BSCF's Formal Objections to Proposed Schools' Relocation and Subsequent Housing Development  Map 

Head of Development Control East Herts Council Wallfields Pegs Lane Hertford SG13 8EQ

18 August 2008

Your Refs: 3/08/1101/OP, 3/08/1102/OP, 3/08/1103/OP, 3/08/1115/OP, 3/08/1116/OP, 3/08/1117/OP

APPLICATIONS TO BUILD TWO SCHOOLS AT WHITTINGTON WAY BISHOP'S STORTFORD AND HOUSING ON THE SITES TO BE VACATED AT WARWICK ROAD, BELDAMS LANE, LONDON ROAD AND ON THE RESERVE SITE AT HADHAM ROAD

1. I am writing on behalf of the Bishop's Stortford Civic Federation to object to these proposals. The Civic Federation brings together the Civic Society and all the active Community and Residents' Associations in the town into a partnership representing over 6000 households. The remainder of this letter sets out the grounds of our objections.

Planning Policy Context

2. New development proposals are rightly expected to conform with national policies for development control and the relevant provisions of the adopted Regional Spatial Strategy and the adopted Local Plan. The application to relocate two schools from their present sites to Whittington Way provides the catalyst for the housing development applications. If the schools stay where they are, the other applications will automatically fall away. It is therefore sensible to concentrate primarily on the application relating to Whittington Way.

3. The Whittington Way proposed development site falls within a larger area of Green Belt between the Bypass and Bishop's Stortford. It is the most open Green Belt site remaining largely undeveloped within the Bypass. It is therefore important to establish the national, regional and local policies relating to such a site. National policy on the Green Belt is set out in the Planning Policy Guidance note PPG2. This has been supplemented by a circular and direction issued by the then Office of the Deputy Prime Minister in 2005. Relevant extracts from both documents are set out immediately below.

4. Government Green Belt Policy - PPG2  Map 

• The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. (para 1.4)
• The purposes of including land in Green Belts [checking unrestricted urban sprawl, preventing neighbouring towns from merging, safeguarding the countryside from encroachment, preserving the setting of historic towns, encouraging recycling of urban land] are of paramount importance to their continued protection, and should take precedence over land use objectives. (para 1.7)
• The essential characteristic of Green Belts is their permanence. Their protection must be maintained as far as can be seen ahead. (para 2.1)
• Once the general extent of the Green Belt has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within urban areas. (para 2.6)
• Where existing local plans are being revised and updated, existing Green Belt boundaries should not be changed unless - other exceptional circumstances exist, which necessitate such revision. (para 2.7)
• The general policies controlling development in the countryside apply with equal force in Green Belts but there is, in addition, a general presumption against inappropriate development within them. Such development should not be approved except in very special circumstances. (para 3.1)
• The construction of new buildings within a Green Belt is inappropriate unless it is for the following purposes:
  • agriculture and forestry
  • essential facilities for outdoor sport and recreation
  • limited extension, alteration or replacement of existing dwellings
  • limited infilling in existing villages and limited affordable housing
  • limited infilling or redevelopment of major existing developed sites (para 3.4)

5. The general presumption against any new development in the Green Belt has been expressed in PPG2 in the strongest and clearest possible terms. The emphasis on openness and permanence taking precedence over other considerations (such as landscape features or the nature of the vegetation) is particularly relevant to this application. It is clear that the proposals would fall within the definition of 'inappropriate development' as set out in PPG2.

6. ODPM Circular 11/2005 - The Town and Country Planning (Green Belt) Direction 2005  Map 

The messages contained in PPG2 are reinforced in this circular and direction as the following extracts show:

• Save for a few specific exceptions, as detailed in para 3.4 of PPG2, the construction of new buildings inside a Green Belt is inappropriate development. (para 3 of the circular)
• The effect of the Direction is to require local planning authorities to refer any planning application which falls within para 3 of the Direction, and in respect of which the authority does not propose to refuse planning permission, to the Secretary of State at the appropriate regional Government Office' (para 8 of the circular)
• If it appears that the application is for inappropriate development in the Green Belt, the authority should than decide whether the development would significantly impact on the openness of the Green Belt. - The magnitude of impact is likely to be heightened if the Green Belt is narrow, or partly confined by existing (or planned) development, or if it is prominent in the landscape at the development site. Potential impacts will also be greater if the development site is overlooked by or close to residential development - (para 11 of the circular)
• In considering the scale of the development, regard should be had to the bulk, form and height of the building or buildings - For example - a large single storey warehouse with a total floor space of 1000 square metres or less, may have a significant adverse impact on the openness of the Green Belt - (para 12 of the circular)
• Where it will involve intensive on-site activity, large numbers of parked vehicles, considerable transport movements to, from, or around the site - it will have a potentially significant impact on the Green Belt, even if any building constructed is below the floor space threshold in para 3 (a) of the Direction. (para 12 of the circular)
• In deciding whether a planning application should be referred to the Secretary of State under para 3(b) of the Direction, an authority should take account of all the above considerations, regardless of the very special circumstances which it may consider exist to justify the grant of planning permission. (para 17 of the circular)
• This Direction shall apply to any application for planning permission involving inappropriate development on land allocated as Green Belt in an adopted local plan ' which would involve:

1. the construction of a building or buildings with a floor space of more than 1000 square metres; or
2. any other development which, by reason of its scale or nature or location, would have a significant impact on the openness of the Green Belt.

Where a local planning authority does not propose to refuse an application for planning permission to which this Direction applies, that planning authority shall first consult the [First] Secretary of State. (paras 3 and 4 of the Direction)

7. The impact of these proposals on the Green Belt would be considerable and irreversible. They would involve the construction of buildings with approximately 31500 m² of floorspace; 500 car parking spaces; terracing of those parts of the site which are not built on to provide level playing fields in place of the currently gently sloping hillside; sports pitches will be floodlit, and the whole site would be surrounded by a 2 metre high security fence. There can be no doubt that a campus with potentially 3000 students will generate a huge number of traffic movements. This particular Green Belt site is quite narrow and the site as a whole is bordered on three sides by residential development.

8. The clear presumption of both PPG2 and the circular and direction is that permission for this development should be refused. If, nevertheless, the local planning authority believe that the justification advanced by the developers is so exceptional that the normal expectation of permanent Green Belt protection should be set aside, they must refer the application to the Secretary of State for possible call in. Refusal or referral to the Secretary of State are the only two courses of action open to them.

9. Planning Policy Statement 1 - Delivering Sustainable Development

The presumption against the proposed development is reinforced in PPS 1 which in para 5 for example makes the following point:

'Planning should facilitate and promote sustainable and inclusive patterns of urban and rural development by:

'protecting and enhancing the natural and historic environment, the quality and character of the countryside, and existing communities.'

