roads are often the only available links between one RoW and the next.
2. ADDITIONAL EVIDENCE DOCUMENTS
a. EXAM 113 – Housing Technical Paper
Revise policy requirement 6 to remove references to the delivery of the Link Road, the BHS would like to see the specification of ‘and will be required to provide new crossings on the A6 and crossings over the new link road to improve and maintain connections; it is essential that the development contribute towards the delivery of and is served by an appropriately designed and routed new link road between the A6 and M1 Junction 11a’ to remain as part of the paper on the condition that the cycleway is a multiuser route open to equestrian users.
b. EXAM 114 – Transport Technical Paper
The BHS supports the partnership working of CBC with Bedfordshire Rural Communities Charity in providing links to the wider bridleway network for horse riders but would suggest more emphasis is placed on the equestrians being included in the high quality walking and cycling routes to areas of green spaces not just on the wider network. The BHS also supports the ‘measures to mitigate the traffic impacts of the proposed development on the strategic and local road networks together with footpaths, cycleways, bridleways, and green corridors should be included’ laid out under 3.2.11.
3. THE LOCAL PLAN FOR CENTRAL BEDFORDSHIRE
Within Central Bedfordshire, there is a both a demonstrable demand for safe access for equestrians and a documented lack of provision. The issues identified in the Central Bedfordshire Outdoor Access Improvement Plan 2012-2031 with Outcome 2 – Bridleway connectivity is increased identifying plans ‘to increase connectivity in south west/east Central Bedfordshire – working with Cycling and Horse riding communities to propose and deliver new network links.
We hope that Central Bedfordshire Council will take the opportunity to address the disjointed nature of Bedfordshire’s Right of Way network this in the current Review, and ask that the Plan should include:
a. Recognition of equestrians as vulnerable road users
Historically, pedestrians and cyclists have been considered as the main vulnerable road users. Equestrians are however increasingly recognised as being part of this group: during the Parliamentary Debate on Road Safety in November 2018 Jesse Norman, Under Secretary of State for Transport, stated that
“We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders.”
We therefore ask that the Local Plan includes Central Bedfordshire’s equestrians as vulnerable road users, to ensure that their needs are considered equally alongside those of pedestrians and cyclists.
b. Inclusion of equestrians in the Central Bedfordshire Sustainable Transport Strategy
The term ‘Active Travel’ applies to journeys undertaken for a range of purposes, whether to reach a place of work or local amenities, or for recreation. It is also the case that many of the routes that are used to walk or cycle to work or school are the same routes which at other times provide for recreational use.
It is now acknowledged that horse-riding is as much an ‘active travel’ mode as recreational walking or cycling. At the recent Parliamentary Debate on Active Travel in Westminster Hall, Robert Courts MP proposed that “horse riders…ought to be thought about in the context of active travel as well.” This was endorsed by Michael Ellis, Minister of State for Transport, who confirmed that “Active travel includes horse riders and bridle paths – this debate includes them.”
Cambridgeshire is demonstrating good practice, James Palmer, Cambridgeshire and Peterborough Mayor has stated in a current transport consultation : ‘Active Travel – cycling, Walking and Horse Riding Promoting active and sustainable transport like walking, cycling and horse riding are key objectives at a national, regional and local level.’ He has also stated that Greenways are an ‘… off road route for walking, cycling and horse riding.’ The recently adopted Joint Cambridgeshire and Peterborough Local Transport Plan defines Active Travel as: ‘Active Travel: Physically active modes such as walking, cycling or horse riding.’ We would ask that all Active Travel provision must therefore be embedded in new transport projects in the same way for all modes. We therefore suggest that horse-riding should be included within the emerging Central Bedfordshire Travel Plan and Local Plan and would welcome the opportunity to contribute the development of this document.
