Bishop’s Stortford South, Thorley House, Whittington Way & Wrenbridge Transport Hub at St James Way

Development Management, East Herts District Council 24 March 2023

Attn: Ms Jill Shingler Sent by email

Dear Ms Shingler,

3/23/0248/VAR: Variation of condition 4 (Servicing and Delivery Plan) of planning permission: 3/22/0510/REM – Amending the wording of condition 4 to allow HGVs to travel to and from the South via all A class roads which link to the site.

I am writing on behalf of the Bishop’s Stortford Civic Federation (BSCF) to object to the above application by Wrenbridge to further vary Condition 4 of the application 3/22/0510/REM. The condition was first granted consent on 25 August 2022 and is now subject to an appeal lodged on 13 February 2023 in parallel with this application.

Condition 4 is a Service and Delivery Plan designed to prevent an estimated 208 HGV movements per day generated by the consented development using any route other than St James’s Way west to gain access to/from the A120 and M11. The variation of the wording of the condition to include a ban on HGV’s travelling south on the A1184 through Sawbridgeworth was proposed, agreed and added to the wording of the condition by Development Management Committee (DMC) members at the DMC meeting that recommended consent for the 3/22/0510/REM application.

The applicant’s grounds for revising the condition are that it does not now meet the six tests for a planning condition set out in para. 56 of the NPPF and wishes to revert to the original wording of the condition before it was amended by the DMC members. The applicant’s submissions include Counsel’s Opinion that if the variation is not approved – and Wrenbridge appeals – “it will be difficult for the Council to satisfy the Inspector that Condition 4 is necessary (the first of the six tests); and it might also be difficult for the Council to satisfy the Inspector that Condition 4 is “reasonable in all other respects” (the sixth of the six tests).”

BSCF believes that, despite the threat of an appeal, the LPA should maintain the amended wording of Condition 4 because the revision was, and remains, both ‘necessary’ and ‘reasonable’ to avoid planning harm to Sawbridgeworth and Spellbrook. Also, you should consider extending the condition to include Herts Highways’ (HH) recommendation to extend the ban to all commercial vehicles over 3.5 tonnes in their response to the application dated 20 February 2023.

Our grounds for objection to this variation are: .

The revised Condition 4 is ‘necessary’ to avoid planning harm to Sawbridgeworth

The applicant’s Planning Statement (PS) says that precluding HGVs from using ‘A’-classified roads when travelling south from, or north to the site was not the original intention of the condition but rather to ensure HGVs did not rat run through Bishop’s Stortford to get to the A10 or M11. Their Counsel’s opinion is that it is clear from documents such as the Officer’s Report (OR) to the DMC that the concern was to avoid HGVs travelling through Bishop’s Stortford to the site and that the revised condition goes beyond what is ‘necessary’ to avoid this and therefore “beyond what is required to avoid the identified “planning harm”.

In fact, the planning harm which was identified in the over 350 objections to the Reserved Matters (REM) application focused on the impact of the estimated 208 daily HGV movements – including those detailed in BSCF’s objection and presented by us to the DMC. These clearly included the impact on Sawbridgeworth and is again demonstrated by the current total of 222 further public comments on this variation – all of which are objections and almost all from Sawbridgeworth residents and their representatives. Regardless of what was agreed on the scope of Condition 4 in the OR, the community’s concern was not limited to avoiding HGVs travelling through Bishop’s Stortford. In this case therefore it was the action of the DMC – by recognising the community’s concern; identifying this gap in the original condition; and proposing the revised wording to extend the restriction to the A1184 through Sawbridgeworth – which was ‘necessary’ to avoid the planning harm.

The revised Condition 4 is ‘reasonable’ to avoid planning harm to Sawbridgeworth

The Counsel’s Opinion also advises that “it might [our emphasis] also be difficult for the Council to satisfy the Inspector that Condition 4 is ‘reasonable’ in all other respects” as required by the NPPF. This is mainly based on the view that it is “at least arguably unreasonable” to prohibit HGVs from using the alternative A-road route to/from the south, through Spellbrook and Sawbridgeworth, “having regard to the status of the route and the number of HGV movements that the scheme will generate” – implying that 208 movements per day (40% of which are in the evening and night-time) will have limited planning harm.

