3. Appendix 1: Sustainable Transport in Central Bedfordshire

Thank you for your letter dated 2 July 2020. I live in Toddington.
I am concerned that there is not enough emphasis on the Railway. If a developer wants to build HAS49 and HAS50 in Toddington then he should be made to build a Maglev or similar to a Hub station at Harlington so people can get to work. Harlington is the ideal Hub as there is so much land for development to the west and northwest of the station. Also Harlington should have it's own slip road from the M1 to a modern carpark (£3.50 per day)
HAS 20 and HAS 21 should be extended to the Northwest so that more people can easily walk from the new homes to the Harlington Hub. Westoning should be extended up to the railway and a busway alongside the track could take people to the Harlington Hub.
The site of Ampthill Station could also be reopened with a busway alongside the track to Flitwick.
You must remember that there will be £100,000,000,000 available when we cancel HS2.

HCC welcomes the opportunity to comment on the Central Bedfordshire Local Plan additional evidence supplied as part of the examination process.
HCC notes that the following documents are the subject of this consultation;
• EXAM 106 - Prologis Park Marston Gate Expansion Scheme Comparison Document
• EXAM 107 - Sundon Rail Freight Interchange Alternative Site Assessment
• EXAM 108 - Biggleswade Holme Farm Planning Design Delivery Analysis Report
• EXAM 109 - Employment Land Update
• EXAM 110 - North Luton LVIA Addendum
• EXAM 111 - Statement of Common Ground between Highways England & Central Bedfordshire Council
• EXAM 112 - Employment Technical Paper
• EXAM 113 - Housing Technical Paper
• EXAM 114 - Transport Technical Paper
• EXAM 115 - Sustainability Appraisal of the Central Bedfordshire Local Plan Supplementary Report
• EXAM 117 – CBC Schedule of Suggested Main Modifications arising from Additional Evidence
HCC wishes to make the following comments;
EXAM 106 through EXAM 112 – HCC has no comments to make.
EXAM 113;
At the regulation 19 stage, HCC noted the options in the plan for building new large communities comprising thousands of dwellings and that the Local Plan covers areas close to the Hertfordshire boundary. Where such new developments in Central Beds are close to the Hertfordshire boundary, residents from the increased Central Beds population may likely cross the boundary into Hertfordshire to access services or to work. This may put pressure on already busy services within Hertfordshire. HCC would therefore need to ensure that no additional strain is placed on the existing services in Hertfordshire as a result of new or increased cross boundary flows of people into Hertfordshire. If this is likely to be the case, Hertfordshire supports the introduction of new services within Central Bedfordshire. Where developments are close to the Hertfordshire border and are likely to place strain on Hertfordshire services, HCC welcomes the opportunity to continue to work with Central Bedfordshire as new developments are progressed.
EXAM 114;
Appendix 1 on Sustainable Transport, paragraph 3.2.3 mentions a transport hierarchy, but it does not mention reducing the need to travel in the first instance, followed by consideration of sustainable modes and then changing the mode of travel. The first bullet point of Policy 1 of the Hertfordshire LTP4 makes this hierarchy clear. This consideration also appears to be absent from the rest of the paper.
EXAM 115: No comments
EXAM 117: No comments
HCC made several comments on the Central Bedfordshire Regulation 19 consultation. HCC would like to reiterate those comments as HCC has no further comments to make on any of the materials presented in this consultation.
We hope the above comments are of assistance to you and we would like to continue to work with Central Bedfordshire to ensure the best outcomes surrounding cross-boundary issues

This submission focusses on the related issues arising from the Hearing Sessions into Central Bedfordshire’s Local Plan and the Inspectors’ letter dated 30th September 2019. It forms the basis of Ridgmont Parish Council’s objections in relation to the soundness of Central Bedfordshire Council’s Revised Sustainability Appraisal and other documents, which are the subject of the consultation. The objection is pursuant to the allocation SE2
PLEASE SEE ALL ATTACHMENTS

See attachment

The North Luton Consortium has comments relating to Appendix 1: Sustainable Transport of EXAM 114. Please see our attached representations under the heading 'Statement of Common Ground between Highways England and CBC (EXAM 111) and Transport Technical Paper (EXAM 114).

I’m writing to object to the additional evidence that has been produced as part of the Examination of the Central Bedfordshire Local Plan.

