BSCF letter to EHDC on two Goods Yard redevelopment planning applications
3/16/0530/OUT: Hybrid application for up to 682 residential units...
3/16/0707/FUL: Planning application for surface level car parking
Design and Access Statement (Solum Regeneration): Design and Access Statement - detailed plans
East Herts Council
|30 April 2016|
BISHOP'S STORTFORD STATION GOODS YARD DEVELOPMENT PROPOSALS
YOUR REFS: 3/16/0707/FUL AND 3/16/0530/OUT
1. I am writing on behalf of the Bishop's Stortford Civic Federation to make comments on these two planning applications.
2. I should say at the outset that the Goods Yard site has been an eyesore for far too long, and that the Civic Federation welcome the principle of development taking place there and we are happy with the suggested mix of uses. We also recognise that Solum have made considerable efforts to engage with the local community, including the Civic Federation, in working up their proposals, which makes a welcome contrast to our experience of the approach of some other developers.
3. This makes it all the more disappointing that we do not feel able to support the applications in their present form. Our reasons are set out in the rest of this letter and, I might also say in passing, that although over 200 documents have been supplied, the applications are both difficult to follow and appear to be silent on a number of important issues.
Phasing of the Scheme
4. Our view (supported by Herts Highways) has always been that no development should take place on the site unless provision of a southern access point is provided for vehicles. At present, all traffic approaching the station, either for pick up and drop off or for parking, has to gain access from a northern part of the site even when approaching from the south. This traffic unavoidably joins the most congested part of the road network and in particular the approach to Hockerill cross roads. This junction has recently been reported as suffering the worst air pollution in the County with nitrogen oxide emissions regularly reaching up to double the legally permissible maximum.
5. As a result, an Air Quality Management Area (AQMA) has been established at the junction, although there is no sign of any attempt being made by our local authorities to do anything actually to manage the air quality. However, one management action which clearly can be taken by East Herts Council is to refuse planning permission for any development which might be expected to make the already illegal level of air pollution even worse.
6. A southern access point on to the goods yard site would clearly have a beneficial impact because traffic approaching the station from the south would then be able to avoid this critical part of the road network altogether. Without it, any development is likely to generate more traffic and worsen the current unacceptable situation.
7. These applications do indeed contemplate a southern access road for parking, for residents and for public service vehicles, and this is very welcome. The problem is that this route would not become fully operational until phase 4 of the scheme is completed. Prior to that, the plans contemplate completion of the hotel, retail units and 462 dwellings in the first three phases. The last phase of the scheme cannot be commenced until Network Rail agrees to release the sidings which they are currently using. While the application suggests that each phase of the scheme will take 18 months to complete, there is at present no certainty about the timing of the last phase and, until then, the first three phases will lead to an unacceptable increase in traffic congestion and air pollution. Network Rail is a joint partner in this development proposal and presumably has a financial interest in seeing it completed as quickly as possible.
8. We therefore suggest that commencement of any development on site should be conditional upon Network Rail providing a binding date by which it will have vacated the sidings so as to release and, if possible, bring forward phase 4 of the scheme for development.
Traffic Impacts of the Earlier Phases
9. We appreciate that with a site of this complexity, development will have to be phased, but we do have additional concerns about the traffic impacts of the intermediate phases of the scheme which do not appear to have been modelled.
10. Firstly, the scheme contemplates replacing the two entry and exit points into the station car parks with one – using an improved and widened Anchor Street as the only point of entry. Not only will this have to meet the needs of all the existing station traffic, it will also be used to serve the additional traffic generated by the hotel and 462 apartments. Although queuing times into and out of the existing car parks are claimed not to be a problem at the moment, we think that that it certainly will become an issue when all the traffic is concentrated on one point and has to serve the new development as well.
11. Secondly, the impact of construction traffic during the development seems to have been overlooked. Although a partial southern access route to the site is identified in the earlier phases of the scheme, this is described in the application as being for pedestrians and buses only. In our view, if construction traffic is to be road based, rather than using the railway as we would prefer, it is essential that all of it uses this route so as to avoid the town centre road network. This part of the network is already subject to an HGV ban (except for deliveries) in recognition of the inability of the network to handle unrestricted traffic of this nature. If construction traffic is allowed on to the town centre network the congestion and pollution effects will be intolerable while the effectiveness of the HGV ban will be undermined.
