Mr Chris Martin
Spatial Planning and Economy Unit
CHN216, County Hall
SG13 8DN
10 August 2017

Your ref: PL\0850\17

1. I am writing on behalf of the Bishop’s Stortford Civic Federation to make representations about the proposed developments on the Herts and Essex School’s Warwick Road and Beldams Lane sites.

2. I should say firstly that the Civic Federation welcomes the decision by the school to stay at its present location and understands that, having made that decision, it wishes to make better use of its assets. We do not therefore object to the principle of what the school is trying to achieve. Our concerns relate to whether the proposals which are the subject of these applications (and the separate one to be made to Uttlesford District Council) are an appropriate way of achieving the school’s basic objective. We understand this to be to expand on a permanent basis to 6 Forms of Entry (FE), and to provide additional classroom capacity on the Warwick Road site by converting the existing gym for the purpose. The gym would be relocated to the sports field on the north side of Beldams Lane and upgraded into a multiple use sports facility; and additional open air pitches would be provided on the southern side of Beldams Lane to replace those which would be lost as a result of these development proposals.

Loss of Amenity

3. The school playing field is in a residential area, and is mostly surrounded by housing. Because the school use the playing field only in the summer term and do not let it out to other organisations, it provides an area of tranquillity for local residents for most of the year and indeed, informally, they use it for recreational purposes themselves. There is no night time activity or lighting on the site. All of this will disappear under these proposals and, unless they are members of one of the suggested partner sports clubs, local residents will suffer a severe loss of amenity.

4. This will partly be the result of the loss of a much appreciated open space. But it will also arise from a huge intensification of the use of the site. It is anticipated (Planning Design and Access Statement paras 7.14 and 7.15) that there will be use of some part of the site from 9am – 10pm on Mondays to Thursdays, 9am – 11pm on Fridays and Saturdays, and 9am – 8pm on Sundays. Moreover such activity can be expected to involve using some part of the site over substantially the whole of the year, rather than during school hours in the summer term only.

5. We were also surprised to see a proposal to include a licensed bar in the development with a suggestion that its use might be restricted to the opening hours of the sports facilities. While a bar may often be provided at sports clubs, this is an application to provide enhanced school sports facilities where provision of a licensed bar would not normally be regarded as appropriate. We therefore suggest that limiting opening hours to those when the site is in use is not a sufficient restriction. The bar should not be allowed to open when any school activity is taking place on the site, unless it has been specifically licensed to do so for a particular event. In addition, if the facilities are intended to be hired out for private social events, these can create significantly more disturbance to local residents than use for sports. We suggest therefore that the planning authority needs to establish more clearly the intended use of the sports hall and, if necessary, set a limit on the number of occasions in the year when it may be used for non-sports activities.

Noise and Light Pollution

6. Local residents will thus be affected by a huge increase in activity, which will be reflected by noise, and at certain times floodlighting when sports activities are taking place, and also by the noise of people arriving at and departing from those activities – all too often by car. As such this would appear to be at variance with policy DES3(c) of the District Plan now submitted for examination in public. This states

‘Avoid significant detrimental impacts on the amenity of occupiers of neighbouring properties and land, and ensure that their environments are not harmed by noise and disturbance or by inadequate daylight, privacy or overshadowing.’

7. Policies EQ2 and EQ3 in the Environmental Quality chapter of the Draft District Plan dealing respectively with noise and light pollution are also relevant to this application.

8. In the preamble to EQ2 the plan explains that noise generating developments such as sports facilities should be located at an appropriate distance (not defined) away from noise sensitive development such as residential or hospitals. This proposal is close to both and the application includes the provision of a noise barrier fence. While this may mitigate the noise, it will of course increase the visual intrusion experienced by neighbouring properties. This might be mitigated if the sides of the fence facing towards other properties were softened by suitable planting.

9. The noise assessment also rather glosses over the impact of noise on the development from Stansted Airport. In particular, it makes no mention of the noise exposure of the site to the south of Beldams Lane to which the open air playing fields will be relocated. This will suffer even greater exposure to aircraft noise than the existing playing field and is also closer to the M11. It should also be borne in mind that the airport is currently preparing a planning application which could potentially lead to an increase in passenger numbers from the present 25 mppa (million passengers per year) to 44.5 mppa and an increase in the number of flights by almost 60%.

10. While the new playing fields are the subject of a separate planning application to a different authority, if the noise climate should be deemed unsuitable for their intended use then none of this development could proceed. The County Council should therefore ask for this assessment to be provided before reaching any decision.

11. It is unfortunately impossible for a layman to judge from the information provided under the heading ‘Light Assessment’ what the impact will be or whether it will be unacceptably adverse to neighbouring users.

Traffic Implications

12. Finally, we review the traffic implications. It seems implausible to us that the road network at various pinch points can cope with any increase in traffic, even if the amount generated is a low as the modellers, whose results can only amount to an approximation, project in their assessment. Relevant also to the assessment, though understandably not taken into account by the applicants, is the plan by the NHS to relocate two GP surgeries to the Herts and Essex hospital. This will not require planning permission since it involves occupying underused existing capacity. But it will generate significant extra traffic along Haymeads Lane. We trust Herts Highways will allow for this in their own assessment of the applications.

13. It is noted in the transport assessment (para 5.7.5) that if development impacts result in increased traffic of 5% or greater, then junctions may be required to be analysed in more detail. Conveniently, the modelled impacts fall just below this threshold. At Warwick Road/London Road junction, the figure is 4.5% in the morning peak and 4.7% in the afternoon school run peak. To put this into context, 5 movements more than the 49 claimed to be generated would reach the threshold in the morning peak and 3 more movements also compared with 49 in the afternoon school run peak.

