BSCF's comments on the Town Centre Study undertaken by Allies and Morrison
See here for the Old River Lane: Bishop's Stortford Planning Framework Consultation on East Herts District Council's website
East Herts Council
Wallfields, Pegs Lane
|2 December 2016|
Dear Ms Knight
TOWN CENTRE PLANNING FRAMEWORK
1. I am writing on behalf of the Bishop's Stortford Civic Federation with comments on the study recently completed by Allies and Morrison.
2. I should say at the outset that Bishop's Stortford has for a long time needed a holistic view of the town centre and how it should develop in the future to make best use of the assets and facilities we all enjoy, and to ensure that new development enhances the townscape – not something which could be said of developments we have experienced in the past. We therefore welcome the initiative of East Herts Council in commissioning this study, and believe that many of its suggestions could lead to the improvements we would like to see. For example, new pedestrian bridges over the river, and a focus on the riverside in the town centre could transform this much under appreciated asset and the town centre as a whole
3. However, as the study acknowledges, while some proposals may be capable of delivery in the relatively short term, others may depend on the co-operation of landowners who are not currently contemplating any change to their property holdings – the flour mill being a case in point.
4. We are therefore focussing our comments on matters which are within the control of local authorities and which may be achievable in the reasonably near future – traffic and parking; the Old River Lane Area, and the Station and Southern Riverside. We would like to see early action on improvements which can be readily achieved in the short term so that this study will be seen to have had a practical impact unlike similar exercises which have been carried out in the past.
Traffic and Parking
5. The study suggests (in section 2.4) that Bishop's Stortford is underperforming as a retail centre compared with other similar settlements. We suspect that the comparators chosen are not really similar. Of the towns listed on page 33, only Horsham has a similar geographical location (close to a new town and a major airport, beyond the M25 but close to London) but it also has a population some 20000 greater than Bishop's Stortford’s. We are not in the Cotswolds or a cathedral city. So suggesting that our retail floor space offer should be comparable is perhaps misleading.
6. Moreover, while prospective developments, such as Bishop's Stortford North (BSN), will undoubtedly generate a demand for more convenience floor space, we would expect this to be provided locally, rather than creating the need for much more town centre floor space, where we already have a Waitrose, a Sainsbury and an Aldi, together with an edge of town Tesco. In the case of comparison goods, we doubt whether the town, even with an enlarged population, would support a significant increase in floor space. We have recently lost our most upmarket retailers – Clement Joscelyne, Tissimans and Pearsons and lack of turnover was the major if not the only factor.
7. The study also seems uncertain as to what sort of increased retail presence it wants to encourage. If they are to be branches of major national chains then Bishop's Stortford will simply become more like every other high street. If the aim is to foster diverse independent retailers, then typically they will be looking for smaller outlets than the national multiples.
8. Finally, retail analysts do not seem to have caught up with the general population in shopping on line rather than in a store. Marks and Spencer, to name a recent example, is shedding floor space (though not in Bishop's Stortford we understand), not opening new stores. We therefore question the claim in section 4.6 that the town will need another 10000 sq m of retail floor space by 2026, especially in the town centre rather than in neighbourhood centres.
9. Our reason for discussing these issues under traffic and parking is that, to the extent that the town’s retail offer is underperforming, we think it is because potential shoppers are deterred by traffic congestion and difficulty of finding convenient parking. Sorting this out will be the key not only to making the town a more attractive shopping destination, but also to unlocking some of the other improvements suggested by the study. And so this is where we need to start.
10. At the moment the town centre road network just about works but it is easily disrupted by even mild perturbations (temporary closure of the M11 or a burst water main for example). From observation, congestion does seem to be getting worse, and not just in the peak hours so loved by transport modellers. We also have the AQMA at Hockerill which frequently breaches mandatory air pollution limits and reflects the chronic problems caused by the absence of a south east quadrant to the by pass.
11. It is essential therefore that any proposed changes to the network are modelled so that their impact can be identified both individually and cumulatively and we strongly support the recommendation to that effect in page 110 of the study. I might add that in the past we have had very little confidence in the impacts of developments on the town which Herts Highways have modelled, and hope that something both more sophisticated and plausible can be developed for this purpose. We also hope that it will enable different permutations to be tested easily and cheaply. We understand that one of the problems with Herts Highways’ SATURN model is that any change in assumptions requires a costly fresh model run.
