GRIDSERVE Electric Forecourt Stevenage Knebworth Park, Stevenage - April 2021

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GRIDSERVE Electric Forecourt Stevenage Knebworth Park, Stevenage - April 2021
GRIDSERVE
Electric Forecourt® Stevenage

Knebworth Park, Stevenage

April 2021

Peacock + Smith Limited   T: 0113 243 1919
Suite 9C, Joseph's Well   E: leeds@peacockandsmith.co.uk
Hanover Walk
Leeds LS3 1AB
GRIDSERVE Electric Forecourt Stevenage Knebworth Park, Stevenage - April 2021
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

Report

1.   Introduction                                                              3

2.   Site Description and Planning History                                     6

3.   Proposed Development                                                      9

4.   Planning Policy Context                                                  16

5.   Planning Assessment                                                      25

6.   Summary and Conclusions                                                  42

Appendices

Appendix 1: Appeal Decision 9th December 2020 (APP/F160/W/20/3248674) Electric Car Charging
Service Station, Fosseway (A429), Lower Slaughter, Gloucestershire, GL54 2EY

Prepared by: Mike Spurgeon

Approved by: Chris Creighton

This report has been prepared by Peacock + Smith Ltd with all reasonable skill, care and diligence. The scope of
the report is subject to specific agreement with our client and should not be relied upon by any other party. Any
third party that use this information does so at its own risk. Peacock & Smith accepts no responsibility for
information contained within this report which has been independently produced or verified. Should you have any
issue with regard to this report, please contact the Director at Peacock & Smith identified above.
GRIDSERVE Electric Forecourt Stevenage Knebworth Park, Stevenage - April 2021
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

1.1.   This Report comprises a Planning Statement prepared on behalf of our client GRIDSERVE in
       support of a planning application for the construction of an Electric Forecourt® at land to the
       north west of Junction 7 of the A1(M), Knebworth Park, Stevenage.

1.2.   The description of development provided on the Application Form reads as follows:
             Erection of electric vehicle charging station with ancillary uses to include retail and food and
             drink with associated electrical infrastructure, car parking and landscaping.

1.3.   The proposed development will comprise a GRIDSERVE Electric Forecourt® with 24 Electric
       charging spaces, 8 branded Electric charging spaces, 6 additional Electric charging spaces and
       3 HGV Electric charging spaces, along with 29 staff and customer car parking spaces and 7
       stacking or queuing spaces. Included in this parking provision is a total of 5 accessible parking
       spaces, 3 of which will be accessible Electric charging spaces. A motorcycle parking space with
       anchor point will also be provided, along with 12 cycle parking spaces, in the form of 6 Sheffield
       cycle stands.

1.4.   The ground-floor of the proposed two-storey amenity building will house ancillary retail, café
       and associated facilities for drivers and passengers of vehicles to use while their vehicles are
       charging. The first-floor would be laid out as a customer lounge and waiting area. The building
       would also provide associated facilities for drivers including toilets, informal seating areas and
       workspace. The retail space would not exceed 160 sq. m, while the café would have an area of
       approximately 60 sq.m. These are of a limited scale and nature, and are considered ancillary to
       the principal use of the site as an Electric Forecourt®.

1.5.   The proposal also includes the engineering works involved in the provision of connection routes
       to the electricity network. The point of connection would be at a location to the south-west of
       Junction 7 of the A1(M).

1.6.   Access to the Electric Forecourt® would be provided by a new roundabout which would enable
       traffic travelling via the A1(M), to turn into the site without the prospect of any conflict with
       vehicular traffic travelling to or from Knebworth House or the Novotel site to the south.

1.7.   This site represents a unique opportunity for the provision of an innovative form of infrastructure
       provision that will serve the rapidly-growing market for electric vehicles and contribute towards
       building confidence in the reliability and availability of high-quality and high-capacity charging
       facilities to serve both passing traffic, local residents and businesses located in and around
       Stevenage. The presence of a facility providing rapid, electric vehicle charging in an easily-
GRIDSERVE Electric Forecourt Stevenage Knebworth Park, Stevenage - April 2021
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

       accessible location will improve the attractiveness of owning and operating an electric vehicle.
       In addition, the presence of this type of facility makes it possible for people living in flats and
       housing without charging points to own and operate an electric vehicle.

1.8.   Increased ownership and usage of electric vehicles as opposed to petrol or diesel powered
       equivalents will contribute towards achieving significant improvements to air quality and will also
       help the Council to meet its ambitious carbon reductions as set out in the Climate Strategy and
       the recently declared Climate Emergency. The facility will also create employment in the form
       of five new jobs as well as additional employment required to support the planning, design,
       environmental and construction phases of the development.

1.9.   The application is submitted following pre-application discussions with planning officers who
       have expressed their support for the approach and indicated that the proposed development
       would represent very special circumstances that would justify what would otherwise be
       considered inappropriate development on Green Belt land.

