Response to housing and school proposals east of Hitchin Road

Fairfield Parish Council has today submitted its responses to proposals by Campbell Buchanan to build 180 houses and a two form entry school on land east of Hitchin Road.

The full response is as follows:

CB/16/01455 – The Parish Council objects to the proposals on the following grounds.

  • The proposals represent inappropriate and un-sustainable greenbelt development, outside of the current settlement envelope
  • The application is premature with respect to the emerging Neighbourhood Plan
  • Insufficient information has been provided to analyse the extent of highway impacts and any mitigation required
  • Impact upon highway safety, particularly at the Eliot Way roundabout
  • Inconsistency between plans submitted by the applicant and those within the supporting reports
  • Waste / effluent management systems in the vicinity are inadequate and the proposals will intensify the issues
  • Flood risk / development within

Further detail on each of these items follows:

Inappropriate & Un-Sustainable Greenbelt Development

The proposals sit outside of the current development envelope and on greenbelt land. The NPPF includes a presumption in favour of sustainable development, however this site cannot be considered as sustainable, certainly on the grounds of transport, not being within walking distance of a local train station or of employment opportunities and being served by very limited bus services, which CBC has been considering reducing further. The proposals would therefore inevitably require future residents to rely upon the private car for the majority of journeys, contrary to the aims of government guidance at a local and national level.

Paragraph 49 of the National Planning Policy Framework concerning the presumption in favour of sustainable development is being heavily relied upon to justify the proposed development but the presumption is only valid for sustainable development.

Policy TP1A of the CBC Core Spatial Strategy requires developers to show how developments will reduce the need to travel and reduce reliance on cars; the proposal fails on both counts and should be refused accordingly. Policy DPS19 requires developments to be “readily accessible by public transport, cycle and on foot…”, however the proposal site is served by limited public transport and is beyond a ‘reasonable’ walking distance from the local train stations as well as the major employment areas in Letchworth & Hitchin. Cycle routes to and from the nearest major urban areas are also sub-standard.

We believe this site is not sustainable on economic grounds. With no Community Infrastructure Levy in place there will be no contribution being paid directly to the parish to mitigate the effects of the development.  Currently, for economic reasons, it is the policy of CBC to use the New Homes Bonus to support the provision of front line services across Central Bedfordshire, and not directly in support of areas affected by development.  Provision has already been made towards a new school building following the granting of permission for the development of the former Pig Testing Unit site.

Prematurity With Respect to Emerging Neighbourhood Plan

Given that Fairfield Parish is a designated Neighbourhood Planning area and that the Neighbourhood Plan is in the process of being completed, it is considered that this application is premature and its approval would undermine and be prejudicial to the neighbourhood planning process. This is of particular importance given the significant the scale of development when considered in the context of the existing number of dwellings in the Parish. Precedent has been set for this in decisions by planning inspectors and the communities secretary in decisions such as that for a residential development in Rother District Council in March 2014 (appeal decision) and early 2015 (decision upheld by communities secretary).

Highway Impacts & Conflicting Information

The proposals provide junction capacity analysis based upon traffic surveys undertaken in 2013. At the time of these surveys only a relatively small proportion of the new homes at the ‘south of Stotfold’ (Greenacres and adjacent developments) were completed / occupied and in the meantime the majority of dwellings have been completed and occupied, therefore in order to provide a true and accurate analysis, updated survey data must be obtained. In addition to the junctions currently analysed by the applicant’s consultant, the triple mini-roundabout junction to the south of the site between Stotfold Rd, Arlesey New Rd, Wilbury HiIls Rd and Bedford Road should be analysed, as we are aware that significant peak hour queues (over 20 vehicles on the southbound approach) and delays occur at that junction and the application proposals would have an impact upon the junction.

With regard to highway safety, we have concerns with the design / alignment and use of the Eliot Way roundabout, via which the proposals will be accessed. The eastern arm of  the roundabout is currently only utilised by a small number of dwellings and those residents have voiced significant concerns over the difficulty of exiting onto the roundabout. While there is no adverse safety record at the junction, the proposed increase in traffic using the junction is significant. We ask that the applicant is required to submit an independent road safety audit for the new junction arrangements, prior to any planning decision being made. This should also account for the impact of the proposed new pelican crossing, just south of the Eliot Way junction. This crossing will be heavily utilised during peak hours, due primarily to the location of the new school and as such, queues will build across the roundabout, potentially blocking vehicle traffic seeking to enter / exit the school and the new dwellings / shop etc.

