Mr B Adams (Old Thorley and Twyford Park Residents Association - OTTRA) - Objections to Proposed Schools' Move Map
Letter to Development Control, East Herts District Council
Mr S Drinkwater
Director of Neighbourhood Services (Development Control)
East Herts District Council
|15 September 2008|
Planning Applications Nos:
3/08/1117/OP Land at Whittington Way, Bishop's Stortford;
3/08/1103/OP Bishop's Stortford High School, Bishop's Stortford;
3/08/1102/OP Herts and Essex High School, Bishop's Stortford;
3/08/1101/OP Beldam's Lane Sports Pitches, Bishop's Stortford;
3/08/1115/OP and 3/08/1116/OP Land South of Hadham Road.
I wish to express total opposition to these six planning applications for reasons listed below. My points apply most particularly to applications 3/08/1117/OP, Land at Whittington Way, Bishop's Stortford, and to 3/08/1103/OP Bishop's Stortford High School. However, since these and the remaining four applications are all part of a very large New School and Re-Development Scheme, my general comments on 1) Green Belt and Environment, 2) Transport Considerations and 3) Providing for Educational Need, may be taken to apply to the whole overall scheme.
1) Green Belt and related Environmental Concerns
The Supporting Planning Statement (SPS) page 3, paragraph 2.5 quotes Policy GBCI, Local Plan Second Review as follows: "Within the Metropolitan Green Belt ... permission will not be given for inappropriate development unless very special circumstances can be demonstrated that clearly outweigh the harm by reason of the inappropriateness or any other harm." The Local Planning Inspector has stated inter alia (SPS page 4, paragraph 2.7) " I do not accept that it is necessary to remove land from the Green Belt to enable secondary school needs of the town to be met."
Whether it is suggested that the 20 ha Whittington Way redevelopment would, if implemented, still be classed as Green Belt or not is a mere technicality; once the Green Belt has been breached, vast harm to the environment will have been done and a devastating precedent for future green belt development around the huge school campus and beyond will have been irrevocably established.
The large-scale plans (1:200) produced by Mayer Brown Ltd of the area around the proposed Bishop's Avenue/Whittington Way roundabout and around the Pynchbek/Whittington Way roundabout already propose the destruction of approximately 60 numbered trees. The smaller scale (1:1000) plan of these roundabouts and the proposed schools site seem to suggest the destruction of around 35 trees. Thus already the loss of almost 100 trees is proposed! The company Tree Fabrik describe this as "a small loss" (SPS page 42, paragraph 11.19)! We are blithely assured that a gain will result from tree planting; how many decades are required for the regeneration of mature hedgerow trees?
Further, the northern boundary of the development, on the plans already cited and those at the public exhibitions (not 'consultations') are drawn right up to the boundary of Thorley Lane and up to the boundary of domestic gardens in Pynchbek! One can only ask – Why? What further, undisclosed plans are afoot? Local councillors were challenged on this point at a public protest meeting on May 24th 2008 - no reply was forthcoming. Again, what is mean by "alterations to the existing landscaping" (between Whittington Way and Thorley Lane)? No development permissions should be granted when none of this is clear.
The above paragraph concerns land adjacent to the southern boundary of the Twyford Park Estate (i.e. all those houses accessed from Bishop's Avenue). At the northern boundary of this estate, the proposed housing development on the site of the existing Bishop's Stortford High School (TBSHS) will mean huge infilling of land which is now largely playing fields. Twyford Gardens and Grace Gardens will have houses - and even roads – abutting their back gardens. If the proposed 220 houses were built, it would mean almost continuous housing from the southern edge of Bishop's Stortford to the centre of the town. This can only be described as "harmful impact on the environment of the surrounding area." (SPS page 7, paragraph 3.3). How can it "protect and enhance the natural built environment" (SPS page 33, paragraph 10.1)?
