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BFARe critique Bedford Borough’s report on the alternative EWR Alignments

 Summary 

The Mayor of Bedford Borough, Tom Wootton, convened a Council meeting on 6th February 2024 to present the findings of three consultant reports that compare alternatives to the EWRCo preferred route through Bedford and out across north Bedfordshire countryside. These reports were from Systra, SLC Rail and JBA. 

In his summary report, Jon Shortland, the Council’s Head of Planning and Infrastructure concluded there was no clear winner between any of the options, with the southern options, including BFARe’s proposed hybrid route, performing almost as well as the northern options. 

Our full analysis of the consultant reports can be found below.

BFARe considers that if the consultants had undertaken more rigorous and in-depth analyses, the BFARe alternative would have come out as the clear winner. Our note explains our position in more detail, but in summary, the main issues are: 

  • The Systra report, looking at the economic implications, concludes there is little to choose in terms of GVA benefit to the Borough between north and south options. However, their analysis contains some misunderstandings and some significant modelling flaws, which unfairly penalises the BFARe option against the others. It is clear it would deliver the most GVA benefit of any of the options, including EWRCo’s preferred route. 
  • The SLC Rail Report wrongly states EWRCo’s decision-making process had been sound, which is a highly contentious conclusion. For example, decisions have been based on false, incomplete, misleading and withheld information and distorted feedback from the 2019 consultation. There were unexplained variations in construction cost estimates between 2019 and 2020 which misled affected residents. The need for homes in the Poets area to be demolished was known to EWRCo as early as 2018 – and to the previous Bedford Borough Council administration in 2019 – but was not disclosed publicly until 2021. 
  • BFARe disagrees fundamentally with SLC Rail when they estimate our alternative will require the demolition of 10-20 homes, when it is highly likely none will be lost. (This compares with 66 being required in the Poets area under EWRCo’s proposals.) 
  • SLC Rail also fail to consider impact on landscape character and visual amenity. Sections of countryside north of Bedford (and around Roxton when considered alongside the A428 improvements) are highly vulnerable to change. Some of the most significant additional impacts of the EWR Co route are due to the hilly topography it would cross, such as construction costs and impacts, carbon impact, operational costs and freight suitability. However, SLC Rail either say it is not possible to assess at this stage, or the impacts are the same for all options. We disagree. 
  • On the JBA report (flooding) no conclusions were drawn on the merits of each route, due to the lack of data from EWRCo. 

SLC Rail also question the need for 6 tracks north of Bedford, whereas we know EWRCo have consistently rejected the notion of 4 shared tracks. The BFARe hybrid option avoids the need for demolitions in the Poets area completely, whilst continuing to deliver town centre connectivity and regeneration prospects. 

Our full analysis of the Consultants’ reports can be found below.

Background 

In Autumn 2023, the Mayor of Bedford Borough, Tom Wootton, commissioned three consultant firms to compare the merits of EWRCo’s Preferred Route alignment (RA1 with Tempsford variant) in Bedford Borough against alternative proposals including those put forward by BFARe and ERTA, together with four other options generated by EWRCo (RA1, RA9, Varsity, and Varsity Hybrid). At a special Council meeting on 6th February 2024, Jon Shortland, the Head of Planning and Infrastructure, presented the results of those consultant reports, together with his own overview. 

The reports were from JBA (flooding issues) Systra (economic issues) and SLC Rail (differentiating criteria). The JBA report was inconclusive owing to a lack of suitable data from EWRCo, so we do not consider it in this response. 

BFARe welcomes the open and transparent way in which the alternatives have been considered and reported to the public by the Council, but we are not satisfied the BFARe option has been properly assessed or accurately reported. 

Mr Shortland’s report concluded there was “no clear winner” amongst the routes considered – “the southern options are almost as good as the northern” – but further work on each option could change these findings. 

BFARe firmly believes a more rigorous analysis of alternatives to EWRCo’s Route E would clearly point to the BFARe hybrid option delivering the best solution to serve Bedford and the Borough as a whole – “the clear winner” in Mr Shortland’s words. 

As context to the Borough Council’s comparative appraisal, it is relevant to consider how EWRCo have themselves evaluated and compared routes through Bedford Midland with routes to the south of the town. 