1.10. The application is supported by the following reports and information:

             Archaeological Desk Based Assessment prepared by HCUK Group;
             Design and Access Statement prepared by Bowman Riley Architects;
             Drainage Layout prepared by CPA Consulting;
             Flood Risk & Drainage Assessment by CPA Consulting;
             Landscape and Visual Impact Assessment by Enplan;
             Landscape Strategy by Enplan;
             Noise Impact Assessment by Delta Simons
             Preliminary Ecological Appraisal prepared by Delta Simons;
             Transport Statement and Travel Plan prepared by Bryan G Hall Ltd; and
             Tree and Hedgerow Survey by Delta Simons

       Purpose and Structure of Report

1.11. The Report seeks to address all relevant planning considerations prior to drawing conclusions as
       to the merits of the application.

1.12. The remainder of this Report is structured as follows:

        (a)   Section 2: describes the site and discusses its planning history
        (b) Section 3: describes the proposed development
        (c)   Section 4: positions the proposals in the context of planning policy
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

     (d) Section 5: analyses the planning considerations relevant to the proposal
     (e)   Section 6: summarises and concludes
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

       Site Location

2.1.   The site is situated to the north west of Junction 7 of the A1(M), to the south and west of
       Stevenage, and in particular the extensive commercial areas to the east of the motorway. The
       western spur of the junction also provides access to the Knebworth House via a privately owned
       and privately-maintained road through the Knebworth Estate.

2.2.   The A1(M) currently marks the western edge of development in Stevenage, although this
       distinction is less clear further to the north where areas of land to the west of the motorway are
       allocated for residential development, and adjacent to Junction 7, where the Novotel site is
       situated to the south-west of the junction.

                                         Figure 1: Site Location

2.3.   The site is currently a level area of land bounded to the east by the steep embankments leading
       to the A1(M) and the slip road on to the northbound carriageway, and to the south by the private
       access road to Knebworth House. The western boundary of the site is defined by the existing
       fields and hedgerows, while the area to the north is open fields forming a gap between the
       northern boundary of the site and Knebworth Woods/Newton Woods which cover an extensive
       area to the north and west of the site.
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

2.4.   The land to the east of the motorway is characterised by the presence of commercial and
       industrial premises at the extensive Gunnels Wood employment area. The main town centre and
       mainline railway station providing direct links to London and Peterborough is relatively close to
       the site, approximately one mile to the north, while the residential areas to the south of Stevenage
       are approximately 1km to the east.

       Site Description

2.5.   The application site extends over an area of 2.37 hectares to the west of Junction 7 of the A1(M).
       The developable area of the site extends over approximately 1.1 hectares, immediately to the
       north-west of the junction, while the remaining area enclosed by the red line on the Site Location
       Plan includes the land currently forming the route of the private access road across the
       Knebworth Estate, as well as a small section of the roundabout which forms a part of the junction
       itself. This includes land to the south of the Novotel complex where works would be carried out
       to provide a link to the point of connection to the electricity grid.

2.6.   A substantial part of the main developable site will be used for landscaping and drainage
       features, the details of which are included within the submitted landscape plans and landscape
       study which have been prepared by Enplan which forms part of the planning application
       submission.

2.7.   In planning terms, the site is within the Metropolitan Green Belt and within a small area between
       the west of the A1(M), and the boundary between Stevenage Borough and North Hertfordshire
       District.

2.8.   There are no listed buildings or Conservation Areas in close proximity, with the existing
       developed areas to the east of the motorway occupied by large industrial and commercial
       buildings.

2.9.   The site falls within Flood Zone 1 and is at low risk from flooding from rivers and sea. There are
       no areas

       Planning History

2.10. There are no planning application records relating directly to the site itself.

2.11. The planning history of the Novotel site to the south is relevant, although it is evident that planning
       permission for the erection of the hotel itself pre-dates any records that are available online from
       Stevenage Borough Council.
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2.12. It is also notable that an area of land approximately 1 km to the north has been allocated for
      housing. This represents a significant expansion of Stevenage to the west of the A1(M).
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

       The Opportunity

3.1.   Electric vehicle ownership is on an upward trajectory with many forecasters predicting
       exponential growth over the next two decades. Indeed, by 2040 Bloomberg New Energy finance
       predicts that 55% of all vehicles being sold worldwide will be electric, and 33% of all fleet vehicles
       will be electrified. The UK is bringing forward the ban on the sale of new ICE vehicles from 2040
       to 2030 and to also include hybrids in the ban.

3.2.   As combustion engine vehicles are replaced as one of the main transportation solutions for mass
       transit, a significant barrier to overcome is to provide a viable charging solution. The
       infrastructure needs to remove the sense of ‘range anxiety’ (i.e. the fear of having insufficient
       power to reach your destination or the next charging infrastructure) and for users to be able to
       fully recharge in a practical time frame.

3.3.   The key challenge for electric vehicle charging is not usually related to the supply of electricity
       itself, it is the speed at which that electricity can be transferred into a vehicle’s battery. This
       means that a standard 13-amp socket would only be able to charge an electric vehicle at less
       than 10 miles per hour of charge. Doubling this to a 7kW (the maximum allowable for domestic
       properties where the majority of charging is currently undertaken) will extend charging time to a
       maximum of around 20 miles per hour of charge. Whilst this may be adequate if you are charging
       overnight, it is not viable in the context of longer distance travel. The other challenges with the
       current deployment of charging solutions include:

            The significant proportion of households without off-street car parking to charge their
             vehicle (43%).

