The Hertfordshire County Council Highway Authority has reviewed the Bengeo Nursery development and recommended refusal of the current proposal. Their objection centres round 2 areas:
- Insufficient space for waste collection lorries
- Poor consideration given to access for pedestrians and cyclists
Their full assessment of the proposals can be viewed below.
The area of Bengeo Nursery, and the surrounding land, have been earmarked by the District Plan for the construction of 150 homes. This was considered necessary to satisfy housing demand in the area up until 2031.
This development would see 44 houses and 8 flats built on the site of Bengeo Nursery.
Assessment from HCC Highways Authority
Proposal
Demolition of garden nursery and the erection of 52 dwellings including access, parking, amenity, public open space and tree protection measures.
Decision
Notice is given under article 18 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 that the Hertfordshire County Council as Highway Authority recommends that permission be refused for the following reasons:
Application: EH/621/2019 District Ref: 3/19/1826/FUL Site: Former Bengeo Nursery Sacombe Road, Hertford
Decision
Notice is given under article 18 of the Town and Country Planning (Development Management Procedure) (England) Order 2015 that the Hertfordshire County Council as Highway Authority recommends that permission be refused for the following reasons:
- There is insufficient width of carriageway shown on the layout plans within the site layout plan for waste collection vehicles in current use to turn around and to leave in a forward gear. This would be prejudicial to general provisions of highway safety and convenience and contrary to National Planning Policy Framework and not in accordance with Roads in Hertfordshire Highway Design Guide and minimum turning provision within developments contained within the Manual for Streets.
- The proposal, due to poor pedestrian and cycle permeability across and to and from the site, conflicts with pedestrian and cyclist safety and the ability to encourage walking, cycling, use of public transport and reduce the reliance on the private car as represented in national and local policy. Contrary to the National Planning Policy Framework and Policy 1 of Hertfordshire’s 4th Local Transport Plan.
Description of the Proposal
The subject site is located within the East Hertfordshire District Council area.
This is a full application for demolition of garden nursery and erection of 52 dwellings.
History
The Highway Authority has provided an informal pre-application advice in June 2018 under EH/348/2018 for an outline application for up to 50 units.
Analysis
The applicant has provided a Transport Statement and Travel Plan Statement for review as part of the application package. This is considered sufficient and in line with the requirements of the Roads in Hertfordshire: Highway Design Guide 3rd Edition, Section 1: Policy Information and General Guidance, Chapter 7: General Requirements for Transport Assessments, para 7.3 of the Roads in Hertfordshire Guidance.
Site Description
The site is located on land east of Sacombe Road in Bengeo. It is an existing plant nursery and agricultural land site located at the northern extent of the Bengeo urban area, adjacent to Sacombe Road.
The section of Sacombe Road along the frontage of the site is an unnumbered classified road and is currently subject to the 30mph speed limit.
Sacombe Road has a single, undivided carriageway approximately 5.5m wide with a single lane of traffic available in places. A pedestrian footway, albeit very narrow is provided along the western side of Sacombe Road.
Vehicle Access
The submitted drawing shows the application site will be served via an upgraded vehicle access from the Sacombe Road.
The visibility of 2.4m x 43m from the access as shown in Appendix G of the TS is not in line with the Manual for Streets (Fig 7.18) standards, which require it to be measured up to the kerbline. The Highway Authority is however satisfied that adequate visibility can be achieved from the access within land under the control of the applicant or land within the adopted highway, maintained by the Highway Authority. The details can be secured by a planning condition.
Internal Road Layout
Within the application submission there is a Layout Plan drawing number 18/017/SK001P5, this shows a principal access road that will form the main vehicle access to the development with connections to a system of cul-de-sac access roads. This has been tested with a swept path analysis of a large waste collection vehicle, shown on the Waterman’s drawing number 15509-WIE-ZZ-XX-DR-C-05004 revision A01.
Appendix L illustrates the Waste Collection Strategy. Some of the dragging distances to the Bin Collection Points around various locations of the housing layout exceed the recommended maximum standard of 25m contained in the Roads In Herts Guidance (Para 6.8). The East Herts Waste Collection services would ultimately need to be satisfied with the proposed arrangement.
The tracking of a refuse shows that it will overrun or oversail the footways and common areas across the site. It also fails to take into account any vehicles parked in the road. Para 9.2 of the Roads in Herts also states that where on-street parking is likely to occur, the carriageway should be a minimum of 5.5m wide. The internal road layout shows that the roads will be less than 5.5m and since no parking controls will be in place parking cannot be easily controlled and will result in vehicles parking on roads obstructing access for refuse and footways obstructing pedestrians.
The tracking of a refuse does not take into account on street parking on the western side of Sacombe Road. At least two publicly available parking spaces would need to be lost to accommodate turning manoeuvres of a refuse vehicle.
Given the problems with refuse vehicle tracking and the width of the internal roads to accommodate manoeuvring space for waste collection vehicles, the proposed development fails to meet the requirements for waste storage and collection contained in Manual for Streets.
