By Email
Development Management
East Herts Council
Pegs Lane
SG13 8EQ 22 July 2021
Attn: Ms Fiona Dunning

Dear Ms Dunning

YOUR REF: YOUR REF: 3/21/1493/REM – Employment Area at Bishop’s Stortford South

2 years ago Bishop’s Stortford Civic Federation (BSCF) attended meetings at East Herts District Council for overall approval of the development of Bishop’s Stortford South. At the time assurances were given that the Employment Area would be a Business Park providing a large number of highly skilled, high value businesses and light industry jobs, including in the tech sector. More recently the Bishop’s Stortford Independent reported as many as 1000 jobs.

This is not what is now on offer. At a recent community meeting Wrenbridge, the developer, said it did not know where the figure of 1000 jobs came from and their estimate was for 300 – 550 jobs in warehousing and trucking, whereas the norm for a site of this size and activity (a 200,000 sq. ft, transport operation, with HGVs in and delivery vehicles out) is more like 250–300.

Our main concerns though are that as a distribution centre generating a declared 104 HGV two-way movements 24/7, 40% of which will be between the hours 11:00 pm – 07:00 am:

  1. It could not be in a worse location, being equidistant (7 miles) from the M11’s existing Junction 8 and its new Junction 7A as well as some distance from the A120 and the A414. Thus many communities in and around Bishop’s Stortford will be exposed 24/7 to increased and extended noise, vibration, and air pollution, etc. from articulated HGVs in particular, and especially at night. This is especially true for the following communities:
  1. The western periphery of Bishop’s Stortford – and the eastern part if and when HGVs choose to ‘short-cut via the Hockerill AQMA.
  2. Central Sawbridgeworth, where there is an AQMA from north to south.
  3. Central Spellbrook, to the south of Bishop’s Stortford.
  4. Central Standon, to west of Bishop’s Stortford.

In addition there are several schools on or close to these routes, or their pupils’ routes to and from their school, thus heightening their already high exposure to poor air quality and road safety, especially if they walk or cycle to and from the school.

  1. The original Transport Assessment was carried out 5 years ago and was for the site’s use for business and light industry and not 24/7 trucking and distribution.
  2. While the Noise Impact Assessment (NIA) on the site that accompanies the current application suggests only a slight change in noise levels this is in comparison to the site’s use for business and light industry and not 24/7 trucking and distribution. In addition it fails to:
  1. Recognise the site will generate noise 24/7 and not just at morning and evening peak hours. Also, noise will be heightened at the change of shifts, around 10:00 pm(?) at night and around 06:00 am(?) the early morning.
  2. Spell out that an HGV will, on average, arrive or leave every 5.5 – 6 minutes at night and 7.5 – 8 minutes during the day, and may need to wait to enter or leave its service yard or parking space while an HGV ahead is manoeuvring, and taking the whole road width to do so (see Swept Path Analysis drawings, Transport Compliance Statement (TCS) Annexe A3). Thus the noise and vibration time envisaged in the NIA could well be more than 1 min 53 sec (NIA Table 3).
  3. Include for a potentially large number of additional lorry (HGV?) movements on site. This is suggested by the up to 37 extra HGV parking places, all of which, it is presumed, will need to manoeuvre into their service yard space once it becomes available, thus generating further noise and vibration. Alternatively, if an HGV is unloaded where it is parked there will be extended noise from the movement of pallets and/or the attendant forklift trucks.
  4. Make any assessment of the impact additional noise generated by HGVs up to 7.5t GVW and/or smaller delivery vehicles, all of which make a warning noise while reversing as well as other noises.
  5. Compare the noise generated 24/7 to the current ambient noise levels rather than the Business Park originally outlined. That would have been a largely daytime operation, on average, 8 hours per day 5.5 days per week, with little or no noise at outside of these hours/days.

All these show the NIA’s shortcomings.

  1. The development does not contribute to the NPPF’s aim of contributing to sustainable development. The following policies/objectives particularly apply:
  1. Environment: “to contribute to protecting and enhancing our natural, built and historic environment; including making effective use of land.”.
  2. Social: “strong, vibrant and healthy communities … with accessible services and open spaces … and support communities’ health, social and cultural well-being.”.
  3. Economic: “to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places …”.

These are discussed in some detail in Colin Arnott’s letter of objection dated 21 July 2021 and also in EHDC’s Conservation Officer’s internal report dated 13 July 2021. We will therefore not repeat them here. Rather we request that they are read and fully taken into account when the application is decided.

It is unfortunate that district and county councillors are only now becoming aware of the probable negative impacts on health, jobs, and the environment that granting of outline planning permission in 2019 is now likely to cause. This is despite nearly 1,500 public objections at the time.

BSCF therefore strongly objects to the proposed development. It also considers that if East Herts Council’s planners and HCC’s transport planners are not to be guilty of culpable negligence in granting such a “just do what you like” planning permission for Bishop’s Stortford South in 2019 they must find ways to make the developers think again, especially with respect to this Reserved Matters Application. For example, by revisiting the now wholly discredited original Transport Assessment and the agreed mitigation measures, plus the current Transport Compliance Statement and Noise Impact Assessment that accompany this application and the relevant NPPF objectives.

Moreover, because of the above and the 436 current objections from the public, we request that this application is decided by the Development Management Committee and not by the responsible Planning Officer.

Yours sincerelyPaul Dean
Bishop’s Stortford Civic Federation
c.c. Mr Mark Youngman, Development Management Group Manager, Hertfordshire County Council