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The letter below has been sent to East Herts District Council by the Civic Society regarding the proposed development of 149 homes adjacent to London Road.

We also have a new entry on the Civic Society Initiative in the members section.

Ms. Elizabeth Humby
Development Control,
East Herts Council

Dear Ms. Elizabeth Humby,

Re planning application 3/09/1061/FP
Retention of existing nursery together with the erection of 149 new residential
dwellings with parking, amenity and infrastructure.
Land adjacent to London Road, Buntingford

Whilst Buntingford Civic Society (membership circa 250 local households) accepts that development will take place on this site, we object to this proposal as it stands and ask that the East Herts Council refuse the proposed development for the following reasons:

1. The proposed density of housing is too high.

2. There is inadequate provision for parking.

3. Affordable housing should be more evenly distributed across the site.

Each of these points is dealt with below

1. The proposed density of housing is too high

(a) It is contrary to PPS3 (Housing) para 16. The application, in its attempt to justify the number of dwellings, states that it complies with PPS3 (Housing) para 16 in that it is well connected to public transport. This is quite untrue. A large proportion of the proposed dwellings will be sold to people who work well away from Buntingford and who will travel by car as the only practical and affordable means of transport.

(b) It is contrary to the East Herts Local Plan. The East Herts Plan, which was drawn up taking the requirement of PPS3 and other Government Planning Documents into account, came to the reasonable conclusion that this site, together with other designated sites, should provide 109 dwellings in the period to 2011. Recently,

outline planning permission has been given for 60 dwellings on other sites within the Town (land behind Greenways and the Allotment site). The proposal for 149 dwellings on this site will bring the total approved in this period up to 209, almost twice the level proposed in the East Herts Plan and well beyond that envisaged in policy SD2. The development of this site to the density proposed, taken together with the development of the other two sites already referred to, is contrary to the spirit of policy HSG1 and not in accordance with policy BUN1.

(c) Taking the developments on the three sites cited, together with that on recent windfall sites, the number of dwellings in Buntingford will expand by some 10% or more over a relatively short period, putting some stress on local facilities and the local community. Potential Gypsy and Traveller sites will only add to this problem.

(d) Taking the above into account, we propose that the building density be limited to 30 dwellings per hectare, rather than accepting the applicant�s high density of 43 per hectare. This would yield a total of 109 dwellings on this site alone.

2. There is inadequate provision for parking

(a) The provision of car parking space is not in accord with guidelines laid down by East Herts in �SPD Vehicle Parking Provision at New Development�. The applicant proposes to provide 265 spaces for 149 dwellings. Bearing in mind that, as explained above, residents would be reliant on motor vehicles, the parking provision should be near to the maximum indicated in the SPD Appendix B. Using these figures, the parking provision should be for 310 spaces.

(b) As part justification, the applicant quotes that 2001 census figures show vehicle ownership at 1.61 cars per dwelling and that the application corresponds to a slightly higher figure. This is a false justification, as those likely to move into the new development will be of an age distribution quite different from the overall 2001 population of Buntingford. Comparison should be made with car ownership on a similar development with similar transport links, the Bovis Estate for example.

3. Affordable Housing should be more evenly distributed across the site

(a)It is contrary to SPD Affordable Housing and Lifetime Homes, para. 6.20, which quotes that affordable housing should be distributed across a site to facilitate an integrated and sustainable community.East Herts plan BUN3 II e requires that the development be properly integrated across the whole of the site under consideration. The developer�s financial considerations should not outweigh good planning requirements.

4. Additional Points

(a) Accuracy. The Civic Society is concerned that the application contains a few inaccuracies. Apart from the false claim that the site is well served by public transport, a point is made that the disused railway line on the site boundary is a public right of way. It is not. A more thorough reading than has been possible in the very limited time made available for consultation might show up other errors.

(b) East Herts Climate Change Strategy. It is not at all clear that the proposals are in line with this.

(c) Community Involvement. There has been no community involvement in the preparation of the proposal. The briefing of neighbouring residents a few weeks in advance hardly constitutes involvement; the Town Council were not informed until after the planning application had been registered.

In Conclusion

We ask that the planning application be refused for the reasons outlined above namely that it is contrary to PPS (Housing) para 16 as well as to East Herts Local Plan Policies SD2, HSG1, BUN1 and BUN3IIe and the Affordable Housing and Lifetime Homes SPD. To approve the proposed development would indicate that expediency outweighs proper planning considerations and that we are returning to a period of piece-meal decision making in which transparency is far from obvious.

The Civic Society would also like to point out that it supports the submission made on this matter by Buntingford Town Council.

On behalf of Buntingford Civic Society, yours sincerely,

R.F.Jackson (Trustee and Executive Committee Member)

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