Parsonage Residents Association - Objections to Proposed Schools' Move Map
Letter to Head of Development Control, East Herts District Council
Head of Development Control
East Herts Council
Parsonage Residents Association
Registered Charity No. 243905
Your Refs: 3/08/1101/OP 3/08/1102/OP 3/08/1103/OP 3/08/1115/OP 3/08/1116/OP 3/08/1117/OP
APPLICATIONS TO BUILD TWO SCHOOLS AT WHITTINGTON WAY BISHOP'S STORTFORD AND HOUSING ON THE SITES TO BE VACATED AT WARWICK ROAD, BELDAMS LANE, LONDON ROAD AND ON THE RESERVE SITE AT HADHAM ROAD
I am writing on behalf of the Parsonage Residents Association (The PRA) to object to these proposals. The PRA is a registered charity that represents 1300 households in the Parsonage Lane area who are members, and a map of the area of benefit is attached. The remainder of this letter sets out the grounds of our objections.
Planning Policy Context
The Whittington Way proposed development site falls within a larger area of Green Belt between the Bypass and Bishop's Stortford. It is the most open Green Belt site remaining largely undeveloped within the Bypass. We believe that it is important to see the proposed development in the context of national, regional and local policies relating to such a site.
Government National Green Belt Policy – PPG2
The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. (para 1.4)
The purpose of including land in Green Belts is to check unrestricted urban sprawl; prevent neighbouring towns from merging; safeguard the countryside from encroachment, and preserve the setting of historic towns. The PRA believes that these objectives are of paramount importance to their continued protection, and should take precedence over other land use objectives. (para 1.7)
Once the general extent of the Green Belt has been approved it should be altered only in exceptional circumstances.
If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within urban areas. (para 2.6) Inappropriate development should not be approved except in very special circumstances. (para 3.1), and there should be a general presumption against inappropriate development within them.
The construction of new buildings within a Green Belt is inappropriate unless it is for the following purposes:
- agriculture and forestry
- essential facilities for outdoor sport and recreation
- limited extension, alteration or replacement of existing dwellings
- limited infilling in existing villages and limited affordable housing
- limited infilling or redevelopment of major existing developed sites (para 3.4)
The general presumption against any new development in the Green Belt has been expressed in PPG2 in the clearest possible terms. The emphasis on openness and permanence taking precedence over other considerations (such as landscape features or the nature of the vegetation) is particularly relevant to this application. The PRA believes that these proposals fall within the definition of 'inappropriate development' as set out in PPG2.
Regional Spatial Strategy for the East of England
The version of the East of England Plan which has been approved by the Government was published in May 2008. It identifies some strategic revisions to the Green Belt. In a local context the most important of these is for the area known as 'Harlow North' a few miles to the south of this development proposal. However, apart from the proposed strategic revisions, the policy in SS7 clearly states that
'The broad extent of green belts in the East of England is appropriate and should be maintained.'
The East Herts Local Plan Adopted in April 2007
Because its development was so far advanced, the Government agreed that the former procedure for the consideration and adoption of Local Plans should apply to the East Herts Plan and this is therefore the detailed document for the control of development until 2011. At the last stage of public consideration before the adoption of the Plan, EHDC proposed the removal of part of the Whittington Way site from Green Belt protection and its redesignation for educational use (to provide two schools of the same size as the current proposal). The proposed redesignation was considered in some detail at the Examination in Public into the Local Plan and rejected by the Inspector.
The Inspector's report on the Local Plan also dealt with the site at Hadham Road which had been acquired by the County Council many years previously for educational purposes. Her conclusion on this was that, "The Reserve Secondary School Site, Hadham Road, as defined on the Proposals Map, is reserved for residential development as a Phase II site and will only be released for development if sufficient additional secondary school capacity is provided elsewhere in the town."
The Inspector's recommendations have been incorporated in the Local Plan adopted by EHDC in April 2007. The Local Plan makes no provision for any alternative use for the two sites currently occupied by the Boys' High School and the Herts and Essex School, nor for the use of the separate Herts and Essex School playing field site in Beldams Lane. In addition therefore to the use of the Green Belt site in Whittington Way for educational purposes, any alternative use of the three sites which the schools would vacate as a result would also represent major departures from the recently adopted Local Plan.
