East West Rail 2021 Consultation Response

East West Rail 2021 Public Consultation

Written response from Mohammad Yasin, MP for Bedford and Kempston

Section C: Bedford – a new Bedford Station, a new Bedford St Johns Station, improvements to the existing railway and a new section of railway

 

Overview/background:

I welcome the opportunity to respond to the 2021 consultation.

Bedford is now a well-established and growing riverside commuter town, but it needs continued investment to remain an attractive and prosperous place to live. Towns can fall into deep decline missing out on investment and connectivity opportunities like the Oxford to Cambridge arc which may only arise once in a generation.

The establishment of a rail link between Oxford and Cambridge to assist East West transport has been a desire for decades. This new corridor should improve connectivity and even reduce freight on congested roads which were never built to take such traffic. Further, the development of a housing and job creation corridor between these two significant and culturally important centres is overall a great opportunity for Bedford.

For our town to be bypassed by one of the biggest infrastructure projects while neighbouring towns and cities reaped the benefits was not an option for me as the MP for Bedford and Kempston. This was the main reason for my support for Route E in 2019.

EWR said at the time of the initial consultation in 2019, that taking a route via Cambourne, B or E, would avoid the most environmentally challenging areas, for example, the southern routes and the proximity to the RSPB Nature Reserve, Sandy Warren Site of Special Scientific Interest and other heritage assets. My thinking at the time of the decision to support Route E, was that this route would have a less detrimental impact on the environment, given the comments about routes B and E.

In an ideal world there would be no environmental damage, but all infrastructure projects incur some such costs – which is why it was so vital to consider the impact of each route.

Getting traffic off the roads and on to electrified train lines or alternative green energy transport like hydrogen in the future, is going to be vital in tackling the climate change crisis.
 
Bedford Borough Council has pledged to become Carbon Neutral by 2030. I fully support rail electrification of the whole EWR line. It’s preposterous that the Government would even consider building new transport infrastructure going into the 2030s without clean energy being a priority.

The UK has set itself a legally binding target of reducing carbon emissions to net zero by 2050, and rail travel will be crucial to realising this.

In November 2021, the UK will host the crucially important UN Climate Change Conference. If the Government is serious about reaching its own climate change targets, it cannot sincerely make the case to build new rail infrastructure that does not ensure that rail plays its part in fostering a green recovery from the pandemic and transport infrastructure that is sustainable and fit for future generations. EWR should stand as a beacon of net zero rail, so I am disappointed not to see a commitment to this in the current plans.

 I strongly believe the new rail links will support the much-needed regeneration of the centre of Bedford and the delivery of the Town Centre Masterplan, including major improvements to the station, and its connectivity with the rest of the town. The investment will provide access to jobs and leisure in Bedford for people in new or expanded settlements served by the railway and enhance Bedford Midland in becoming an interchange of national importance.

Bedford Borough has a population greater than that of the cities of Oxford and Cambridge. The rail connectivity that currently supports its economic prosperity and growth is poor, other than to London. Recent and severe disruption to rail services during the Midland Mainline upgrade, and then the downgrading of services because of the pandemic has had a negative impact on our town and has dissolved trust with rail users and train companies.

So far, residents have not yet experienced the benefits following the years of disruption to services which are still not an improvement on the 2017 offering and the disruption caused by the Bromham Road bridge is still an annoyance felt in recent memory.

Proposing radical new changes against this backdrop has been difficult for the town as there is a general suspicion that residents could once again experience the pain of years of disruption (and possible displacement) without the promised gains.

Concerns of constituents:

Consistent and persistent concerns about EWR consultation plans fall into two broad categories: residents unhappy about the 2019 consultation itself and the chosen Route E;  and residents living in what is locally known as the ‘Poets’ area whose homes are at risk because of EWR extension plans around Bedford station.

  • How the Technical Report conclusions of 2019 have been so dramatically changed from something reasonable to something which clearly will be a long-term additional drain on national resources particularly over a future period of constraint?
  • How the original consultation was poorly publicised and conducted without full disclosure of certain facts, such as the potential impact on Poets quarter in Bedford and the widening of the tracks north of the town;
  • the enormous and costly disruption to Bedford town;
  • the destruction of many homes in Poets Quarter;
  • the costly re-rebuild of Bromham Road rail bridge;
  • irreparable damage to countryside to the north of the town; and
  • significant negative impact on schools, streets, homes, wildlife and the environment around Hawk Drive (a planned access route for the construction works).
  • the key question of who will be travelling by train post Covid – the pandemic will have a huge impact on people’s confidence to use public transport, especially when the vast majority can easily travel more cost effectively in their own cars or work from home..
  • Concerns over an increased use of freight on the line.