There are conflicting plans within the submissions, particularly the revised site / master plan and the plans within the Transport Assessment. The conflicts relate in particular to the proposals to provide a new footway along the eastern side of Hitchin Road, from a point just south of the Eliot Way to the junction with Dickens Boulevard, plus a proposed pelican crossing to the north of the Dickens Boulevard junction. These items are relied upon and set out in the Transport Assessment, however appear to have been removed from the latest site plans.

Vehicle trip rates for the school and the dwellings are based upon generic Bedfordshire and national rates, which can only provide very rough approximations, which we believe to be under estimating the volume of new traffic. With the development replicating the existing split of land uses within the ‘main’ Fairfield development, it would appear far more sensible and accurate to utilise trip rates derived from surveys of traffic generated by the existing housing / convenience store at fairfield and traffic / modal splits based upon the existing Fairfield Lower School.

Waste / Effluent Management & Associated Health Issues

The proposals are within approximately 150m of a sewage treatment works plant and the additional dwellings, as well as those recently permitted at the ‘Pig Farm’ scheme (a total of 310 dwellings), will all rely upon the use of that plant. There is a history of issues with the plant and associated odour issues impacting residential amenity, including very recent and in fact current intensification, ensuing complaints to CBC and NHDC. The proposals have the potential to make this situation significantly worse and with the new dwellings in such proximity to the plant, new residents would be effected as well as existing residents.

Flood Risk

Residents of nearby Stotfold have experienced flooding from the Pix Brook twice in the last 2 years. The site is bordered by the Pix Brook on the Eastern side. The site itself slopes towards the Brook, which is recognised as being in Flood Zone 3 along this edge and run off from a further 180 houses is likely to cause increased risk of such flooding. Sewage overflow is also reported as having occurred on the proposed site. The proposals could therefore result in increased flooding risk for existing and new residents.

CB/16/01454 – The Parish Council has concerns with the appropriateness of the proposed school location and it’s scale, however support the provision of this new community facility.

The school is proposed to be on the east side of the Hitchin Road, with the majority of residential dwellings in Fairfield are located on the west side of the road. This therefore requires that many children cross the Hitchin Road to attend the school and there are associated risks.

The Parish Council has asked for clarification as to why a two form entry school is proposed, when only a single form entry school would appear to be necessary. No answer has been forthcoming and therefore this over provision appears un-justified and the associated additional funding to be utilised in constructing a larger than necessary facility,  may be better allocated to additional secondary schooling facilities in the area. Should CBC be able to justify the proposed school size with forecast figures, then we would be supportive of the proposed scale.

With regard to the proposed vehicle and pedestrian access to the site, we have concerns with the design of the Eliot Way access / roundabout via which the proposals will be accessed. The eastern arm of  the roundabout is currently only utilised by a small number of dwellings and those residents have voiced significant concerns over the difficulty of exiting onto the roundabout. While there is no adverse safety record at the junction, the proposed increase in traffic using the junction is significant. We ask that the applicant is required to submit an independent road safety audit for the new junction arrangements, prior to any planning decision being made. This should also account for the impact of the proposed new pelican crossing, just south of the Eliot Way junction. This crossing will be heavily utilised during peak hours, due primarily to the location of the new school and as such, queues will build across the roundabout, blocking vehicle traffic seeking to enter / exit the school site. According to the latest site plan, this crossing appears to be the only proposed safe crossing route from the existing dwellings in Fairfield to the new school.

There are conflicting plans within the submissions, particularly the revised site / master plan and the plans within the Transport Assessment. The conflicts relate in particular to the proposals to provide a new footway along the eastern side of Hitchin Road, from a point just south of the Eliot Way to the junction with Dickens Boulevard, plus a proposed pelican crossing to the north of the Dickens Boulevard junction. These items are relied upon and set out in the Transport Assessment, however appear to have been removed from the latest site plans.

Should this application be approved, we would ask that CBC ensure that all associated highway improvement works, pedestrian crossings, traffic orders and footway works are secured by planning condition as pre-commencement items. The Transport Assessment submitted in support of the school proposal appears to be the same document as that submitted with the outline application for adjacent residential development and it is not clear what highway infrastructure / improvements are to be provided in association with each application. We are therefore concerned that the school could be approved, with no requirement for highway improvement or pedestrian safety works.