12. Turning to specific changes proposed in traffic circulation, our comments are as follows:
- Part pedestrianisation of South Street/Potter Street
As a means of improving the environment of the main shopping street itself and rejuvenating the market, we think that this should certainly be investigated, and we would support it if it can be made to work. A system of timed entry ought to ensure that deliveries can be made to commercial premises while creating a much more pleasant shopping environment for most of the day. However, we would also like to highlight some potential difficulties. Firstly, closure actually occurred for a period some 10 years ago when the current surfaces and paving were laid. This created considerable access problems for residents in the Newtown area, Portland Road and Church Street. A permanent arrangement of this kind will need to be accompanied by satisfactory access arrangements for residents and some means of diverting through traffic on to Riverside/Adderley Road. No doubt this will be one of the issues for the proposed traffic study to try to resolve. We should also mention that temporary closure of North Street on market days was recently tried for a period so that it became a pedestrianised market area. This was not a success, and it will be important to win the support of the market stall holders for any change to the present arrangements.
- Making Dane Street/Station Road/Riverside two way
The reason that this is one way at the moment is that articulated trucks need to use both lanes to navigate the sharp bends to access the flour mill. We understand that the flour mill has no plans to move and is a major employer in the town. Whether or not two way traffic is a good idea, it does not seem likely to be capable of implementation in the near future. This will have a bearing on the next suggestion.
- A new road through the goods yard
This was first suggested by Steer Davies Gleave (SDG) some 10 years ago in a traffic study for the whole of the town which was intended to support the BSN development. Their proposals at the time were adopted by EHDC as a strategy for the town, but little if any of their recommendations have been or are intended to be implemented in spite of the fact that the BSN development has now received planning permission. More recently, Herts Highways are reported (by the Solum consortium) to be of the view that any road through the goods yard should be restricted to buses, taxis and access only, and should not be open to all traffic. We have seen no evidence for the basis of this conclusion or whether there is also an element of self interest in minimising the land take of such a road to enable more land to be released for development.
In our view, a southern access road into the goods yard is an essential precondition of any development taking place there. At present all traffic approaching the town from the south has to enter the site from the northern end to gain access to the station car parks and other facilities there. A southern access point would enable such traffic to avoid the town centre network altogether, which should improve traffic conditions at Hockerill, Station Road and South Street. Whether an all purpose through road would have additional benefits is more questionable. On the one hand it might relieve traffic congestion and air pollution at Hockerill.
On the other hand, it might simply shift the problem from the top of the hill to the bottom. Also, if the gyratory system remains one way, would the benefits of the through road (if any) be lost? These are questions which a realistic traffic model should be able to answer.
We have two other comments on the proposed through road. Firstly, SDG suggested, as you do, that this might enable the Station Road railway bridge to be closed to motorised traffic. This is a heavily used pedestrian route and an extremely dangerous crossing point. If it can be achieved we would welcome this. But at the moment it performs a useful function in allowing some traffic to avoid the Hockerill junction itself and so if it cannot be closed to motorised traffic as part of a wider revision of traffic circulation arrangements, then something else will need to be done to provide a safe pedestrian crossing over the railway. Secondly, you propose (on page 93) turning the junction between Dane Street and Hockerill Street into a walkable ’roundel’ junction. However, if Dane Street becomes two way, it will also be the continuation of the road through the goods yard and would become much busier than it is at the moment. We are not sure therefore that the two suggestions are compatible.
Conclusions on traffic circulation
13. The suggestions discussed above contain some interesting ideas which we would like to see tested in a realistic model. We would also like to make a suggestion of our own which may help to make some of those ideas more deliverable. At present the Jackson Square car park, even with an additional exit, contributes to congestion on the network because, unlike its predecessor, the entrance and exits are in the wrong places. As a result, traffic trying to leave the car park conflicts almost immediately with traffic queuing to get in. Reversing the entry and exit points, to replicate the arrangements in the previous car park, might at least help to reduce the risk of gridlock inside the car park. A more radical solution, while the gyratory system remains one way, would be to reverse the direction of the flow from clockwise to anti clockwise. The entrance and exits to the car park could then remain in their current positions. Reversing the flow would also tend to direct traffic away from the main shopping street rather than into it as happens now. We hope you will be able to consider these suggestions.
Old River Lane Area
14. We have some parking and traffic related concerns which are best dealt with under this heading rather than the previous one.
- The first point to note is that traffic conditions at the moment are not affected by the BSN development which has not started yet. So any changes in traffic management will have to be robust in the face of another 2500 homes on the northern side of town, for which Hadham Road and Rye Street will provide the main entry points (for example for commuters to the station). One of our reasons for scepticism about the traffic modelling by Herts Highways was their belief that the town centre road network could cope with this and the Henderson development without any significant changes. We remain unpersuaded.
- This means that proposals for development in this area, which involve putting more traffic on to the Link Road and Causeway, need to be treated with great caution. While improved pedestrian crossings on these roads are needed, their impact on congestion when the roads are carrying extra traffic also needs to be considered.