Para 19 stresses:

'Planning policies should seek to protect and enhance the quality, character and amenity value of the countryside and urban areas as a whole. A high level of protection should be given to most valued townscapes and landscapes, wildlife habitats and natural resources. Those with national and international designations should receive the highest level of protection.'

[Our emphasis added]

Green Belts are, by definition, among the most highly valued parts of our countryside, as much for the functions they perform in checking urban sprawl as because of their intrinsic amenity value.

10. Regional Spatial Strategy for the East of England

The version of the East of England Plan which has been approved by the Government was published in May 2008. It identifies some strategic revisions to the Green Belt. In a local context the most important of these is for the area known as 'Harlow North' a few miles to the south of this development proposal. However, apart from the proposed strategic revisions, the policy in SS7 clearly states that

'The broad extent of green belts in the East of England is appropriate and should be maintained.'

Other relevant objectives of the Plan are set out in para 45 of this letter.

11. The East Herts Local Plan Adopted in April 2007

Because its development was so far advanced, the Government agreed that the former procedure for the consideration and adoption of Local Plans should apply to the East Herts Plan and this is therefore the detailed document for the control of development until 2011. At the last stage of public consideration before the adoption of the Plan, EHDC proposed the removal of part of the Whittington Way site from Green Belt protection and its redesignation for educational use (15 ha rather than the 20 ha now proposed, but to provide two schools of the same size as the current proposal). The proposed redesignation was considered in some detail at the Examination in Public into the Local Plan and the Inspector's summing up is set out below.

'All of which bring into question, in my [the Inspector's] view, the planning wisdom of Policy BIS 24 and of the proposal to remove the [Whittington Way schools] site from the Green Belt. This is a long established area of protected land, serving well-defined Green Belt functions. While not taking issue with the educational reasons for locating the two schools in this area, I do not accept that it is necessary to remove land from the Green Belt to enable the secondary school needs of the town to be met. The Green Belt designation should remain; the circumstances of educational need, as well as the impact on the Green Belt could be considered in the context of a planning application. After all there are examples of educational establishments within the Green Belt elsewhere in the District, and the Council is able to exercise the level of control necessary in such locations. On the other hand, removal of the site from the Green Belt, to accommodate the identified need, weakens the Council's position in safeguarding the principle and permanence of the Green Belt. Other pressing needs could just as well prevail on this approach in arguing for further Green Belt releases' My views above lead me to conclude that Policy BIS 24 should be deleted.' (paras 11.48.7 and 9 of the Inspector's conclusions on this issue in her report on the Local Plan)

* Recommendation - Delete Policy BIS24.
                            Modify the Proposals Map by including Site 571 in the Green Belt
                            (paras 11.48.10 and 11 in the Inspector's report on the Local Plan

12. It is unfortunate that the developers have taken one extract out of context from a balanced consideration by the Inspector of the arguments for and against redesignation of part of the site, and decided to proceed with their planning application. In doing so they have ignored her overall judgment that the case had not been made for removing Green Belt protection, and that the boundaries proposed were somewhat arbitrary and did not follow readily recognisable features. As a result, the southern boundary of the site would be questionable and the rest of the site might not be protected from development if that part were to be redesignated. The site as a whole retains its Green Belt status in the now adopted Local Plan in line with the Inspector's conclusions. The full text of the Inspector's assessment of this issue is attached as Appendix 1 to this letter.

13. The Inspector's report on the Local Plan also dealt with the site at Hadham Road which had been acquired by the County Council many years previously for educational purposes. Her conclusion on this was as follows:

* Recommendation - The Reserve Secondary School Site, Hadham Road, as defined on
                            the Proposals Map, is reserved for residential development as a
                            Phase II site and will only be released for development if sufficient
                            additional secondary school capacity is provided elsewhere in the
                            town (para 11.22.7 of the Inspector's report on the local plan)

14. The Inspector's recommendations have been incorporated in the Local Plan adopted by EHDC in April 2007.  It should also be noted here that the Local Plan makes no provision for any alternative use for the two sites currently occupied by the Boys' High School and the Herts and Essex School nor for the use of the separate Herts and Essex School playing field site in Beldams Lane. In addition therefore to the use of the Green Belt site in Whittington Way for educational purposes, any alternative use of the three sites which the schools would vacate as a result would also represent major departures from the recently adopted Local Plan. The incompatibility of these proposals with national, regional and local policies for Green Belt protection, together with the four major departures they would entail from the Local Plan should of themselves be sufficient to refuse permission for these applications - to do otherwise would suggest that any part of the Local Plan could be set aside to suit the convenience of developers. Local Plans are intended to give certainty to local residents and developers as to what sort of development will be permitted and where. To sanction such major departures so soon after the Local Plan had been adopted would bring the whole planning system into disrepute and would certainly be regarded by the Civic Federation as a matter of more than local importance.

Educational Need

15. As this letter will show, the proposals are devoid of merit in planning terms. The developers therefore rely on arguments falling outside the spectrum of development control to support their claims of exceptional justification to override Green Belt protection. Ostensibly, these arguments are all based on educational need, and therefore have to be critically examined. The arguments can be considered under a number of headings.

16. Size and Condition of Schools

Both the Boys' High School and the Herts and Essex School argue that their existing sites are too constrained to permit expansion beyond their current size of 5 FE (forms of entry of 30 pupils). They also claim that their buildings are in poor condition and that the facilities they provide restrict the range of educational opportunity they can offer.

17. As they have pointed out, both schools are popular and oversubscribed. They both have a good academic record - in the case of the Boys' High School achieved only relatively recently without any expansion in intake or significant alteration to buildings. Both schools are foundation schools which have opted out of local authority control. It is therefore the responsibility of their boards of governors to live within the budgets they have been allocated by central government for running costs (including staffing) and maintenance.

18. It would probably be difficult for either school to expand on its present site. It would not be impossible to refurbish or (in the case of the Boys' High School) replace their buildings without moving to a new location, albeit with some transitional inconvenience. The Boys' High School has sufficient adjacent land for temporary accommodation to be erected to allow for the existing buildings to be progressively demolished and replaced. If the Herts and Essex School were to make better use of its playing field in Beldams Lane (for example by building a sports pavilion and changing rooms on the site and laying out different types of sports pitch) there would be sufficient space on its main site to erect temporary buildings while the limited amount of substandard accommodation was being refurbished or replaced without prejudicing physical education.

19. In summary, neither school needs to expand in order to maintain its academic standards. Neither school needs to move in order to replace or refurbish substandard buildings. They are typical in age and condition of the buildings of many secondary schools in the County which have to live within their means. If the boards of governors who have opted out of local control are finding it difficult to live within their means they should not now be looking to the local community to bail them out through the windfall profits which would arise from this development. If the schools were basing their case for exceptional disregard of Green Belt protection purely on their wish to fund new buildings, their planning application would not be entertained for a moment.

