The committee of the Molewood Residents’ Association is in the process of bringing round a petition against the plans for any residents who wish to object to the development. You can also sign the petition at Good News on The Avenue.
In addition the committee has sent a letter to the East Herts District Council detailing it’s objections. The full letter can be seen below:
Dear Mr Hagyard
Proposal by Bovis Homes Ltd to build on land at Sacombe Road, Bengeo
I wish to object on behalf of the members of the Molewood Residents’ Association in the strongest possible terms to this planning application. The association represents residents of the 1960s Leach Homes estate as well as The Avenue, Lodge Close, The Drive and The Orchard. We are also inviting Buckwells Field residents to join us. We have sounded out opinion and the majority of our members are against this development.
The proposal is unacceptable in absolute terms by impinging on the Green Belt. It is poorly designed and would lead to overdevelopment of a site with inadequate and dangerous access by road. Other key infrastructure, in particular schools and the road network to the south, would be inadequate to cope with this scheme.
Location: Green Belt, Conservation Area and gravel pit
The proposal is not fitting for the landscape character area in which it sits. The development would be contrary to the National Planning Policy Framework 2012 (NPPF), in respect of development within the Green Belt, in that no exceptional circumstances have been demonstrated by the applicant. In addition, it would be contrary to East Herts District Council (EHDC) Local Plan Second Review 2007 (EHDC LP 2007), policies: GBC1, GBC2, GBC3, and GBC14.
Much is made in the Planning, Design and Access Statement of the previously developed nature of the site in its current form. We estimate that 54% in area is in use by the nursery and the remaining 46% in its rough natural state.
The site is outside the Hertford settlement boundary and within emerging policy the site is classed as a fail as a suitable area for additional housing for reasons of infrastructure and inadequate access as a result of the already pressured Sacombe Road. In decision-making the NPPF is clear that planning law requires that applications for planning permission must be determined in accordance with the development plan unless material considerations indicate otherwise. The development would not be in accordance with the existing EHDC LP 2007, policy HE1. Furthermore The development would form a segregated community due to its location and would not form a sustainable development as set out in the NPPF, Sustainable Communities, and is contrary to EHDC LP 2007, policy: SD1.
The proposal is also contrary to EHDC LP 2007, policy ENV23, as the resultant development would give rise to light pollution in the Green Belt.
The development would be contrary to EHDC LP 2007, policy in respect of development next to a Conservation Area.
The development would be very close to Rickneys Quarry (preferred area 2), an identified site within the Hertfordshire County Council Minerals Local Plan 2002-2016, Minerals Policy 3. This does not appear to have been considered.
Bovis Homes Ltd describe the spatial interrelationship of the site, Bengeo and Hertford. What they do not do is point out that the settlement sits on a hill some 35m above Hertford. Connecting roads are on short steep gradients and provide a significant barrier to cycle and, to a lesser degree, pedestrian access.
Quality of design: density, sustainability, layout, building height and soft landscaping
The Planning, Design and Access Statement promises a ‘high quality, safe and accessible environment’. We see no evidence of this.
The development density is too high. The design standard of the proposed development is not exceptional and would not be fitting for a rural location It would therefore be contrary to the NPPF in respect of Requiring Good Design, and EHDC LP 2007, policy ENV1. The proposed layout appears to be cramped and sloppily designed with a rectilinear layout that bears no relation to surrounding streets.
The proposed houses and flats are of small ‘off the shelf’ new build style rather than showing any genuine sympathy with local vernacular. A local architect and member of the Hertfordshire Design Review Panel has described it as a ‘greedy and lazy proposal which would set an extremely low bar if consented, for (further) developments within the green belt’. He commented that the street frontages either side of the entrance are very poorly defined and should be much stronger. In his opinion the density of the site should vary with the edges being more porous and the centre more defined. Car courts are inappropriate in this rural/ edge of settlement context and indicate the obvious over-development of the site.
The green energy target of 10% to be produced on site is considered to be too low. Code for Sustainable Homes level 4 should be achieved for the site.