- Car parking is perceived to be in short supply and will become more so when BSN is completed. Any development which removes existing parking spaces will have to replace them as well as providing extra ones to cope with the enlargement of the town. Therefore, while we would be happy to see Charringtons House and 1 The Causeway redeveloped, we think that such development should be confined broadly to the existing footprint of the buildings and not encroach on to the existing public car park.
- We have an added reason for not building on the public car park. This area of land has never previously been built upon. The office buildings next to it rest on 20 metre piles (which can presumably be reused). The Link Road itself is visibly not on stable foundations. Any development on the public car park would need similar piling. The cost of doing this would encourage any developer to build to an excessive height and density to recover the outlay. This seems to have been one of the reasons for the withdrawal of Hendersons from the previous scheme for the site.
- We have similar concerns about the proposal to develop the site (currently a car park) next to the former Northgate End primary school – a locally important landmark – and to build a new multi storey car park adjacent to it, partly on the site of the existing long stay car park. Allowing development on both the short and long stay car parks will lead to a loss of several hundred parking spaces which the suggested multi storey car park will have to replace. When allowance for significant growth is factored in, how large a land area will the new car park have to cover and how many floors will it need? And what about the piling? This too is a sensitive green space which under the now withdrawn Henderson scheme was to be used as a flood compensation area. The issues of drainage and flooding will not go away, and this too suggests the desirability of less development than is proposed for the area.
- On a more positive note, we like the idea of making Old River Lane a pedestrian route with Cooper’s Yard opening into it, and improving the pedestrian environment in Bridge Street, provided that satisfactory arrangements can be made for deliveries to businesses in Old River Lane and Water Lane. We are doubtful whether any new development in the area should include a significant extra retail element. This is partly because we suspect the demand has been overstated (as discussed above) and partly because we do not want to see the retail heart of the town being dragged northwards towards the newest retail units. This would clearly have been a problem with the Henderson scheme, and the ideas now being proposed might be described as ‘Henderson lite’, rather than anything more imaginative. So further thought needs to be given to possible uses and one which has received a lot of popular support is that the two town centre GP practices might relocate here.
Conclusions on Old River Lane Area
15. We think that there are some interesting ideas for improving the attractiveness of this area, and would be happy to see Charringtons House and 1 The Causeway redeveloped on broadly the same footprint and to the same height. However, we doubt the wisdom of developing on any of the existing car parks, given that the lost spaces will have to be replaced. We also think that that not enough account has been taken of the impacts on traffic and parking of the BSN development which has not yet started, and that ground conditions are likely to make some of the development suggestions prohibitively expensive. We would therefore favour Option B of the layouts considered on page 78 of the report, and think that further thought needs to be given to the amount of and the access arrangements for any development or parking north of the Link Road, given that the need for more parking spaces has to accommodate the prospect of this road carrying much more traffic in future.
Station and Southern Riverside
16. We have discussed the traffic circulation issues in the first section of this response and do not repeat them here. We particularly like the ideas for widening and improving the Station Road crossing of the river, and the opening out of the leisure centre and cinema towards the river. We also agree that the area needs to provide some short stay car parking to replace the facility that was removed with phase 2 of the Jackson Square development. However, we are not sure what the catalyst for these improvements would be.
17. Turning to the goods yard itself, EHDC has before it a planning application for a development which is significantly different from these proposals and to which we have lodged objections. The applicants claim that there is no demand for modern office space in this area and are suggesting instead a development of nearly 700 apartments rising up to 7 floors in height, together with a hotel and some small retail units. The proposal in the Allies and Morrison town centre study is much more suitable, in scale and in mixture of uses, than the planning application, and has been largely endorsed in the recently published version of the District Plan. But the applicants will no doubt argue that anything less that they are proposing would be unviable.
18. We would like to know how the apparent conflict between the suitable and the viable is to be resolved in a way which will result in a development which the people of the town can support. As we have seen with Jackson Square, the wrong sort of development can lead to an irreversible long term adverse impact on the character of the town, and we do not want the same to happen with this last opportunity to create a major improvement. The current planning application is seriously at odds with both the study’s recommendations for this part of the town centre and with the wider vision for the rest of the town. We therefore hope that EHDC, as planning authority, will encourage the developers to go back to the drawing board with a view to producing a scheme which is consistent with this study and with the recently published District Plan.
19. Finally, the question is raised, almost in passing, about relocating the Rhodes Centre to another site to provide a bigger auditorium. We do not support this. We doubt if there is another more central location that would be suitable for the purpose, and with the development of the goods yard, and improved river crossing arrangements, the present location is likely to become a more attractive entertainment centre. So, if the auditorium needs to be enlarged, it should be on its present site.
20. We hope you find these comments helpful.