Planning Application Link: 3/16/0530/OUT: Hybrid application for up to 682 residential units.

Stephen Tapper
Development Control
East Herts Council
Pegs Lane
SG13 8EQ
27 April 2017

YOUR REF: 3/16/0530/OUT

1. Thank you for your letter of 12 April, advising of revisions to this application. We commented on an earlier version of this application in our letter of 30 April 2016 and, for convenience, this letter presents our response to this revision in the same order as before.

Phasing of the Scheme

2. Previously we argued that no development should take place on the site unless provision of a southern access point is provided for vehicles. We note that a southern access road appears to be in the course of construction despite the fact that no planning permission has yet been granted. We also note that the question of whether this should be open to all traffic or purely for residents and public service vehicles has yet to be resolved.

3. Our reason for arguing that no development should take place without a southern access road was that, unless it is actually used to remove traffic which currently has no option but to gain access to the site from the north, the development will lead to increased traffic congestion on the London Road and at Hockerill. Hockerill is an Air Quality Management Area (AQMA) which regularly exceeds mandatory air pollution limits. In these circumstances it would be prudent for the Council not to grant planning permission for developments which can reasonably be anticipated to make air quality worse.

4. Unfortunately, Phase 1 of this scheme seems likely to do just that, since access to the new Station car park, the hotel and residential accommodation will continue to be from the north as at present via Anchor Street and not from the new link road. So while early construction of the new road would be welcome if it were to be granted planning permission, it seems that it will not be designed in such a way as to deliver the intended benefits, at least in Phase 1. Whether it would do so in later phases of the development also remains unclear.

Traffic Impacts of the Earlier Phases

5. Our comments about construction traffic remain valid. In addition, access to the new car park and to the rest of the Phase 1 development is to be provided only through a widened Anchor Street, instead of the current arrangement of two separate access points. We think that this will have serious implications for traffic congestion and also for pedestrian safety, since this will bring more traffic into conflict with the main pedestrian route between the station and the town centre.

Parking Provision

6. Prior to construction work starting on site, it is reported that there were 944 parking spaces provided and, it is claimed (Meyer Brown supplementary note on parking), that a representative survey suggested that occupation peaked at 689 spaces filled. Grossing the occupancy (rather than the capacity) up to meet future growth in rail patronage, it is suggested that 958 spaces will be sufficient once the scheme is completed. There are a number of points to be made about this.

  • The survey was undertaken 2 years ago. A reality check to see whether it reflects current conditions would have been desirable, and it is questionable whether the occupancy rather than the capacity should have been used to gross up the future requirement, given that it is to provide for short stay as well as commuter traffic.
  • The one car park that appeared to be completely full in 2015 was the third party car park which charged significantly less than the other facilities. It therefore seems that pricing policy in the future will have an impact on the level of demand, and how much of it spills over into neighbouring streets to the detriment of local residents. So we cannot tell whether future provision would be adequate without a clear explanation of intended pricing policy.
  • While we welcome the proposal to include short stay parking in the provision, we question whether it will be sufficient, given that no dedicated parking will be provided for the hotel and the ratio of residential parking to dwellings in Phase 1 will be only 0.25.
  • Our further concern in Phase 1 is that only 477 spaces are to be provided in the new car park – well below the level of demand in 2015. The revised application is silent on what if any additional temporary provision is to be made and how access will be provided to any temporary facility.

Station Road Steps

7. Our previous comments remain valid.

The Bus Station

8. Our previous comments remain valid. Moreover, it appears that the stops outside the railway station, as well as being detached from the bus station will be used primarily by Harlow-Stansted Airport services diverted from South Road, and not to replace capacity which will be lost in the bus station itself.

9. Policy GY3 of Neighbourhood Plan 2 (NP2) which has now been forwarded to the Independent Examiner says of the Transport Interchange that only schemes which follow best practice will be acceptable and must be safe for all types of users and usages. We question whether having the bus stops in two separate locations with the main one in its present position meets this requirement.

Traffic Forecasts

10. The expansion of the Aldi store does not seem to have worsened traffic congestion on London Road, although, sadly there has been a fatality outside the store since my last letter. That apart, our previous comments remain valid, and we trust that EHDC will be able to test the effects of the proposals using their own recently commissioned traffic model.