The SPS document, read in conjunction with other supporting documents, contains many internal contradictions. One example is the opposition to an alternative proposal for a new school campus for the Hertfordshire and Essex High School (H&EHS) on its existing playing fields at Beldams Lane with new playing fields south of this. One consideration against this was "the proximity of the school and playing field to the Stansted Airport flight path" (SPS page 24, paragraph 14). Yet the proposed Whittington Way site will be almost under such flight paths! Noise monitors in the vicinity have shown measurements above acceptable levels for educational establishments at present; planned NATS flight-path relocation, coupled with G1 and possible G2 airport expansion, will markedly worsen this situation.
Another example relates to the 'Very Special Circumstances – Summary' (SPS page 9, paragraph 4.2). Part of this refers to "the absence of any significantly harmful impact by the planning application proposals upon the integrity of the Green Belt". Yet even the SPS admits "effects on landscape value was assessed to be of moderate significance and adverse in nature" (SPS pages 38/39, paragraphs 11.6 and 11.8). Moreover, "eight (out of 11) viewpoints" after "planting and screening" were found "still to have potential substantial/ moderate or higher visual effects" ! How can 20 ha of lost Green Belt and ruined views then be "assessed to be of moderate significance and neutral in nature" (SPS pages 38/39, paragraphs 11.5 and 11.7)? Almost as an aside, under 'Geology, Minerals and Ground Conditions' it appears that "piles may be required." (SPS page 43, paragraph 11.21). In this event, there is no mention of possible costs, noise or duration of the pile-driving entailed!
Further, the SPS itself admits (under 'Absence of Significantly Harmful Green Belt Impact'!) that there will be "some urban encroachment."(SPS page 30, paragraph 9.3); as part of the 'Overall Conclusion' it is admitted that "The planning application proposals will clearly have a major impact (my italics) on the existing environment of both the adjoining urban area to the north and the rural area to the south." (SPS page 56, paragraph 11.72)
Finally, there is the breathtaking assertion in SPS page 37, paragraph 10.20 that "the existing natural environment of the Whittington Way site is considered to be of limited value." Just who considered this? Were any residents of Thorley, Twyford or Bishop's Stortford generally given the chance to voice an opinion before plans were produced? I consider the existing views of this natural environment, looking east from St James Way, to be some of the best around Bishop's Stortford.
2) Transport Considerations
The Supporting Planning Statement (page 7, paragraph 3.3) states that "The following planning issues are considered to be of material significance to the planning application proposals: Whether the development proposals are in conformity with the principles of sustainable development ...Whether the traffic that will be generated by the development proposals will have harmful impact on the local highway network." Moreover, the East Herts Local Plan Second Review (SPS page 33, paragraph 10.1) "expects a Sustainability Statement which explains how a proposed development will ... encourage sustainable movement patterns through design and transport infrastructures." Again, "The Transport Assessment prepared by Mayer Brown Ltd describes the measures proposed to ensure that access to the relocated and expanded schools by sustainable transport modes (cycle, walk, bus) is maximised." (SPS page 34, paragraph 10.7). There follows a collection of proposed 'Highway Management Measures' including pedestrian and cycle links and the introduction of new bus services (SPS Pages 49/50, paragraph 11.47)
With these statements in mind, the conclusions from the planning documents beggar belief. Again and again the Supporting Planning Statement and other documents downplay the transport implications of the six planning applications, especially regarding road vehicles. For example, "... it was concluded that the impact of schools traffic would not be harmful to the amenities of nearby residential properties" (SPS page 50, paragraph 11.48) and "The [traffic] model results show ... some decrease (my italics) in traffic on local roads." (SPS page 57, paragraph 12.3) Again, concerning 'primary impacts' during the a.m. peak, "Network modelling has not shown any worsening of traffic conditions during this period" (Transport Assessment – Final, Mayer Brown Ltd, page 49, paragraph 7.39). Writing of the London Road (B1383), particularly the Thorley Hill to Whittington Way section, the Transport Assessment states "... the relocation will not result in worsening conditions along the London Road." The SPS states "it is concluded that the planning application proposals will not have a significantly harmful impact on the safety and capacity of the Bishop's Stortford highway network." (SPS page 61,paragraph 12.20)
The Transport Assessment assumptions for future traffic to the new campus is that the percentages of students and staff for each mode of transport (car, bus, walking etc) would be the same as currently pertains. These assumptions are almost certainly wrong (see later points). However, these assumptions and the Transport Assessment's own predicted figures give the following:
Total student population for each school = 1600
Overall student population at proposed new campus = 3200
Overall school staff population = 479
So, total students and staff = 3679
This is the size of a small university.