BSCF and the many other objectors believe that it is therefore reasonable to consider the planning harm to Sawbridgeworth and Spellbrook including:

Impacts on air quality: The Sawbridgeworth AQMA extends through the town on the A1184, less than 2 miles from the Wrenbridge site and is currently under review due to deteriorating air quality levels. The PS claims that air quality is not a reserved matter and was considered by the original hybrid application (3/18/2253/OUT) in 2018 – but acknowledging that this was based on the site being an office based ‘business park’ rather than an industrial estate generating nearly three times as many HGV’s. In fact, the applicant’s own air quality assessment – presented again with this application – assessed the impact on the AQMA’s at Hockerill Junction and London Road, Sawbridgeworth and “demonstrated ‘Moderate Adverse’ impacts”. It was noted that some mitigating measures “might be required and should be agreed through Section 106 conditions” … “to offset traffic related impacts upon the existing AQMAs”. Again, the DMC recommended that air quality impacts should be mitigated by extending the Condition 4 HGV ban to the A1184 through Sawbridgeworth.
Safety and air quality impacts on schools: We have noted before that air quality and road safety impacts of industrial and distribution centres on the health of school children has been of growing concern in recent planning decisions. Three primary schools and a major secondary school are located in Sawbridgeworth and Spellbrook fronting onto or close to the A1184 and, in Sawbridgeworth, in the AQMA.

Impact of HGV’s on resident amenity: BSCF’s objection to the original REM application highlighted the number of HGV movements trebling from 66 to 208 movements per day, one-third (68) of which are projected to be in the evening or night-time. These are more likely to use routes other than the lengthy A1184 – A120 by-pass to reach the M11 junctions 8 and 7A. The analysis showed most movements to and from the site will be via St James’s Way east dividing nearly equally north through Thorley Street and south to Sawbridgeworth. BSCF believes that the impact on this road network in this location would be ‘severe’, as defined in para 111 of the NPPF 2021, and will not comply with Policy TP1 of the now adopted Bishop’s Stortford Neighbourhood Plan. The routeing provisions of Condition 4 as recommended to the DMC in the OR were intended to mitigate the impact on resident amenity in Bishop’s Stortford. The DMC therefore recommended that it would be reasonable that the same planning harm should be mitigated by extending the Condition 4 HGV ban to the A1184 through Spellbrook and Sawbridgeworth.

An HGV ban is a reasonable way to mitigate the identified planning harm

The PS claims that, because the A1184 forms part of the Primary Road Network (PRN), the primary function of which is to carry goods and people between population centres, “an unnecessary restriction will ultimately be unsustainable and place burdensome time financial costs onto occupier and the units less attractive commercially.” They add that the NPPF emphasises that planning decisions should recognise the needs of different sectors for “suitably accessible locations” and this is “precisely the type of location this form of development should be located”.

BSCF and other objectors have consistently argued that this location, some six miles from the motorway and trunk road network, is wholly unsustainable for industrial and distribution activities compared with the original hybrid consent as a business park location. This is, in part, recognised by the applicant’s support for an HGV ban through Bishop’s Stortford. The LPA has to weigh the overall balance of planning harms and we believe it was reasonable for the DMC to require Condition 4 to extend the HGV ban to include mitigating the same harm to Sawbridgeworth and Spellbrook.

A more effective, alternative measure to mitigate HGV movement impacts such as these on the A1184 would be to seek a Traffic Regulation Order (TRO) which imposes vehicle weight and/or width limits through town centres and other sensitive areas such as AQMA’s and school environs. These are being recommended for consideration by local authorities in these circumstances (see HCL Briefing Paper 6013 on the use of TROs). Indeed, one is in place at the Hockerill junction in Bishop’s Stortford. In Sawbridgeworth and Spellbrook, the increasing demand for access to the new M11 J7A southbound to the M25 and London justifies TRO restrictions all commercial traffic except local deliveries – not just that generated by the Wrenbridge site – and would be easier to enforce.