Reading through the additional evidence for junction 13 of the M1 it does not take into account future factors of neighbouring councils and their plans. Neighbouring councils are sited very closely to Central Bedfordshire’s and have close road links which are not factored into the additional evidence of junction 13 and how this might affect future traffic volume/capacity on our roads within Marston Vale.
Milton Keynes council are planning to create 1000’s more homes just off junction 14 of the M1, this will have a major impact on junction 14 and junction 13 as it offers alternative diversions. Nowhere in their evidence has it taken this into account. Or the fact that more homes will be available to others just minutes up the motorway, lessening the need for more homes in Central Bedfordshire.

It’s also been brought to my attention that the council is not taking into account material changes regarding the size of development and latest ONS projections regarding population growth, which are much lower than they were 2 years ago, so I would question the need for 5000 extra homes on top of the ones already projected to go ahead. A new build 3 bed house on our street sat empty for 2 years before anyone moved into it, where is the need here? New developments at Marston Fields advertise they have sold 3 houses in 3 weeks, so 5000+ homes in 5000+ weeks? The demand is slow and new build houses are still available to buy but sat empty, again where is the evidence for 5000 houses?

The East West Expressway which has since been aborted by the Government, was one of the major justifications for the number of houses in Marston Vale to be viable. With this no longer going ahead where is Central Bedfordshire’s evidence to support the location and infrastructure to support 5000 homes with the potential 10,000+ additional car journeys a day on top of the ones already taking place? We have a very limited bus and train service but majority of travel is by car, this is not sustainable transport, where is their evidence to support it?
I would also like to add that I am sending this email as trying to find my way around the consultation to object (or make any comment) is near on impossible. The consultation was also only brought to my attention by neighbours, not the council, to ask for my opinion on the evidence they have submitted after I objected to previously. I had hoped anyone who had placed an objection would be notified of this consultation with dates of when it starts and finishes but it seems to have been overlooked amongst Covid-19 and heatwave notifications. I only hope you get a good number of villagers responding to this consultation, as it seems there are not many that are aware of it via Central Bedfordshire Council.

Para 3.1.3This technical note documents CBC’s approach to enabling sustainable travel, particularly in response to the growth proposed in the Central Bedfordshire Local Plan and supplements the extensive traffic modelling submitted in support of the Plan, which has identified locations at which growth is expected to create issues on the highway network. This note also provides an overview of current and emerging CBC transport policy and its strong track record in planning, securing funding for and delivering sustainable travel interventions.
1. I am very concerned that CBC will not be able to deliver on sustainable transport as despite strong commitment from Executive Councillors, and amazing hard work from very committed officers, the track record on delivery by CBC is very poor. Despite promises there is still no cycling officer which means that key cycle links in new developments and links and improvements to existing networks and key destinations are missed.
2. With the Eastern Leighton Linslade development despite a year of lobbying by myself as a local CBC Councillor and the very effective Local Cycling campaign group, the planners in charge of this development do not even have a map of the “Green Wheel” referred to in this paper which contains all the cycle routes and plans so that cyclists and walkers can reach their key destinations such as schools employment, station, shops etc. In other words despite asking for it for over a year, the planners of the new housing developments in Leighton Buzzard do not have access to the plans for cycling for the town and so cannot make sure that there are the necessary links from the estate to existing cycle routes and to key destinations.
3. There are such failures in Highways and planning and such a silo mentality that despite some fantastic committed officers who are delivering some great schemes, I as a cllr am having to ask the local cycling group to do a map of the existing cycle routes and plans for cycle routes with the plans for the new estates to give to the planners in order to hope that the links from the new estate fit the existing plans to improve cycling.
4. Furthermore this new estate despite the first tranches of section 106 having been delivered to CBC and over 230 houses being occupied in Clipstone Park has no plans for public transport or travel planning. This is despite the excellent example of Southern Leighton Buzzard where the travel planning cycling and above all the bus service Dash direct delivered a 17-20% reduction in traffic from the TRCIS assessment. This was done through a steering group of CBC, town council, developers, community groups and Arriva.
5. This successful model has not been replicated and new householders are being faced with no travel planning, no advice on cycle routes, no public transport and this is building levels of car ownership far above what was agreed in the plans.
6. There is such a silo mentality that there are no social value calculations or even any understanding of the TOMS framework when assessing bus routes and especially the provision for the elderly. There is a complete inability and total absence of any framework to look at the benefits of sustainable transport across different sectors such as health and well being , cutting carbon, supporting the local economy, reducing loneliness in elderly people, increasing physical activity.
7. I believe as a councillor that SP3 with current management structures is undeliverable. The officers on the ground have huge commitment and so do the Executive Councillors and some schemes despite all the odds are being delivered but the lack of understanding of sustainable transport at a more senior level and the lack of an integrated approach to place delivery, and sustainability makes the aspirations of the plan and the traffic modelling assumptions unrealistic.
8. Southern Leighton Buzzard which is currently still being built out was granted planning permission as an exemplar sustainable transport site with extra funding from DCLG. The plans have been delivered through a steering group of CBC LLTC, community groups, the developers, Arriva and links with local residents. This cut traffic between 17-20% above the TRICS assessment was award winning and the bus service is now running commercially. This was a real practical success and I have attached the report on this from the travel plan coordinator. This is mentioned in section 8 of the table in section 3.3 However CBC has not followed or replicated this model despite significant encouragement from myself as a councillor and despite supportive comments from the executive.
9. The interchange facilities at Leighton Buzzard Railway have been discussed since 2008. There are severe issues with overcrowding of the forecourt. At present there is very little work happening on planning for that scheme mainly due to lack of officers despite section 106 contributions being gathered for it.
10. There has been recently the filling of two long standing vacancies in Highways and a sustainable transport officer but a cycling officer has still not been delivered. It has to be seen whether this will improve delivery and indeed if this is enough officer at the delivery level but I see no change to the silo mentality . There is no understanding that good cycling links and pleasant access to the countryside and town centre encourages high value jobs and skilled professionals to settle in Central Bedfordshire.
11. Highways is top heavy in management at the expense of delivery. It is also encumbered with an ineffective contract that blocks delivery with Ridgeway Jacobs.
12. At present high street pedestrianisation in Leighton Buzzard reveals the present picture clearly. Hugely committed officer working long hours to try to deliver and executive councillors constantly visiting and talking to people, but no cross working from other departments such as regeneration or parking or any attempt to follow the LGA toolkit for town centres. There are not even links between Highways and Comms so the scheme is very poorly communicated leading to increasing hostility to support for pedestrians at the expense of cars.