20. Viability and School Size

The LEA claim Note 1 that the minimum viable size for a new school is 6 FE (about 1200 pupils in total). Arguably, however, 6 FE ought to be regarded as the maximum viable size of school not the minimum. Hockerill Anglo European College is one of the most successful schools in the country and has just received an outstanding Ofsted report. Its students take the international baccalaureat which requires it to support a broader 6^th form curriculum than schools which take A levels. It has only 4 FE, about 750 students, and has resisted calls from the LEA to expand because it believes that the quality of education would suffer.

21. 'Lessons from the Front' published by the Teach First organisation in November 2007 has the following to say about large schools

“[Economies of scale] is an oft cited but potentially misleading argument '. the tendency is for very large organisations such as bureaucracies to find that their size obstructs the delivery of the very outcomes they are created to achieve, as diseconomies of scale begin to emerge. An argument for large schools based purely on cost, then, fails to consider cost-effectiveness, value for money or the cycle of innovation.”

“A school's capability to implement creative initiatives, or respond to sudden problems, can also be impaired as it gets larger '. In many urban complex schools, teachers' time and energy are simply spread too thinly between too many pupils.”

22. There is a growing body of evidence that educational attainment and social behaviour deteriorate in very large schools with the Conservative Party education spokesman claiming ('Guardian' 3/01/08) that nearly three times as many pupils were excluded from large schools as small ones. The then General Secretary of the NUT believed that the optimum size for a secondary school was probably between 800 and 1000 pupils ('Times' 3/01/08). It is reasonable to conclude on the basis of this evidence and of their own academic records that the Herts and Essex and Boys' High Schools have now reached their optimum size of 5 FE. A 60% expansion of both schools contemplated by this proposal with co-location on to a single campus and considerable sharing of facilities seem likely to jeopardise the quality of education and the high reputations which they currently enjoy. It is hard to believe that they will be able to retain their own individual characters as separate schools in these circumstances.

23. Parental Choice

The developers claim that the oversubscription of the two schools shows that there is an unsatisfied demand for single sex education which their proposals would meet.Note 2 The argument is at best unproven and at worst, nonsense. All the schools in Bishop's Stortford are oversubscribed because there is, and has for many years been, a shortage of secondary school places.

24. At present there are on offer 10 FE of single sex places (5 at each of the two foundation schools) and 8 co-educational FE at Birchwood School. Of the other state funded schools in the town, St Mary's provides 5 FE of co-educational places but is a faith school which only the children of Roman Catholics can access. Hockerill Anglo-European College is a part boarding, part international school and so admission to its 4 FE of coeducational places is also restricted. If the developers' proposals were to go ahead the town would ultimately have 16 FE of standard single sex educational places compared with only 8 FE of standard coeducational places shared between three schools of 8 FE each. The alternative (discussed below) of a single new coeducational 6 FE school would achieve a better balance of 10 single sex FE of admission compared with 14 coeducational FE of admission shared across four schools.

25. It should also be noted that the developers' proposals would do nothing to increase parental choice. Enlarging the foundation schools simply offers more of the same, for better or for worse, whereas a fourth new school could offer an alternative range of educational opportunities. The developers' proposals therefore militate against seeking a balance of single sex and coeducational places and militate against parental choice.

26. What the Proposal Would Deliver

Any argument that there is no available site within the existing built up area of the town large enough for a 3000 student campus may be true but is entirely irrelevant. As explained above the two foundation schools are under no compulsion either to expand or move. Moreover they have no duty to provide additional school places to meet the shortfall in Bishop's Stortford. That responsibility rests with the LEA - the County Council. It is therefore surprising that the application to build on Green Belt land is not being led by the LEA.

27. The only argument which might lead to consideration of sacrificing Green Belt protection is that this proposal is the only way in which the shortfall in school places can be met. As presented, it proposes to enlarge the schools by 1 FE each in 2011, with further additions of 1 FE each in 2021 and 2031, bringing both schools up to 8 FE by 2031.Note 3

28. In the view of the Civic Federation, this slow rate of expansion would perpetuate, not cure, the shortfall in secondary places in Bishop's Stortford. There is, moreover a site in County Council ownership at Hadham Road which has been safeguarded for this purpose for many years. At 8.3 ha it is large enough for a 6 FE school (which would have to be coeducational) which the LEA accept is a viable size for a new school. The arguments are set out in more detail below. If they are accepted there would be no justification for sacrificing the Green Belt.

29. The Shortfall in School Places

Appendix 2 to this letter sets out the Civic Federation's analysis of the demand for school places compared with the capacity which the developers are proposing to provide. The clear conclusion to be drawn is that a proposal to provide only 2 additional FE in 2011 will leave the town with a significant amount of unmet demand, if the current rate of house building continues to deliver a projection of 4000 additional houses for Bishop's Stortford by 2021. Because the developers' forecasts look at the total shortfall in school places rather than the shortfall which would occur when parents apply for their children to move to secondary school in year 7, it is not possible to compare the numbers used by the developers (for which no sources have been cited and from which the underlying calculations are absent) with the most recent information published by the LEA about school rolls, demand and capacity in 2007. It seems likely, however, that there would be unmet demand for around 6 FE of places in year 7 by 2011 - the size of a viable new school. While the slow rate of expansion of the schools proposed by the developers may help to maintain the foundation schools' league table standings, it will not satisfy the aspirations of parents of Bishop's Stortford to have their children educated locally. A better solution exists which is to build a new school at the site at Hadham Road which was acquired many years ago by the LEA for just this purpose.

30. The Hadham Road Site

The Hadham Road site is large enough to provide a 6 FE school (a size which the LEA accepts would be viable) without further land acquisition. The undeveloped site has an area of 8.3 ha. The applicants suggest that a 6 FE school requires a site of 8.7 ha - about a sports pitch more than the Hadham Road site.Note 4 The site in Whittington Way is planned eventually to accommodate 16 FE on a site of 20 ha. Even if allowance is made for the space saved by sharing some facilities, a site which is 41% (at 8.3 ha) of the area of the proposed Whittington Way site and which would require much less car parking should be sufficient to accommodate a school which would have only 37.5% (6 FE) of the co-located schools' capacity. If additional playing fields or sports facilities were thought to be needed it might be possible to enter into a partnership agreement with the Bishop's Stortford Rugby Club immediately opposite, who currently use part of the Hadham Road site for training purposes.

31. Although the developers have claimed that an area of woodland on the site reduces the area available for development of a new school to about 7 ha it is a spurious argument.Note 5 The whole site (including an additional part now occupied by the fire station) was acquired by the County Council for educational purposes. Some was let out as an orchard which has now been abandoned and become a 'woodland' as a result, while the remainder was let out for arable cultivation. All of it could now be used for a purpose built new school.