            Limited number of physical chargers, unevenly distributed across the UK.

            Significant variation in the power of chargers; more accessible chargers may be lower
             powered and therefore significantly increasing dwell time.

            Limited standardisation between charging schemes, often needing to join different
             membership schemes to access the charger on or near your chosen route.

            Different charging sockets; there are three different types of charging plugs and not all
             charging points have all available to use.

            Unreliable maintenance of these (including the inaccurate display that a charger is in
             operation when in fact it is faulty).
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

              Location of chargers are primarily at destinations, bringing added value to users of that
               site but not to passing electric vehicle drivers.

              Variations in temperature can significantly impact electric vehicle drivers charging
               requirements due to the additional power required to use interior heaters or air
               conditioning, as well as the performance of batteries in cooler temperatures.

3.4.   At the National level there is unequivocal support for electrifying transportation with the UK
       having the opportunity to become a world leader both in the production and refinement of
       electric vehicles but also in the quality and provision of the charging infrastructure.

3.5.   Since the EU directive (2014) that made a commitment to ensure an ‘appropriate number of
       publicly accessible charging points’ by the end of 2020, the principle to expand the provision of
       charging infrastructure has been widely supported.

3.6.   The Government’s ‘Road to Zero Strategy’ (July 2018) sets out plans to enable a massive
       expansion of green infrastructure across the country, reduce emissions from the vehicles already
       on the UK’s roads, and drive the uptake of zero emission cars, vans and trucks. It also recognises
       the alignment of these objectives with national industrial strategy, leading the industries of the
       future and building the UK’s competitiveness in the face of major global economic trends.

3.7.   At a more local level, policies to support the provision of charging infrastructure are already
       becoming common place. The London Plan standards, for example, require 20% active provision
       (i.e. fully installed from the outset) plus 20% passive provision (i.e. cabling provided for easier
       future installation of charging equipment) in residential developments, and 10% active provision
       plus 10% passive provision in all other developments.            This has supported provision of
       destination chargers as part of new developments but with no mandate for retro- fitting the built
       environment. The Automated and Electric Vehicles Act (2018) also shows a clear commitment
       from the UK Government to ensure the effective management of charging points, as well as
       ensuring a provision for associated services or facilities. Local policies relevant to Stevenage
       Borough are considered in Section 4 of this report.

3.8.   The need for supporting functions to electric vehicle charging has been recently well publicised
       as part of Fastned’s network delivery in the Netherlands. They recently successfully overturned
       a decision to deny the inclusion of toilets, café and retail provision from one of its proposed filling
       stations, setting a strong precedent for the need for ancillary facilities to support your charging
       time.
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

3.9.   There is a notable absence of motorway service areas in this section of the A1(M), with a 25 mile
       gap between South Mimms Services to the south and Baldock Services to the north. While this is
       within the 28 mile (30 minute drive time), which is the maximum recommended gap between
       motorway service areas set out in Government policy 1, this is only on the basis that vehicles travel
       directly between the two service areas on the motorway. Vehicles joining at inventing junctions
       may also have charging requirements.

3.10. In this area of Stevenage there is also a general shortage of rapid charging facilities. As is evident
       in Figure 2 below, there is currently only a single high capacity/rapid charging facility in
       Stevenage, while there are also few alternative facilities in the vicinity which would provide access
       to fast charging for electric vehicles. While there are different types of charger installed in other
       locations, these do not offer fast charging facilities. These represent a very different type of
       charging facility and will not be suitable for meeting the needs of drivers and fleet managers using
       the latest generation of electric vehicles. Therefore GRIDSERVE’s Electric Forecourt® will be
       fundamental in providing the necessary infrastructure to support the mass adoption of electric
       vehicles within the borough and elsewhere.

                 Figure 2: Location of existing rapid charging facilities in and around Stevenage
                                       (Source: https://www.zap-map.com/live/)

As set out in The Strategic Road Network and the Delivery of Sustainable Development (DfT, September 2013).
1
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

      The Concept

3.11. An Electric Forecourt® is the new generation of filling station designed to meet the demands of
      the electric vehicle market. It has been conceived from extensive research into the limitations
      and frustrations with existing charging infrastructure. It will offer reliable, predominantly ultra-
      rapid EV charging units (known as ‘superchargers’), supported by a range of ancillary services,
      designed to maximise the experience of charging and optimise the use of the associated dwell-
      time.

3.12. Vehicle charging will be available as superchargers (350kW, 175KW and 90kW), as well as fast
      (22kW) speeds.

3.13. Users will be both general members of the public as well as fleet vehicle operators and the entire
      functionality of the Electric Forecourt® has been designed around the customer experience. The
      Electric Forecourt® will include scope to book a charging space at a particular time, organise a
      car valet to coincide with your charge, engage with electric vehicle retailers and, in a dedicated
      ‘Lounge’ area, rest and relax, making the most of your dwell-time. This could be simply logging
      onto browse the internet, working at a hot desk or perhaps using a variety of available
      concessions covering retail convenience, food and beverage.