I have already raised many of these concerns with EWR and have had a response in some areas. I am grateful that at my request EWR sought evidence data, on the extent of the 2019 consultation. The postcode data on where consultation postcards was sent was useful and revealed that a postcard was sent by Royal Mail to nearly 40,000 residents in my constituency (39, 975).

Some residents in Brickhill Parish within my constituency, operating largely under the banner of BFARE, still do not believe they were adequately consulted and remain opposed to Route E in its entirety. As this is not part of this consultation I will not go into further detail in this response, but it should be noted that I have raised this with EWR on several occasions outside this consultation.

Bedford Station 8.4:

Bedford Station is long overdue a revamp to improve services, accessibility, parking, and storage for bicycles etc, so I welcome plans for a new station to be built.

However, plans should be more ambitious. Stations are important symbols in town and cities, and it should make a positive architectural and attractive statement for Bedford. EWR must get locals involved in the station design so they have ownership and pride in their local assets.

We know space is limited in the area which is why it must be maximised to the full. I support plans from the Bedford Rail Group who suggest putting the concourse over the tracks and “maximising the use of the space outside the platform footprint.” Which will also mean that “the proposed demolitions of homes and businesses along Ashburnham Road are definitely not necessary.”

Impact on Poets Area and Need to Sell

I am deeply concerned about the homes under threat in the Poets area of my constituency. The 6 track plans will have a substantial impact on many residents whose homes may be subject to a Compulsory Purchase Order, land acquisition or are otherwise affected.
 
In particular, many of the potentially affected residents in the Poets area of  Bedford town have already endured a significant period of disruption (noise, dust, prolonged road closures etc), to their communities due to the electrification of the Midland Mainline and the closure of Bromham Road Bridge.


As outlined in the consultation there was no mention of the need for the requisition of homes in the 2019 consultation:

“greater detail has emerged since the decision to select Route Option E as the preferred route option in 2020 – at that time, it was not known that EWR services would require additional tracks north of Bromham Road. Consequently, EWR Co considered whether this indicates that the route option decision remains valid. EWR Co’s conclusion is that identifying Preferred Route Option E remains sound because….”

EWR has not successfully made the case to significantly alter the consultation plans without consultation and to attempt to gloss over this issue in the consultation. It is having been a very unfortunate development within the Route E plans, that this element emerged as a fait accompli.

The way this was introduced has tarnished the overall public reception of plans that otherwise provide potentially fantastic opportunities for our town. Rather than just vaguely presenting the worst-case scenario plans that have proved extremely distressing to many in the area, EWR and the DFT had time to provide far more detailed plans to show other options, not involving the rather casual demolition of homes, are very much possible.


As a result, I cannot support the 6 track plans as they stand. Although it is not an option on the consultation, I support Bedford Borough Council’s strong case for a 4-track option, with the re-siting of Bedford Midland station to the north of Ford End Road. This re-modelling should incorporate new platforms for the EWR lines but additionally should provide a new platform on the southbound fast line which does not currently exist, but which I understand is currently a major cause of congestion to the north of the station.


Such an approach may help ease congestion for services north of Bedford station and prevent the need for rebuilding Bromham Road Bridge (which has only just re-opened after a year-long closure due to the aforementioned electrification), and perhaps most importantly, protect housing and land. I know from conversations with EWR representatives that this would be a cheaper option for EWR.


Bedford Borough Council (BBC) requested a technical review of whether future services on East West Rail between Bedford and Cambridge could use the existing slow lines between Bromham Road bridge, just to the north of Bedford station, and the junction where the Midland Main Line and the line to Cambridge would diverge.

https://bbcdevwebfiles.blob.core.windows.net/webfiles/Parking%20Roads%20and%20Travel/Strategies%20and%20projects/implications-of-ewr-services-using-slow-lines-north-of-bedford.pdf

The report, as EWR is aware, looked at options around the East West Rail route north of Bedford Midland has shown that the service could run effectively using just the existing four lines and avoid the need to demolish any homes in the Poets area.

The report sees two broad options for EWR infrastructure north of Bedford station. One that provides an additional two tracks from the EWR platforms at the station through to the point of bifurcation from the Midland Main Line; and another that brings the tracks from the EWR platforms to a junction with the Slow Lines just to the south of Bromham Road bridge.

EWR services would use the Slow Lines, alongside other traffic, until the junction for Cambridge is reached, some 800m north of the station.