Pedestrian and cycle Access and facilities
The site layout is poorly developed for pedestrians. The footways are convoluted, missing in places and shared spaces are too narrow to be safely shared between different road users.
The Site Access Design plan submitted in Appendix G shows two new pedestrian crossing facilities in Sacombe Road, however both are to the north of the access with none proposed to the south where pedestrian desire line would be, towards the local facilities, schools, etc and town centre, as shown in Appendix E. The footways also seem to connect only a small portion of the development (private lane of less than 10 plots) instead of the whole development.
The site’s location is ideal to opening it up for pedestrians in the east and North-West direction. Yet, the proposed paths within the site are not clearly designed with multiple connections to the existing PROW and adopted highway network to support pedestrian permeability.
Cycling facilities in the area are generally undeveloped. However, there are multiple opportunities for cycling to be improved as part of the proposals. For example, the strategic location of the site in the centre of the PROW (also allowing access for cyclists) network lends itself to opening it up for cyclists in the east and North-West direction. There is a ROW public restricted byway leading to Chagmore End along the eastern site’s boundary accessed off Wadesmill Road, which is also a cycleway; to the north west there is also a restricted byway/cycleway no 09 leading towards Vicarage Lane, accessed off Sacombe Road.
Yet the proposed paths within the site are not designed to be capable of accommodating cyclists and multiple connections to the existing PROW and adopted highway network have not been provided in order to support cycle permeability. The application fails to demonstrate how access for cyclists can be improved in the surrounding area.
The accessibility audit between the site and the nearest local amenities, schools, gp surgery, retail, bus stops, local centre, etc has not been undertaken to evidence if the future residents will be able to safely walk and cycle to and from the site, as shown in Appendix E.
Loss of park and stride facility to the local school
The Highway Authority is aware of the local objections to the loss of the ‘park and stride’ facility to the Bengeo Primary School, which was provided on this site. This objection however is not a material highway consideration for the following reason: no extant permission exists for such facility/use; the use was provided on a voluntary basis by the land owner; the land is a private land; encouraging driving, rather than walking and cycling to/from the school is contrary to the objectives of the school travel plans and the adopted Local Transport Plan Policy 1; the school catchment areas are set by the school.
20 mph speed zone
A 20mph zone is proposed in the vicinity of the site, in Sacombe Road. Whilst the Highway Authority generally welcomes changes, which aim to reduce the speed limits and increase road safety, in this case, although desirable, the proposed 20mph zone cannot be accepted for the following reasons:
- the site layout is not designed with an active frontage,
- the speed survey was only undertaken on a single day by using a radar speed gun. TA22/81 ‘Vehicle Speed Measurement on All Purpose Roads’ (VSMoAPR) para 4.2, states that more than one set of measurements be taken and that at least two (and preferably more) recording periods at the site are required, at different times of day and on different days of the week. Also the ‘free flow’ conditions at the time of speed check were not compliant with para 3.2 of the same guidance, which states that in free flow conditions headways and lateral displacements are usually so large as to ensure that drivers are in no way prevented, by the close proximity of other vehicles, from driving at the speed of their own choice.
- It fails to comply with the Hertfordshire’s Speed Management Strategy.
Emergency Vehicle access
The details of the emergency vehicle tracking are included in Appendix J. This fails to show each dwelling located within the recommended emergency vehicle access of 45 metres from the highway and is contrary to the guidelines contained in ‘MfS’, ‘Roads in Hertfordshire; A Design Guide’ and ‘Building Regulations 2010: Fire Safety Approved Document B Vol 1 ‘ Dwelling houses’. No evidence of the consultation with the Herts Fire and Rescue has been provided to ensure that the proposals are acceptable, or a sprinkler system is installed.
Parking
Car Parking Provision
Details of the car parking provision are contained in Appendix K of the TS and para 4.5. Parking appears to be consistent with the Updated Vehicle Parking Standards Supplementary Planning Document and the Roads in Hertfordshire: Highway Design Guide 3rd Edition, Section 4 “Design Standards and Advice, Chapter 9″ Vehicle Parking Facilities, para 9.3 Dimensions for car-parking spaces and manoeuvring areas. The proposed parking levels should be assessed by the LPA.
Cycle Parking
Cycle storage areas are included in Appendix L. Based on the Updated Vehicle Parking Standards Supplementary Planning Document and Hertfordshire County Council Cycle Parking Guide one long term (resident) space per unit should be provided. Cycle parking is shown within garages/sheds for some properties but not for all (for example plot 38,37, 39-46, etc). As this is a full application the details of dimensions and location of cycle parking should be shown for each property.
Road Safety Audit
The submitted Stage 1 Road Safety Audit (RSA) is not valid as it is not prepared for the access design supported by the Highway Authority.
Highway Safety
The applicant has obtained collision data from HCC for the recent five-year period (2014-2018). During this time, two serious collisions were recorded involving vulnerable road users (motorcyclists, pedestrian and pedal cyclist). Although no patterns were revealed, the severity of collisions and their location on the local road network is particularly relevant given the emphasis that the TS places on the proximity of the development to the local schools (Bengeo Primary School, Duncombe School Preparatory School, etc.) and in terms of encouraging trips made by sustainable transport.