The incompatibility of these proposals with national, regional and local policies for Green Belt protection, together with the four major departures they would entail from the Local Plan should of themselves be sufficient to refuse permission for these applications - to do otherwise would suggest that any part of the Local Plan could be set aside to suit the convenience of developers. Local Plans are intended to give certainty to local residents and developers as to what sort of development will be permitted and where.
To sanction such major departures so soon after the Local Plan had been adopted would bring the whole planning system into disrepute, and is a matter of considerable importance to the PRA.
The developers putting forward these proposals are seeking to rely on “educational need” as a justification for their acceptance. The PRA have the following comments to make.
Size and Condition of Schools
Both the Boys High School and the Herts and Essex School argue that their existing sites are too constrained to permit expansion beyond their current size of 5 FE (forms of entry of 30 pupils). They also claim that their buildings are in poor condition and that the facilities they provide restrict the range of educational opportunity they can offer.
As they have pointed out, both schools are popular and oversubscribed. They both have a good academic record - in the case of the Boys High School achieved only relatively recently without any expansion in intake or significant alteration to buildings. Both schools are foundation schools which have opted out of local authority control. It is therefore the responsibility of their boards of governors to live within the budgets they have been allocated by central government.
It would probably be difficult for either school to expand on its present site. It would not be impossible to refurbish or, in the case of the Boys' High School to replace their buildings without moving to a new location. The Boys' High School has sufficient adjacent land for temporary accommodation to be erected to allow for the existing buildings to be progressively demolished and replaced. If the Herts and Essex School were to make better use of its playing field in Beldams Lane (for example by building a sports pavilion and changing rooms on the site and laying out different types of sports pitch) there would be sufficient space on its main site to erect temporary buildings while the limited amount of substandard accommodation was being refurbished or replaced without prejudicing physical education.
In summary, neither school needs to expand in order to maintain its academic standards. Neither school needs to move in order to replace or refurbish substandard buildings. If the schools were basing their case for exceptional disregard of Green Belt protection purely on their wish to fund new buildings, their planning application would not be entertained for a moment.
Viability and School Size
The LEA claims that the minimum viable size for a new school is 6 FE (about 1200 pupils in total). Arguably, however, 6 FE ought to be regarded as the maximum viable size of school not the minimum. Hockerill Anglo European College is one of the most successful schools in the country and has just received an outstanding Ofsted report. It has only 4 FE, about 750 students, and has resisted calls from the LEA to expand because it believes that the quality of education would suffer.
There is a growing body of evidence that educational attainment and social behaviour deteriorate in very large schools. It is reasonable to conclude that the Herts and Essex and Boys' High Schools have now reached their optimum size of 5 FE. A 60% expansion of both schools contemplated by this proposal, with co-location on to a single campus, and considerable sharing of facilities seems likely to jeopardise the quality of education and the high reputations which they currently enjoy. It is hard to believe that they will be able to retain their own individual characters as separate schools in these circumstances.
The developers claim that the oversubscription of the two schools shows that there is an unsatisfied demand for single sex education which their proposals would meet. The argument is at best unproven and at worst, nonsense. All the schools in Bishop's Stortford are oversubscribed because there is, and has for many years, been a shortage of secondary school places.
It should also be noted that the developers' proposals would do nothing to increase parental choice. Enlarging the foundation schools simply offers more of the same, for better or for worse, whereas a fourth new school could offer an alternative range of educational opportunities. The developers' proposals therefore militate against seeking a balance of single sex and coeducational places and militate against parental choice.
Any argument that there is no available site within the existing built up area of the town large enough for a 3000 student campus may be true but is entirely irrelevant. As explained above the two foundation schools are under no compulsion either to expand or move. Moreover they have no duty to provide additional school places to meet the shortfall in Bishop's Stortford. That responsibility rests with the LEA - the County Council. It is therefore surprising that the application to build on Green Belt land is not being led by the LEA.
The only argument which might lead to consideration of sacrificing Green Belt protection is that this proposal is the only way in which the shortfall in school places can be met. As presented, it proposes to enlarge the schools by 1 FE each in 2011, with further additions of 1 FE each in 2021 and 2031, bringing both schools up to 8 FE by 2031.
