BSCF's Detailed Comments on Planning Application for 24 Station Road

Mr M Plummer
East Herts District Council
Pegs Lane
SG13 8EQ
11 September 2014

Dear Sirs

Planning Application : 3/14/1387
Land at 24 Station Road, Bishop's Stortford

I write with comments on the above application on behalf of the Bishop's Stortford Civic Federation ('BSCF').

The BSCF is pleased to see proposals coming in for this site which has been sadly neglected for some time. It was unfortunate that the developer's representative was unable to keep his appointment to meet with members of BSCF to discuss the proposals, although he purports to have taken on board BSCF's views.

It is unclear why the developer wishes to deviate from the previous hard-won planning permission for this site, which was granted on appeal, although it may be that financial viability is driving the current far less appealing, and presumably cheaper, design.

It is noted that responses received from Network Rail and English Heritage express serious concerns about the development. The potential for interference with the railway, both during and after construction, is particularly alarming.

The BSCF also has serious concerns about the following aspects of the proposals:

1. Traffic

2. Scale of development

3. Commercial unit

3. Impact on Conservation Area

4. Danger to railway


  1. The narrow, weight-restricted bridge connecting Station Road to the town necessitates single file traffic controlled by phased lights. Any increase may cause traffic to back up to London Road.
  2. The bridge is used by a high volume of students predominantly from Herts & Essex High School to get to the station and into town. Traffic entering/leaving the site will be a hazard for pedestrians.
  3. The development proposes parking spaces for 42 cars where currently no parking is available, resulting in a net increase in traffic to this site.
  4. It also proposes a commercial unit at ground level. Only 1 parking space is designated forcustomers and staff. Any deliveries would presumably be made at the roadside, adding to congestion and in a dangerous position adjacent to traffic lights. Station Road is currently subject to single yellow-lining.
  5. Exiting Station Road at its western end onto Dane Street via the single-file bridge requires a verytight turn which results in vehicles crossing two lanes when executing the turn. This is not adequately demonstrated by the artist's impressions accompanying the application. This junctionis unsuitable for the extra volume of traffic that would be generated.
  6. Traffic leaving at the eastern end of Station Road would exit via the harzardous junction with London Road to join traffic queuing at the notorious Hockerill traffic lights which are operating atover-capacity and which is also an Air Pollution Management Area that cannot support further increases in traffic.

Scale of Development

  1. The height of the proposed building would be 5 storeys, taller than the existing BT buildings, andthis is likely to produce a canyon effect on Station Road.
  2. Although the artist's impressions/plans1 tend to show this as flat, it is important to note that this is a raised site, sloping downwards from London Road to an elevated position with further sloping road access in two lateral directions, towards the station and towards Dane Street.
  3. The new Aldi store is located at the top of the slope. It is a single storey construction with some additions to give height and a varied roofline. Also at the top of the slope is the two-storey Thomas Heskin Court. We feel the roofline should follow the slope of the land so a massive block building of some 5 storeys at the bottom of the slope would be inappropriately large. The elevation drawings2 demonstrate how this development would tower above the Aldi store and appears taller than the existing BT and office buildings on the north side of Station Road3. Drawing 5.154 shows how the development would rise far above all surrounding buildings, including the homes on raised ground at the top of the slope.
  4. The view from the junction of Potter Street/South Street across the bus interchange and train station below this elevated site would be dominated by the sheer bulk of such a tall, solid development looming above it. The effect would be overpowering.
  5. The precedent photographs5 included in the Design & Access Statement demonstrate the developers' use of bold, urban designs in city centre settings. This is a wholly unsuitable style for the Conservation Area of a historic market town.
  6. The development proposes a flat-roof construction yet there is no precedent for this in any other residential development in the town. Again, this styling is too urban for a market town located in the Essex/Hertfordshire countryside.
  7. Other developers have been more successful in integrating modern developments into the Conservation Area by using irregular roof lines and variations in height to soften the effect. In this respect, the application previously granted planning permission on appeal was more suited to this site6.

Commercial Unit

  1. The development proposes a commercial unit at ground level. No parking is set aside for delivery vehicles which would presumably park at the roadside, adding to congestion and in a dangerous position adjacent to traffic lights. Only 1 space is designated for customers and staff!
  2. Historically, occupation of commercial units in the newer developments around the town has been very slow. In some cases, tenants are not forthcoming because the units are actually unsuitable. BSCF is not convinced a commercial unit in this location would be easy to let so could remain empty indefinitely. It is suggested that the lower storey would be better used for accommodation (so allowing a reduction in height of the development) or for additional parking.