3.14. The Concept, when replicated will provide an interdependent network of reliable charging
      infrastructure, is designed to integrate fully into the local environment. In instances where the
      site is within a retail park, existing car park or adjacent to shopping functions, GRIDSERVE’s
      product app will identify and interact with other local amenities.

3.15. The increased provision of larger-scale electric vehicle charging facilities will have an indirect
      impact across the wider region. Small businesses will be able to transition to electric vehicle
      fleets without installing expensive infrastructure as they can use the Electric Forecourt®.
      Additionally, for tourism, large-scale electric vehicle charging will remove barriers and anxiety
      for users of the A1(M), and other routes around Stevenage and the surrounding area.

3.16. The Electric Forecourt ® concept requires a location that is highly visible and readily accessible
      from the main highway network on routes with high daily traffic flows and within a short
      connection to the National Grid in an area with sufficient capacity in the electric network.

3.17. As part of this application, the amenity building will house ancillary services, including a coffee
      shop, retail space, toilets, seating areas and workspace. These uses are all essential to the
      development to ensure a welcoming and useful service is provided for its users. This element of
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

      the proposal is very much ancillary to its main use as an Electric Forecourt ® and as such this
      cannot be considered as retail or commercial development in its own right.

      The Design and Layout

3.18. The Design and Access Statement submitted with the application provides further information
      on the design of the Electric Forecourt ® at Stevenage. The key points on the design of this
      building are:

           Simple steel frame with cladding and glazing;

           An approach to construction which reduces wet trades and therefore construction time;

           A product which is green and clean and uses modern materials including two ‘living green
            walls’ to create a high-profile presence; and

           Solar panel arrays will be installed on the roof of the main building and on the roof of the
            canopies above the main charging areas.

3.19. The two-storey amenity building would occupy a position towards the eastern end of the
      developable area of the site. This building covers an area of approximately 420 sq. m, and
      houses retail and café areas (with a floor area of 160 sq. m and 86 sq. m respectively), and a
      communal space at first floor level (extending over approximately 320 sq. m), which will primarily
      serve as a waiting area for the convenience and comfort of electric vehicle users.

3.20. The choice of building material is to a degree driven by the corporate image and identity that
      GRIDSERVE are looking to develop for all their future sites throughout the UK with clean lines
      and modern in appearance.

3.21. The external appearance of the building has been designed to reflect the corporate image and
      identity that GRIDSERVE are seeking to develop for all their sites throughout the UK with clean
      lines and a modern appearance key features of the design.

3.22. The external materials will be a combination of cladding panels which will all vertically laid.
      Feature cladding panels will be provided to the rear of the building, while the glazing will be a
      frameless curtain walling system and a living green wall façade system will be installed on each
      side of the building.

3.23. The visualisation below shows the proposed building and how it would appear in the context of
      the site and its immediate surroundings. Additional images are included in the Design and Access
      Statement which forms part of this application.
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

                    Figure 3: Visualisation of GRIDSERVE Electric Forecourt ® Stevenage

3.24. Vehicular access to the site will be provided from a new roundabout that will be provided to the
      north of the Novotel site. This currently serves as an access road primarily to the Knebworth
      Estate, with the Novotel the only other property served by the road which links the western side
      of Junction 7 and the estate.

3.25. The provision of a new roundabout will ensure that the increase in traffic and usage of this section
      of road would not be to the detriment of highway safety or the efficient flow of traffic.

3.26. Pedestrian and cycle access to the site is currently limited with the motorway junction presenting
      a physical barrier to pedestrian or cycle access from areas of Stevenage further to the east.
      However, access across the junction for pedestrians and cyclists is possible, and the location of
      the site is such that it is not prohibitively remote from central areas of Stevenage or residential
      areas of Stevenage to the east.

3.27. The planning application seeks consent for 24 Electric charging spaces, 8 branded Electric
      charging spaces, 6 additional Electric charging spaces and 3 HGV Electric charging spaces, along
      with 29 staff and customer car parking spaces and 7 stacking or queuing spaces. Included in this
      parking provision is a total of 5 accessible parking spaces, 3 of which will be accessible Electric
      charging spaces. A motorcycle parking space with anchor point will also be provided, along with
      12 cycle parking spaces, in the form of 6 Sheffield cycle stands.
GRIDSERVE Electric Forecourt ®

Knebworth Park, Stevenage

                 Figure 4: Proposed Layout of GRIDSERVE Electric Forecourt ®, Stevenage

3.29 An important aspect of the proposed development is the provision of renewable energy in the
      form of solar power generation on the roof of the buildings and canopy structure.

3.30 Installed estimated 60kWp of rooftop solar, producing 63.57MWh of energy over the course of
      a year. It is assumed that the building (excluding equipment) will consume approximately
      46kWh/m2, or a total of 33.58MWh meaning that the on-Site PV will cover 189% of the required
      energy for the building.