The PRA believes that this slow rate of expansion would perpetuate, not cure, the shortfall in secondary places in Bishop's Stortford. There is a site in County Council ownership at Hadham Road which has been safeguarded for this purpose for many years. At 8.3 ha it is large enough for a 6 FE school (which would have to be co-educational) which the LEA accept is a viable size for a new school.
The Shortfall in School Places
Appendix 1 to this letter sets out the Bishops Stortford Civic Federation's analysis of the demand for school places compared with the capacity which the developers are proposing to provide. The PRA agrees with their conclusion that a proposal to provide only 2 additional FE in 2011 will leave the town with a significant amount of unmet demand, if the current rate of house building continues to deliver a projection of 4000 additional houses for Bishop's Stortford by 2021. It seems likely, however, that there would be unmet demand for around 6 FE of places in year 7 by 2011 - the size of a viable new school. While the slow rate of expansion of the schools proposed by the developers may help to maintain the foundation schools' league table standings, it will not satisfy the aspirations of parents of Bishop's Stortford to have their children educated locally. The PRA agrees with the BSCF conclusion that a better solution exists which is to build a new school at the site at Hadham Road which was acquired many years ago by the LEA for just this purpose.
The BSCF propose that the Hadham Road site is large enough to provide a 6 FE school (a size which the LEA accepts would be viable) without further land acquisition. The undeveloped site has an area of 8.3 ha. The applicants suggest that a 6 FE school requires a site of 8.7 ha - about a sports pitch more than the Hadham Road site. The site in Whittington Way is planned eventually to accommodate 16 FE on a site of 20 ha. Even if allowance is made for the space saved by sharing some facilities, a site which is 41% (at 8.3 ha) of the area of the proposed Whittington Way site and which would require much less car parking should be sufficient to accommodate a school which would have only 37.5% (6 FE) of the co-located schools' capacity. If additional playing fields or sports facilities were thought to be needed it might be possible to enter into a partnership agreement with the Bishop's Stortford Rugby Club immediately opposite, who currently use part of the Hadham Road site for training purposes. The PRA support this proposal.
Schools are meant to play an active role in their local communities. The swimming pool at the Herts and Essex school is well used by other groups outside the normal school day. Although these would be replaced at the proposed new schools, sharing of facilities may mean that there is much more pressure for school use and fewer opportunities for the community to benefit. Moreover, the remote location of the site will make it less accessible to people in the PRA area of benefit as it is moving nearly two miles away.
Relocating and enlarging the two schools at the same time will be hugely disruptive to the education of a generation of children, as staff take their eyes off the ball of teaching while they focus on the preparations for the move and its aftermath. Parents whose children are already at the schools have not been asked whether they wish the moves to happen. They have simply been told by the boards of governors very late in the day that this is what is intended to happen. Had they been aware of these intentions earlier, it might have influenced their choice of school.
Local Plan Transport Policies
The East Herts Local Plan reflects the Regional Plan's overall objectives in its own aims and objectives and the transport assessments list them. The Local Plan also notes that as the local planning authority it has a major role to play in integrating transport planning objectives with the location, type and design of development.
No school travel plan accompanies these applications. On the contrary, the transport assessment says that a comprehensive plan will be developed. It is hard to see how an application which contemplates providing 500 car parking spaces can be described as one which 'restricts car parking and car access at and around schools'. This application therefore does not meet the requirements of Local Plan Policy T4.
Specific Location Issues
There are overwhelming access arguments for keeping the foundation schools where they are, and these are particularly relevant to residents in the PRA area.
Both are located in residential areas and have the ability to attract a high proportion of pupils from within walking distance. The Herts. & Essex High School is within walking distance of all pupils in this area, and the High School is on a bus route. The proposed site at Whittington Way is not within walking distance, and is not well served by public transport from this area.
The High School is on one of the main bus arteries into town. The Herts and Essex School is within easy walking distance of the bus and train stations. Since both schools appear to attract about a quarter of their pupils from Harlow, Sawbridgeworth and Stansted Mountfitchet, (LEA's evidence to the Local Plan EiP shows 229 pupils attending the Boys' High School and 219 pupils attending the Herts and Essex School from these places) accessibility of existing public transport services is very significant.
Current and prospective brownfield developments in the town centre will add another 1000 dwellings within walking distance of one or both sites.
