BSCF's views on Herts County Council's planning application for new school and playing fields in Bishop's Stortford North by the A120
Mr Chay Dempster
Spatial Planning and Economy Unit
CHN216, County Hall
|23 November 2014|
6FE SECONDARY SCHOOL A120 BISHOP'S STORTFORD NORTH
YOUR REF: SLUP/CC0774
1. I am writing on behalf of the Bishop's Stortford Civic Federation to let you have our views on this planning application. While the Federation welcomes the decision by the County Council to secure the provision of the secondary school places which the Bishop's Stortford North (BSN) development can be expected to generate on the north side of the town, we believe that the application submitted is flawed in a number of respects and that outline permission should therefore not be granted at this time. This letter explains why.
2. The detail of our objections is set out in the remainder of this letter. In summary they are as follows:
- The County Council have underestimated the demand for secondary school places implicit in the most recent version of the draft district plan. This envisages over 5000 new homes being provided in Bishop's Stortford (including BSN) and Sawbridgeworth. Using the Council’s metric of 1 FE generated per 500 dwellings, the proposed new housing would generate a peak demand of 10 FE not the 8 FE which the Council have assumed in support of this application.
- The County Council have also made the unrealistic assumption that there will be no increase in cross area flows – net movement of pupils to schools in the area from places further afield. A more reasonable assumption – that these will take up about 30% of the extra school places as they have done for many years at our existing schools – would add a further 2-3 FE to the overall demand for places.
- The County Council’s claim that the proposed 6 FE school will be sufficient to meet the long term demand for school places is therefore incorrect, and the Council appear to have no plan to meet the excess in demand above 6 FE. The precondition that the land being surrendered in BSN for the proposed school should be exchanged for residential development on the Council owned site in Hadham Road cannot be met. Policies BIS7, saved from the adopted district plan and BISH5 in the draft district plan both require that the demand for secondary school places will be satisfied elsewhere before the site can be released.
- Removal of the proposed Bishop's Stortford South development from the draft district plan would significantly reduce the demand for school places and might then add some weight to the County Council’s belief that one 6 FE school would be sufficient to meet the long term demand. But the draft district plan has further stages to complete before the housing numbers in it are finalised.
- The transport assessment has made the wrong assumption about the number of dwellings to be displaced from BSN by this development. It will lead to the removal of 150 not 250 dwellings.
- The transport assessment should model not just the final position after completion of all the development, but the intermediate situation, after BSN phase 1 and the Hadham Road site have been developed for housing but before a second access point to BSN has been created on the A120. Until the new roundabout is installed, the traffic congestion is likely to be worse than if the Hadham Road site had itself been used for a school.
- The application needs to explain how the public will be able to gain access to the separate sports facilities and whether they can be brought into use in advance of the completion of the A120 roundabout which appears to be the only point of access for emergency vehicles.
- The proposal appears in some respects less suitable as a pair of sites than the one the Council already own in Hadham Road from the perspectives of walking distance from residential areas, traffic congestion implications, harm to undeveloped Green Belt land and value for money – the site which the developers would surrender is less than half the size of the one owned by the County Council.
Demand for school places
3. The County Council’s approach to forecasting demand for school places was last subject to rigorous scrutiny in 2011 when it supported an appeal by two Bishop's Stortford Schools to relocate to a Green Belt site on the south side of the town. The appeal was refused and the County Council’s approach to forecasting was subject to some critical examination in the Inspector’s report. The forecast made then comprised four components – data from GP surgeries etc about births, JMI and secondary school population within the Educational Planning Area (EPA), pupil yield from new housing, and cross area flows.
4. The County Council can continue to update its forecasts with recent data from the first two sources. In the case of the third source of demand – new housing – the assumption at the time of the public inquiry was that BSN would deliver 2728 new dwellings, ie rather more than is now proposed at somewhat less than 2600. At that time the implicit assumption (not discussed at the public inquiry) was that the pupil yield from new housing was 1 FE per 1000 dwellings. As a result, the main generator of demand was perceived to arise from the so-called cross area flows – net intake of pupils to Bishop's Stortford schools from outside the EPA, mainly from Essex.