The current Bedford Borough Local Plan lead by example with Policy 91 – Access to the countryside iv. ‘All new routes should be multiuser routes and dedicated as bridleways with a minimum width of 4 metres.’ We would suggest this is included in the Central Bedfordshire Local plan showing consistency across the county.
c. Equestrians to be included in any shared-use routes, wherever possible
In order to maximise opportunities within development to help provide more off-road links for equestrians, where shared-use routes are created for active travel as a part of any development, planning policy should support the automatic inclusion of horse riders on shared off-road routes, unless there are specific reasons why this is not possible.
Conflict with cyclists is sometimes given as a reason for excluding horses from shared routes, but this rarely has anything to do with either the horse or the bicycle, simply the inconsiderate person who happens to be riding one or the other. Horse riders and cyclists as two vulnerable road user groups have more in common with each other than differences. This is illustrated by the work that the BHS are doing in partnership with Cycling UK in the current ‘Be Nice, Say Hi!’ campaign and with Sustrans in their ‘Paths for Everyone’ initiative.
The key to a successful shared route is the design: for example, rather than positioning a cycle path down the centre of a route with verges either side, the cycle path should be positioned to one side and the two verges combined to provide a soft surface for walkers, runners and horses on the other. (This also addresses the issue of horse droppings which, as research has confirmed, represent no danger to health and disperse quickly, particularly on unsurfaced paths.)
d. Reference to the Central Bedfordshire Public Rights of Way Standards and Guidance for Development
Central Bedfordshire Council has developed this guidance for planners and developers in response to feedback from local authorities, which indicated that they would welcome more information about how they can include equestrians in their work, engagement and consultation. We would like to work in partnership to develop this further.
A good example of this is ‘Equestrians in Hampshire – a reference guide for Transport, Planners, Developers and other decision makers’ document written by members of HCAF with support from Hampshire Countryside Service and the BHS, this document has been widely circulated within and beyond Hampshire, sparking interest from other authorities outside the county. We would like to work with Central Bedfordshire Council to create a similar document specifically for Bedfordshire to so that the proposed new bridleways, when implemented, will restore connectivity within the wider RoW network in a way that will benefit all users, including equestrians.
We would urge Central Bedfordshire Council to incorporate the principles set out in this guidance into their planning policy: most particularly, that equestrians should be considered and consulted with at an early stage within the planning of any major housing or infrastructure development.
4. CONCLUSION
Horse riding is a year-round activity which (along with associated activities such as mucking out and pasture maintenance) expends sufficient energy to be classed as moderate intensity exercise. The majority of those who ride regularly are women, and a significant proportion of riders are over 45. For some older or disabled people, being on horseback or in a horse-drawn carriage gives them access to the countryside and a freedom of movement that they would not otherwise be able to achieve. There are also considerable psychological and social benefits from equestrian activities, as the BHS is demonstrating through the Changing Lives through Horses initiative.
Equestrianism is a popular activity in this part of Bedfordshire, and one which contributes significantly to the local economy. The equestrian community in Central Bedfordshire currently has many difficulties in finding safe access within the area, mainly as a result of past development. Many of these issues could be addressed and resolved through good planning of future development. We hope therefore that the Central Bedfordshire Local Plan will include policies that will support this.

SEE ATTACHMENT
The Inspectors have raised significant concerns in relation to the Council’s Sustainability Appraisal and site assessment process. This reflects concerns we have expressed previously about the way in which a new settlement at Beadlow Manor was assessed and its omission of as a reasonable option in the SA report.
The Council has Council has commissioned further SA work but the Beadlow new settlement is still not identified as a reasonable option. In the absence of an assessment by the Council, DLA Town Planning has undertaken its own assessment using the Council’s criteria and findings as a reference point. The findings show the Beadlow scheme to be among the best of the options available when assessed as the Council as assessed other proposals.
The significant contributions to infrastructure investment (including highway and education) made possible through the Beadlow development warrant serious consideration, particularly as the Council’s current strategy fails to address these key infrastructure deficiencies.