3.31 In addition to the generation of renewable energy on the site the building on the Electric
      Forecourt® will use energy efficiency measures to improve the building efficiency and reduce
      overall energy consumption. Measures to include air tightness, high quality materials for
      insulation, rainwater capture as well as energy efficient lighting.

3.32 As a general principle for the site, all energy demands, including heating and cooking, will be met
      with electricity, which will be 100% renewable.
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4.1.   Section 70(2) of the Town and Country Planning Act 1990 and Section 38(6) of the Planning and
       Compulsory Purchase Act requires that planning decisions should be taken in accordance with
       the development plan unless material considerations indicate otherwise.

4.2.   The statutory development plan for Stevenage currently comprises the Stevenage Local Plan
       (adopted May 2019).Material planning policy considerations include the National Planning Policy
       Framework (2019) which is supported by Planning Practice Guidance (PPG).

4.3.   Other material policy considerations include Stevenage Borough Council’s Climate Change
       Strategy (September 2020) and the recently declared Climate Emergency June 2019). At the
       national level, the Government’s ‘Road to Zero Strategy’ (July 2018), the Automated and Electric
       Vehicles Act (2018) and the Government’s announcement to bring forward a ban on tknebworth

4.4.   The sale of petrol/diesel cars to 2030 are all relevant. A recent appeal decision for an electric
       vehicle charging station in Gloucestershire (see Appendix 1) refers to these as material
       considerations in planning decisions.

       Stevenage Borough Local Plan 2011-2031 (Adopted May 2019)

4.5.   The Stevenage Borough Local Plan sets out an overall vision to guide and direct development up
       to 2031. The plan contains both strategic and detailed policies which seek to address key spatial
       issues as well as providing a basis for decision making. A number of policies which are considered
       relevant to the consideration and determination of this planning application. These policies are
       summarised below.

4.6.   Policy SP1: Presumption in favour of sustainable development, reflects the positive approach
       that the Council are taking to considering development proposals. It states that the Council will
       apply a presumption in favour of sustainable development and that officers will work proactively
       with applicants to find solutions to enable proposals to be approved where possible. This
       presumption in favour of sustainable development is applicable where proposals accord with the
       development plan.

        Where there are no policies relevant to the application or relevant policies are out of date at the
        time of making the decision, we will grant permission unless material considerations indicate
        otherwise. In these cases we will take into account whether:
        a.   Any adverse impacts of granting permission would significantly and demonstrably outweigh
             the benefits when assessed against the policies in the NPPF, or any other relevant planning
             guidance issued by the Government, taken as a whole; or
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        b.   Specific policies in that guidance indicate that permission should be refused or development
             should be restricted.

4.7.   Policy SP2 is entitled Sustainable development in Stevenage. This policy seeks to apply the
       principles of sustainable development and reduce the impact of development on climate change.
       The policy states that planning permission will be granted where development proposals can
       demonstrate (as applicable), how they will:

        a. Deliver homes or jobs that make a positive contribution towards the targets in this plan;
        b. Supply a mix of uses, make good use of land and maximise opportunities for brownfield
           redevelopment within the town;
        c. Regenerate areas of the town that are under-performing;
        d. Reduce deprivation, improve quality of life and make sure that residents share in the
           benefits of regeneration and growth;
        e. Raise the aspirations, earnings, education level or life expectancy of residents;
        f. Provide a mix of homes and jobs for all sectors of the community;
        g. Promote journeys by bus, train, bike and foot and reduce the need to travel;
        h. Work within the limits of infrastructure and increase capacity where this is necessary to
           support development;
        i. Make high-quality buildings and spaces that respect and improve their surroundings, reduce
           crime and the fear of crime;
        j. Support facilities and services that encourage people to live, work and spend leisure time in
           Stevenage;
        k. Produce places and spaces that enable people to live a healthy lifestyle;
        l. Take a proactive approach towards energy use, including renewable energy and energy
           efficiency measures where practicable and appropriate;
        m. Avoid or prevent harm from flood risk, contamination and pollution;
        n. Protect and improve important open spaces, wildlife sites and habitats;
        o. Preserve or enhance areas and buildings of historical and archaeological interest; and
        p. Increase community awareness and involvement so that residents are involved in, and proud
           of, their town.

4.8.   Policy SP6 is entitled Sustainable Transport. Parts c, d and e of the policy are relevant to the
       consideration of this application.

        We will create the conditions for a significant increase in passenger transport, walking and
        cycling. We will require new development to provide an appropriate level of car parking. We will:
             c.   Support the provision of sustainable transport schemes as identified in local transport
                  plans and other relevant plans and strategies;
             d.   Refuse permission where development proposals fail to provide any relevant plans or
                  assessments relating to transport;
             e.   Assess proposals against the car and cycle parking standards set out in the
                  Supplementary Planning Documents; and

4.8    Subsequent sections of this policy go on to refer to the need for developments to ensure that
       development is accessible for cyclists and pedestrians. Part f of the policy goes on to read as
       follows:
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             f.          Require new development to make reasonable on-site, off-site or financial
                         contributions in accordance with Policy SP5 including (but not limited to):
                          i.     The creation or improvement of routes to, from or in the vicinity of the site;
                          ii.    The provision of crossings, underpasses, bridges or other appropriate means of
                                 traversing significant barriers for pedestrians and cyclists;
                          iii.   The implementation of parking control measures within or in the vicinity of the
                                 development site; and / or
                          iv.    The implementation of other transport schemes identified in our delivery plans

4.9   The above refers to Policy SP5 of the Local Plan which is entitled ‘Infrastructure ’. The policy
      requires that the infrastructure needed to support the achievement of targets and proposals set
      out in the plan will be provided and that new development will ‘contribute fairly’ towards
      providing infrastructure consistent with the demands that it creates.