Previous consultations by EWRCo and relevance to decision-making 

In 2019, EWRCo put forward 5 Route Options (A-E) for connecting Bedford and Cambridge. Routes B and E were similar between the ECML and Cambridge and only differed between Bedford and the ECML. In summary, Route B went south of Bedford (with an interchange with the MML in the vicinity of Wixams) and Route E went through Bedford Midland and then across the north Bedfordshire countryside. Whilst Route E was seen as delivering opportunities for connectivity with Bedford town centre, challenges were envisaged with it potentially having complex linkages with the MML. Route B could support new homes south of Bedford whilst Route E could support new homes “through densification of Bedford town centre”. Slightly longer Oxford-Cambridge journey times would result from routing through Bedford Midland (Route E) compared with Route B. The indicative upfront construction costs in 2015 prices were c£2.6bn for Route B and c£3.4bn for Route E (the latter being by far the most expensive of the 5 options). 

In the Preferred Route Option report (2020) EWRCo set out their reasons for identifying Route E as the preferred option. 

Taking into account their main route selection criteria, EWRCo asserted:

  • Route E would provide the greatest transport benefits for users serving the most households in the catchment surrounding Bedford Midland, and better connectivity than a new station south of Bedford (para 1.21); 
  • The GVA (productivity) benefits of routes via Bedford Midland and routes via a new station to the south of Bedford would be very similar (para 1.28); 
  • Several large housing sites south of Bedford had already been allocated and an EWR service south of the town was not seen as adding to that position, whereas EWRCo referred to the Borough Council’s argument that a Bedford Midland option could support new housing as part of the regeneration of the town centre and potentially new opportunities north of the town (para 1.36); 
  • Route E costs had now fallen in relative terms to being the second cheapest £3.7bn (2019 prices) versus £3.9bn for Route B (para 1.37) but the reasons for that change were not explained; 
  • Routes via Cambourne (both Route B and Route E) had the fewest environmental impacts. EWRCo said that the specific route alignment that was chosen would ultimately determine impact on environmental features, but singled out that careful consideration would be given to potential noise, vibration and air quality impacts in the Bedford urban area (paras 1.39 and 1.40). Bedford town centre was considered a high risk hotspot (Route E) but no high risk hotspots were identified for Route B south of Bedford (Table 15.8); 
  • All options were expected to be able to satisfy existing and potential freight demand; 
  • All options could provide an acceptable level of operational performance, particularly if the EWR tracks through Bedford were fully segregated from existing infrastructure; 
  • Safety risk was not considered to be a differentiating factor (para 1.42). 

Reflecting the issues identified and the comparisons made between Routes B and E in the 2019 and 2020 reports, BFARe’s 2021 Consultation response put forward a hybrid between Routes B and E, picking up on the advantages of each route proposal whilst avoiding many of the downsides of Route E. In particular, 

  • Even wider Bedford related catchments would be served, with services calling at town centre stations (both Bedford Midland and St Johns), and at a new South Bedford Parkway station at Kempston Hardwick which could also accept fast through services not requiring a stop at Bedford Midland (a situation similar to the station arrangement at Bletchley and Central Milton Keynes); 
  • GVA benefits would be augmented by providing several station locations, allowing both town centre connectivity and out of town accessibility; 
  • Bedford BC aspirations for town centre regeneration and housing could still be achievable, whilst there would be additional transport support for south of Bedford sites, increasing their viability and attractiveness for development; 
  • Town centre environmental impact, including from additional traffic congestion and parking pressure, would be reduced, and EWR freight movements to/from the south and west could be routed away from the town centre; 
  • EWR and Thameslink/MML tracks would remain segregated, but the threat of acquisition and demolition of homes in the Poets area would be totally removed; 
  • Broad consideration of the topography north and south of Bedford (for the BFARe and the EWRCo options respectively) suggests significant advantage to the BFARe route in terms of engineering complexity, cost, environmental impact, and reduced risk. 

We have raised particular concerns with the Chief Executive of EWRCo that the BFARe 2021 consultation response was not seriously assessed in the 2023 Route Update Announcement documents and have still not received a satisfactory response. This disregard for local opinion and elected officials is typical of the EWRCo approach, and the matter is now the subject of Freedom of Information Requests. 


For further information

BFARe Press Office

Steve Arnold (BFARe) press@bfare.org.uk

BFARe is a Limited company. Company number: 13332104, Reg Address: Union House, 111 New Union Street, Coventry, West Midlands, CV1 2NT, United Kingdom