|The Planning Inspectorate
Room 3/19 Eagle
Temple Quay House
2 The Square
|11 December 2006|
1. I am writing on behalf of the Bishop's Stortford Civic Federation to object to the appeal lodged by David Ward (representing Wilson Bowden) against refusal of detailed planning permission for Phase 2 of a mixed residential and commercial development at Jackson Square and the Riverside, Bishop's Stortford. The basis of our objection, and in support of EHDC’s grounds for refusal relates to reasons 1 and 2 – that the proposal represents overdevelopment in relation to height, scale, massing, appearance and density.
2. The East Herts Local Plan Second Review Re-Deposit Version Nov 2004 (the Local Plan) states in para 8.1.1, Environment and Design, that East Herts is under continuing pressure for development. This being the case, it goes on to say: it is therefore important that the quality of what is built, for whatever use, is of the highest standard possible and the natural and built environment is conserved and enhanced for the benefit of present and future generations.
3. The Local Plan objectives include:
These objectives should be borne in mind when considering the objections to the proposed development.Height
4. Bishop's Stortford is an historic market town with a mediaeval core which has grown into its present form over many years. The town centre, and in particular, the shopping area immediately to the west of the site which is the subject of this appeal, has a wide variety of buildings. Their predominant height is three or four storeys, and this is true of the town centre generally. Even where the land falls away sharply from Potter Street, the original Jackson Square development, to which Phase 1 of this development is an addition, is no more than four storeys high on its eastern side.
5. It is considered that the proposal is of excessive height. Even though the buildings on the western edge of the development would be three storey, they would be dominated to the rear by the proposed six storeys adjacent to the River Stort. In addition the development proposes a series of excessively high buildings on the northern side of Station Road where the buildings are predominantly two storey. The only buildings of a similar height to those proposed are the Westmill flour mill site and Phase 1 of this development.
6. The proximity of the Westmill flour mill should not be used to justify the height of the development. At present it is an isolated eyesore. Its commercial activity is not appropriate to the town centre and we hope that in due course it will move to a more suitable location.
|Photo 2 Enlarge|
|Photo 1 Enlarge|
7. Phase 1 of this development is of either 5 or 6 storeys high and its most prominent, cliff-like facades are those most visible to the public from a considerable distance. They dwarf all the other buildings around them. See Photos 1 and 2.
8. The Bishop's Stortford Civic Society (the predecessor organisation to the Civic Federation) objected particularly to the height of Phase 1 and succeeded in getting the roof line lowered to preserve historic views of the parish church. It is a matter of regret that we did not also succeed in persuading the planning authority at the time to reduce the overall height of the development by at least 1 storey. However, the fact that Phase 1 is proceeding should not be used as a justification for repeating all the same mistakes in Phase 2, which would happen if this appeal is allowed. Instead, Phase 2 should be reduced by one or two storeys to reflect the prevailing height of surrounding development.Scale and Massing
9. Policy ENV3 of the Local Plan, Character and Environmental Quality, states that: in considering development proposals the following will be taken into account: (b) the compatibility of form, bulk and density of the development with the surrounding area.
10. It is not considered that enough attention has been paid to this aspect of the proposal. As with the issue of height, it is clear that proposed development relates only to Phase 1 in terms of scale and massing. When viewed from the existing town 'high street' (South Street), the banks of the River Stort, Sworder's fields, and almost anywhere in the vicinity, the scale and mass of the proposal is disproportionate to any other existing development in the town.Appearance
11. Local Plan Policy BIS14: Town Centre Sites For Redevelopment states, in relation to the Riverside and Adderley Road site that in its consideration of development proposals the Council consider that:
(c) the form of new development should improve and complete the townscape and strengthen and enhance pedestrian and cycle movement in the town…
(f) a civic quality in the town should be established with buildings of a public and cultural form.
12. The proposal does not complete the townscape; in fact it detracts from the existing townscape creating a completely new area of the town of an alien appearance and no visual linkage to the older surrounding buildings.
13. In addition, although a civic quality is hard to define, it is not considered that a predominantly 6 storey development constructed in materials unlike any of the surrounding area creates a civic quality in Bishop's Stortford; rather the appearance of the buildings are those of a schematic 'anytown' approach to development. It would be hard to find any references to the form of the existing townscape and history of the town, which surely must form an integral part of public and cultural form.