4.10 The policy goes on to state that the Council will:

        a.   Permit permission where new development
                  i.        Makes reasonable on-site provision, off-site provision or contributions towards (but
                            not limited to) the following where relevant:
                            affordable housing; biodiversity; childcare and youth facilities; community facilities;
                            community safety and crime prevention; cultural facilities; cycling and walking;
                            education; flood prevention measures; Gypsy and Traveller accommodation;
                            health care facilities; leisure facilities; open spaces; passenger transport; play
                            areas;
                            policing; public realm enhancement; road and rail transport; sheltered housing;
                            skills and lifelong learning; sports; supported housing; travel plans; utilities and
                            waste and recycling.
                  ii.       Includes measures to mitigate against any adverse impact on amenity or the local
                            environment where this is appropriate and necessary; or
                  iii.      Meets any specific requirements relating to individual sites or schemes set out
                            elsewhere in this plan;
        b.        Use developer contributions, legal agreements, levies or other relevant mechanisms to
                  make sure that the criteria in (a) are met;
        c.        Deliver a major reconfiguration of the road network in and around the Town Centre to
                  catalyse regeneration;
        d.        Work with Hertfordshire County Council, Highways England, the NHS, the Local
                  Enterprise Partnership and other relevant service providers and agencies to deliver
                  additional highway, education and health capacity as well as new and enhanced open
                  spaces and community and leisure facilities; and
        e.        Co-operate with other utilities and service providers to ensure that appropriate capacity
                  is available to serve new development.
        f.        Ensure new development does not have an adverse effect on the Lee Valley Special
                  Protection Area (SPA). New development post 2026 will only be permitted if the required
                  capacity is available at Rye Meads STW, including any associated sewer connections.

4.11 Policy SP3 is entitled ‘A strong, competitive economy’. This sets out the approach to the provision
      of employment and how accommodation and sites will be provided for within Stevenage. The
      Council seeks to develop a diverse economy with accessible employment and deliver a significant
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      increase in the number of businesses and jobs in the Borough. The allocation of land through the
      Local Plan seeks to:

       a.     Provide at least 140,000 m2 of new B-class employment floorspace over the plan period
              from Allocated Sites for Employment Development;
       b.     Permit high intensity B-class employment uses in the most accessible locations. This
              includes high-density offices to the west of the railway station as part of a comprehensive
              and co-ordinated mixed-use development.
       c.     Continue to remodel Gunnels Wood to meet modern requirements and provide a high
              quality and attractive business destination. This will include the continued development of
              the Stevenage GSK and Bioscience Catalyst Campus at the south of the employment area.
       d.     Protect an employment area at Pin Green and retain a range of B-class employment
              accommodation in suitable locations elsewhere in the town.
       e.     Work with Central Bedfordshire Council and North Hertfordshire District Council to
              ensure an appropriate level of employment provision within the wider A1(M) / A1 corridor
              over the plan period. The Borough Council will support, as required:
              i.     A new, strategic employment allocation at Baldock to be delivered through North
                     Hertfordshire's local plan; and/or
              ii.    The continued development of the Stratton Business Park at Biggleswade through
                     Central Bedfordshire's local plan.
              f.     Recognise the important role played by the town’s retail, health and other non-B
                     Class land uses in providing employment.

4.12 Policies relating to the design of development are also important considerations in the
      determination of this application. Policy SP8 is simply entitled ‘Good Design’: This policy requires
      that new development should achieve the highest standards of design and sustainability through
      requiring that development will:

       a.     Preserve and enhance the most important areas and characteristics of Stevenage whilst
              delivering substantial improvement to the image and quality of the town’s built fabric;
       b.     Require significant developments to be masterplanned to ensure the delivery of high-
              quality schemes;
       c.     Set out detailed design criteria and require applicants to have regard to Supplementary
              Planning Documents and other relevant guidance; and
       d.     Implement the Government's optional Technical Standards to ensure schemes deliver the
              space, accessibility and water efficiency expected of modern developments.