Having attended the “Transport” hearing before the Planning Inspectors at Chicksands on 23rd July 2019 I naturally still have concerns from a transport perspective.
I would therefore like my concerns brought to the attention of the Planning Inspectors, as you sensibly suggest, as a formal submission as comments on the Transport Technical Paper as part of the continuing consultation, and passed on to the Inspectors for their consideration.
My comments from a land use and transport planning perspective, as follows : -
There does not appear to be an updated Local Transport Plan (LTP), despite the fact that many adjoining local authorities now have these – either in draft or final forms.

There is mention in Appendix 1 of the Transport Technical Paper of the Access for All bid for Flitwick railway station. When the DfT made additional funding available after the last bid round, Flitwick gained approval in March 2020. So like Biggleswade it now requires delivery. No doubt Central Beds will take this into account.
There is no mention of Strategic Rail Freight/Intermodal Interchanges : Sundon adjacent to M1 Junction 11A and the new M1 – A6 link road; Ridgmont - despite the planning application for the additional warehousing/enlargement of the existing there. Given East West Rail (EWR) this is a serious omission at such a key location. Ridgmont is also immediately adjacent to Junction 13 of the M1 motorway.
Under sustainable travel/transport there is no mention of the proposed Wixams railway station (an initiative admittedly largely by Bedford Borough Council) – but half the Wixams garden villages growth site is within the CBC unitary authority.
If there is common ground between CBC and Highways England, where is the common ground between CBC and the rail industry, including Network Rail, TOCs and the East West Rail (EWR) Company?
I note with particular interest the recent planning application for the proposed Flitwick Transport Interchange scheme, which was submitted towards the end of last week to Central Beds Council as the planning authority. This follows the part-funding for the scheme announced by SEMLEP on the 4th August.
Scheme details (including the AECOM work for CBC) :
http://cbstor.centralbedfordshire.gov.uk/publicportalviewer/publicViewer.html?caseID=CB/20/02736/FULL
Given the “Access for All” improvements at Flitwick railway station, for which the rail industry bid was successful in March this year, it is important there is full co-operation and co-ordination between the unitary authority, Network Rail, GTR and any other stakeholders, in the execution and delivery of all the proposals for the station

It is unsound because the planning on traffic and mitigation methods for M1 Junction 13 are flawed. This junction is strategically important and the plan cannot be sound with a flaw such as this.

The traffic forecast needs to be revised to properly take the Oxford to Cambridge Expressway into account

See attachment

The North Luton Consortium has comments relating to section 5 of EXAM 111 on the M1 Junction 11a Mitigation. Please see our attached representations under the heading 'Statement of Common Ground between Highways England and CBC (EXAM 111) and Transport Technical Paper (EXAM 114)'.