32. Schools in the Community

Schools are meant to play an active role in their local communities. At the Boys High School the sports hall is let on a long lease to a charitable trust and provides a valued community facility. Likewise, the swimming pool at the Herts and Essex school is well used by other groups outside the normal school day. Although these would be replaced at the proposed new schools, sharing of facilities may mean that there is much more pressure for school use and fewer opportunities for the community to benefit. Moreover, the remote location of the site will make it less accessible to local people, a particular loss in the case of the Herts and Essex School which would be moving nearly two miles away.

33. The proposal would also lead to the Bishop's Stortford Rugby Club losing its training ground at Hadham Road. The suggestion that the sports facility at Jobbers Wood could provide an alternative would involve a journey of about three miles from the Rugby Club. On the other hand, building a new school at Hadham Road could enable the Rugby Club to continue to enjoy this facility. New community facilities would be created in a part of the town which currently has none and the geographical spread of schools would maximise the opportunities for community engagement by them.

34. Funding and Timing

It has been argued that the LEA has no budget for a new school at Hadham Road - although it has found a substantial sum to support investigation of the Whittington Way site which will simply be lost to the developers if the scheme does not go ahead. It is unsurprising that the LEA has no budget for something it is not currently planning to do. The funding it is likely to need immediately is probably no more than it has already committed to Whittington Way. New schools are usually built under PFI arrangements which require no capital outlay by the LEA. The LEA already owns the Hadham Road site and there would thus be no call on the LEA's capital budget at any time to build a new school there. The revenue costs of a PFI scheme would only be triggered when it is completed and the school is occupied. Thus the only immediate costs would be those of identifying a private sector partner and negotiating the agreement.

35. The applicants acknowledge this but argue that the LEA would not be likely to gain PFI credits from central government to cover the expenditure before 2014 leading to completion no earlier than 2017.Note 6 Clearly this is a matter of speculation, since the LEA has no scheme at present on which to base an application for those credits. Even if this assessment is right, however, it should not influence the decision on these applications. Buying a few years advantage now should not be allowed to override the decision on where our children will receive their education for the next forty years or more, if the location which delivers earlier is the wrong one.

36. Moreover, the time benefit itself may be slight for two reasons. Not building the 775 houses which the developers propose will reduce the immediate additional pressure on school places that would otherwise arise. And to assume that the two boards of school governors will have the capability to bring this multi-million pound development for which they have not yet obtained permission into use by the autumn of 2011 seems optimistic on their part. The fact that Countryside Properties have asked for outline planning permission for five years rather than the normal three suggests that they share our scepticism about the ability of the boards of governors to have completed the project and relocated by 2011.

37. Finally it should be noted that the commercial terms on which the schools are to acquire the Green Belt site and the developers the vacated school sites have not been disclosed. Indeed such agreements may not yet have been concluded. All the major housebuilders are at present drastically writing down the value of their land banks as a result of the slump in the property market. There is no reason to suppose that the sites under consideration here will be immune from those market pressures. Given that the decline in property values has not yet halted there can be no assurance that the proceeds from the proposed housing developments will in fact be sufficient to pay for the building of two new 6 FE schools or their subsequent expansion.

38. Educational Disruption

Relocating and enlarging the two schools at the same time will be hugely disruptive to the education of a generation of children as staff take their eyes off the ball of teaching while they focus on the preparations for the move and its aftermath. Parents whose children are already at the schools have not been asked whether they wish the moves to happen. They have simply been told by the boards of governors very late in the day that this is what is intended to happen. Had they been aware of these intentions earlier, it might have influenced their choice of school.

39. Clearly, starting from scratch with a new school will have none of these disruptive effects. The LEA might argue that starting a school from the lowest year up is more challenging than grafting on extra places to an existing institution Note 7, but with the amount of new housing destined for the county in the East of England Plan it is a challenge they are going to have to get used to. And it clearly can be done. Yanveh College is a faith school in Borehamwood which opened in 2006. It has an annual admissions number of 150 but it had only 213 pupils on its roll in 2007. It was oversubscribed in both its first two years of admissions (when the numbers admitted were smaller). That pattern of incremental growth is what is needed in a new school in Bishop's Stortford.

40. Conclusions on Educational Need

The case on educational need has not been made. The proposals on offer are a substandard solution.

• As foundation schools the two schools have opted for financial independence. Their condition is typical of many schools in the county which have to make the best of the assets they have. They should not expect the local community to pay, through unwanted housing, for what will be to them a free rebuilding. Refurbishment or rebuilding in situ will always be more difficult than moving to a green field site, but that is not an argument for removing Green Belt protection.
• The size the schools intend to grow to, co-location and shared use of facilities are likely to be detrimental to the separate characters of the two schools and their ability to maintain high educational standards.
• The proposals will do nothing to improve parental choice or the balance between single sex and co-educational opportunities. For most parents the realistic choice will lie between these two schools and Birchwood as now but with twice as many single sex as co-educational places on offer. Some parents, moreover, are likely to conclude that with shared use of facilities and transport to school, the foundation schools' offer is no longer one of genuinely single sex education. A fourth new school would overcome all these problems.
• The LEA has the responsibility for ensuring that the demand for school places is met. The gap between supply and demand is increasing. The proposals in these applications understate the likely future level of demand and are likely to prolong the shortfall in places for years to come rather than closing the gap as a new school would be able to.
• The LEA has a suitable site, large enough to accommodate a viable new school. It would increase the opportunities for community engagement rather than leaving all the new facilities stranded on the edge of town.
• Funding is not a planning issue but the LEA's lack of foresight in preparing for the alternative to these proposals is not a justification for sacrificing the Green Belt. The alleged timing advantage of these proposals over the alternative is likely to be largely illusory. In present property market conditions, the sufficiency of the funding cannot be assured.
• The disruption the moves will cause to the education of the current generation of children was not a matter on which their parents were consulted during the gestation of the proposals and would be avoided by the development of a fourth new school.

There is no educational justification for overriding the normal presumption that Green Belt protection should be permanent.

Planning Considerations Affecting the Whittington Way Site

41. Green Belt Status

The site has Green Belt protection. The proposed development is clearly inappropriate within the meaning of PPG 2. The preceding arguments demonstrate that there is a viable alternative way of meeting Bishop's Stortford's need for additional school places. There is thus no exceptional reason for overriding Green Belt protection. The Inspector's report on the Local Plan concluded that the boundaries of the proposed site appeared somewhat arbitrary and lacking in natural features. She though that redesignation of this part of the site would make it difficult to maintain the permanence of the rest of the site as Green Belt. The proposed development should not be granted planning permission. If the planning authority is nevertheless minded to do so it should refer the application to the Secretary of State for determination in accordance with ODPM Circular 11/2005.

