BSCF objections to planning application for multi-storey car park at Northgate End

Transport assessment referred to in this letter: High Level Review of the Transport Assessment, Northgate End Car Park Development, Bishops Stortford

Kevin Steptoe
Head of Planning and building Control
East Herts Council
Pegs Lane
SG13 8EQ
19 March 2018

Dear Kevin

Your Ref: 3/18/0432/FUL UTT/18/0460/FUL - Planning application for multi-storey car park at Northgate End: UTT/18/0460/FUL

1. I am writing on behalf of the Bishop's Stortford Civic Federation to object to this planning application. Our grounds of objection come under a number of headings.

Nature of the Development

2. It is clear from the planning statement that this application forms part of a wider plan to develop the whole of the Old River Lane (ORL) site within the boundary of Link Road, much of which is at present occupied by surface level car parking. In order to free up the main site for other uses, the car parking which would be displaced would need to be located elsewhere. Both anecdotal evidence and parking surveys indicate that availability of short stay parking spaces is limited, which causes congestion in the town centre and discourages people from shopping there, so the application aims to provide extra spaces.

3. The application therefore is an enabling development for a much larger town centre scheme, but it is being presented as a free standing application. This creates a number of problems about how to assess it.

4. We therefore believe that to look at this in isolation as a free standing application risks repeating the mistakes we have experienced with previous town centre developments which have all been sanctioned on a piecemeal basis. To take one example from the recent past, the Leisure Centre was provided with no parking because the public riverside car park was immediately adjacent. Subsequently, the Council permitted development of the site with a private car park beneath and, not surprisingly, the Leisure Centre has struggled commercially ever since. By looking at this proposal in isolation from the development it is meant to enable, this too runs of the risk of putting the wrong facility in the wrong place.


5. When the repurchase of the Old River Lane site was announced in 2015, it was said that the income generated from existing uses of the site would yield a return of 5-6% - at current interest rates a good, risk free rate of return. Since the site is now in Council ownership the timing of any development is entirely within the Council’s discretion and we would therefore expect the Council not to bring forward proposals which would add to short term disruption and may lead to inappropriate long term uses.

6. In fact we believe that there are a number of reasons for not rushing into a development which may turn out to be misconceived.

7. So if, belatedly, the Council recognises that development of ORL as a whole now runs the risk of killing the goose that lays the golden eggs, and delays any larger development for a substantial period, the alternatives to this application as a means of providing an extra 121 parking spaces rather than 581 mostly replacement spaces can be looked at afresh.

Traffic Congestion

8. Turning now to the merits of the application itself, we think that there are enough shortcomings in the proposal to justify refusal of planning permission. We reach this conclusion on the basis of a professional high level review of the assessment which we commissioned from the transport consultancy, Edwards and Edwards. A copy is attached. In summary, the main problems with it are as follows.

9. Taking these points together, we do not believe that the TA provides an adequate reflection of the adverse impact of the development while it exaggerates the benefits. We anticipate that, by concentrating all the parking entrances and exits at the same point at which the traffic from BSN converges, creating a new pedestrian flow which needs protection by a signal controlled junction, making allowance for a further pedestrian crossing to the Castle Park, and creating a new access for the ORL site, the Link Road will become gridlocked.

Air Quality

10. It is not clear on what assumptions the largely favourable report on air quality was based. Clearly if queueing traffic becomes the problem we anticipate, then pollution at the Northgate End junction could rival the levels experienced at Hockerill. For residents immediately downwind of the development, the operation of the MSP itself could give rise to unacceptable levels of pollution. It is not clear whether the consultants have given thought to or attempted to model the impact of the car park operation in addition to the traffic congestion, or indeed what assumptions they have made about traffic congestion and queueing.

