The Goods Yard
30th October 2022 BSCF Response to Transport Assessment
East Herts District Council
Attn: Mr Richard Freeman
Sent by email
YOUR REF: 3/22/1613/OUT: Full and Outline permission for residential dwellings (use class C3), and commercial floorspace together (Use class E) with associated car parking, plant, sub station, landscaping, public realm and infrastructure works
- I am writing on behalf of the Bishop’s Stortford Civic Federation about this application, further to my letter dated 26 September, about the Transport Assessment (TA) supporting this application. I should mention at the outset how disappointed we are that the Planning Department did not see fit to notify BSCF that the TA had been published on the planning portal, given that we had twice informed the department of its absence and had expressly reserved the right to comment further if and when it was published. In fact the TA appears only to have been published the day after Herts Highways commented that the lack of a TA had led it to recommend refusal of the application. We feel that this reflects very poorly on the performance of both the applicant and the Planning Department.
- Turning to the TA itself, to a large extent the documents themselves confirm the shortcomings which we had anticipated in our previous letter. In summary they are as follows:
- The Neighbourhood Plan for All Saints, Central, South and part of Thorley was made (adopted) in July 2022 and is the most up to date part of the local planning framework, to which considerable weight ought therefore to be attached. The TA, dated August 2022, ignores this entirely and instead quotes at length from the previous Neighbourhood Plan, which has now been superseded.
- The latest version of this Plan contains extensive revisions to Transport Policies. In particular, Policy TP1 emphasises that TA’s should take account of actual local traffic conditions, including traffic surveys no more than three years old. Although this is a complete new planning application the traffic data used in this TA was agreed with Herts Highways in 2017 and has simply been adjusted to reflect the change in the dwelling total compared with the previously approved application.
- The TA argues (para1.14) that these data pre-date the COVID pandemic and the clear changes in work patterns and represent a worst case. No evidence is offered to support this assertion, because the authors of the TA have not made the effort to find any evidence, and there is equal reason to believe that if such evidence were to be found it would not support this assertion. The pandemic has led to a significant reduction in the use of public transport, with people preferring the security of their private car if this is an option open to them. Nationally, road traffic has returned to pre-pandemic levels.
- The assertion also takes no account of the traffic impact of the other major developments (though not yet the Goods Yard) in Bishop’s Stortford which are now beginning to be occupied, or of the alteration in the road network, which has resulted in the narrowing of Station Road to a single lane of traffic at the point where it is joined by the access road to the multi-storey car park. This has resulted in significant tailbacks in Dane Street in peak periods.
- BSCF’s previous comments about Mayer Brown’s track record on TA’s in Bishop’s Stortford, absence of plans for an improved transport interchange, and absence of plans to retain or provide alternative step free access from east of the railway to the town centre remain valid.
- One point about which our anticipation has not been borne out by the TA itself concerns station car parking, where there has in fact been considerable discussion with the railway authorities. They have confirmed the observation we made previously that while leisure travel has recovered to pre pandemic levels, rail commuting has not, and is unlikely to do so. What impact this might have on peak road traffic is unclear, given the amount of suppressed demand locally, people preferring to use their car rather than public transport, and the lack of any evidence. But it certainly suggests demand could be met with a smaller second car park.
- The TA proposes however, that the car park should remain the same size as in the previous application, with the details of its usage and eventual configuration being left for a reserved matters application. We do not think this important aspect of the development should be left in so uncertain a state. Either a reduction in the size of the car park should have been included with this application, or the lower floors of the completed multi storey car park should be set aside for short stay car parking, to provide a facility for visitors to the southern end of the town centre (including the leisure centre) where there has been no such provision since the former riverside car park was developed.
- In conclusion, therefore, BSCF believes that the TA is not fit for purpose, and should be withdrawn, along with the application itself until a proper assessment has been carried out. If the application is not withdrawn, permission should be refused for these reasons and for the other reasons set out in its letter of 26 September.
Bishop’s Stortford Civic Federation
The Goods Yard – BISH7 Planning Application 3/17/2588/OUT
This development will not be completed according to the planning permission granted in 2018, primarily because Network Rail has decided to retain the siding close to the disused signal box. Citing ‘financial viability’ the developer now wants to increase the approved number of homes from 641 – compared to ‘around 600’ in the District Plan – to ‘up to 753’, on a smaller site. With such an increase in numbers – as well as elsewhere in the town, one wonders who is bearing the development risk. In many cases it certainly doesn’t seem to be the developers or EHDC!