Messrs Vincent and Gorbin
4 December 2019


  1. I am writing on behalf of the Bishop’s Stortford Civic Federation in response to the statutory consultation being undertaken on behalf of the Bishop’s Stortford Boys’ High School (TBSHS) about the proposed disposal of its existing site, following on from its proposed move to a new development on the southern boundary of the town.
  2. We have concerns both about the manner in which the consultation has been undertaken and about the principle of disposal.
  3. Dealing first with the way in which consultation has been undertaken

The Civic Federation received notice of the consultation on 20 November, some four weeks after it had started.
Local residents received an invitation some two weeks ago to respond to consultation about proposals for development of the proposed new school at Bishop’s Stortford South. The invitation made no reference to this apparently being a consultation required by statute about the disposal of the existing school site.
Formal notice of the consultation was advertised in a newspaper whose main area of coverage lies outside Bishop’s Stortford rather than in the Bishop’s Stortford Independent, which is the local paper for the town.
Press coverage has been about the proposed redevelopment of the site rather than explicitly about its disposal.
The exhibition which I attended last night made no reference to this parallel consultation exercise.

  1. Turning now to the principle of disposal, the relevant policy in the recently adopted District Plan for East Herts states

The Bishop’s Stortford High School site will only be released for residential development if sufficient secondary school capacity is provided within the Bishop’s Stortford South development or elsewhere within the town.’

It is therefore incumbent upon Herts County Council as the relevant local authority to demonstrate that this requirement can be fulfilled. They have not done so.

  1. As the recent planning application to themselves for the new school site made clear, demand for additional secondary places will reach 12 Forms of Entry (FE) as a result of housing allocations to Bishop’s Stortford and Sawbridgeworth. We believe this is an underestimate, because it discounts the possibility of demand from outside the Education Planning Area (EPA) increasing above its current level in spite of major housing developments planned and already taking place in neighbouring areas around us. It is also contrary to all past experience of how secondary school places have been allocated in the EPA.
  2. But the local authority have no firm plans even to met their own assessment of demand. Currently they are planning to commission one new 6 FE school on a development to the north of the town. Site constraints mean that it cannot be expanded beyond that size. TBSHS would have the ability to expand by 2 FE at its new location at Bishop’s Stortford South, leaving a shortfall of 4 FE to be met.
  3. The local authority has proposed that the Herts and Essex School should also be expanded to 8 FE – as the other single sex school in town it would be necessary in any case in order to ensure that equal provision was made for boys and girls, in accordance with the Equality Act 2010. However, the site of the school’s campus is constrained and the ability of the surrounding road network to accommodate an additional 500 or so people on the site has not been demonstrated. And even if such an expansion were shown to feasible, that would still leave a shortfall of at least 2 FE.
  4. It therefore seems to us that the consultation, as well as having been poorly executed, is premature, since the precondition for the disposal of the site has not been satisfied.
  5. Finally, if the objections we have set out above could be satisfactorily overcome, we do not believe that the school playing field should be disposed of for development in any circumstances. It is a green field site which has never been developed and so the presumption of developing brownfield sites first does not apply to this part of the site. Its disposal is not required to accommodate the housing total of around 150 dwellings which have been allocated to this site in the adopted District Plan.
  6. That plan was adopted only last year following a lengthy consultation and examination process and the developer made no suggestion during the process that a higher housing total should have been included. There is a shortage of open recreational space in the area, which will be made worse by the proposed redevelopment of the site. In our view, the playing field should be retained as recreational open space for the benefit of the neighbouring community. This is what happened when the site of the Havers Infant School was redeveloped and the same approach should be adopted here.
  7. I understand that the consultation closed yesterday. However, in view of the shortcomings in the process which I have referred to above, and the fact that I thought I should attend the exhibition before writing to you, I should be grateful if you would confirm to me that you will take these comments into account in any submission that you might make to the Secretary of State.

Yours faithfully

John Rhodes