5. In considering the educational impact of the development actually proposed for BSN (2200 dwellings with one application for fewer than 400 dwellings still outstanding), the County Council appears to have doubled its assumption of the pupil yield from new housing to I FE per 500 dwellings. The only explanation given to the Civic Federation for this change is that the actual dwelling mix is now known. Given that BSN was always intended to be predominantly family housing and that the total number of dwellings has gone down since 2011, it strains credulity to accept this as a sufficient explanation for a change of such magnitude. We are not in a position to form a view as to whether this is a more appropriate metric than the one used by the County Council at the public inquiry 3 years ago since the basis of neither of them has been justified. But we do expect that it should be applied consistently to all the prospective housing envisaged in the draft district plan. This does not appear to have happened.
6. Appendix A to the planning statement sets out the assessment of educational need as follows
‘The modeled secondary pupil forecast for the Bishops Stortford and Sawbridgeworth planning area indicates peak demand for 3 forms of entry (FE) of additional capacity to meet need from the area within the forecast period, to 2025. This forecast includes an assumed housing trajectory that reflects the latest stated position outlined in East Herts District Council’s Draft District Plan Preferred Options consultation document, but excludes the proposed development of 2650 new dwellings at Bishops Stortford North (BSN).
‘Based on Hertfordshire’s child yield model for new housing developments, the 2650 new dwellings proposed for BSN (ASRs 1-5) indicates a peak demand of 5 FE. This yield is expected to be in excess of 4FE for 8 years and in excess of 3 FE for 16 years, with a long term average of 2.5FE. HCC believes that these peaks are sufficiently long (spanning approximately 9 years) to require and justify permanent provision of core facilities and sufficient land to accommodate the total yield.’
7. This implies that the demand generated by housing proposed in the draft district plan (the preferred strategy was published for consultation in May 2014) would amount to 8FE with 5FE being generated by BSN and the rest by new housing elsewhere within the EPA. However, this forecast of educational demand was prepared in September 2013 and was based on an earlier version of the draft plan at the time that the planning application for BSN was being considered. At that time the plan included only 4078 additional dwellings in the EPA, including BSN (this is consistent with a metric of 1FE per 500 dwellings). The consultation draft of the plan actually provides for 5196 new dwellings within the EPA and so the overall demand for places which the housing numbers in the plan would generate (including BSN) is 10FE, not 8FE.
8. Moreover, 1000 of those dwellings are provided for on Green Belt land south of Bishop's Stortford with start and completion dates falling within the same timescale as the BSN development. There is no reason to suppose that the dwelling mix would be significantly different from BSN – they are not going to be mainly small apartments – and so the demand for school places can be expected to be similar. Since they would be on the opposite side of town from the proposed school in this application the only realistic means of access to the new school would be by car.
9. The Bishop's Stortford Civic Federation has objected strongly to the development of the Bishop's Stortford South site which is currently within the Green Belt and which is not supported by any forecasts of population growth other than a wish to relocate inward migration here rather than elsewhere within the district. We do not know whether this development will remain in the version of the plan which East Herts Council chooses to adopt – they are still considering consultation responses. Meanwhile, given that the County Council has no plans to meet the demand for secondary school places which, on its own methodology, this development would generate, we trust that it will join us in objecting to any major residential development on this site on the grounds that it would be educationally unsustainable.
10. The final element in the County Council’s forecasting methodology is the so-called cross area flow – the net addition to the demand for school places from pupils travelling into Bishop's Stortford from outside the EPA, after offsetting pupils travelling from within the EPA to schools outside it. Because of the location of the EPA and the nature and location of the alternative provision, most of this additional demand comes from Essex with very little compensating outward movement to Essex. The County Council’s own data show that for many years about 30% of the population in secondary schools in the EPA comes from Essex addresses, with a further increment from more distant parts of Hertfordshire. This is also shown graphically on a series of maps in the appendices to the transport assessment which identify the home locations of pupils at each of the schools.