42. The precedents referred to by the applicants Note 8" for setting Green Belt protection aside to satisfy educational need do not apply in this case. In the case of Cheshunt secondary schools, the site in question had been zoned for the purpose in the Local Plan. In the case of the Whittington Way application, the Inspector rejected the proposal to remove Green Belt protection from the site in the Bishop's Stortford Local Plan. In both decision letters quoted, the Government Office decided that the applications did not give rise to wider than local issues. In the case of the Whittington Way application, setting aside the recently adopted and up to date Local Plan in so material way would bring the planning system itself into disrepute. Moreover, as this letter has explained, there is a preferable way of meeting the educational need which does not involve sacrificing the Green Belt. Of the other examples for which no details have been given, it is perhaps worth mentioning that a decision taken on the Leventhorpe School some forty years ago does not provide a suitable context for reaching a similar decision on these applications today.

43. Access and Traffic Congestion

Like the evidence on educational need, the transport assessments give a highly selective presentation both of what the developers believe the present situation to be and how it would be affected by their proposals. It is therefore worth beginning this section of our objections, with a few statements of the obvious which somehow seem to have eluded the applicants.

• Proposals which add 775 dwellings to the housing stock and around 2000 more people to the town's population will generate more traffic than proposals for meeting educational demand which do not include this large increase in housing.
• Sites which are undeveloped at present at Beldams Lane, Hadham Road and Whittington Way add no traffic to the immediately surrounding road networks. The alternative way of meeting educational demand by building a new school at Hadham Road would mean that only that site would become a traffic generator.
• The approach roads to the town are becoming increasingly congested for much of the time and are not capable of having their capacity significantly increased. Intelligent traffic management systems are at best a palliative which may provide a temporary improvement in traffic circulation towards and within the town centre, but after a few years they will be overwhelmed by the seemingly inexorable growth in car ownership.
• Bishop's Stortford already has one of the highest levels of car ownership in the country: 78% of households own one car and 11% own three or more cars.Note 9 If educational facilities are moved to a site which is markedly less accessible than the current locations, it defies belief to think that the modal share of trips to school by car can be pegged at its current level.

Before discussing site specific considerations, it is important to look at the wider context.

44. National Planning Policy

PPS 1 highlights in para 13 one of the key principles of sustainable development:

'Regional planning bodies and local planning authorities should ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car...'

PPG 13 which deals with Planning and Transport says in para 38:

'Higher and further education establishments, schools and hospitals are major generators of travel and should be located so as to maximise their accessibility by public transport, walking and cycling.'

45. East of England Plan

The transport assessments refer to only two brief extracts from the Regional Transport Strategy. Here are some extracts in the Plan which they appear to have overlooked.

• The first of the objectives in the Plan's overall spatial vision is to reduce the region's impact on, and exposure to, the effects of climate change. The first two ways it seeks to do this are by
  • locating development so as to reduce the need to travel
  • effecting a major shift in travel away from car use towards public transport, walking and cycling
• The third objective is to realise the economic potential of the region and its people by, amongst other things
  • ensuring adequate and sustainable transport infrastructure.
• Policy SS4 in the spatial strategy deals with the role of market towns and suggests that their sustainability should be increased by, amongst other things
  • improving the town's accessibility, especially by public transport.
• Policy T1 sets out the objectives of the Regional Transport Strategy. Two of them are to
  • manage travel behaviour and demand for transport to reduce the rate of traffic growth; and
  • improve access to jobs, services and leisure facilities.

46. Local Plan Transport Policies

The East Herts Local Plan reflects the Regional Plan's overall objectives in its own aims and objectives and the transport assessments list them. The Local Plan also notes that as the local planning authority it has a major role to play in integrating transport planning objectives with the location, type and design of development.

47. This is reinforced by policies T3 and T4. Policy T3 requires developments that are likely to generate significant movement and travel demand to submit a transport assessment to accompany the planning application. Transport assessments accompany these applications. Policy T4 requires a satisfactory 'travel plan' to accompany such applications. It adds explicitly

'For proposals for new or expanded school facilities a school travel plan should be provided, which promotes safe cycle and walking routes, restricts car parking and car access at and around schools and includes inter alia, on-site changing and cycle storage facilities.'

No school travel plan accompanies these applications. On the contrary, the transport assessment says that a comprehensive plan will be developed.Note 10 It is moreover hard to see how an application which contemplates providing 500 car parking spaces can be described as one which 'restricts car parking and car access at and around schools'. This application therefore does not meet the requirements of Local Plan Policy T4.

48. General Critique of Transport Assessments

The transport assessments contain a number of shortcomings which mean they cannot be relied upon either to represent accurately the present position or the impact which these proposals might have. Weaknesses which we have identified include the following:

• Surveys appear to have been carried out to establish the modes by which pupils and staff travel to school. The survey data appears to cover the entire school populations, which is commendable. Both schools have high percentages of children who walk, with significant use of bus and train services. Unsurprisingly, cycling is significant only at the Boys' High School. As a result only about a third of pupils travel to school by car. The opportunity could have been taken to ask pupils and their parents how they would intend to travel to school at the proposed new location. This would have given some indication of how great a challenge it would be to ensure that no increase took place in car's modal share. If it were felt that the current generation of pupils was not an adequate predictor of the future, then the question could have been asked at feeder schools instead.

Unfortunately, either the question was not asked, or it was asked but the answer was found to be inconvenient. The assessments therefore include a target that the modal share of car would remain unchanged, but then take it as a given that the target will be achieved for purposes of modelling the traffic impacts.Note 11 This makes any results completely unreliable. The new site is within walking distance of fewer properties than the existing sites. Moreover, around 1000 dwellings are either in the course of construction or zoned for such development in the Local Plan in town centre locations. These sites are within walking distance of both existing schools, and so their mode share of walking might be expected to increase in future. That would not be the case with the Whittington Way site.