4.13 This policy is supported and supplemented by Policy GD1: High Quality Design. This states that:
      Planning permission will be granted where the proposed scheme (as applicable):

       a.     Respects and makes a positive contribution to its location and surrounds;
       b.     Improves the overall ease of movement within an area for all users;
       c.     Creates a safe environment that designs out crime;
       d.     Creates, enhances, or improves access to, areas of public open space, green
              infrastructure, biodiversity and other public realm assets;
       e.     Does not lead to an adverse impact on the amenity of future occupiers, neighbouring uses
              or the surrounding area;
       f.     Complies with the separation distances for dwellings set out in this plan;
       g.     Minimises the impact of light pollution on local amenity, intrinsically dark landscapes and
              nature conservation;
       h.     Incorporates high quality boundary treatments when located on the street frontage;
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        i.     Complies with other relevant policies and has regard to guidance which may influence
               site layout and design, including (but not necessarily limited to):
               i.      Requirements relating to active frontages in Policy EC5;
               ii.     The parking and access standards in Policy IT5 and the Parking Provision SPD;
               iii.    Site-specific considerations identified in Policies HO1, HO2, HO3 and HO4;
               iv.     Housing mix requirements in Policies HO8, HO9 and H10;
               v.      Accessibility requirements in Policy HO11;
               vi.     SuDs and flood risk considerations in policies FP1 and FP2
               vii.    Open space standards in Policy NH7; and
               viii.   Conservation area guidance in Policy NH10;
        j.     Meets the nationally described space standards;
        k.     Makes adequate provision for the collection of waste; and
        l.     Has regard to the Stevenage Design Guide Supplementary Planning Document and any
               other appropriate guidance.

4.14 Policy SP10: Green Belt is particularly relevant to the consideration of this application. The policy
      states that the Council will support the principles of the Green Belt in order to provide long-term
      certainty over the limits of development. The policy refers to the Green Belt Review and how this
      has been used to establish defensible long-term Green Belt boundaries which it indicates will
      allow scope for the continued growth of Stevenage up to at least 2031. Part b of the policy states
      that the Council will work with neighbouring districts of North Hertfordshire and East
      Hertfordshire to create a coherent and connected Green Belt boundary around the town. It refers
      to land being safeguarded in North Hertfordshire to meet the needs of Stevenage beyond the
      plan period.

4.15 In respect of planning applications, the policy states that the Council will decide applications for
      development in the Green Belt in accordance with national guidance and any other relevant
      policies.

4.12 Policy GB1: Green Belt identifies broad locations which are detailed on the policies map where
      land is to be designated as Green Belt. This includes an area of land which includes the
      application site and other land between the A1(M) to the east and the boundary with North
      Hertfordshire to the west. The policy refers to this area as: Land at Junction 7 and to the south
      of this junction, bounded by the A1(M).

4.13 Policy SP11 is entitled Climate Change, flooding and pollution. The relevant aspects of this relate
      specifically to how the Council will work to limit, mitigate and adapt to the negative impacts of
      climate change, flood risk and all forms of pollution. The approach will be to:

        Ensure new development minimises and mitigates its impact on the environment and climate
        change by considering matters relating (but not necessarily limited) to the provision of green
        space, renewable energy, energy efficiency, water consumption, drainage, waste, pollution,
        contamination and sustainable construction techniques;
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4.14 This policy is supplemented by Policy FP1 Climate Change, which states that: :

        Planning permission will be granted for developments that can incorporate measures to address
        adaptation to climate change. New development, including building extensions, refurbishments
        and conversions will be encouraged to include measures such as:
              Ways to ensure development is resilient to likely future variations in temperature;
              Reducing water consumption to no more than 110 litres per person per day including
               external water use;
              Improving energy performance of buildings;
              Reducing energy consumption through efficiency measures;
              Using or producing renewable or low carbon energy from a local source; and
              Contributing towards reducing flood risk through the use of SuDS or other appropriate
               measures.

4.15 Policy SP12: Green infrastructure and the natural environment states that the green
      infrastructure, natural environment and landscape of Stevenage will be protected, enhanced and
      managed. The policy states that:

        Green infrastructure, natural environment and landscape of Stevenage will be protected,
        enhanced and managed, and we will positively acknowledge its influence on Knebworth Woods
        SSSI and Lea Valley SPA.

4.16 In doing this, the local planning authority will:

        a.     Create, protect and enhance key areas of open space and biodiversity value including:
               i.     parks, recreation grounds, amenity spaces and woodlands which are integral to the
                      open space structure of Stevenage as Principal Open Spaces. This will include
                      Fairlands Valley Park;
               ii.    locally important wildlife sites; and
               iii.   a series of ten green links around the town. These will be collections of spaces that
                      are worthy of protection for their connectivity and their recreation, amenity or
                      wildlife value.
        b.     Preserve, create, protect and enhance locally important linear features including:
               i.     the historic lanes and hedgerows which pre-date the New Town; and
               ii.    structural green spaces along major routes within the town.
        c.     Create and protect multi-functional green space and sports facilities as an integral part
               of new developments in accordance with the latest standards and permit the creation of
               other new open spaces where they will meet an identified deficit;
        d.     Mitigate or, as a last resort, compensate for the loss of green infrastructure or assets of
               biodiversity importance resulting from development; and
        e.     Only grant planning permission if an adequate assessment of priority habitats and species
               has been undertaken. Any identified impact on these habitats and/or species will need to
               be avoided, mitigated or compensated.