11. This element of demand, rather than the pupil yield from new housing, formed the main component of the case for expanding school capacity when the schools’ relocation appeal was considered in 2011. At the public inquiry, the County Council’s method of forecasting this element of demand was subjected to critical scrutiny and indeed the Inspector found some shortcomings in the underlying rationale for the calculations.
12. Nevertheless, there is good reason to suppose that demand from this source will continue to increase as well. The draft district plan for Uttlesford (which is more advanced than the one for East Herts) proposes more housing development in Stansted Mountfitchet and a 2000 dwelling settlement at Elsenham. Newport Free Grammar School has limited scope to expand while Forest Hall Academy (formerly Mountfitchet College) was until recently in special measures and has no 6th form. East Herts’ district plan proposes a settlement of 3000 dwellings north of Harlow during the plan period (to 2031) and in the early years of such development, parents are more likely to want to send their children to an established school in the EPA rather than to any new facility on site or to Harlow.
13. However, the County Council’s forecast of demand to 2025 appears to make no allowance for any increase in cross area flows arising from developments outside the EPA in spite of the weight they attached to it at the public inquiry only 3 years ago. This is not something within the County Council’s control. Each school is its own admissions authority and the same will be true of the proposed new school at BSN. Indeed, to achieve critical mass as quickly as possible, any such school would be wise to extend its catchment beyond the EPA and it will be the closest new school to Stansted Mountfitchet and Elsenham. If the County Council were adopting a prudent approach to meeting demand, it might anticipate growth in cross area flows commensurate with growth of demand within the EPA, ie 2-3 additional FE.
Reserve school site at Hadham Road
14. The claim the County Council make in their application (Planning Statement para 4.1.1) is that one 6 FE school will be sufficient to meet the longer term demand arising from all the prospective housing developments in the EPA (apart from the cross area flows which they have ignored) with any shorter term peak in demand capable of being met by marginal or temporary increases in capacity at other schools. The analysis above suggests that this assumption is both complacent and mistaken.
15. The relevance of the issue to this application arises because of the basis on which the County Council and the developers have agreed that a site for the school should be provided on the BSN site. In summary, the developers have agreed to release the land within BSN, provided that the County Council will make over to them the larger site on the other side of the Hadham Road from the BSN development for housing. If planning permission is not granted for housing on the Hadham Road site, then the land will not be released for the proposed new school on BSN.
16. The use of the Hadham Road site in both the saved policies of the current district plan and in the draft district plan is subject to an explicit restriction. In the saved polices, BIS7 states that the reserved secondary school site, Hadham Road, is reserved for residential development and will only be released for development if sufficient additional secondary school capacity is provided elsewhere in the town. This is referred to in para 3.2.2 of the County Council’s planning statement. The policy is repeated in identical terms in the draft district plan as policy BISH5 to which, surprisingly, the planning statement makes no reference.
17. Since, as we make clear in this letter, the County Council has not made a consistent or prudent forecast of the demand for school places in Bishop's Stortford and Sawbridgeworth, and a new 6 FE school while, necessary, would appear at the present time to be insufficient to meet that demand, it follows that the Hadham Road site cannot yet be released for housing, and moreover, no planning application has been made to do so. Were such an application to be made we would object to it on the grounds set out above. It would therefore appear that in the present state of knowledge, a 6 FE school on the site proposed at BSN is not capable of delivery and should not therefore be granted planning permission.
18. When East Herts Council publish the next version of the district plan, it may reduce the provision of housing in the area, as we have suggested, though we understand that this too will be subject to consultation before an examination in public takes place. It will therefore be some time before the housing total for the area is finally adopted, but at the very least, the County Council should wait until East Herts have published a version of the district plan which reflects the outcome of their consultation before considering whether they are still able to pursue this application as a standalone scheme.
Transport and access
19. We have the following concerns about the reliability of the results of the modelling which suggest that the traffic impact of a school on BSN would be negligible, in comparison with the housing that would otherwise be built on the site.