The current permission for the Bengeo Nursery site set conditions relating to building height to protect residential amenity. The proposal would result in roof heights greater than those limits causing significant harm to views of countryside and low-level rural activity to residents of dwellings to the west (Buckwells Field), south (Bengeo Mews) and east (Wadesmill Road and Bengeo Meadows) as well as users of the adjacent allotments.
The excessive density has led to houses around the edge of the site being much to close to the site perimeter and existing mature trees and hedges. The vision set out in the preapplication consultation exhibition was for an estate offering ‘green space and play areas’. The main streets should (as they are in Buckwells Field) be tree-lined. The proposed green space assessment for the development is not sufficient, and a S106 agreement to ‘pay’ for other areas is not appropriate. Any development should provide sufficient on site.
The ‘central green space’ will be too small to be of any practical use. All the photographs used to illustrate its features and, presumably, inspiration in the Planning, Design and Access Statement are of larger more open areas.
It is claimed in the Planning, Design and Access Statement that ‘the use of native plant species will be encouraged to strengthen biodiversity’. In our view the excessive density, high level of parking and tiny back gardens will massively outweigh such efforts.
Infrastructure: schools, roads and drains
Current infrastructure in the area is not adequate to support further significant development,
There is considerable pressure on school places in the immediate locality, and the resultant development with the levels of proposed family housing will add to this.
Sacombe Road is a narrow road, unsuitable for considerable volumes of traffic. The road is already at capacity, if not more so. In addition to this, the proposed development is considered to be contrary to EHDC LP 2007, policy, TR1. The road is already difficult to pass along safely for road users of any kind due to the additional traffic and parking associated with the Buckwells Field (Fairview Serenity development). This does not seem to have been taken account of in the submitted Transport Assessment. This situation becomes dangerous twice a day during term time as parents of children at Bengeo Primary School seek to deliver and collect their offspring.
In order to assess the likely effects on highway and transport infrastructure and services the applicant has provided a Transport Assessment report for the proposal. The main omission from this report is any reference to the existing parking conditions in Sacombe Road. It might be assumed that the site visits made were virtual ones since Google Maps Street View still shows Sacombe Road pre Fairview development and free of parked cars during the day. A frequency of 30 minutes is given for the 333 bus. During the off-peak period the 333 route serves Molewood and Revels Road alternately, providing an hourly service from the Molewood shops (or Greyhound pub). Similar gaps in basic local knowledge are evident in the errors in describing train and bus services and the presence of the Sainsbury supermarket at the old brewery site.
Prior to the Fairview development there was some on-street parking during the week on the west side of Sacombe Road during school term time for limited periods at the beginning and end of the school day for parents to drop off and pick up their children. Also at weekends there was some on-street parking when junior football matches were played on the playing field. Following the Fairview development on-street parking is now present for most of the day on the west side of Sacombe Road. This would appear to be overspill parking from the Fairview development and is in addition to the short term school parking noted above. This parking effectively reduces the road width to a single lane in the vicinity of the proposed development, forcing northbound traffic onto the wrong side of the road and potentially into the path of oncoming traffic. As well as reducing the road width, the parking also blocks the junction visibility for traffic leaving the Fairview development, so that traffic turning onto Sacombe Road is in effect blind to oncoming traffic.
The applicants describe the special interrelationship of the site, Bengeo and Hertford. What they do not do is point out that the settlement sits on a hill some 35m above Hertford. Connecting roads are on short steep gradients and provide a significant barrier to cycle and, to a lesser degree, pedestrian access. In our view this is symptomatic of a lack of understanding of the existing local travel realities and which lead to increased car use.
We also believe that the traffic generated by the 58 homes proposed on the site would place additional unacceptable pressure on the Bengeo rat run leading south from the site via The Wick and The Avenue and emerging at Hertford North via Beane Road. No reference is made in the technical reports on traffic and transport to the fact that residents of this development would be theoretically barred from using this route by the area-wide Access Only ban in place.