However, if the LPA is minded to approve this variation in Condition 4, removing the DMC’s mitigation initiative – and, potentially, irrespective of the outcome of this application – we believe that a TRO should be pursued by the relevant local and highway authorities.

The restriction on HGV’s should be extended to all commercial vehicles over 3.5 tonnes

We note that since the submission of the application and the supporting Transport Note dated 8 February 2023 there has been a further significant exchange of comments and responses between Wrenbridge’s traffic consultants and HH. HH’s comments on 20 February recommend approval of the variation to remove the revised wording of Condition 4 – despite agreeing it at the DMC – but now recommends that the remaining ban on HGVs (over 7.5 tonnes) through Thorley and Bishop’s Stortford should be extended to lighter lorries and large vans (over 3.5 tonnes).

On 10 March, Wrenbridge’s traffic consultants posted a response accepting HH’s revised wording of the Condition but rejecting the proposal for extending the scope of the commercial vehicle ban to 3.5 tonnes.

BSCF notes that while a further HH response is reported as being submitted on 10 March it is not posted yet. We therefore reserve the right to comment further on this when it becomes available. However, BSCF has already objected to the REM application that, by generating more than 200 HGV movements per day plus a potentially higher number of associated lighter commercial vehicle movements, a development in this location would have an unsustainable impact on Bishop’s Stortford, Thorley and Sawbridgeworth. We would therefore support the inclusion of an extended 3.5 tonne ban as part of Condition 4, as currently recommended by HH, and it’s extension to include the A1184 through Spellbrook and Sawbridgeworth.

Conclusion and Recommendation

BSCF believes it was both ‘necessary’ and ‘reasonable’ for DMC members to add this wording to the Condition 4 to extend the mitigation of the above identified planning harms. We therefore object to the above application by Wrenbridge to further vary Condition 4 of the application 3/22/0510/REM and recommend that the application is refused. If the Condition is amended we recommend that this is limited to the inclusion of an extended 3.5 tonne ban in the condition as currently recommended by Herts Highways.

Yours sincerely

Colin Arnott

Committee Member, Bishop’s Stortford Civic Federation

stortfordcf@gmail.com

Development Management, East Herts Council 31 May 2023

Attn: David Lamb sent by mail

Dear Mr. Lamb

Ref 3/23/0681/FUL: Change of use of land and the erection of 9 dwellings, with associated landscaping, vehicular access and parking. Land At Thorley House, Thorley Street, Thorley, Bishops Stortford

I write on behalf of Bishop’s Stortford Civic Federation (BSCF) to object to the above application for two principal reasons:

Failure to provide Affordable Housing

Part of the application site formed part of the Hybrid consent granted for Area A of the Bishop’s Stortford South (BSS) development in 2019. The Masterplan for BSS indicated that this area would be developed for the affordable housing component of Area A. The current, extended, application site comprises the garden of Thorley House, Thorley Street, which was also released from the Green Belt in the East Herts District Plan 2018.

This application is for the development of eight large 4-bed houses and one 5-bed house averaging over 200m2 IFA each and set in extensive amenity space ranging between 220m2 to 850m2 per house. Since the site now extends beyond the red line boundary of the Hybrid Consent for Area A, a new full application has been submitted and the development is not limited by the parameters of the hybrid consent. The only reference to affordable housing in the Planning Statement (PS) accompanying the application now asserts in para. 4.12-13 that “the proposal does not meet the minimum threshold for providing affordable housing.”

We assume that this is based on the widely used definition of ‘major’ housing developments being those of 10 or more homes which triggers a requirement for affordable housing. However, although the policy review in section 4 of the PS shows how the development complies with District Plan housing policies HOU1 and HOU2 on housing type, mix and density, it ignores the affordable housing policy HOU3. This requires that “Affordable housing provision will be expected on all development sites … as follows: (a) up to 35% on sites proposing 10 or fewer gross additional dwellings, where the dwellings would have a combined gross floor space greater than 1,000 square metres“. Para 3.5 of the PS shows that the development proposes fewer than 10 homes but totals 1,850m2 of which 35% should therefore be affordable housing.