This technical note examines, at a high level, the feasibility of this second option from the point of view of line capacity and timetabling.

The conclusions drawn in the BBC-developed design, show there are no conflicting moves between westbound EWR services and existing MML services, other than a need to comply with the standard 4-minute headway on the Up Slow line.


In my meeting with EWR representatives on 28 May 2021, I raised the report conclusions with EWR, and although they raised concerns that any further traffic on the existing 4 lines would worsen the already congested line and risk travel disruption that would affect 3 rail franchises should problems occur (a point I do take on board)  EWR did commit to giving full consideration of the SLC report and at the very least take on as many of the SLC report recommendations as possible.

These tracks have been upgraded and resignalled in recent years and could certainly cope with the additional EWR services.

 

It is worth noting that the SLC report which is an evidence-based view that only four tracks are necessary is the same conclusion that Network Rail came to in their “East West Rail Central Section Phase 2f Report”.  It states on p42 that the aspiration to run a 6 trains per hour (tph) passenger services and 1 tph freight train on the Slow Lines to the north of Bedford Midland station for [EWR] could be accommodated.

 

On p43 it states that “With regards to the MML north of Bedford Midland station, the analysis concludes that there is available capacity on the Slow lines for the proposed service specification.”

 

I have made it known to EWR that I remain unhappy at the way residents whose homes may be at risk have been treated. I am very disappointed in the Need to Sell document and letter to impacted residents. The way this has been handled by East West rail has had a detrimental impact on residents and caused a lot of problems for the Cllrs who live in the area who have been subject to sustained personal attacks and abuse, despite themselves being opposed to the 6-track plans.  It’s unfair that EWR have not done more to inform residents that the rail line is a Department for Transport/EWR project and that there is no realistic scope for local elected representatives to alter conclusions from the 2019 consultation.

Although my position is to protect homes in the Poet’s area it would be remiss of me not to also ensure that residents get the best possible deal should the worst-case scenario arise.  EWR should have put forward transparent and unified need to sell and blight proposals at the very beginning so affected residents had real agency with which to make informed decisions.

I do not think EWR have met their own 5 principles when dealing with the community on Need to Sell and blight payments. It appears that all of these negotiations are being conducted behind the scenes on a sporadic basis. Details are vague, incoherent and badly explained. The methodology for qualifying for the Need to Sell scheme is random.

For instance, I’m concerned that Need to Sell residents have to prove the market value of their homes has “generally” been reduced by 15% to qualify for the scheme. Why this bar has to be met is not explained. Why should homes affected by say 5%, 10 % or up to 15% be expected to agree not to be compensated?

Other rail projects (such as HS2) have made no such requirements so EWR need to remove this arbitrary bar.

I would like to see much clearer, fairer and more consistent proposals.

As I made clear to EWR in correspondence at the beginning of the 10 week consultation, this should have included setting out the inclusions on the parameters of the scheme for both those who may want to sell now, and for those who may want to do so in the future.

Affected residents would have benefitted from being aware of the potential timescale so they could make informed decisions and organise their lives accordingly. At the moment, they can’t, and the lack of detail has been a significant source of distress both for those affected and local representatives trying to support and guide them.

I am very concerned that affected residents are being told to “consider taking independent professional advice if your land or property is potentially affected by the East West Rail Project”. Many residents simply cannot afford such an option and even if they could, should not be expected to be out of pocket to access legal representation or advice for detriment to themselves from EWR/DFT plans. It is therefore essential that EWR should make funding provision for recommendations they have made within the need to sell offer which must include access to legal advice.

I am encouraged that in my meeting on the 28 May with EWR representatives that they acknowledge the point (though I note they did not respond to (in writing or otherwise) to  my letter of the 8 April 2021 where I  set out my preliminary response and  raised these concerns/recommendations for improved support for residents.

EWR representatives explained in the meeting of the 28 May 2021 that it was important that legal advice was totally independent of EWR, a point I totally agree with but it should have been obvious to EWR that a list of independent approved solicitors could and should have been offered to affected residents to seek free legal advice with the fee billed to EWR. In no way, shape or form should affected residents have to pay for access to legal advice in relation to EWR impact on homes or negative value on homes because of EWR plans. In fact, all affected residents must be assured that legal advice and instruction will be covered and made available to all affected residents as soon as possible.

I was told to encourage affected residents to call EWR dedicated helpline and they would seek to assist with this request but once again, this offer should be made to all affected residents and should not be arranged on a behind the scenes one to one basis.