Of this 3679 population:
Total students and staff arriving by car = 1482
Total students and staff arriving by bus = 678
So, overall total travelling by car and bus = 2160
The predicted number of students involved in car-sharing is 178; assuming 2 per car, this gives 89 'double-occupied' cars, and 1304 cars bringing just one staff member or student. So the total predicted cars involved = 1393
Allowing for part-time teachers (or others) arriving outside the a.m. or p.m. peaks, this still suggests around 1300 cars plus the buses required for 678 students arriving in the morning peak – based on the Transport Assessment's own predicted figures.
Despite all this, the planning applications claim that there will be "no worsening" of traffic, so producing "no harm" and "no impact". These claims are patently nonsensical. Moreover, the consequences of the schools' relocation, as regards traffic, would almost certainly be worse than the above figures suggest.
It is stated that "The Traffic Modelling exercise has been predicated on the assumption that the proportion of car trips ... can be constrained to the same level [as now]." (SPS page 57, paragraph 12.3). It is presumed that the percentage of students and staff who walk to this proposed out-of-town campus will be as it is now. Of course, there will be an appreciable drop in the percentage walking (total numbers predicted at 1156!); many of these will arrive by car and bus – as will many of the predicted 89 cyclists.
Neither has any mention been made of the extra pupils from the housing development on the current High School site (220 houses) or from the other 550 houses to be built on the current Herts and Essex school site and the Patmore Close/Hadham Road sites. This will increase the Bishop's Stortford population by almost 2000 according to planners' predictions; many of these will be school children.
It is also to be noted that no mention has been made of traffic difficulties at the Pig Lane/London Road junction – already a notorious accident 'black-spot', the London Road/South Road (Total garage) roundabout, the Latchmore Bank (A1060)/Pig Lane junction (another accident zone) or many other affected junctions.
Finally, the Transport Assessment suggests that the a.m. peak time traffic delay at the projected Bishop's Avenue/Whittington Way/campus entrance roundabout would be 5 seconds. From personal experience at the Bishop's Avenue/Whittington Way junction, I know that the average peak time delay is already well over 5 seconds!
The claims made in the Transport Assessment are spurious; if the various developments are allowed, traffic chaos will ensue.
3) Providing for Educational Need
The need to provide a significant number of extra secondary school places in Bishop's Stortford, phased in over the next two decades is not in dispute. However, I would contend that the current proposals, producing desecration of the Green Belt coupled with vast urban house-fill and the concomitant traffic gridlock, is the worst way of meeting this need.
The whole tenor of the various planning documents (especially the Supporting Planning Statement) and of the public promulgations (not consultations) in May 2008 is that the proposed Green Belt development and concurrent house building on the old school sites constitutes the only feasible way forward; this is emphatically not so.