12. In our view, provision of only 0.6 spaces per residential dwelling is inadequate. While the nature of the accommodation and its location, and the provision of some kind of car club, may reduce car ownership among flat dwellers, the district generally has one of the highest levels of car ownership in the country. Even if not car owners themselves, the people living in the apartments may well be visited by car owners. Where are they to park? The provision for commuters looks barely sufficient to keep pace with demand. If there is not enough car parking provided on site, the demand will spill out on to the surrounding road network as it already does with commuter traffic.
13. Another potential demand which seems to be left unsatisfied is parking for the general public rather than commuters. When the leisure centre was built, no car parking was provided on the grounds that the Riverside car park was available. With the completion of Jackson Square, parking there has become private, and so there is no suitable parking to serve the leisure centre which may help to explain its struggle to succeed commercially. We therefore consider it essential that some of the new provision should be made available for short stay users. At present, there is no parking provision for vehicles entering Stortford from the south. Cars need to be driven through town to the car parks on the north side of town. This is a golden opportunity to provide car parking provision on the south side of town.
Station Road Steps
14. We are pleased that the need to improve this crossing point at both the top and bottom of the steps has been recognised. We note from figure 3.11 of the transport assessment that there have been several accidents in the area. With one JMI school, three secondary schools and the Herts and Essex hospital all lying to the east of the railway line, this is a major pedestrian route across the railway and is heavily used by children. Unfortunately, the designs accompanying the application are unclear as to exactly what improvements are proposed and whether they will be sufficient to mitigate the risks the junction creates.
The Bus Station
15. Paragraphs 5.17 – 5.19 suggest that, from observation, the maximum occupation of buses at the station is only four vehicles and that even this is momentary. The application therefore proposes reducing the size of the bus station to four stands with two additional drive through stops outside the railway station. However, although this section of the assessment notes that there are a number of Thursday only services, the counts of bus station occupancy were made on a Tuesday and a Wednesday. The Thursday services are operated to provide a service from the outlying villages to Bishop's Stortford market and several of the buses lay over at the bus station until they are due to make their return journey. I attach two photos of the bus station taken at about midday on Thursday 28 April showing six and seven buses in the bus station – three of them being in the lay over bays. While it may be argued bus lay overs are not the best use of town centre land, the extra mileage involved in parking on an out of town site may affect the viability of the services which in turn could have an adverse impact on market traders.
16. Moreover, Meyer Brown will be familiar with the claims made for Bishop's Stortford North that, thanks to their proposed green transport initiatives, the new bus service for that site will be very well used, and space in the bus station will need to be found for it. It therefore seems to us short sighted in the extreme to provide only for the supposed current maximum requirement at the bus station, particularly as the maximum requirement has been under reported. It also leads us to wonder whether other aspects of traffic congestion and the operation of the road network have been similarly misrepresented.
17. We were astonished to read in paragraph 4.31 of the transport assessment that traffic has reduced in the morning and afternoon peaks at Hockerill junction since this is not an experience confirmed by personal observation. Perhaps the problem is that the assessment focuses only on the conventional peak hours. As it acknowledges, peak use of the station car park falls outside the conventional peak hours. Moreover, the opening of the Aldi store in London Road has dramatically worsened congestion at various times of day, even on Sundays, which do not normally feature in transport assessments. The impact of the store on traffic congestion was not anticipated by Herts Highways who agreed that it would be no worse than the site’s previous use as a car showroom and garage. They have since agreed that the expansion of the store’s floorspace and parking bays by over 30% will lead to an improvement in traffic circulation. That optimistic assumption will be put to the test in the near future when the alterations are completed.
18. In the meantime, given the level of congestion at Hockerill and the status of the AQMA, we suggest that an assessment of the impact of this proposed development should be extended to cover other times in the day which also give rise to congestion, such as the school run. It might be prudent to run a sensitivity test based on a greater level of traffic generation by the development than the assessment has assumed. And any endorsement of the results by Herts Highways should be treated with extreme caution.