Conservation Area

11. The Conservation Area Management Plan adopted by the Council identifies the whole area consisting of Grange Paddocks and Town Meads as an important open space. It recommends (para 6.143) that unless the need for small scale recreational or other community facilities are required, it is important that the site be protected from development and remains available as a diverse open space for residents of the town and visitors to the adjacent town centre. It is difficult to reconcile this recommendation with the erection on part of the site of a six storey car park, which would moreover be quite out of scale and keeping with the existing development in the adjoining area.

12. Although the Conservation Area Management Plan is silent on the ORL site, the previous development proposal by Hendersons was the subject of a review by the Urban Design Panel of English Heritage (as it then was). Having emphasised that the relationship between the ORL site and the existing town is critical, some of their comments would seem to be equally relevant to the proposals the Council are now considering. For example

‘One of the reasons the ORL indicative scheme includes very substantial blocks (which risk repeating the mistakes of Jackson Square) is that they contain very substantial and inflexible forms of development like the cinema which might better be sited elsewhere.’

‘There is a strong body of local opinion which values and welcomes the retention of the public space at the north of the site, but less audible public valuing of the supermarket car park. However, with its mature trees and outlook to the motte and to quality buildings on the edge of town, there are few better. It should only be built over after careful thought.’

‘Sites of this scale are routinely built out at one time and, whatever the conceit above ground, are in fact one building. The Panel advises that truly distinct and separate buildings should be constructed, perhaps over an extended timetable, thus allowing for flexible scheme development over time and reusability in the future.’

13. Whether viewed in isolation or as part of the wider ORL development aspiration, this application seems to be seriously at variance with the purpose of having a conservation area but all too characteristic of the past practice of East Herts Council of ignoring its own planning policies whenever it finds them inconvenient.

Alternative Parking Provision

14. As we suggest above (para 3, fourth bullet point), the preferable long term course of action would be to convert a proportion of long stay all day parking spaces in the town centre into short stay parking and relocate long stay parking to the edge of town. This would deal with the perceived shortage of spaces which deters people from shopping here and would avoid the high cost of extra town centre provision. The new car parks on the periphery would need to be supported by park and ride services, but as SDG noted in their transport strategy, such a policy requires a comprehensive plan for parking in the town and a ten year implementation period to bring about the adjustment in travel behaviour.

15. The Council adopted SDG’s strategy as their own over ten years ago but have so far not attempted to progress this part of it. Indeed they ducked the issue of park and ride when giving planning approval for BSN. So, bearing in mind SDG’s suggested timescale for implementation, some extra provision might be needed on a short to medium term basis.

16. There is of course an obvious location for these extra spaces. We suggest that all that is needed is to add extra floors to the recently provided car park on the site of No1 the Causeway. Unlike the application site, this one is wholly brownfield. As such it addresses one of the core planning principles set out in para 17 of the NPPF by reusing land that has previously been developed and is not of high environmental value. In contrast, the application site has never had on it more than surface level development (the former cattle market) and some of it is untouched green open space.

17. The No1 the Causeway site would involve no rearrangement of pedestrian or traffic flows and would place the extra spaces as close as possible to the existing retail centre. Moreover, it has retained and marked the 20 metre piles that would be necessary to support any new construction on the ORL site. By contrast, new piling would be needed on the application site. So, if extra spaces are needed for the short to medium term, this is the cheap and easy way to provide them. Two or three additional floors should be sufficient to provide the equivalent net increase in spaces. Such structures are never beautiful but it would at least simply be replacing the eyesore that was there before and, with similar dimensions, would be no more intrusive.

18. All development is meant to pass a sequential test and it is clear that with this alternative available, the application site fails it. Without the car park on the application site, there would be no obvious reason to proceed with the flats and shops, whose main purpose seems to be to hide the car park rather than being a suitable development site for such a busy junction.


19. We therefore believe that planning permission for this application should be refused. In summary our reasons are

I am copying this letter and attachment to Cllrs Warnell and Gary Jones and to James Parker and Maria Fuller at the Town Council with the request that the letter and attachment are circulated to members of the Town Council Planning Committee.

Kind regards