Prior to this consultation response, I have also made clear to EWR that they must include the impact of mental distress in any compensation package, whatever the outcome of the consultation. A number of affected residents are frightened about the proposals; afraid about their future, being ripped away from their communities, friends and neighbours and confused and disempowered about their options for redress or where to begin facing such a potential, significant life change.

EWR must provide clear and transparent proposals and more support in the form of a detailed community plan.


It is difficult for any of us to make informed decisions when parts of the consultation raise more questions than answers and this lack of transparency just fuels suspicion, rumour, and misinformation.


EWR did communicate to me in the meeting on the 28th May that they recognise this as an issue and said the consultation was an ongoing piece of work – that the 9th of June deadline was just one date, but that the consultation is ongoing and that even beyond the consultation deadline, there will be more details published and ongoing engagement.

I appreciate that EWR will not have final plans yet and I realise the project is huge and genuinely a work in progress but EWR must do more to reveal the pros and the cons of different outcomes and present this in a way that is simple for my constituents at any level of knowledge about the consultation to understand.

I have also made the case, in writing and in meeting with EWR representatives to extend the consultation so that it includes at least one in person public meeting. Covid has had a huge impact on everybody’s lives and it is in my view a totally reasonable request. At the time of writing, it is by no means certain that lockdown restrictions are going to be lifted on 21 June, not least in Bedford as one of the hotspot areas. It will not be known before the consultation period ends. It is therefore unlikely that  face to face public meetings are going to be recommended in the near future, but EWR must ensure that their “ongoing dialogue” with residents includes in person public meetings as soon as its safe to do so.

On freight, what we know from the public consultation documents is that there is a maximum possibility of one freight train per hour and they will not be permitted to operate during the night.

I raised the concerns over freight on the line and I was told that there is still a study underway to “understand what the capacity and demand would be on EWR for freight including the potential demand, the capacity considerations on EWR infrastructure, and the potential constraints elsewhere on the network. This work will inform the approach to the next stage of design and the assessment of the environmental impacts of the Project”

I was told it was important to understand, freight train operations are not like passenger trains. They operate on demand, so freight companies bid to run a freight train if there is space, not just on the EWR line but on the connecting routes so even if there is capacity, freight trains won’t necessarily run. Freight trains are already in use on the Bedford lines and I’ve never had a complaint from a resident.

On the Marston Vale line for instance, there are 5 freight train paths per day available but only one a week is used.

 

Section B: Bletchley and the Marston Vale Line – improvements to the existing infrastructure, stations and level crossings:

 

The argument made in the consultation for the improvement on the Bedford to Bletchley and the Marston Vale (Varsity) Line is well made. I agree that it is a once in a generation opportunity to invest in upgrading the Marston Vale Line to meet the needs of the community and railway customers, now and in the future.

I also agree that it is not possible to introduce a fast, reliable and frequent service between Oxford and Cambridge without making a significant investment in the Marston Vale Line.

The consultation is right to recognise the existing line, which was built in the nineteenth century to serve a very different customer base, now suffers from poor reliability and low usage, although EWR Co recognises the importance of this line to some parts of the community.

As the consultation recognises, passengers using the line have had to endure an increasingly unreliable service for years, to the point where a rail replacement bus service is frequently used.

Being aware of the significant problems that have arisen on the line because of frequent signalling problems, I am convinced by the arguments for new infrastructure which will also meet the objective set by the Office of Road and Rail to close all level-crossings because they pose a safety threat and disruption to road traffic.

As identified in the consultation report, there is no formal provision for pick-up and drop-off of passengers along the route. Most have no facilities for cycle parking and no specific arrangements are available to facilitate interchange with local transport. It is also recognised that pedestrian access routes to some stations are unattractive to potential users. One of the worst examples of this is Kempston Hardwick, where pedestrian access is from a busy, unlit rural road that has no footways.

I also see the case for drainage improvements, repair or strengthening of existing earthworks (cuttings and embankments) and replacement of the signalling system.

I also want to see much clearer plans on whether the line will be built with net zero rail as a priority. Given the very urgent need tackle climate change, it is necessary for new all new rail infrastructure to be built with rail electrification or alternative green infrastructure as a priority.

I have been concerned for some time, as have a number of my constituents that the lack of investment in the service amounted to a managed decline.  Because of the slow and unreliable service, service users dropped off over time opening a false argument that there is small demand for the service.

This is clearly unsustainable and totally unfair for rail users, in particular the students using the service from Bedford to access Bedford College.