• A further question could have been asked at feeder schools about travel intentions, if a new school were to be built at Hadham Road with the existing schools staying where they are, compared with a new school at Whittington Way. The results, if the question had been asked, would have given some indication of the relative accessibility attractions of Whittington Way and the alternative. However, that information is also missing from the survey, and therefore rules out option D in the transport assessments as a comparator, because the additional school places are not location specific - in fact the model redistributes the additional places outside the town.Note 12
• An alternative, though less satisfactory, way of addressing this issue would have been to carry out a sensitivity test - for example, by assuming for Whittington Way that the car modal share increased from a third to a half at the expense of walking and cycling. No such test appears to have been carried out.
• Traffic volume information appears to have been based on 'on-site observations'.Note 13 The times, duration, locations, frequency and methods of data collection have not been described in the assessments. Automatic traffic counters have now been installed at many locations in the town, but it seems unlikely that they were in place early enough to have informed these assessments.
• Results have been published only for the am and pm peak hours because this is all the model is capable of analysing. While the am peak will include traffic generated by the school run, the pm peak from 17.00 to 18.00 conveniently excludes it. The school run generates its own peak earlier in the afternoon and it causes more of a problem than the morning because parents arrive early at school and wait rather than simply dropping off a child and leaving. The assessments provide no information about this.
• Traffic impact is not just a phenomenon which occurs for an hour twice a day. For sites which are undeveloped at present, the 24 hour impact of a new housing estate will be of concern to neighbours. For sites which the schools are vacating, one form of traffic impact which occurs predictably twice a day for 40 weeks in the year will again be replaced by a 24 hour impact for 365 days a year. Total traffic volumes might actually increase even though the school run destination will have been relocated. The assessments provide no information about these issues.
• It is reported that the input model and assumptions have been agreed with the County Council - presumably Herts Highways.Note 14 This in itself is a cause of profound misgiving. Herts Highways have an unenviable reputation in Bishop's Stortford. Having insisted on entry and exit locations for the new multi-storey car park which cause periodic gridlock, they have yet to acknowledge their mistake or produce a technical solution to a problem entirely of their own creation. They were also instrumental in enabling the Herts and Essex Hospital site in Haymeads Lane to be developed to its current density by undertaking to redesign the junction with Dunmow Road. As a result EHDC included in the planning permission a condition (unfortunately not enforced) that the development was not to be occupied until a redesign had been agreed. Four years and several trials later, Herts Highways have still not managed to produce an acceptable redesign. The conclusion in these assessments that adding 200 dwellings to the area in Beldams Lane will largely be neutral at the junction suggests that either the model or the input data or both are wrong.
• The conclusions about the Haymeads area suggest that the transport consultants were unaware of its use as a rat run in the absence of a south eastern quadrant to the Bypass. Their lack of awareness is reinforced by the fact that Pig Lane has not been identified as a source of congestion either now or under the development proposals. Yet it is an important ingredient in the rat run, traffic using its junction with London Road is a serious cause of congestion almost immediately opposite the Boys' High School, and its use would certainly intensify if both schools relocated to Whittington Way.
• The impression being conveyed by the assessments is either that the problems are negligible or will be masked by the more general increase in traffic. However, an additional 6 FE plus 775 houses will generate plenty of additional traffic which will have to go somewhere. The most likely diversion will be on to the bypass. The assessments look only at a couple of junctions and not on the impact on the capacity of the bypass itself.
• It has been assumed for purposes of running the model that the Bishop's Stortford transportation strategy has been implemented in full - in particular the linking of all the town's traffic signals into an integrated traffic control system and the construction of the link road through the station goods yard. There is no evidence that these improvements will have happened by 2011. Moreover, it seems that the allegedly negligible impact of the schools' relocation and extra housing compared to the present is simply a measure of the effect of the strategy's full implementation rather than a proper analysis which compares the impact of these applications on the highways network as it is today with the impact of the schools in their present locations and a new school at Hadham Road.Note 15 
  • Given the fundamental inadequacies in the assessments, it is impossible to know what, if any, impact the mitigation measures will have, but it seems inconceivable that they will be adequate. For the most part they are aspirational and if they do not achieve the desired result, there would be no way of rectifying the problems if planning permission had been granted. Taking the proposals in turn
  • Traffic management and pedal and cycle links in Whittington Way - impact not quantified, particularly for the pm school run. Measures not needed if scheme does not proceed.
  • Amend existing bus schedules and revise dedicated bus services - costs not estimated. Diverting commercial bus services from established routes or increasing frequencies usually adds to cost. Merging dedicated bus services may save costs but is likely to lead to parental concerns that schools transport is no longer single sex. Not needed if scheme does not proceed. How will the interests of children who travel by train be met?
  • Introduce comprehensive school travel plan - the schools should have separate plans covering all these contents anyway. Failure to submit such a plan with these applications means that they are non-compliant with a key requirement of the Local Plan.
  • On site car parking and traffic management plan - volume of car travel contemplated seems likely to be incompatible with Regional and Local Plan policies to reduce the need to travel, especially by car. Not needed if scheme does not proceed.
  • SCOOT traffic control along London Road - ignores Pig Lane junction. Unless it is part of a comprehensive scheme covering all the traffic signals in the town it will simply shift congestion to another location not covered by the assessments.
  • Annual monitoring report to the Council - which Council? In the likely event of the report cataloguing failure to achieve objectives, the relocation decision will have become irreversible and the opportunity for remedial action lost.

49. Specific Location Issues

There are overwhelming access arguments for keeping the foundation schools where they are.

• Both are located in residential areas and have the ability to attract a high proportion of pupils from within walking distance.
• The Boys' High School is on one of the main bus arteries into town. The Herts and Essex School is within easy walking distance of the bus and train stations. Since both schools appear to attract about a quarter of their pupils from Harlow, Sawbridgeworth and Stansted Mountfitchet, (LEA's evidence to the Local Plan EiP shows 229 pupils attending the Boys' High School and 219 pupils attending the Herts and Essex School from these places) accessibility of existing public transport services is very significant.
• Current and prospective brownfield developments in the town centre will add another 1000 dwellings within walking distance of the one or both sites.
• The separate locations of the two schools mean that traffic congestion problems are dispersed rather than concentrated in one location.
• Developing the Hadham Road site will provide the best access for the quadrant of the town and outlying villages which have no standard state secondary school places. It is also on one of the main existing bus arteries into town.
• Developing the existing schools sites for housing will not make traffic congestion go away but will lead to different problems - not least from the occupants trying to get to the relocated schools.

50. There are equally strong objections on access grounds to relocating the schools to Whittington Way.

• Fewer pupils will be within walking distance (Proof of evidence by Mr Thomsett, EHDC to the local plan EiP in response to objections from the Bishop's Stortford Civic Society para 6.25. It also appeared to ignore the town centre developments in its dwellings count).
• The congestion problems will be concentrated in one place - the road network cannot support a 3000 pupil school run at a single location.
• A peak hours town centre to school bus service no longer appears to be planned. Although it is doubtful if such a service would be viable it makes it more likely that existing train users will switch to the car.
• The interchange penalty for public transport is well known - people who would have to change from one bus to another in the town centre are more likely to do the whole journey by car.
• Residents of Thorley Park have only two ways out of the estate by road - on to Great Hadham Road or on to Whittington Way. They would risk being cut off by the school run twice a day.
• Using the bypass to access the site will defeat its purpose, which is to be a bypass - not a local distributor road.
• Access issues were not addressed in the published version of the Bishop's Stortford Transport Study in spite of the poor accident record of the Thorley Street/Whittington Way junction Note 16 and the reduced opportunities for walking to school which relocation would create.