Other national guidance and local policies also impose site area thresholds on affordable housing provision including:

The policy review also quotes extensively from the NPPF 2021 but fails to note that the definition of major development used in the national framework (p.68) refers to housing developments of 10 or more homes or of sites greater than 0.5ha’s. This site is 0.9ha’s and is therefore a ‘major’ development requiring affordable housing.
the applicant’s policy review includes the Bishop’s Stortford Neighbourhood Plan Review (NPR) for All Saints, Central, South and part of Thorley. The NPR also adopts the NPPF definition of major development to include sites greater than 0.5ha’s. The exclusion of affordable housing also therefore contravenes the relevant Neighbourhood Plan adopted in July 2022.
The NPR Policy HDP4(b) also says that any housing development proposal “shall show how it meets the criteria and requirements set out in the East Herts Affordable Housing SPD May 2020″. This SPD, adopted after the District Plan but not referred to at all in the application, details the authority’s current affordable housing provision requirements. Paras 2.0.1-3 appears to update policy HOU3 by reverting to the ‘major development’ standard of the NPPF with para 2.0.3 concluding “the Council will not seek affordable housing contributions on sites with less than 10 dwellings unless the site is 0.5 hectares or more“.

The proposal therefore does not meet either the District Plan standard because it exceeds a combined gfa of 1,000m2 or the NPPF, NPR and SPD standards because it exceeds 0.5ha – significantly in both cases. Indeed, the applicant shows that the development space and amenity standards exceed ‘Nationally Described Space Standards’ of a minimum IFA of 124m² and 128m² for a two-storey, 4-bed and 5-bed dwellings respectively. On this basis, even minimum standards for any development of nine 4-bed homes would always exceed the 1000m2 threshold of HOU3 and require provision of affordable housing.

It is therefore difficult to understand why the applicant asserts that the proposal “does not meet the minimum threshold for providing affordable housing” without any reference to the relevant development plan policies or national guidance. BSCF is aware that recent major developments in East Herts have granted consent for housing development in excess of plan allocations but with no, or significantly reduced, affordable housing provision contrary to these policies. We believe this is detrimental to meeting the strategic housing needs of the District Plan and that the application should be refused on these grounds.

Highway Impact and Safety

A detailed design for a new access to the site from Wittington Way and a Transport Statement (TS) – as required for major developments – have been submitted in support of the application. The applicant believes that the Statement confirms that the trips generated can be accommodated on the local highway network without any significant impact on highway safety or capacity and para 3.10 of the PS concludes that “there are no substantive highway or transportation reasons why the proposals as submitted should not be permitted”

This is based on the view that Whittington Way has undergone recent highway upgrades to accommodate the BSS development including the construction of a new roundabout on Whittington Way 40 metres west of the site.

BSCF notes that Herts Highways has recommended refusal of the application because there is insufficient or conflicting information supplied to reach a recommendation on the possible implications for highway safety and convenience. Specifically, this includes:

The need to close an existing access to the site from Whittington Way;
That the proposed western junction radius will impact on the central island crossing point and the access point should be moved further to the east; and
That insufficient information is provided in the TS to assess the impact on the highway network.

We support Herts Highways refusal recommendation for these reasons, noting in particular that both the highway design and the impact assessment are based on a TS which adopts the severely flawed Transport Assessment parameters of the BSS development carried out some seven years ago. The cumulative impact assessment should be updated to take account of significantly increased flows around the site; three additional unplanned junctions from Area A of BSS on to Whittington Way; and to assess the impact of an additional access to Whittington Way between the junction with Thorley Street and the new roundabout at Bishop’s Avenue on the capacities and operational safety of these junctions.