In order to improve pedestrian access to the site and in what we believe to be a misguided attempt to ‘share’ the inadequately small green area in the site with the wider community a pedestrian crossing is proposed on Sacombe Road. It is our view that this crossing should be located south of the Fairview access since it is likely that the great majority of the pedestrian movement from the proposed development will be to the south towards the school and other facilities in Bengeo. Relocating the crossing southwards would eliminate the need to cross the Fairview access road as with the current proposals.
Bovis Homes Ltd claim that ‘the need to travel will be minimised and the use of sustainable modes will be maximised’. We see no evidence of this. A Residential Travel Plan supports the Transport Assessment report. This was produced by the same transport consultant and therefore repeats many of the fundamental misunderstandings and errors about travel facilities and services in the vicinity. We note that it is proposed (at para 5.2.1) that ‘In order to implement the TP a Travel Plan Coordinator (TPC) will be appointed by the occupier’. We do not understand how this would work in practice and how it would be in any way sustainable. Given this flawed understanding of the existing situation and of future management it is difficult to have any faith in the working Travel Plan to be produced were the development to be complete.
Some of the parking bays provide for house on the site would be laid out end to end. These would be of limited practical use because of the car ‘shuffling’ necessary. Evidence from Bucklers Field shows that unless very generous garages are provided they are unlikely to be used. As noted above, car courts are inappropriate for this site. In addition it is our contention that they tend to be under-used leading to further pressure on neighbouring roads. Taken together these factors are likely to result in even more pressure on roads outside the development.
The proposal of a pumping station on the development is not sufficient, and may potentially give rise to issues with aquifers in the local area. There is also concern that the development would not be in accordance with EHDC LP 2007, policy ENV21.
Bengeo also lacks other essential infrastructure eg a doctor’s surgery or pharmacy.
Ecology and landscape
We have already stated that the excessive density would lead to houses around the edge of the site being much to close to the site perimeter and existing mature trees and hedges. These existing trees and vegetation form a natural screen around the perimeter of the site, especially along the north, west and east perimeters; they offer the opportunity to screen any new housing from the surrounding countryside, and are therefore need full consideration in the design.
There are a number of pinch points where development is too close to these trees:
- The proposed access road along the northern boundary runs well within the canopies of trees as it is very close to the boundary; at one point it appears to be approximately 1m away from the centre of a mature sycamore (which has an 8m canopy radius). The root systems of all trees either semi-mature or mature along this boundary will be damaged through the construction of this road.
- There is many examples where trees are positioned very close to proposed to buildings: all around the northern corner, the middle of the Sacombe Road boundary and middle of the southern boundary. Roots will be damaged during the construction and no consideration has been given to the future size of the trees – many of the trees are semi-mature and growth room needs to be allowed for if they are to remain as a natural screen in the landscape. Any trees that survive the development phase would be under huge pressure by residents to be cut back – compromising their health and growth.
- Garden sheds are included in the design and there are many places where these have been positioned right under tree canopies in the layout, in particular on the eastern boundary. This will again put future pressures on the trees to be cut back from residents. They would be better moved.
In order to protect these valuable natural features we ask that these steps are taken:
- A full survey of all trees around the perimeter needs to be commissioned by the developer, including accurate measurements of canopy radius. Recommended works should also be included to ensure that the trees are made safe.
- It is recommended that the District Council places a Tree Preservation Order (TPO) on the existing trees at the site, so that some further protection of them can be given during development phase, and to ensure that trees are managed as best as can be once residents move in.
- Move all development (buildings, roads, garages, sheds, driveways) away from the canopies of trees – the tree canopy is a very rough estimate of the root area and usually an under-estimate and so this is a minimum requirement. A development-free width of at least 8m along the whole boundary of the site would protect existing trees and allow some growth room to semi-mature trees, as well as space for more landscape tree planting. This would require reducing the density of housing at the site.
Miscellaneous
Reference is made in the Planning, Design and Access Statement to the East of England Plan. This was revoked on 3/1/13 as announced on 11/12/12.
Yours sincerely
Nick Gough
Chairman
Molewood Residents’ Association