- The wrong amount of housing has been assumed to be displaced by this proposal. The site being surrendered by the BSN developers is 3.5 ha (Transport Assessment para 2.2.3). We were advised at the public exhibition that this would provide for about 150 dwellings (a density of 43 dwellings per ha seems a reasonable supposition). However, the assessment actually assumes a displacement of 250 dwellings (Technical note 1 page 1) and so a net increase of 100 dwellings after the residential development of Hadham Road has been overlooked in the assessment.
- All the modelling has been based on completion of the scheme, of all the residential development and of the suggested transport improvements. Clearly this is necessary, but we are also concerned about access during intermediate stages. No timescales are given for the start and completion of the proposed school, but we trust that it will be open before the completion of BSN which is expected to take some 10 years. Otherwise intolerable pressure would be put on other Bishop's Stortford secondary schools prior to the opening of the new one. Indeed, earlier opening is implied by the suggestion in the transport assessment that access to the new school will be from Hadham Road, to the west, until such time as the new roundabout on the A120 is completed.
- The new roundabout forms part of the second stage of the development (ASRs 3, 4 and 5) and its completion could therefore be many years away. The school will of course attract pupils from beyond BSN – indeed we have suggested earlier that it will actively seek to do so to achieve critical mass as quickly as possible. At the same time, some residents in the first phase of development will want to send their children to one of the already established schools. If the school starts by expanding from year 7 upwards, parents of older children moving to the area will have no choice but to do so.
- Both we and the Development Management Committee of East Herts Council have expressed considerable scepticism about the modelled results for the first stage of development and the impact on Hadham Road. That modelling did not allow for the presence in the first phase of development of a secondary school. Given the proposed access arrangements, the effect can be expected to be the same as if the school were to be built on the Hadham Road site itself. We understand that Herts Highways have expressed concerns about the traffic impacts of locating the school there. Indeed, if the Hadham Road residential development were to be completed before the second phase of BSN started, the congestion effects would be much worse. This is unfortunately all too likely to happen, as it would enable the developers to defer the expense of the new roundabout on the A120. So the intermediate impact of the school without completion of BSN phase 2 and the new A120 roundabout also needs to be modelled.
- Public access to the proposed playing fields will be only via the proposed footbridge over the A120 and emergency vehicular access will be only from the proposed new roundabout on the A120. This gives rise to two concerns. Firstly, it is not clear what community use of the sports facilities will be available outside school hours. The school will presumably want to keep its premises (including the footbridge and car park) secure and so how the public will be able to park or gain access to the playing fields site or any changing facilities needs to be explained. Secondly, the sports facilities clearly cannot be brought into use until access for emergency vehicles is made available. As suggested in the previous bullet point the new roundabout is not likely to be completed until some time after the opening of the school, and until then it will have no sports facilities of its own.
20. These considerations lead us to suggest that planning permission should not be granted until these concerns have been addressed. Indeed because transport and access is such an important issue it should not be treated as a reserved matter to be sorted out by officers of different departments of the County Council in private but should be brought back to the Development Control Committee of the Council for approval.
Suitability of the sites
21. We repeat that we support the principle of a new secondary school to help meet the demand which BSN and other developments will generate. However, given that this proposal would encroach on the Green Belt and would extend the developed area of Bishop's Stortford beyond the bypass, we have reservations about the suitability of these sites for the proposed development. These concerns arise especially because immediately adjacent to BSN the Council already has in its ownership a site of nearly 9 ha on Hadham Road which could accommodate all the proposed facilities within a single site and would not encroach on the Green Belt. For reasons which escape us, the County Council has for many years appeared to treat its disposal as a more urgent priority than adequate secondary educational provision. It seems to us that an objective assessment of the relative merits of the two alternatives should be carried out, before permission is granted for this planning application.