The present separate locations of the two schools mean that traffic congestion problems are dispersed rather than concentrated in one location.
Developing the Hadham Road site will provide the best access for the quadrant of the town and outlying villages which have no standard state secondary school places. It is also on one of the main existing bus arteries into town. Developing the existing schools sites for housing will not make traffic congestion go away but will lead to different problems - not least from PRA residents trying to get to the relocated schools.
There are equally strong objections on access grounds to relocating the schools to Whittington Way. The congestion problems will be concentrated in one place - the road network cannot support a 3000 pupil school run at a single location, and the use of cars for the “school run” will likely increase substantially from the PRA area.
A peak hour’s town centre to school bus service no longer appears to be planned. Although it is doubtful if such a service would be viable, it makes it more likely that existing train users will switch to the car. The interchange penalty for public transport is well known - people who would have to change from one bus to another in the town centre are more likely to do the whole journey by car. Using the bypass to access the site will defeat its purpose, which is to be a bypass - not a local distributor road. Access issues were not addressed in the published version of the Bishop's Stortford Transport Study in spite of the poor accident record of the Thorley Street/Whittington Way junction and the reduced opportunities for walking to school which relocation would create. The attractions of the Hadham Road site for a new 6 FE school are in many ways the obverse of the objections to the Whittington Way site. In particular Traffic congestion caused by the school run would be dispersed and would of course be much less. The site would serve the quadrant of the town in which no standard state secondary school places are provided. If the ASR's should be developed, as the Local Plan contemplates, the site would be within walking distance of them. The Whittington Way site by contrast would be so remote that ASR residents would be forced to access the schools by car using the bypass.
Noise The Whittington Way site is close to (in practice sometimes underneath) one of the main take off and landing flight paths for Stansted Airport. Even if the planners do not regard this as a safety issue, the constant noise disturbance makes this an unsuitable site for educational facilities or residential development. PPG 24 which deals with Planning and Noise makes this clear: 'It will be hard to reconcile some land uses, such as housing, hospitals or schools, with other activities which generate high levels of noise, but the planning system should ensure that, wherever practicable, noise-sensitive developments are separated from major sources of noise (such as road, rail and air transport and certain types of industrial development).'
For several years Bishop's Stortford has experienced simultaneous construction on many sites across the town. This has led to severe degradation of the environment on the approach roads and in the town centre itself. Although the town centre enjoys the benefit of a HGV ban, it is almost impossible to enforce on construction traffic because the multiplicity of sites means that it is difficult to tell whether a construction lorry is delivering to a site or simply taking a short cut.
The problem is particularly acute along Stansted Road, London Road, Dunmow Road and at Hockerill traffic lights, all of which are access roads from the PRA area to the Town Centre, and most of the Town. This problem will be repeated if the existing school sites are redeveloped for housing, since the Herts and Essex site is within the restricted area, and construction may still be continuing at other sites in the town centre at the same time. Since the Hadham Road site is close to the bypass, any mandatory routes for construction traffic would be much easier to enforce, and would cause very little disturbance in the town, and in the PRA area.
Consultation Process and Results
It is worth repeating two statements which are quoted in the developers' report on the results of consultation.
'The views of local people are an integral part of the planning process and the case for the community's voice to be heard is clear.' 'Community involvement should happen at the point at which people recognise that they have the potential to make a difference.'
The contrast with what has actually happened over proposals which have taken many years to bring to this stage is striking. Neither school has consulted parents about how they would like to see the schools develop, even though the project timetable, if achieved would affect all children aged 15 or less. Only one feeder school has been referred to in the stakeholder consultation - presumably because it shares a site with the Boys High School. So prospective parents have not been consulted either.
The public exhibitions earlier this year were principally occasions for the schools to present their case as though the relocation and its housing consequences were settled decisions.
In short the approach of the applicants has been a denial of the recommendations in PPS I that people should be involved in such proposals at a time and in a way which enables them to make a difference. In spite of the unwillingness of the applicants to engage with the public in any serious way, the community has expressed its opposition to these proposals in the clearest possible terms, not least in the responses to the exhibition questionnaires. The PRA trust that the local planning authority will support the clearly expressed views of the local population by dismissing these applications.
Yours faithfully,Edna Forrest
Parsonage Residents Association