For these reasons we therefore ask that you refuse permission for this application

Yours sincerely

Colin Arnott

Committee Member, Bishop’s Stortford Civic Federation

stortfordcf@gmail.com

www.stortfordcf.org.uk

Development Management, East Herts District Council 27.03.2023

Attn: Ms Jill Shingler Sent by email

Dear Ms Shingler,

Our grounds for objection to this variation are:

The revised Condition 4 is ‘necessary’ to avoid planning harm to Sawbridgeworth

The revised Condition 4 is ‘reasonable’ to avoid planning harm to Sawbridgeworth

BSCF and the many other objectors believe that it is therefore reasonable to consider the planning harm to Sawbridgeworth and Spellbrook including:

Impacts on air quality: The Sawbridgeworth AQMA extends through the town on the A1184, less than 2 miles from the Wrenbridge site and is currently under review due to deteriorating air quality levels. The PS claims that air quality is not a reserved matter and was considered by the original hybrid application (3/18/2253/OUT) in 2018 – but acknowledging that this was based on the site being an office based ‘business park’ rather than an industrial estate generating nearly three times as many HGV’s. In fact, the applicant’s own air quality assessment – presented again with this application – assessed the impact on the AQMA’s at Hockerill Junction and London Road, Sawbridgeworth and “demonstrated ‘Moderate Adverse’ impacts”. It was noted that some mitigating measures “might be required and should be agreed through Section 106 conditions” … “to offset traffic related impacts upon the existing AQMAs”. Again, the DMC recommended that air quality impacts should be mitigated by extending the Condition 4 HGV ban to the A1184 through Sawbridgeworth.
Safety and air quality impacts on schools: We have noted before that air quality and road safety impacts of industrial and distribution centres on the health of school children has been of growing concern in recent planning decisions. Three primary schools and a major secondary school are located in Sawbridgeworth and Spellbrook fronting onto or close to the A1184 and, in Sawbridgeworth, in the
Impact of HGV’s on resident amenity: BSCF’s objection to the original REM application highlighted the number of HGV movements trebling from 66 to 208 movements per day, one-third (68) of which are projected to be in the evening or night-time. These are more likely to use routes other than the lengthy A1184 – A120 by-pass to reach the M11 junctions 8 and 7A. The analysis showed most movements to and from the site will be via St James’s Way east dividing nearly equally north through Thorley Street and south to Sawbridgeworth. BSCF believes that the impact on this road network in this location would be ‘severe’, as defined in para 111 of the NPPF 2021, and will not comply with Policy TP1 of the now adopted Bishop’s Stortford Neighbourhood Plan. The routeing provisions of Condition 4 as recommended to the DMC in the OR were intended to mitigate the impact on resident amenity in Bishop’s Stortford. The DMC therefore recommended that it would be reasonable that the same planning harm should be mitigated by extending the Condition 4 HGV ban to the A1184 through Spellbrook and Sawbridgeworth.

An HGV ban is a reasonable way to mitigate the identified planning harm

The restriction on HGV’s should be extended to all commercial vehicles over 3.5 tonnes

Conclusion and Recommendation

Yours sincerely

Colin Arnott

Committee Member

Bishop’s Stortford Civic Federation

stortfordcf@gmail.com

View planning application

Update on Planning Permission Given 10.08.2022

You’d be forgiven for having missed it but on 10^th August Wrenbridge were finally granted permission for their revised Industrial and Distribution Park planning application at Bishop’s Stortford South. A specially convened East Herts Council Development Management Committee in the middle of the holiday season was obviously considered a good time to bury bad news.

And it was always likely to be bad news because Wrenbridge had bought the site with the benefit of a so-called Outline (in principle) permission granted to Countryside in 2019 allowing them to choose from a ‘menu’ of potential office, technology, industry, distribution, and showroom uses. EHDC still have to explain why they granted outline consent for such a wide range of employment uses on a site which was allocated in the District Plan and masterplanned by Countryside as a ‘Business Park’ providing nearly 1000 jobs in offices and technology businesses.