Demand for School Places

11. Our previous comments remain valid.

Scale and Appearance of Development

12. The saved policies of the 2007 District Plan are now 10 years old but do nevertheless remain a material consideration. Policy BIS11 of that plan allocated 700 dwellings to the whole of the Goods Yard/John Dyde site. On the John Dyde part of the site, 250 dwellings were completed prior to the adoption of the 2007 plan. It therefore follows that under the currently applicable saved polices, some 450 dwellings ought to be the maximum development to be considered on the Goods Yard site in respect of this policy

13. More recently, EHDC has finalised a new District Plan for review by the Planning Inspectorate following an Examination in Public. While the plan cannot be adopted until that process is complete, it is a clear expression of the Council’s most recent aspirations for the site to which significant weight should be attached. Indeed, it would make a mockery of the planning system to ignore those aspirations, simply because a developer has lodged an application which is inconsistent with them and with the saved polices which are still in force. Policy BISH7, covering the Goods Yard, says that it will provide ‘at least 400 homes’ and that this should include 3-4 bed family homes. Policy GY2 in NP2 goes further and suggests that the limit on the number of dwellings should be set even lower at 250.

12. Thus the clear trend of all the relevant local planning policies is that the dwelling total should be very much less than 680 and that the dwelling mix should be different and not exclusively apartment blocks. While 680 dwellings might be argued as being consistent with ‘at least 400’, the spirit of EHDC policies for the site reflected in both the saved policies of the last plan and the prospective polices of the future District Plan and of the Neighbourhood Plan for the area is that there should be a much lower density of residential development on the site.

13. Moreover, Policy GY1 of NP2 also suggests that the development should have the following characteristics

‘An attractive and welcoming appearance particularly to those arriving in the town in the train station area, providing a memorable gateway to Bishop’s Stortford with clear sightlines from the railway station entrance towards the old Maltings buildings, the river and St Michael’s Church. Development must be of a high quality that demonstrates an understanding of local history and acknowledges the vernacular style and materials to the south of the Stort footbridge, as well as the scale of nearby buildings to the north of it.’

14. These considerations add weight to our previous objections to the scale and density of the proposals, which in summary were

  • The buildings should be limited to five storeys in height.
  • In the interest of building a more stable community, the residential element should not consist exclusively of flats, given the large number we already have in the town centre.
  • Not enough was being proposed to improve the public realm and amenity value of the river,
  • The appearance of the buildings themselves seemed to be undistinguished products of computer aided design which would do little to enhance the depressing quality of previous major developments by the riverside or provide an uplifting gateway to one of the main entrances to the town.

15. We suggested that the developers should provide a three dimensional model of their proposals so that their impact could be better appreciated before a decision is taken. We trust that EHDC will insist on this being completed before the meeting of the Development Management Committee proposed for 17 May.

16. The response of the developers has been to alter the appearance of the hotel to something a little less like a Travel Lodge, but otherwise seek to justify development of up to seven floors in height by relying on the maximum heights of all the other developments along the river from Jackson Square to Tanners Wharf. We feel that the town deserves better than a relentless succession of Stalinist blocks to fill the gap in between. Moreover, apart from Tanners Wharf which is largely detached from the town centre, building heights decrease the further away from the town centre you go and we would expect new development to reflect that pattern.

17. The developers also point out that East Herts currently cannot demonstrate a five year supply of land for housing. That issue is intended to be addressed by the new District Plan, but in the meantime, it should be pointed out that the requirement applies to the whole of the district. There is no shortage of housing land for development in Bishop’s Stortford, with planning permission for some 2500 homes at Bishop’s Stortford North, as well as other brownfield sites being developed in the town centre. Additional housing in Bishop’s Stortford will not address the shortage of land for housing in other parts of the district.


18. This is such a significant site that we feel that no development at all would be preferable to another inappropriate one and we do not agree that planning permission is a luxury that can follow along retrospectively after development has started. In summary, we believe that this application should be refused for the following reasons:

  • Phase 1 of the scheme for which full permission is sought will generate more traffic and worsen congestion and pollution at the Hockerill AQMA. It is not clear at what point in the development the new road under construction will alleviate traffic congestion.
  • Providing only a single point of access to Phase 1 of the development will increase traffic congestion in Station Road and conflict with the main pedestrian route from the station to the town.
  • The parking to be provided in Phase 1 is insufficient and no information has been provided about what if any temporary additional facilities will be provided. It is also doubtful whether the long term provision will be adequate.
  • The suggested improvements to Station Road steps are unclear.
  • The reduced size of the bus station is insufficient to meet present demand, and plainly will not be able to cope with the additional services to be provided to support new development elsewhere in the town.
  • The traffic forecasts should be tested on the new traffic model of the Bishop’s Stortford town centre.
  • The impact on the demand for school places seems to have been ignored.
  • The scale and density of the residential element is excessive, and the dwelling mix is wrong. The proposals are incompatible with the saved policies for the site in the former District Plan and the prospective polices in the new District Plan and of Neighbourhood Plan 2.

19. I am copying this letter to James Parker, Chief Executive of Bishop’s Stortford Town Council, with a request that he copies it to the members of the Town Council Planning Committee.

20. Could I also take this opportunity to say that I would like to address the proposed Development Management Committee meeting to consider this application on 17 May.


Notification stating that the Goods Yard planning application (3/16/0530/OUT) was refused.