The following points have either been hardly considered or not considered at all. The list is not exhaustive.
a) The phased demolition of at least some one-storey buildings on the existing school sites and their replacement by two or three-storey buildings does not appear as a possibility. However, the Hawkins Brown Design and Access Statement for the new schools' campus specifically allows for buildings 'up to three storeys.' (HBDAS page 22, paragraph 7 and page 29)
b) Hawkins Brown, referring to TBSHS and H&EHS, states that "phasing/decanting strategy" for redevelopments on existing sites "would be very disruptive to the continuing operations of the school." However, many schools nationwide have coped with on-site developments, by means of careful phasing, use of perfectly adequate temporary demountable classrooms with full provision of utilities and by other measures.
c) The use of Hadham Road/Patmore Close site for a new school which would eventually be 6 form entry – as Herts County Council originally intended when it bought this land. Hawkins Brown "estimated a generalised site requirement for a 6.F.E. school ... of 8.7 ha." (SPS page 21, paragraph 7.6). The site in question is 9.4 ha. It would also give a far better geographical distribution of students around Bishop's Stortford, would have better transport links from the bypass, would not be under flight paths and would provide an increase in co-educational school places to balance the then concurrent expansion of single-sex places at TBSHS and H&EHS. Thus a new school would provide more parental choice in terms of type, location and school size.
d) It appears that the Private Finance Initiative as a means of paying for a new school has not been sufficiently explored. The 'credits' for this, it is suggested, would only be available through the Government's 'Building Schools for the Future Programme' and that Bishop's Stortford is not currently programmed to receive funding until around 2013 – 15 (SPS Pages 17/18, paragraph 6.8). However, I believe that some local authorities (e.g. Oxfordshire) have been successful in applications to bring this funding forward; HCC could well cite such financial provision in a submission to central government.
e) A further reason for not developing schools on existing sites has been the diminution of playing field space this would cause. However, nearby provision may well be available – e.g. south of Beldams Lane for H&EHS and on the edge of Southern Park (Thorley Lane access) for TBSHS. The latter would be much closer than the Jacob's Wood site already in use.
f) It is noted that the proposals envisage 8 F.E. schools, which are large. The statement that 'In Hertfordshire, there is strong evidence that larger schools have relatively higher levels of attainment' needs to be treated with scepticism; nationwide, there is no compelling evidence of such a correlation. What may well be true, from apocryphal evidence, is that most parents do not prefer large schools; the small/medium size of both TBSHS and H&EHS has previously been deemed a virtue.
g) It has been claimed that currently around 5% of students at TBSHS and 3.5% at H&EHS come from outside Bishop's Stortford. Some of these students come from Harlow and further afield in Essex. A phasing out of such 'long-distance' provision would increase the places available for nearby Bishop's Stortford Students without increasing overall numbers. There is no mention of this in the published proposals.
Neither local residents nor parents at primary schools have ever been consulted on their views concerning the proposals. Further, it can be seen that the planning documents – especially the Supporting Planning Statement – are built upon inaccuracies, inconsistencies, bland assurances and totally unwarranted assumptions. If implemented, the six linked planning proposals would cause deterioration to the quality of life of current and future residents of Bishop's Stortford, including its children; they would ruin a vital part of the local Green Belt and they would create a precedent for yet more Green Belt destruction. I urge you to recommend refusal to grant outline planning permission.
Yours sincerely,Mr B J N Adams
Cc. Mr Mark Prisk, MP
Mr K Steptoe, Head of Planning and Building Control, EHDC
Mrs Diane Hollebon, Chairman of EHDC
Mr John Harris, Director for Children, Schools and Families, HCC
Mr Robert Gordon, Leader of HCC
Ms Mary Bayes, HCC (Bishop's Stortford Rural)
Mr John Ingham, Clerk to B/S Town Council
Development & Infrastructure Division (Development Plans), GOEast
East Herts Councillors for Bishop's Stortford:
Councillor Andy Graham
Councillor Mike Wood
Councillor Colin Woodward
Councillor Keith Barnes
Councillor Mione Goldspink
Councillor Robert Taylor
Councillor Jill Demonti
Councillor Ralph Gilbert
Councillor Duncan Peek
Councillor Graham McAndrew
Councillor Allen Burlton
Councillor Robert Parker