Proposed medical centre at Silver Leys
Letter from BSCF to Development Control, East Herts District Council
The BSCF outlines its concerns about the proposed medical centre at Silver Leys.
East Herts Council
Hertford SG13 8EQ
|3 May 2012|
Your Ref: 3/12/0448/FP LAND AT SILVER LEYS, HADHAM ROAD, BISHOP'S STORTFORD, PROPOSED MEDICAL CENTRE
1. I am writing on behalf of the Bishop's Stortford Civic Federation about these proposals.
2. The Federation welcomes in principle the improvement and upgrading of medical facilities in the town, not least to compensate for the loss of the general hospital we had some years ago. We agree that the premises occupied by the practice in South Street are cramped and outdated. They would be difficult to modernise both for the provision of medical care and to meet modern standards for disabled access.
Suitability of location
3. The practice would no doubt find it cheaper and operationally more convenient to deliver services from a single site. But we have to remember that the practice is there to meet the needs of patients – patients are not there to suit the convenience of the practice. Patients find the locations of the two surgeries in South Street and at Bishop’s Park highly accessible. South Street is right in the town centre close to the bus and train stations and the main town centre car parks. It has a pharmacy next door. People who commute to work in London, Cambridge or the airport can visit the surgery without losing much of their working day and people can combine a visit to the surgery with other things they might need to do in the town centre. The Bishop’s Park surgery is served by the regular and frequent 308 bus service which covers many of the residential areas in the town. There is ample car parking, and here too a visit to the surgery can be combined with other activities such as shopping at Tesco which also has a pharmacy.
4. It would no doubt be possible to establish from the practice data base how many of their registered patients live within walking distance (say 2 km) of one or other of the existing medical centres and how this would compare with the proposed new centre at Silver Leys. We suggest that before making any recommendation to the development control committee, you require this information to be made publicly available. We believe that both the existing medical centres are the most convenient to access for the large numbers of people who live to the south of the town but this is something that can easily be verified by requiring the promoters to supply the data as we suggest.
5. The Government’s recently published National Planning Policy Framework (NPPF) includes amongst its core planning principles the effective use of land by reusing land that has been previously developed (brownfield land). It also expects local planning authorities to apply a sequential test to planning applications for main town centre uses to help preserve the vitality of town centres by making sure that core uses remain there. This is reinforced by local plan policy SDI which requires new developments of this kind to encourage sustainable movement patterns and to achieve the sustainable use of resources such as land. In our view, the proposals comply with neither these national nor the local planning policies for sustainable development.
6. The Bishop’s Park medical centre does not need to be replaced or to relocate. It is very well situated where it is and occupies a building which was built for the purpose and is only about 20 years old. The South Street centre does need to be replaced, but ideally in a location close to its existing site or a little further south, to meet the needs of the people who live there. However, the promoters of this scheme have persuaded themselves that only co-location to a single site will do and they have concluded that there is no suitable town centre site available for such a development. Only a green field site on the edge of town would meet the requirement. This is an argument frequently deployed by developers who always prefer greenfield sites. With these proposals the need for a greenfield site arises by specifying the wrong business requirement which conspicuously fails to address the need for medical centres to be in locations to which their patients can have close and easy access.
7. There are plenty of town centre sites which, on the face of it, could be adapted to provide a modern replacement facility for South Street if that was the only requirement to be met. They include the Drill Hall and Oxford House, both owned by the NHS but apparently surplus to requirements, Charringtons House where Hendersons show no sign of exercising their planning permission; the empty retail units in Jackson Square Riverside, and the almost immediately adjacent site in South Street which has been granted planning permission for a hotel but which shows no sign of being used for that purpose. If the station goods yard were ever to be developed that could provide another suitable location. Any of these would encourage sustainable movement patterns, the re-use of previously developed land, and would retain an activity in the town centre which would help to maintain its vitality and support other commercial activities by bringing people into the town centre.
Reasons for recommending refusal of this application
8. It is obvious that, whatever its merits as a medical centre, it is on the wrong side of town and will be inaccessible to most patients except by car or, if they are not in a position to drive, by taxi. Since the young, the sick and the elderly tend to form a high proportion of the clientele of a medical centre they are more likely than the population as a whole not to have access to a car or be able to drive to their surgery.
9. Looking at the planning, rather than the business case for these proposals we suggest that the following provide more than sufficient grounds for refusal
- Retention of Community Facilities (LRC 11 in the local plan) ‘Proposals which will result in the loss of community facilities will be refused unless suitable alternative facilities are provided on site, in the locality or relevant catchment area.’ These facilities are not on site, in the locality or relevant catchment area.
- Making Development More Sustainable (SD1 in the local plan). As discussed in para 5 above, this explains that new developments of this kind are expected to encourage sustainable movement patterns and that it is Government policy to develop land, particularly within town centres and brownfield sites in preference to greenfield sites. If relocation were confined to the South Street centre, there are clearly plenty of town centre opportunities which have not been explored and which would permit continued use of sustainable forms of travel.
- Traffic Reduction in New Developments (TR1 in the local plan). ‘Developments generating additional traffic will be required to incorporate measures … to ensure that alternative options to the private motor vehicle are available to the users of the site.’ The bus services serving the site are irregular, infrequent and wholly inadequate in contrast to the existing locations. The transport assessment appears to be unaware of the 308 service to Bishop’s Park which means that it is much better served by public transport than Silver Leys. Although we have heard rumours of a community bus service, there is no mention of it in the application. It would be bizarre to sanction a development which requires such a service at a time when councils are trying to save expenditure. And it would last only as long as we the taxpayers were prepared to pay for it. It also appears that the traffic survey was undertaken on 15 July 2008 when we understand that the main demand generator on Hadham Road – the Bishop's Stortford College – was closed for the summer holiday, which suggests that no reliable conclusions can be drawn from it.
- The Bishop's Stortford Settlement plan makes no reference to this possible development even though discussions started with officers almost immediately after the adoption of the plan in 2007. It does not therefore conform with the settlement plan.
The Federation hope that these will be sufficient and powerful reasons for you to recommend refusal.
I am copying this letter to James Parker, Chief Executive of Bishop's Stortford Town Council
Chair, Bishop's Stortford Civic Federation