Wrenbridge originally applied in 2021 for what was clearly a Distribution or ‘Logistics’ Park but withdrew the application after Herts Highways agreed with nearly public 500 objectors that it would have unsustainable traffic and environmental impacts and recommended refusal. Wrenbridge then undertook an extensive consultation with the Councils and objecting groups and individuals and came back in March 2022 with a revised application, now described as an ‘Advanced Industrial Estate’. The design and layout were improved but is still single storey ‘sheds’ for industrial and distribution use – but no use for businesses requiring the multi-storey Office or Research space that was originally planned.

Bishop’s Stortford was poorly represented at the meeting. Of the EHDC ward councillors for the area, only Cllr John Wylie appeared and spoke against the loss of the planned Business Park and the traffic impacts. The Town Council were not represented and had already responded that the Council had no objections to the application. There are only two Development Management Committee members from Bishop’s Stortford – one of whom one was absent – while none of the substitute members was from Bishop’s Stortford. Sawbridgeworth was better represented by committee member Cllr Ruth Buckmaster who led on objections from the committee and the Town Council attended but was not invited to speak.

With limited notice of the meeting given to around 150 organisations and individuals who objected to the revised application, the Federation took up the only available public speaking slot at the meeting to put forward our objections and those of individuals and organisations we had consulted with including resident associations and the Parish and Town Councils. Bishop’s Stortford Climate Group also separately e-mailed DMC members directly before the meeting objecting to the failure to address climate change policies and impact issues.

Our presentation focused on the traffic impact which the application failed to make clear would generate 208 new HGV movements per day – of which 68 will be at night – and that most of these will not use the by-pass but will turn north through Thorley Street towards the town and south to Sawbridgeworth to get to the M11 junctions. This would even higher if the proportion of distribution and storage uses increased and, as long as this use is included in the application there is nothing to prevent all of the space being used for that purpose. We were also the only objector to point out that the replacement of a Business Park with industrial and distribution uses provides 20% less space and 50 -75% fewer jobs – significantly reducing the economic benefits which justified allocating the area for employment uses in the District Plan and the Masterplan in the first place.

East Herts planning officers acknowledged most of the objections raised but recommended approval mainly on the grounds that the industrial and distribution uses complied with the 2019 Outline consent and conditions could not be changed now – including a condition we proposed to restrict night-time working and deliveries. They also tried to restrict discussion on the impact of HGVs because Herts Highways had withdrawn their earlier objections and it was no longer a ‘relevant matter.’

In fact, it was Wrenbridge who recognised the strength of public opinion on the impact of HGVs -offering more concessions to traffic objections than EHC planners. The company themselves proposed a planning condition for a ‘Framework Servicing and Delivery Plan’ to restrict all HGV movements trying to access the M11 or the A120 to the by-pass. The condition tries to impose HGV route monitoring on companies occupying the development. Most of the Committee discussion was then about how companies would be expected to monitor delivery routes used by drivers following sat-navs directing them to much shorter routes. There was also a long debate about how enforceable a condition was which used planning enforcement procedures which rely on residents reporting drivers who do not turn north on to St James’s Way. Planning and legal officers responded that these were the only powers now available to them and the application was approved by the Committee with a rewording of the condition on routing through Sawbridgeworth.

So, have all the objections and petitions had any effect? Wrenbridge did respond with a better consultation campaign than most developers in Stortford and now claim to be developing an Advanced Industrial Centre rather than a Logistics Park with a significantly improved design and the proposal to manage HGV impacts. But the development simply remains the wrong use in the wrong place. The failure is with the planning process and, with no restrictions on the uses permitted, it remains to be seen what type of industrial or distribution businesses we actually get. This was always likely to be the outcome when, three years earlier, the planning authority granted a very open-ended Outline consent meant to encourage developers to maximise the amount of development while minimising contributions to mitigating its impact.