Car Club Bay and electric charging points
To meet the Local Transport Plan 4 Policy 5h, the Highway Authority needs to ensure that any new parking provision in new developments provides facilities for electric charging of vehicles, as well as shared mobility solutions such as car clubs. Yet the details of car club or electric charging points are not provided as part of this development. The EV charging can be secured by a planning condition. The Highway Authority will however ask that the Applicant provides the evidence of discussions with the car club operator(s) in providing a vehicle on this site. It can be reasonably expected that one of parking bays on the site could reasonably be converted to a car club bay by way of appropriate markings / signage.
This could later be secured by way of a Section 106 obligation associated with any Planning Approval.
ACCESSIBILITY
PUBLIC TRANSPORT
Rail
The nearest railway station is located approximately 1 mile south west of the development is Hertford North. Hertford North currently has an hourly service to Stevenage and a half hourly service calling all stations to Moorgate.
Bus Access
The nearest bus stop is located approximately 300m south of the site on Bengeo Street. The bus stop has one service that operators from the stop, this is service 333 operated by CentreBus under contract to Hertfordshire County Council. The 333 has a Monday-Friday 30 minute frequency and a Sunday frequency of hourly between 9:47 – 16:47.
Facilities are basic and would warrant improvement under the three tests of the CIL regulations.
ACCESSIBILITY/ SUSTAINABLE TRANSPORT CONTRIBUTIONS
Discussions with HCC’s Transport Access and Road Safety unit (TARS) identified that, as a requirement of the development a section 106 agreement would need to secure the upgrading of the nearest bus stops in Bengeo Street:
Kessel kerbs approx. £8000 Per bus stop: x2;
Shelter approx £8000 Per bus stop: x 2
Totalling= £32,000.00
Mitigation
Planning Obligations / Community Infrastructure Levy (CIL):
The HCC’s Planning Obligation Guidance (2008) implements a two-strand approach to planning obligations in order to address the immediate impacts of the new development (first strand), and the cumulative impacts of all development on non-car networks (second strand).
The Highway Authority will seek, wherever possible, to secure highway works via planning Condition and s278 agreement.
First strand:
- Bus stops improvements;
- Pedestrian crossing facilities and new footway in Sacombe Road.
Second Strand (s106):
In accordance with the HCC Planning Obligations Guidance, contributions are sought on a unit rate basis and are pooled where appropriate. For residential use the charge is based on the number of bedrooms. This is calculated based on the accessibility zone the mix given in the planning application form:
- 4 one-bedroom units x £625= £2,500;
- 15 two-bedroom units x £750=£11,250;
- 22 three-bedroom units x £1125=£24,750;
- 11 four-bedroom and more units x £1500=£16,500.
Total: £55,000.00 (£80,850.00 with the SPONS uplift).
The contribution is payable on first occupation of the site. The contribution is to be index-linked (SPONS) from the date of the S106 agreement to the date of payment (this produces an uplift of approximately 47% (£25,850.00 and with the uplift: £80,850.00.) to the figures quoted in the aforementioned Toolkit). The contribution is to be set aside towards implementing sustainable transport measures.
TRIP GENERATION AND DISTRIBUTION
Existing Trip Generation
The existing trip generation rates are based on the traffic survey undertaken on Tuesday 24th April 2018 between 7:30-9:30am and 4:30pm-6:30pm. The existing number of trips generated by the existing nursery (bedding plant specialists) is contained in Appendix M of the TS.
Proposed Trip Generation
The proposed trip generation rates are based on the TRICS database. The sites used in the analysis are “Houses Privately Owned” land use category.
The TRICS analysis excludes sites in Greater London, Ireland and Scotland and refined to developments of 10 to 82 units with an edge of town location. Overall, this approach to estimate the number of trips generated is considered to be robust.
The predicted number of trips generated by the proposed development is contained in the Table 4 of the TS.
The proposed development is expected to have a negligible impact on the local highway network and the impact of development would not be severe.
Trip Distribution
The trip distribution is based on Census Journey to Work data for the East Herts D14 area. Trips have been assigned using the route finder in Google Maps. The majority of trips are shown to use Wadesmill Road and Bangeo Street, which is reasonable.
Travel Plan Statement
The application is accompanied by a Travel Plan Statement, prepared in accordance with the HCC Travel Plan Guidance for Business and Residential Development (2014) link:www.hertfordshire.gov.uk/travelplans.
The Travel Plan team are satisfied with the submitted TPS.
Construction Management Plan
The Construction Management Plan (CMP) is outlined in Section 7 of the TS. This provides some general principles for the proposed works. The details should be secured by a planning condition. The CMP template can be downloaded from the Hertfordshire’s website: https://www.hertfordshire.gov.uk/services/highways-roads-and-pavements/business-and-developer-information/development-management/highways-development-management.aspx#managementplans
CONCLUSION
Hertfordshire County Council (HCC) has reviewed the information provided and wishes to object to the proposed development.