The attractions of the Hadham Road site for a new 6 FE school are in many ways the obverse of the objections to the Whittington Way site. In particular

• Traffic congestion caused by the school run would be dispersed and would of course be much less
• The site would serve the quadrant of the town in which no standard state secondary school places are provided.
• If the ASRs  Map  should be developed, as the Local Plan contemplates, the site would be within walking distance of them. The Whittington Way site by contrast would be so remote that ASR residents would forced to access the schools by car using the bypass.

51. Housing

Since 1991 Bishop's Stortford has supplied over 40% of East Herts new housing. At the last census it had 28% of the district's population, but the disproportionate allocation of housing since then will have removed the size and character of the town still further away from other market towns in the district such as Hertford and Ware. Shortage of school places is simply one aspect of the physical and social infrastructure deficit which the town has suffered as a result. The last thing which Bishop's Stortford needs is even more housing than was contemplated in the Local Plan, but that is what would happen under these proposals. Since housing development is not permitted on the Green Belt site (the Local Plan Inspector rejected proposals to do so) the proposals appear to us simply to be a back door way to achieve windfall development on brownfield sites after the housing allocations have been settled in the Local Plan. Our specific objections are

• The Hadham Road site may only be used for housing if the demand for school places in Bishop's Stortford is being met elsewhere. Meeting that demand at Hadham Road avoids the unwanted additional houses
• The three sites (including the Beldams Lane playing field) which the schools propose to vacate are not zoned for housing in the Local Plan and their suitability for this purpose, including their impact on traffic congestion, was not assessed during the Examination in Public into the Local Plan. The traffic impacts have been discussed above. The evidence produce about the suitability of their locations for housing applies with equal force to their existing uses.
• The applications provide for 775 dwellings which would otherwise be dispersed across the whole of East Herts.
• In addition, the proportional catchment based distribution of any unmet housing need will mean that having received an additional 775 houses, Bishop's Stortford will receive a correspondingly higher proportion of any balance to be met to achieve East Herts' overall housing allocation.
• Without any of this development it appears that Bishop's Stortford has sufficient land identified to achieve or overachieve its allocation in the Local Plan to 2011. Whether all those opportunities will be exploited will depend on market forces.
• There is no prospect that these housing developments would reduce the pressure to develop the ASRs  Map . The East of England plan provides a challenging housing target for East Herts to meet for 2021. The owners of the ASRs will point to this, and their current status in the Local Plan as reasons for pressing to develop them as well.

52. Comments on the proposals for individual sites will be provided in letters from the relevant residents' associations.

Environment

53. Landscape

Generally, the developers argue that the sites do not have any significant ecological importance, apart from the loss of green wedges and playing fields if the applications succeed. Equally, there is no expected damage to bird, mammal or reptile populations. However, the Whittington Way site development would have landscape impacts that it is claimed would be of moderate significance and adverse in nature. In the long term it is claimed that this gets better, moving to neutral in nature. We do not accept for one moment that there can be any improvement or neutrality in landscape views given the size and character of the development, including 31500m² of buildings, 500 car parking spaces, terraced sports pitches and a 2m high perimeter security fence. Artificial lighting with flood lit sports pitches would extend the lit edge of Bishop's Stortford and would be quite different in character from the strips of light along the existing roads. The Local Plan Inspector may have had such considerations in mind in rejecting proposals for redesignation of part of the site.

54. Archaeology

All sites have had both desk and physical studies, including archaeological assessments. The most important conclusions concern archaeological evidence. The west side of the Boys' High School playing fields contains an archaeological area that would have an adverse effect if it were built on. The Whittington Way site is even more important as it contains Bronze Age, Iron Age and Roman remains over much of the site and would require extensive stripping to uncover and analyse the evidence. The assessment concludes that the magnitude of impact is extensive and would be of major significance. Thus the site must be fully excavated and recorded before any development on it could be contemplated. This would be of positive benefit to our understanding of pre Roman history and of the viticultural and agricultural practices within a Roman estate.

55. Noise

The Whittington Way site is close to (in practice sometimes underneath) one of the main take off and landing flight paths for Stansted Airport. Even if the planners do not regard this as a safety issue, the constant noise disturbance makes this an unsuitable site for educational facilities or residential development. PPG 24 which deals with Planning and Noise makes this clear:

'It will be hard to reconcile some land uses, such as housing, hospitals or schools, with other activities which generate high levels of noise, but the planning system should ensure that, wherever practicable, noise-sensitive developments are separated from major sources of noise (such as road, rail and air transport and certain types of industrial development).'

56. The issues involved are

• Current ambient noise levels are dominated by aircraft noise
• Current ambient noise levels are close to BB93 limits and in some instances exceed them.
• NATS airspace change proposals planned for 2009 would move the Buzad noise preferential departure route closer to the site causing a deterioration of the noise climate and over flying of the site. It remains to be seen what the outcome of that consultation will be.
• If the Generation 1 application for Stansted Airport were approved, aircraft movements would increase by about one third and a disproportionate number (53%) would operate during normal school hours causing further deterioration of the noise climate.
• If the Generation 2 planning application were approved in the declared Option A segregated mode, this would mean that communities will be overflown to the south west of the existing runway for both take offs and landings. This will be very close to the site and cause still further deterioration of the noise climate.
• Any one of the developments listed above will mean that the Whittington Way site would no longer meet BB93 maximum noise level requirements.

57. Construction Traffic

For several years Bishop's Stortford has experienced simultaneous construction on many sites across the town. This has led to severe degradation of the environment on the approach roads and in the town centre itself. Although the town centre enjoys the benefit of a HGV ban, it is almost impossible to enforce on construction traffic because the multiplicity of sites means that it is difficult to tell whether a construction lorry is delivering to a site or simply taking a short cut. The problem is particularly acute along Stansted Road, London Road, Dunmow Road and at Hockerill traffic lights. This problem will be repeated if the existing school sites are redeveloped for housing, since the Herts and Essex site is within the restricted area, and construction may still be continuing at other sites in the town centre at the same time. Since the Hadham Road site is close to the bypass, any mandatory routes for construction traffic would be much easier to enforce, and would cause very little disturbance in the town.

Consultation Process and Results

58. It is worth repeating two statements in PPS 1 which are quoted in the developers' report on the results of consultation.

'The views of local people are an integral part of the planning process and the case for the community's voice to be heard is clear.'

'Community involvement should happen at the point at which people recognise that they have the potential to make a difference.'

59. The contrast with what has actually happened over proposals which have taken many years to bring to this stage is striking. Neither school has consulted parents about how they would like to see the schools develop, even though the project timetable, if achieved would affect all children aged 15 or less. Only one feeder school has been referred to in the stakeholder consultation - presumably because it shares a site with the Boys' High School. So prospective parents have not been consulted either.

