Transport assessment referred to in this letter: High Level Review of the Transport Assessment, Northgate End Car Park Development, Bishops Stortford
Head of Planning and Building Control
East Herts Council
29 May 2018
NORTHGATE END MULTI-STOREY CAR PARK (MSP)
Your Ref: 3/18/0432/FUL UTT/18/0460/FUL – Planning application for multi-storey car park at Northgate End: UTT/18/0460/FUL
1. I am writing on behalf of the Bishop’s Stortford Civic Federation to comment on the amended proposal for the car park and the transport assessment addendum supporting the amended proposal. This letter follows the same order of subjects as our previous objection letter dated 19th March 2018 but does not repeat those objections in detail. Unless otherwise qualified in this letter, those objections remain valid
Nature of the Development
2. The proposal is being put forward as an enabling development so as to release the Old River Lane site for a mixed use development including the provision of apartments and a new arts centre. However, the applicant’s plans for the site are at the moment purely aspirational and subject to the completion of feasibility studies, particularly in the case of the proposed arts centre. There is no certainty that these aspirations can or will be fulfilled, and the planning authority should attach no weight to them in determining this application, which has been submitted as a free standing application.
3. The proposal, as amended, maintains the existing access to the Waitrose car park along Old River Lane. One of the main public interest benefits previously attributed to the scheme was that it would enable Old River Lane to be converted into a pedestianised boulevard. Under this amended proposal that benefit is not deliverable and therefore gives rise to the question about whether any public benefit can be attributed to the scheme to offset the undoubted detriment to the conservation area and the added traffic congestion which would arise at Northgate End.
4. The reference in para 3.3.6 of the Transport Assessment Addendum (May 2018) to options showing the inclusion of the Waitrose access at Northgate End implies that this aspiration has not been abandoned but merely parked in the hope of getting planning permission for an otherwise unacceptable scheme. This seems like the piecemeal and incremental approach to planning which we have seen so often in Bishop’s Stortford where, once the principle of development has been conceded, incremental changes are subsequently allowed which would have led to refusal of permission if they had been known at the outset.
5. Retaining the current access to the Waitrose car park means that 20 fewer parking spaces would be lost. The net increase in spaces therefore would amount to 141 rather than the 197 claimed in the application. No justification has been provided for this increase.
6. As we pointed out previously, the eventual development proposal for the Old River Lane site as a whole is unknown and so therefore is its impact on traffic and pedestrian flows.
7. All of these considerations reinforce our view that if additional parking provision is to be made on the north side of Link Road that decision should be made in the context of a planning application for the whole of the Old River Lane site. This would allow an informed judgment to be made about how the needs of motorists and pedestrians would be met in that part of town and whether, in view of the otherwise detrimental impact of the multi-storey car park (MSP), the benefits outweighed the disadvantages.
8. Our previous objections to embarking on this scheme at the present time remain valid, though we appreciate that the amended proposal has been tabled with a view to persuading Waitrose to withdraw its objection.
9. We have commissioned Edwards and Edwards to carry out a high level review of the transport assessment addendum and it is attached as part of our objection. Given the volume of material and the ridiculously short time allowed by the planning authority to comment on it, they make it clear that they may not have been able to identify all the issues of concern. Nevertheless there are still significant shortcomings in the assessment of the proposed scheme.
- The net increase in publicly available parking is still overstated and has not been justified.
- The issue of conducting traffic counts during the Bishop’s Stortford College summer holiday has not been addressed. Fresh counts made earlier this month will also be unrepresentative, because, traffic flows on Hadham Road have been severely affected for the last 3 months by construction of the Bishop’s Stortford North (BSN) access roundabout at its western end. Traffic from the west of town will have diverted to alternative routes to avoid the congestion.
- The use of TEMPRO to uplift traffic forecasts rather than specific factors linked to planned developments is unsatisfactory. The justification that BSN will be largely self contained in traffic terms seems to be based on mistaken assumptions, and the impact of the development of Old River Lane itself is a major unknown.
- While the performance of the Northgate End junction shows some improvement if the roundabout is replaced with signal controls, it does not require the creation of the MSP to reconfigure the junction in this way.
- Traffic backing up to enter the Waitrose car park would no longer be an issue, but the junction would still be operating at capacity as soon as the MSP opens, and relocating the car park creates a major vehicle/pedestrian conflict which does not exist at present.
Air quality and Amenity
10. Since we are not persuaded that the modelled impacts of traffic congestion are representative, our previous objections remain. The need for piling to support the structure of the MSP is also likely to have a severely detrimental impact on the amenity of nearby residents.
11. Our previous objections remain. In the absence of any public interest benefit there is no justification for this gross intrusion into the conservation area.
Alternative Parking Provision
12. As explained in our previous letter, this scheme largely replaces existing short stay parking and no justification has been provided for that provision to be increased. This is hardly surprising since there is no overall strategy for parking provision and pricing for the town. We believe that the correct long term solution is to relocate long stay, all day parking to the edge of town, supported by park and ride, so as to free up town centre spaces for short stay users – not to build more capacity in the town centre. If some temporary extra short stay provision is needed while this policy is put into effect, it should be provided at Old River Lane and not to the north of Link Road.
13. We believe that the applicant should withdraw this application so that that the question of the amount and location of parking can be considered as part of the overall development of the Old River Lane site. If the applicant is not prepared to do so, then we believe that planning permission should be refused. No justification has been provided for the scheme other than that it will release the Old River Lane site for development. Since the nature of that development is aspirational and may never be implemented, and its impact on the transport network is unknown, achieving the release of the site is not a sufficient reason to grant planning permission and the Council will suffer no financial loss from refusal – existing uses generate a respectable rate of return. There is no public interest benefit to outweigh the damage to the conservation area and the adverse impact on traffic congestion that would arise.