Colin Arnott BSCF

Objection to planning application 12th July 2022

Development Management
East Herts District Council
Wallfields
Pegs Lane
Hertford SG13 8EQ

Attn: Ms Fiona Dunning Sent by email

Dear Ms Dunning,

Ref 3/22/0510/REM: RESERVED MATTERS APPLICATION BY WRENBRIDGE LLP FOR E(g)(ii), E(g)(iii),
B2 and B8 USES AT BISHOP’S STORTFORD SOUTH

I write on behalf of BSCF to object to the above application described by the applicant, Wrenbridge
(FREOF V Bishops Stortford) LLP (‘Wrenbridge’) as an application for:
“Approval of reserved matters for layout, scale, appearance and landscaping of 3/21/1749/VAR
(approved under outline planning 3/18/2253/OUT) for E(g)(ii), E(g)(iii), B2 and B8 uses including
servicing, landscaping, means of enclosure and associated works and infrastructure.”
Summary and Recommendation
We have reviewed the key planning, transport and other documents submitted in support of the
above revised application and responded to the consultation dialogue offered by Wrenbridge and
the local planning and highway authorities on our comments at the BSS Steering Group. However,
we remain of the view that proposed development still does not comply with the Outline consent
parameters and is not sustainable in economic, environmental or social terms. The main issue
remains that the Reserved Matters application for industrial and warehousing use does not comply
with the Outline Consent which was based on office based Business Park use parameters set by
local plan employment policies, the BSS masterplan and the Outline Consent. E(g)(i) office-based
business park uses are omitted from the current revised application.
The revised development is now presented as an ‘Advanced Industrial Estate’ targeting B2, E(g)(ii)
and (iii) users but – while the application will still potentially have a significant B8 distribution
component – we have objections to the transport assessment and impact including:
• The need for a revised assessment of transport impact with an appropriate ‘Worst Case’
Scenario considering and presenting a B8 distribution use scenario as the ’worst case’. A
Business Park cannot be considered as a worst case because Wrenbridge are not applying
for such a use.
The TCS shows that even an Advanced Industrial Estate will have an unsustainable transport
impact. Compared with the Outline consent for a business park, HGV movements treble from 66 to
208 movements per day, one-third (68) of which are projected to be in the evening or night-time –
and if used for distribution operations, HGV movements will be significantly higher still. The impacts
on the road network would be ‘severe’ as defined in para 111 of the NPPF 2021 and will not comply
with Policy TP1 of the emerging Neighbourhood Plan.

Moreover the use of the site for industrial or distribution purposes – compared with the permitted
office-based business park use – will also be unsustainable in economic, environmental and social
terms as defined in the NPPF including:
Economic and Employment Impact: The loss of the site as a Business Park and it’s
replacement by an industrial and distribution development has now reduced the effective
area allocated for employment use from 21,000m2 to 16,770m2 and the expected 900-1,000
new, mainly office, jobs to 251-466 mainly industrial jobs. This is 20% less space generating
50 -75% fewer jobs – a significant underutilisation of the District Plan allocation of the second
largest employment area in East Herts at BSS. The revised application therefore does not
comply with key parameters of the Outline Consent or with Policy DPS1 on maximising
opportunities for jobs growth. The type of jobs created also does not match the needs of the
local labour market – drawing in a wider commuting workforce and failing to meet the NPPF’s
economic objective for sustainable development.
Other Social and Environmental impacts are contrary to the NPPF’s social objectives for
sustainable development – Though some of the environmental impacts have been mitigated
by design and layout improvements, most of the potentially severe impacts on the built
residential environment and local road network remain and there are clearly unsustainable
impacts on the health and well-being of existing and new residents and on schools –
principally the result of the impact of HGV’s on air quality and noise.
For these reasons we continue to object to the revised Reserved Matters application and respectfully
request that approval of it is rejected.
A detailed analysis of the reasons why this application should be rejected is attached.