14. The materials proposed are unlike any other material seen in the town (even the neighbouring apartments in Masterman’s Wharf are of a more traditional type of brick) and makes no attempt to harmonise the original part of Jackson Square with the new part. In fact the only buildings that the appearance of phase 2 relate to are those of Phase 1.
|Photo 3 Enlarge|
15. Although it may be too early to judge how the development will appear once the materials have weathered, it is a matter of concern that the brick in Phase 1 has already begun to stain as illustrated in Photo 3. A development such as this might not look out of place on an inner city site, but it is completely alien to the character of this old market town in height, scale and appearance.
16. The current Phase 2 proposal would be as unsuitable in its surroundings as Phase 1. In height, scale and appearance, the only development to which it would bear any relationship is Phase 1 – not to any of the surrounding townscape.
17. If Phase 2 were allowed to proceed unaltered, this would no doubt be used to justify redevelopment of the flour mill site on a similar scale, which would turn the River Stort into a gloomy canyon. Phase 2 in its present form would in any case leave the river in shadow for much of the day which is scarcely likely to enhance its amenity use.
18. On the other side of Station Road to this development lies a much larger brownfield site – the station goods yard – which is also scheduled for redevelopment. Our concern with Phase 2 of the Riverside development is not just its unsuitability, viewed by itself, but the precedent it could set for development on a similar scale on the station goods yard. If that were to occur, the character of the town would be irrevocably altered for the worse. It is a matter of great regret to the Federation that a swathe of brownfield sites which together could have transformed the town centre for the better have so far been the subject of such poor quality developments, of which this is the latest example.
19. Reducing the scale and height of Phase 2 by one or two storeys will provide the opportunity to create a more sympathetic development which complements and enhances its surroundings and provides a good precedent for future developments on adjacent sites. In order to do this, however, the density will have to be reduced, either by providing fewer residential units, or removing the retail element from Phase 2 or both. Density
20. The housing allocation for the Adderley Road/Riverside site is identified in policy BIS2 of the Local Plan, the final version of which will shortly be approved by the Inspector, as being 150 of which 45 should be affordable. Outline planning permission was granted for a scheme which would provide approximately 150 dwelling units in Phases 1 and 2 taken together. This density of development is reiterated in the Local Plan, in policy BIS 17, which identifies the provision of approximately 150 dwellings of which up to 40% should be affordable.
21. It was originally anticipated that 45 affordable units would be provided (all in Phase1) and that these would be 30% of the total dwellings in Phases 1 and 2 combined. However, during the course of working up the details of Phase 1, the developers increased the number of affordable units to 60 and EHDC changed its policy on the share of the total which these should represent from 30% to 40%.
22. The combined effect of these changes ought to have left the total number of residential units to be provided unchanged at 150. What appears to have happened is that the developer has applied the former figure of 30% of affordable units to the 60 which are now being provided in Phase 1 to arrive at an overall total of 200 units. This is an increase of a third on the total envisaged in the outline planning permission and repeated in the Local Plan. By no stretch of the imagination can it be regarded as 'approximately' 150.
23. Clearly, if Phase 2 of the development were scaled back from 95 to 45 units (to achieve a total of 150 for both phases) it would be possible to design a building much more in scale and in keeping with its surroundings, but a similar result could be achieved by removing the retail element from Phase 2 and including a somewhat higher number of dwellings.
24. It might be argued that the dwelling density is not out of keeping with the densities agreed for other parts of Bishop's Stortford such as the nearby Anchor Street development. However, Anchor Street is a purely residential development. Jackson Square and the Riverside includes a large area of commercial development and a multi storey car park. If the land area occupied by these is included in the dwelling density calculation it will of course produce a spuriously low figure. The proper comparison with other purely residential developments is to use only the land area occupied by the residential element of this development to calculate the residential density. This is likely to produce a figure for this development more in keeping with an inner city development than one appropriate to a country market town.Conclusion
25. In conclusion, to allow Phase 2 to proceed on the lines proposed by the developer would have a seriously adverse impact on the character of the area. The town's residents, as evidenced by several consultation meetings that have taken place on the proposal, are unanimous in their view that it is completely unsuitable. It would, moreover, set a precedent for other nearby sites to be developed on an equally excessive scale. We therefore urge the Secretary of State to turn down this appeal. I would also like to take this opportunity to register the wish of the Federation to present oral evidence at the public inquiry into the appeal and to be notified in writing of the appeal decision.JOHN RHODES