Demand for School Places
19. This is another issue on which the application is silent. It seems to be an illusion among planning officers and developers that occupation of flats has a contraceptive effect, leading to child free households. Unfortunately, the house price inflation experienced in Bishop's Stortford means that, however much people starting a family would like to do so in a house, they often cannot afford to move into one. The developers will no doubt hope that the issue can be resolved as far as they are concerned by a S106 payment. However, money will not buy places if our schools are not physically capable of being expanded.
20. We would therefore like to know how much demand for school places the development is expected to generate, whether the generation factor is one which has been agreed with the County Council and, particularly for JMI places, whether the schools nearest to the development will be capable of expansion sufficient to accommodate the increased demand.
Scale and Appearance of Development
21. We have said before and repeat here that the maximum height of the development should be limited to 5 storeys, with lower height development as proposed nearer the river. This will lead to a reduced number of flats, but we feel that, in any case, the density proposed of 117 dwellings per hectare (as measured by the total site area) may be appropriate for a city location but is too high for a market town like Bishop's Stortford. While East Herts may be anxious to close the gap in its five year supply of land for housing, even a reduced number of flats would still represent a substantial increase over the 200 dwellings allocated to the site in the draft District Plan.
22. Planning and development are not simply abstract methods of achieving housing targets. They result in the creation of communities. The character of Bishop's Stortford as a community has changed markedly as a result of previous town centre developments and these proposals would more than double the number of flats in the centre of the town. Large developments of this kind tend to have more transient populations who may have less of a stake in the future of the town and its attractiveness as a place to settle in for the longer term. A reduced number of dwellings may therefore make a better contribution to community cohesion.
23. The site is one of the last opportunities to make a positive virtue of the benefits of the river as an attraction rather than something to be hidden away as has occurred in the past. The proposals do make a positive contribution in setting the building line back from the edge of the river and creation of public open space. But we think that more could be done, given that this appears to be the limit of the public realm improvements being considered. In particular, we would hope that there would be an opportunity to provide some serviced temporary moorings for boats, and provision of a pub or café at the millennium bridge might add some vitality to the area and complement the development on the other side of the river.
24. Finally, we have concerns about the appearance of the buildings themselves. This development will provide the gateway to Bishop's Stortford for all those using public transport and we would like to see buildings of real distinction. The trouble with the elevations accompanying the application is that they look exactly what they are – computer generated images created with too little evidence of human intervention. Moreover, if the hotel is a standard Travel Lodge slab, it will mean that the most prominent building on the site is one that would normally be seen beside a motorway junction rather than at the edge of an historic town centre. We know it is difficult to capture, but we would like to see a development that generated some excitement in its appearance.
25. We have suggested to the developers that it would help decision makers to appreciate the impact of their proposals if they were to create a three dimensional physical model of them (as happened with Jackson Square) and we hope that you will encourage them to do so before the application comes forward for decision.
26. Some of our concerns might be allayed by reducing the height of the buildings and the number of flats. But regrettably, in its present form, we do not feel able to support this application. Too often in the past the town has suffered from an attitude that any development will do. However, in this case, we feel that the importance of getting it right means that a decision should not be taken until we are all satisfied that what finally emerges is the best that can be achieved. We imagine that your own inquiries will take some time and therefore suggest that no decision should be taken in advance of the completion of the town centre study which the Council have recently commissioned. We shall all want to be assured that the proposals complement what is intended for the rest of the town centre.
27. I am copying this letter to James Parker, Chief Executive of Bishop's Stortford Town Council.
Reply from the Planning Department at East Herts District Council. Top
BSCF response to the letter of 13 October 2016 (see immediately above) from the Planning Department at East Herts District Council Top
East Herts Council
|16 October 2016|
BISHOP'S STORTFORD STATION GOODS YARD DEVELOPMENT PROPOSALS
YOUR REFS: 3/16/0707/FUL AND 3/16/0530/OUT