Yours sincerely
Colin Arnott
Committee Member
Bishop’s Stortford Civic Federation
stortfordcf@gmail.com
www.stortfordcf.org.uk

Overview

Many people will know that the most controversial aspect of the Bishop’s Stortford South development of land released from the Green Belt for housing and schools was last year’s planning application by Wrenbridge for development of the large, 3.5 hectare, area of ‘Employment Land’ at the south-east corner of the site. The 500 public objectors who wrote to East Herts Council – and many more who signed a petition raised by local residents – therefore welcomed Wrenbridge’s withdrawal of the application for nearly 20,000 m2 of what appeared to be large distribution and storage sheds when it seemed likely to be refused. The main objection was to the large number of HGV and other lighter commercial vehicles these ‘logistics’ operations will generate and the expectation that they would rat-run through the centre and south-east of the town to get to M11 Junction 8 and through Sawbridgeworth to the new Junction 7A instead of making the 6-mile trip round the by-pass. There was also concern about the noise, air quality and visual impact on the adjoining new housing, care home and existing Thorley Street communities. It was simply the wrong place for such a development.

Moreover, it was not what was promised when Bishop’s Stortford South was planned and released from the Green Belt. The allocation made in the District Plan – and assessed when the Outline (‘in principle’) consent was granted in 2019 – was for a Business Park of mainly office buildings expected to generate nearly 1000 new jobs needed in the area, parking and public transport would be provided and HGV and other commercial traffic would be minimal. However, in a careless wording which the local planning authority will still have to explain if this development goes ahead, the Outline consent actually granted was for any mix of employment uses including a Business Park but also industrial and distribution uses – or a Car Showroom for good measure!

Having bought the site with the benefit of this broad definition of employment use, Wrenbridge are now back with an amended application submitted in March following an extensive and well organised public consultation campaign. The design and layout of the buildings has been improved and some of the units have been made more suitable for small businesses in what is now described as an advanced manufacturing and service estate. However, with the growth of internet shopping and home deliveries, logistics site values are higher than for housing and hard to find so, not surprisingly, Wrenbridge have again included distribution uses in their application whilst omitting the Business Park office uses originally planned.

A revised assessment now shows that the traffic impact of a modern industrial estate will be significantly greater than a Business Park. Although total vehicle movements are less than originally estimated – mainly in the peak commuting hours – the number of HGV movements trebles to 208 movements per day and 68 of these will be in the evening or night-time. Moreover, if most of the development is used for distribution operations, HGV movements will be significantly higher still – and the previous application suggested 40% of these would be between 11pm and 7am. At the moment Wrenbridge is presenting a Business Park as a ‘worst case’ because total vehicle movements (mostly cars in the peak hours) are higher – even though they are no longer applying for that use. Yet the community’s main concern is with HGV and other commercial vehicles throughout the day and night and BSCF believes that use as a Distribution Centre should be assessed as the worst case – a use that is still being applied for.

Even if the use is as a modern industrial estate, the assessment also confirms residents’ concerns that HGV’s and other traffic are more likely to use routes other than the lengthy by-pass to reach the M11 junctions. The analysis shows that, although a proportion of the trips to and from the site use St James’s Way west, most movements will be via St James’s Way east. 55% of these then turn north through Thorley Street and 45% south to Sawbridgeworth. Again, the proportion of these which is HGVs would be significantly higher if the main use is as a Distribution Centre.

Finally, the justification for removing the site from the Green Belt was the limited availability of large sites which were critical to achieving the job growth required by the District Plan. The land at Bishop’s Stortford South is the second largest employment site in the District Plan and was allocated specifically to accommodate a 21,000m2 Business Park generating 900-1000 mainly office jobs. Wrenbridge acknowledges that its use as an Industrial estate – now reduced to 16,770m2 of single storey ‘sheds’ – is expected to generate only 251-466 jobs. That’s 20% less space generating 50 -75% fewer jobs – a significant underutilisation of the District Plan allocation.

For all these reasons BSCF will still urge the East Herts Council, as the local planning authority and Herts CC as the Highways Authority to recommend refusal of the revised application.

Colin Arnott

28-04-22

Update on Planning Permission Given 10.08.2022

Objection to planning application 12th July 2022

Overview

The Goods Yard