22. Some of the relevant issues in a comparison would be as follows
- Access The walking isochrones in the transport assessment show good access to the proposed site from BSN itself within 1km but very limited coverage of the existing developed north side of the town. The 2km isochrone (maximum acceptable walking distance) covers somewhat more of the north side of town, but also built up areas to the east of the Stort. Access from this side of town, even if theoretically within walking distance, is more likely to be by car in view of the access arrangements actually proposed. In comparison, if the same isochrones were drawn on the Hadham Road site, BSN phase 1 would fall within the 1km isocrhone and the rest of the development within the 2km isochrone. In effect the 2km ischrone at Hadham Road covers the same area of BSN as the 1km isochrone of the schools proposal. But within the 1 and 2km isochrones, the Hadham Road site covers a much larger part of the developed northern side of town where there is currently no secondary school. The assertion in para 3.3.20 of the planning statement that many future occupiers of BSN would need to get to a school on Hadham Road by coach or car is clearly wrong and highlights the need for an objective and independent assessment of the two alternatives.
- Traffic Until such time as the A120 new roundabout is completed the traffic impacts of a school on the BSN site would be the same as or worse than those arising from a school on the Hadham Road site (see second bullet point in previous section).
- Sports Facilities We think it is intrinsically unsuitable to have sports facilities accessible only by a pedestrian footbridge on a separate site and out of the sight of the main school buildings. The BSN site is undulating and will require terracing to provide flat playing surfaces. We have referred to the problems of community and emergency access in the last bullet point in the previous section. By contrast, the Hadham Road site is completely flat and there should be no difficulty in providing emergency or community access – after all it is immediately next to the Fire Station.
- Green Belt We acknowledge that sports facilities are a permitted exception to Green Belt development. However, the proposal will radically change the character of the landscape. Flat terraced pitches, particularly if they have all weather surfaces and floodlighting, will be quite different from the rolling pastoral scene there at the moment and will no doubt be treated by developers as an urban extension beyond the bypass, giving rise to pressure for further extensions. If changing facilities and equipment storage are provided on site they will further alter the character of the landscape. If they are not, how will the grass be cut? By contrast, no such problems arise at Hadham Road, and it is not within the Green Belt.
- Value for money We acknowledge that this is not a planning issue. Nevertheless, the question needs to be considered. Exchanging the Hadham Road site which the Council owns for the BSN site which is less than half the size, gifts to the developers a site for an additional 100 dwellings. It also involves the Council in a further outlay in acquiring the land for the sports facilities from a third party. It is hard to see how this can benefit the taxpayer. At the very least the developers should be required to surrender a site of the same size as the one at Hadham Road, which would then avoid the need for an extension into the Green Belt on the wrong side of the bypass.
23. We support the principle of providing a new 6FE secondary school on the north side of town to meet the demand which BSN and other developments will generate. However,
- The scheme will not be sufficient by itself to meet the demand for secondary school places implicit in the most recent draft of the East Herts district plan and the Uttlesford draft district plan. The County Council has not fully recognised and appears to have no plans to meet that excess demand. The release of the Hadham Road site on which the proposal apparently depends cannot yet therefore take place and the scheme is not deliverable.
- Removal of the proposed Bishop's Stortford South development from the district plan would considerably reduce the projected excess demand and might make a single 6FE school an appropriate long term solution, but the draft district plan is still a long way from adoption.
- The transport assessment contains an incorrect assumption about dwelling numbers, needs to assess separately the intermediate situation before completion of the new A120 roundabout, and needs to explain how access to the sports facilities can be made available prior to completion of the emergency access arrangements.
- The sites have intrinsic drawbacks because they are divided by the bypass and involve encroaching on the Green Belt, whereas the Hadham Road site does not. An objective assessment of the merits and value for money of the alternatives needs first to be carried out.
24. We therefore trust that, unless the application is withdrawn to remedy the defects we have identified, planning permission will be refused.
25. I am copying this letter to Cllrs Barfoot, McAndrew and Woodward, to Kevin Steptoe, Head of Planning and Building Control at East Herts Council and to James Parker, Chief Executive of Bishop's Stortford Town Council.
President, Bishop's Stortford Civic Federation