So, a total overhaul of the service, introducing fast trains will revitalise the service, attract passengers and offer a much-needed reliable service offering greater connectivity for Bedford making it a fantastic transport hub. The merging of stations to allow fast trains only will be welcomed by my many of my constituents but equally retaining the local stopping service with no station closures or resightings is important in serving their customer base. It is for the residents of the villages directly affected by the plans to decide what works for them. As the MP for Bedford and Kempston, not representing those villages, it is therefore not for me to declare a preferred concept.

However, both options will require the existing train service between Bletchley and Bedford to be suspended during the construction period. I would like to see more detail on the length of time it will take to construct each option and I would like to see the details of the rail replacement service. EWR and the DFT should consider considerable price reductions and no charges for students for the considerable inconvenience to them that building the new infrastructure will cause.

Freight:

The consultation says in addition to the passenger services, “the line will continue to cater for freight traffic. Currently, up to five freight paths per day are timetabled over the Marston Vale Line, although many of the paths are often not used.”

This is far too vague. It does not say whether the 5 freight paths (though not used) will increase or not. Much more detailed information is needed on this.

Bedford St Johns station relocated a short distance to the south or west:

I am persuaded by the case for the Bedford St Johns option 1: Hitchin alignment (Hospital station).

Key characteristics of this option are that it:

  • Provides a replacement Bedford St Johns station close to the existing location;
  • Achieves a line speed of 40mph, which exceeds the 30mph minimum objective and is a substantial improvement compared to the current maximum speed of 15mph; •
  • Promote the use of public transport to/from the existing hospital, which is adjacent, and help to reduce car dependency.
  • The construction of the new station would also unlock the development potential of the area and become the catalyst to consolidate the existing nature of the urban structure, providing the opportunity to reduce the surface car parking in the area.
  • The alignment makes use of the existing Ampthill Road overbridge, which used to pass over the old Hitchin railway. Initial dimensional checks suggest that it should be possible to retain the bridge without any major structural modifications.

According EWR, the works for the new EWR alignment would be largely offline from the existing railway, with the impact on the existing line limited to the location of tie-ins.

The consultation identifies that Option 2 would be “significantly more complex and disruptive to construct than Option 1 and would therefore incur a higher capital cost.” Construction would also be more disruptive to the operation of the railway since most of Option 1 can be built off-line, whereas Option 2 is likely to require more extensive railway closures. Construction would also be more disruptive to the operation of the railway since most of Option 1 can be built off-line, whereas Option 2 is likely to require more extensive railway closures.

By making use of existing bridges, in addition to reducing the capital cost, Option 1 would maximise the size of the development area site to the north east of the alignment that is included in the Local Plan, whilst providing good access from the relocated station to the hospital and offering integration opportunities with future developments.

I am concerned that a station to the south in Option 2, would require “construction within an existing residential area” which I worry would threaten homes. This should be avoided at all costs.

I am pleased to see Option 1 is EWR’s emerging preferred option but concerned that this is vague.  In the current consultation, I, along with the residents in the Poets area were very surprised to see homes under the prospect of demolition in the 2021 preferred route E plans.

In this context, I am troubled by the phrase,

“further investigation of both options will be undertaken during the next stage of development following consultation feedback and development of the timetable.”

There must not be a repeat of future consultations involving the demolition of homes presented as a preferred option route out of the blue. EWR must be very clear that the relocation of Bedford St John’s station will not endanger homes, particularly when Option 1 clearly removes this risk.

Conclusion:

This consultation has been a huge undertaking under the difficult circumstances posed by the pandemic and I would like to take this opportunity to thank Will Gallagher and Jordi Beascoechea from the EWR Co for their polite and often helpful engagement with me and my office. They undertook work I asked of them, responded on most occasions, and did strive to answer my questions as fully, openly, and honestly as possible.

I am also encouraged that even after the close of the consultation, EWR have indicated that  they will keep an open dialogue with the Bedford community and as they pledged to me will “continue to talk to the communities along the route and their representatives as they further progress and develop the design of the East West Rail Project.

EWR  told me the  best way to be notified of any future activities they will hold following consultation is to sign up to their newsletter here.

I am reassured that a bare minimum “there will be further opportunities to formally raise issues for their consideration, including a statutory consultation. Following the statutory consultation, EWR Co will submit plans to Government, and the Planning Inspectorate will carry out a public examination of their application, which will also provide another formal opportunity for comment.”

However, the implementation of the 2019 and 2021 consultations has been sub optimal and I hope EWR learn lessons from this ahead of the planned statutory consultation and take on board some of the criticism around much more transparent, fair  and detailed information and engagement.

 

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