60. The public exhibitions earlier this year were principally occasions for the schools to present their case as though the relocation and its housing consequences were settled decisions. In spite of this, a high proportion of attendees completed questionnaires and the results were strikingly at variance with those the applicants might have wished for. For example:

Q2 - does the town need more school places? 492 - yes; 112 - no.
Q3 - is relocation and expansion the best way to do it? 178 - yes; 376 - no.
Q6 - are the sites appropriate for 'much needed' housing in the area? 144 - yes; 429 - no.

61. Q5 was even more slanted than Q6. It read:

'Parental choice is a key feature of educational provision in the town. How important is it that the Boys' High School and the Herts and Essex High School retain their single sex identities as part of the proposals?'

This question thus confuses the issue of parental choice with the different issue of single sex or co-education and further confuses the schools' current single sex identity with what the proposals might deliver in the future. A genuine consultation exercise would have presented the alternatives objectively and, in the words of PPS 1, at a time when people recognise they have the potential to make a difference. In spite of the applicants' best efforts to delay public involvement until the last possible moment and secure a favourable result, respondents have made clear by majorities of between two and three to one that they object to these proposals.

Summary and Conclusions

62. Planning context.

• National and regional planning policy places great weight on preserving the Green Belt permanently with a clear presumption against any development of the kind proposed. The developers tried and failed to get the designation of the site changed in the Local Plan. The sites that would be vacated by the schools are not zoned for housing in the Local Plan. Building on the Green Belt and four major departures from the Local Plan are more than sufficient reasons to refuse permission for these applications. To do otherwise would undermine confidence in the value of the planning system - a concern of more than local significance.

63. Educational Need

• The two foundation schools do not need to expand or move. Evidence suggests that expansion on the scale contemplated would diminish educational attainment and social skills, and weaken the schools' separate identities. Having opted out of local control, they should not now be expecting to invest in new facilities at the expense of the local community.
• The proposals would not enhance parental choice or deliver the best balance between single sex and co-educational places.
• While Bishop's Stortford needs more school places, the proposals understate the current gap between demand and capacity and seem designed to perpetuate rather than close that gap.
• The Hadham Road site is large enough for a viable new co-educational school. It offers a better solution to the identified educational need from the perspectives of meeting the shortfall in places, parental choice, community engagement, location and avoiding disruption of the education of the current generation of school pupils.
• Whether sufficient funding or a 2011 opening date can be delivered at Whittington Way is questionable. Even if they could be confidently relied upon, they are not considerations which should override the overwhelming educational and planning disadvantages.

64. Local Planning Considerations

• Green Belt - No exceptional need to build on the Green Belt has been demonstrated. A better solution to the identified need is available which does not destroy the Green Belt or put the rest of that site at risk of development.
• Traffic and Access - The proposals fail to comply with national and local policies to reduce the need to travel, especially by car, and fail to comply with the Local Plan policy requirement to submit a school travel plan with the application.
  • Transport Assessments - They are unfortunately completely unreliable for a number of reasons including the following:
  • Having surveyed current travel to school by mode, the assessment simply assumes that the same shares will be maintained without any survey of existing pupils or at feeder schools of travel intentions either to Whittington Way or to a school at Hadham Road. The relative accessibility of the options to walkers, cyclists and public transport users is therefore untested.
  • No sensitivity test has been undertaken to identify the impact if the assumption about modal shares is incorrect and car travel turns out to be higher.
  • The impact is modelled only for the am and pm peak hours and specifically excludes the afternoon school run impact.
  • They compare current circumstances with projections that assume that the Bishop's Stortford transportation strategy has been fully implemented by 2011. There is no evidence that any of it will have been implemented by 2011. They do not therefore compare like with like, but instead indicate the importance of having that strategy implemented before any new development on this scale is contemplated.
• Location - Compared with the Hadham Road site the Whittington Way site is in a highly unsuitable location because:
  • The existing sites are better placed than Whittington Way to encourage walking and cycling and the use of public transport.
  • Using the Hadham Road site for a school would increase opportunities particularly for walking and cycling - the Whittington Way site would reduce them. Accessibility to Whittington Way would become even more of a drawback if the ASRs  Map  were developed.
  • The Hadham Road option would ensure that the congestion impacts on the road network were dispersed rather than concentrated in a single location.
  • The Hadham Road option would avoid the traffic generated by an additional 775 houses.
• Housing - Since 1991 Bishop's Stortford has provided over 40% of East Herts housing allocations even though we still have only about 28% of the district's population. Such expansion is progressively destroying the character of the town. Without any of the proposed developments Bishop's Stortford has enough land identified to achieve or over achieve its housing allocation to 2011. The town could not absorb a further 775 dwellings on top of that.

65. Environment

• The Whittington Way proposal would have an adverse visual impact on the landscape and be a serious source of light pollution.
• The Whittington Way site is one of major archaeological importance which would need to be surveyed over its entirety before any development of it could be contemplated.
• Simultaneous development of several sites would make the current HGV ban relating to central Bishop's Stortford impossible to enforce in relation to construction traffic - a problem the town has now been suffering from for several years.

66. Noise

• The Whittington Way site is already at the margins of compliance with the maximum noise limits for new schools prescribed in Building Regulations.
• Breaches of those limits would become a regular event if either Stansted Airport were allowed to expand to 35 mppa or more or the south westerly take off route were moved closer to the town as proposed by NATS.  

67. Consultation

East Herts Council is to be commended for the extended period it has allowed to take delivery of comments on these proposals and the arrangements for considering responses. Unfortunately, that willingness to engage with the public has not been shared by the applicants. In particular:

• There has been no consultation or engagement with the parents whose children attend either school during the course of the preparation of these proposals.
• There has been no consultation with feeder schools (apart from one) and so no involvement of prospective parents.
• There has been no consultation, until the recent public exhibitions, with other members of the communities who will be affected by one or more of the developments.
• The exhibitions could best be characterised as a propaganda exercise whose main purpose appeared to be to try to persuade people that the decisions had already been taken apart from settling some minor details.

In short, the approach of the applicants has been a denial of the recommendations in PPS I that people should be involved in such proposals at a time and in a way which enables them to make a difference. In spite of the unwillingness of the applicants to engage with the public in any serious way, the community has expressed its opposition to these proposals in the clearest possible terms, not least in the responses to the exhibition questionnaires. We trust that the local planning authority will support the clearly expressed views of the local population by dismissing these applications.

68. I am copying this letter to Mark Prisk MP, to John Ingham, Clerk to the Town Council with the request that he copies it to all Town Councillors and to the Government Office for the East of England, so that they may have advance notice of the major issues to which these applications would give rise if the Local Planning Authority were minded to approve them. I would also like to record the wish of the Civic Federation to speak at the meeting of the Development Control Committee scheduled for 16 October to consider these proposals.

John Rhodes
Vice Chairman,
Bishop's Stortford Civic Federation