14. London Road has a succession of critical junctions in a short distance all of which give rise to conflicting vehicle movements and which also have very poor sight lines for motorists trying to gain access to London Road. These are at Crescent Road (south), Crescent Road (north)/Warwick Road, the station car park, the Aldi supermarket, Station Road and Grange Road. All of these lead to the notorious congestion black spot at Hockerill. There is also a pelican crossing at the station car park/Crescent Road junction, and because Warwick Road is a cul de sac, it is very heavily used by pedestrians as a safe route between the town centre and bus and train stations and points further east which include the Herts and Essex hospital and Birchwood school as well as the Herts and Essex school.

15. The only mitigation proposed by the applicants is to reduce the height of the shrubbery at the western end of Warwick Road. While this would be welcome in improving the visibility of pedestrians using the pelican crossing it will have very little impact on the sight line for drivers which is mainly restricted by development in London Road itself. Because the transport assessment accident records end in September 2016 (paras 3.7.1 and 3.7.4) they do not record the fact that there was unfortunately a pedestrian fatality earlier this year on the London Road between Crescent Road and Station Road.

16. In these circumstances, we think that the operation of the junctions along this stretch of London Road should be properly modelled, given that the projected traffic generation is only marginally below the level at which modelling would be required anyway. When Aldi applied to increase the size of their store and car park, we suggested that all the traffic, rather than just pedestrians, should be signal controlled from the Crescent Road (north) junction to the Aldi car park. Our suggestion was not taken up then, but we believe that this application adds weight to it.

17. In the case of the Linkside Road/Beldams Lane junction the additional traffic generated is put at 4.7% in the evening peak. An additional 2 movements above the 25 claimed to be generated in the evening peak would meet the threshold. It should also be noted that community use of the sports facilities will generate significant additional traffic outside the normal peaks, to the detriment of the amenity of residents. Most surprisingly, the impact on the Dunmow Road/Haymeads Lane junction, which we understand to be operating above capacity in the peaks, does not seem to have been modelled at all. Indeed, in response to concerns expressed in questionnaires about traffic conditions at that junction the applicants’ say

‘If the junction is improved, the effect will most likely be to increase the amount of traffic using the rat-run via Beldams/Linkside/Haymeads.’

So, although this development will increase traffic volumes at this junction, worsening conditions for all users, nothing needs to be done because supressed demand would soon fill any capacity enhancement.

School Travel Plan (STP)

19. The application places weight on the implementation of a school travel plan to minimise the traffic impacts of the proposals. Indeed in para 6.2.1 the transport assessment says

‘Management of the school will have a significant impact upon the effectiveness of the STP and will ensure that the impact of pupil drop-off and collection trips will be minimised.’

20. The school of course has a travel plan already. At the 2011 public inquiry into its relocation proposals it produced evidence that car travel to school had reduced from 33% of the total pupils in 2007/08 to 28% of the total in 2010/11 and that car sharing had increased. The figures may not be directly comparable with those in the transport assessment (para 3.9.8) because the park and walk category did not exist in the earlier survey data. However, even if that category is excluded entirely, the figure had gone up again to 29% in 2012 and 43% in 2017.

21. So, however, well intentioned, the impact of travel plans seems to wear off after a few years, and the same can be expected to happen again. Moreover, travel plans are directed as much towards parents as to the pupils attending the school. In this context I am attaching a letter sent to me by the Headteacher last year in response to one from me about a parent who regularly obstructed access to our house so as to be as near as possible to the main school entrance. The issue was not one of safety but lack of consideration for others. As you will see from her reply, the ability of the school to influence the behaviour of parents is rather limited.

22. We are also sceptical about the effect of the 6th form parking proposals. While those eligible for permits may be happy to use them, there appears to be nothing that can prevent those who are not eligible from driving to school anyway and parking in the surrounding streets.

23. Finally, we are concerned that expansion of the school to 8 FE appears to be a possibility. The County Council have an option to acquire sufficient playing fields for 8 FE and the Education Capacity Report concerning the premises also reviews an 8 FE option. Rather than allow the school capacity to increase in increments, none of which is ever sufficient in itself to deem the traffic impacts unacceptable, we believe that the traffic impact of an increase to 8 FE compared with the present should be assessed now, so that if the impacts are indeed unacceptable, that option can be ruled out for the future.


24. In conclusion, an application such as this requires a balance to be reached between the loss of amenity and increased noise, light pollution and disturbance from which the local residents will undoubtedly suffer, and the benefits that the wider community of Bishop’s Stortford will be able to enjoy should this development go ahead. While we are sympathetic to the aspirations of the school, we do not feel that enough consideration has been given to the disbenefits which the local residents will suffer. We have made some suggestions about restrictions on the use of the new facilities and improvements to the suggested noise barrier. We are also sceptical about the traffic impacts which have been modelled and whether adequate mitigation has been proposed. And we believe that the traffic impacts of any possible expansion to 8 FE should be modelled now, so that if they are unacceptable, further incremental growth options can be ruled out. Until these concerns have been addressed we do not feel able to support this application in its present form.

25.I should also add that it reflects very poorly on the commitment of the school and the County Council to engage with the local community that the application should have been submitted only a week before the start of the school summer holiday and that only 28 days have been allowed for comment. As a result many people who may have wished to respond will have been deprived of the opportunity to do so.

26. I a copying this letter to Cllr Wyllie, Kevin Steptoe, Head of Planning and Building Control at East Herts Council, Roger Harborough, Director of Planning at Uttlesford District Council and James Parker, Chief Executive of Bishop’s Stortford Town Council.

Yours sincerely