Objection to planning application 12th July 2022

Development Management 
East Herts District Council
Pegs Lane
Hertford SG13 8EQ 
Attn: Ms Fiona Dunning Sent by email
Dear Ms Dunning,
I write on behalf of BSCF to object to the above application described by the applicant, Wrenbridge
(FREOF V Bishops Stortford) LLP (‘Wrenbridge’) as an application for:
“Approval of reserved matters for layout, scale, appearance and landscaping of 3/21/1749/VAR
(approved under outline planning 3/18/2253/OUT) for E(g)(ii), E(g)(iii), B2 and B8 uses including
servicing, landscaping, means of enclosure and associated works and infrastructure.”
Summary and Recommendation
We have reviewed the key planning, transport and other documents submitted in support of the
above revised application and responded to the consultation dialogue offered by Wrenbridge and
the local planning and highway authorities on our comments at the BSS Steering Group. However,
we remain of the view that proposed development still does not comply with the Outline consent
parameters and is not sustainable in economic, environmental or social terms. The main issue
remains that the Reserved Matters application for industrial and warehousing use does not comply
with the Outline Consent which was based on office based Business Park use parameters set by
local plan employment policies, the BSS masterplan and the Outline Consent. E(g)(i) office-based
business park uses are omitted from the current revised application.
The revised development is now presented as an ‘Advanced Industrial Estate’ targeting B2, E(g)(ii)
and (iii) users but – while the application will still potentially have a significant B8 distribution
component – we have objections to the transport assessment and impact including:
• The need for a revised assessment of transport impact with an appropriate ‘Worst Case’
Scenario considering and presenting a B8 distribution use scenario as the ’worst case’. A
Business Park cannot be considered as a worst case because Wrenbridge are not applying
for such a use.
The TCS shows that even an Advanced Industrial Estate will have an unsustainable transport
impact. Compared with the Outline consent for a business park, HGV movements treble from 66 to
208 movements per day, one-third (68) of which are projected to be in the evening or night-time –
and if used for distribution operations, HGV movements will be significantly higher still. The impacts
on the road network would be ‘severe’ as defined in para 111 of the NPPF 2021 and will not comply
with Policy TP1 of the emerging Neighbourhood Plan. 

Moreover the use of the site for industrial or distribution purposes – compared with the permitted
office-based business park use – will also be unsustainable in economic, environmental and social
terms as defined in the NPPF including:
Economic and Employment Impact: The loss of the site as a Business Park and it’s
replacement by an industrial and distribution development has now reduced the effective
area allocated for employment use from 21,000m2 to 16,770m2 and the expected 900-1,000
new, mainly office, jobs to 251-466 mainly industrial jobs. This is 20% less space generating
50 -75% fewer jobs – a significant underutilisation of the District Plan allocation of the second
largest employment area in East Herts at BSS. The revised application therefore does not
comply with key parameters of the Outline Consent or with Policy DPS1 on maximising
opportunities for jobs growth. The type of jobs created also does not match the needs of the
local labour market – drawing in a wider commuting workforce and failing to meet the NPPF’s
economic objective for sustainable development.
Other Social and Environmental impacts are contrary to the NPPF’s social objectives for
sustainable development – Though some of the environmental impacts have been mitigated
by design and layout improvements, most of the potentially severe impacts on the built
residential environment and local road network remain and there are clearly unsustainable
impacts on the health and well-being of existing and new residents and on schools –
principally the result of the impact of HGV’s on air quality and noise.
For these reasons we continue to object to the revised Reserved Matters application and respectfully
request that approval of it is rejected.
A detailed analysis of the reasons why this application should be rejected is attached.

Yours sincerely
Colin Arnott
Committee Member
Bishop’s Stortford Civic Federation


Many people will know that the most controversial aspect of the Bishop’s Stortford South development of land released from the Green Belt for housing and schools was last year’s planning application by Wrenbridge for development of the large, 3.5 hectare, area of ‘Employment Land’ at the south-east corner of the site. The 500 public objectors who wrote to East Herts Council – and many more who signed a petition raised by local residents – therefore welcomed Wrenbridge’s withdrawal of the application for nearly 20,000 m2 of what appeared to be large distribution and storage sheds when it seemed likely to be refused. The main objection was to the large number of HGV and other lighter commercial vehicles these ‘logistics’ operations will generate and the expectation that they would rat-run through the centre and south-east of the town to get to M11 Junction 8 and through Sawbridgeworth to the new Junction 7A instead of making the 6-mile trip round the by-pass. There was also concern about the noise, air quality and visual impact on the adjoining new housing, care home and existing Thorley Street communities. It was simply the wrong place for such a development.

Moreover, it was not what was promised when Bishop’s Stortford South was planned and released from the Green Belt. The allocation made in the District Plan – and assessed when the Outline (‘in principle’) consent was granted in 2019 – was for a Business Park of mainly office buildings expected to generate nearly 1000 new jobs needed in the area, parking and public transport would be provided and HGV and other commercial traffic would be minimal. However, in a careless wording which the local planning authority will still have to explain if this development goes ahead, the Outline consent actually granted was for any mix of employment uses including a Business Park but also industrial and distribution uses – or a Car Showroom for good measure!

Having bought the site with the benefit of this broad definition of employment use, Wrenbridge are now back with an amended application submitted in March following an extensive and well organised public consultation campaign. The design and layout of the buildings has been improved and some of the units have been made more suitable for small businesses in what is now described as an advanced manufacturing and service estate. However, with the growth of internet shopping and home deliveries, logistics site values are higher than for housing and hard to find so, not surprisingly, Wrenbridge have again included distribution uses in their application whilst omitting the Business Park office uses originally planned.

A revised assessment now shows that the traffic impact of a modern industrial estate will be significantly greater than a Business Park. Although total vehicle movements are less than originally estimated – mainly in the peak commuting hours – the number of HGV movements trebles to 208 movements per day and 68 of these will be in the evening or night-time. Moreover, if most of the development is used for distribution operations, HGV movements will be significantly higher still – and the previous application suggested 40% of these would be between 11pm and 7am. At the moment Wrenbridge is presenting a Business Park as a ‘worst case’ because total vehicle movements (mostly cars in the peak hours) are higher – even though they are no longer applying for that use. Yet the community’s main concern is with HGV and other commercial vehicles throughout the day and night and BSCF believes that use as a Distribution Centre should be assessed as the worst case – a use that is still being applied for.

Even if the use is as a modern industrial estate, the assessment also confirms residents’ concerns that HGV’s and other traffic are more likely to use routes other than the lengthy by-pass to reach the M11 junctions. The analysis shows that, although a proportion of the trips to and from the site use St James’s Way west, most movements will be via St James’s Way east.  55% of these then turn north through Thorley Street and 45% south to Sawbridgeworth. Again, the proportion of these which is HGVs would be significantly higher if the main use is as a Distribution Centre.

Finally, the justification for removing the site from the Green Belt was the limited availability of large sites which were critical to achieving the job growth required by the District Plan. The land at Bishop’s Stortford South is the second largest employment site in the District Plan and was allocated specifically to accommodate a 21,000m2 Business Park generating 900-1000 mainly office jobs. Wrenbridge acknowledges that its use as an Industrial estate – now reduced to 16,770m2 of single storey ‘sheds’ – is expected to generate only 251-466 jobs. That’s 20% less space generating 50 -75% fewer jobs – a significant underutilisation of the District Plan allocation.

For all these reasons BSCF will still urge the East Herts Council, as the local planning authority and Herts CC as the Highways Authority to recommend refusal of the revised application.

Colin Arnott