Conservation Area

  1. This site is located in the Bishop's Stortford Conservation Area ("CA"). The proposed policy onnew development in the CA (HA4) from the District Plan Preferred Options portal is:
    "New development, extensions and alterations to existing buildings in Conservation Areas will be permitted provided that they preserve or enhance the established character or appearance of the area. Development proposals outside a Conservation Area which affect its character and setting will be considered likewise. Proposals will be expected to:
    (a) Respect established building lines, layouts and patterns;
    (b) Use materials and adopt design details which are traditional to the area;
    (c) Be sympathetic in scale, proportion, form, height and overall character to the surrounding area;
    (d) In the case of alterations and extensions, be complementary and sympathetic to the parent building; and
    (e) Conform to any 'Conservation Area Appraisals' prepared by the District Council and safeguard all aspects which contribute to the area's significance, including important views and green spaces."
    A CA is defined as an area of 'special architectural or historic interest, the character or appearance of which it is desirable to conserve or enhance'.
  2. This proposal should be considered in the context of the whole CA and what it does to 'preserve or enhance the established character or appearance' of the whole CA (not just the immediate surroundings containing other wholly inappropriate buildings ie BT offices).
  3. This view is echoed by English Heritage in its response to this application. It states 'the appropriateness of the proposed development within the CA is questionable' and considers the development would 'neither sustain nor enhance the character and therefore the significance of the CA and it would in fact be harmful'. It adds it is 'not persuaded that the design has been informed by a clear understanding of the qualities that justify inclusion of this site and its environs in the CA' and concludes the proposals would be 'harmful to the character of the Bishop's Stortford Conservation Area'7 .
  4. Moreover, the recent Conservation Area Appraisal recommends8 that views are sought on the prospect of achieving selected improvements or comprehensive redevelopment of the area defined by Hockerill Street, and London Road, the Telephone site to the south and railway to the west.' The Appraisal clearly considers the Station Road area to be a candidate for improvement,the implication being that those buildings currently in this area are not meritorious. We would suggest that incorporating a development designed to complement unmeritorious buildings would thus be contrary to the Appraisal's recommendation to improve this part of the Conservation Area.
  5. "Planning authorities should identify specific opportunities within their area for the conservationand enhancement of heritage assets. This could include, where appropriate, the delivery of development within their settings that will make a positive contribution to, or better reveal the significance of, the heritage asset".
    We could suggest that this development does not meet those criteria: it would tower over existing buildings eg Thomas Heskin Court so, rather than 'making a positive contribution', this development would completely overwhelm not just the neighbouring buildings of the Conservation Area but the surrounding area as well.
  6. The emerging Conservation Area Appraisal places emphasis on the protection of precious views and vistas. Views across the river valley from London Road to the historic 'Newtown' would be blocked by a high rise development in an elevated position.

Amenity of New Residents

  1. Although purporting to provide outdoor space for residents, the alignment of the two blocks would mean the sun would not penetrate into the garden area until late afternoon.
  2. Being adjacent to the railway line, it is unclear how residents will be protected from noise nuisance. In addition, we echo Network Rail's serious concerns about potential interference with the rail network during construction and would add our concerns about the proximity of the garden area and the safety of residents' children.

Findings of the Previous Inspector

  1. The developer quotes in its Planning Statement9 from the findings of the Inspector. However, that appeal concerned a vastly different development proposal from that before the Committee currently. The inspector's findings cannot therefore be relied upon when considering these proposals.
    Further relevant findings of the Inspector's report included:
    "The articulated front elevation proposed and the variation in height and materials across the width of the site would not produce a canyon effect in Station Road. Rather I consider that the design and materials would result in a scheme which brings interest to the street scene and which would be an enhancement of the Conservation Area. There are already 2 more monolithic buildings in Station Road which are both higher than the 2 tallest elements of the proposed scheme, and therefore I do not find that the proposed residential block would be out of keeping with the established character of this part of the Conservation Area."
    Whilst the Inspector acknowledges the site's elevated position, vieable from the town centre, she accepts that there is "room for some softening landscaping and again I consider that the variation in building height and detailing along this flank would mean that the building would be a positive contribution to the townscape at this point."
    These quotes demonstrate those features of the previous application that the Inspector found acceptable:
    - Variation in height (to reduce canyon effect)
    - Design and materials (to bring interest to the street scene)
    - Lower than existing 'monolithic buildings'
    All of which are no longer applicable to the current proposals for this site.
    Since the inspector found the previous application acceptable, there is no reason to deviate from that design.
  2. Although the developer suggests it is not 'in the interests of the public that this site remains undeveloped' and that the Council should not seek conditions or obligations that 'cause the scheme to be unviable'10, the Council should not be lured by such threats into sanctioning an unsuitable development on a prominent site in the Conservation Area. The site, albeit seeming unloved and unwanted, is low level and, as such, hardly visible to the public whose interests the developer is so keen to protect. It is more important that the Council exercises its duty to the people of Bishop's Stortford in bringing forward a development that is in keeping with the town.
    If it transpires that a housing development is unviable for reasons of site contamination and 'extraordinary build cost' due to 'being adjacent to the station'11, this merely demonstrates that the site is unsuitable for housing and should remain in commercial use, not that the Council must go to any lengths to facilitate housing.


In summary, the BSCF believes the proposals do not satisfy the following policies:

ENV1 – Design & Environmental Quality

ENV25 – Noise Sensitive Development

ENV2 – Landscaping

BH6 – New Development in Conservation Areas

LRC3 – Recreational Requirements in New Developments

BSCF welcomes the development of brownfield sites in preference to the land-grab of Greenfield sites but such developments must be tasteful, attractive and sympathetic to the surrounding property. This is particularly important when proposed developments are located in the Conservation Area, where they must 'preserve or enhance the established character' of the Conservation Area.

For the reasons set out above, BSCF objects to the planning application put forward and recommends refusal of the application currently presented.

Yours faithfully

Jill Wade
On behalf of the Bishop's Stortford Civic Federation


1 P13 Design & Access Statement Part 1; p7 Part 2, for example
2 Proposed Elevations – Drawing Nos. D12 & D14
3 P1 Design & Access Statement, Part 1
4 P9 Design & Access Statement, Part 3
5 P27 Design & Access Statement, Part 3
6 P1 & 2 Design & Access Statement, Part 2
7 P2 Letter from English Heritage dated 27 August 2014
8 Bishop's Stortford Conservation Area Appraisal para 6.101 on p48 ('Opportunities to secure improvements')
9 P13 Planning Statement para 4.8
10 P4 S106 Report
11 P13 Planning Statement