4.17 Policy NH5: Trees and woodland relates to proposals which affect or are likely to affect existing
      trees. The policy requires that:

        Existing trees must be protected and retained where possible, and sensitively incorporated
        into developments.
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4.18 The policy goes on to state that where it can be demonstrated that the loss of trees is
      unavoidable, planning permission will be granted where:

        a.    Sufficient land is reserved for appropriate replacement planting and landscaping;
        b.    Replacement trees or planting are provided which are;
              i.     Of equal or better quality than the trees which are lost;
              ii.    Sensitively incorporated into the development;
              ii.    The need for the use of the site outweighs the amenity of the woodland; or
              iii.   It can be demonstrated that there would be a net gain in the quality of any remaining
                     woodland through the enhancement of the recreational, amenity, landscape and/or
                     nature conservation value of the remaining woodland and that there would be
                     provision for its improved long-term management.

4.19 The proposed development makes provision for substantial areas of planting which significantly
      outweighs the loss of a limited number of trees as part of the development proposals. This aspect
      of the scheme is in accordance with Policy NH5 as set out above.

      Supplementary Planning Documents

4.20 In addition to the Statutory Development Plan, there are a number of Supplementary Planning
      Documents (SPD), which represent material considerations in the determination of planning
      applications.

4.21 Among the relevant SPD is that entitled ‘The impact of development on Biodiversity’ which was
      adopted by the Council on 18th March 2021. The SPD states that the DEFRA Biodiveristy Metric
      2.0 (or as subsequently amended), must be applied to all planning applications where requested
      to do so.

4.22 The SPD goes on to state that in order to demonstrate a measurable net gain in biodiversity,
      applicants should demonstrate that development achieves a minimum 10% net gain post
      development, when compared with the pre-development baseline.

4.23 Provision is made for offsetting of any shortfall of biodiversity enhancement relative to the target
      level of 10% net gain, either through the identification of off-site solutions or through payment of
      financial contributions to the local planning authority in order to enable suitable measures to be
      provided elsewhere.

      National Planning Policy Framework – NPPF (February 2019)
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4.24 Paragraph 7 of the NPPF states that the purpose of the planning system is to contribute to the
      achievement of sustainable development. Paragraph 8 sets out the three overarching objectives
      which contribute to sustainable development:

       a)     an economic objective – to help build a strong, responsive and competitive economy, by
              ensuring that sufficient land of the right types is available in the right places and at the right
              time to support growth, innovation and improved productivity; and by identifying and
              coordinating the provision of infrastructure;
       b)     a social objective – to support strong, vibrant and healthy communities, by ensuring that a
              sufficient number and range of homes can be provided to meet the needs of present and
              future generations; and by fostering a well-designed and safe built environment, with
              accessible services and open spaces that reflect current and future needs and support
              communities’ health, social and cultural well-being; and
       c)     an environmental objective – to contribute to protecting and enhancing our natural, built
              and historic environment; including making effective use of land, helping to improve
              biodiversity, using natural resources prudently, minimising waste and pollution, and
              mitigating and adapting to climate change, including moving to a low carbon economy.

4.25 Paragraph 11 sets out a presumption in favour of sustainable development. For decision-taking
      this means:

       approving development proposals that accord with an up-to-date development plan without
       delay; or where there are no relevant development plan policies, or the policies which are most
       important for determining the application are out-of-date, granting permission unless:
       the application of policies in this Framework that protect areas or assets of particular importance
       provides a clear reason for refusing the development proposed; or
       any adverse impacts of doing so would significantly and demonstrably outweigh the benefits,
       when assessed against the policies in this Framework taken as a whole.”

4.26 Paragraph 47 states that planning law requires applications for planning permission be
      determined in accordance with the development plan, unless material considerations indicate
      otherwise. Decisions on applications should be made as quickly as possible, and within statutory
      timescales unless a longer period has been agreed by the applicant in writing.

4.27 Section 6 of the NPPF supports the Government’s objective of building a strong, competitive
      economy. Significant weight should be placed on the need to support economic growth and
      productivity, taking into account both local business needs and wider opportunities for
      development (paragraph 60).

4.28 Section 8 of the NPPF promotes healthy and safe communities.                   Paragraph 91 seeks for
      developments to promote social interaction; be safe and accessible; and enable and support
      healthy lifestyles. This section is followed by Section 9 which promotes sustainable transport.
      Paragraph 108 states that development proposals should be assessed as to whether appropriate
      opportunities to promote sustainable transport modes have been taken up; safe and suitable
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      access to the site can be achieved for all users; and any significant impacts on the transport
      network, or on highway safety, can be mitigated to an acceptable degree.

4.29 Paragraph 109 states that development should only be refused on highways grounds if there
      would be an unacceptable impact on highway safety, or the residual cumulative impacts on the
      road network would be severe.

4.30 Section 11 of the NPPF concerns the effective use of land. Paragraph 117 states that Planning
      policies and decisions should promote an effective use of land in meeting the need for homes
      and other uses, while safeguarding and improving the environment and ensuring safe and healthy
      living conditions. Paragraph 122 sets out that planning policies and decisions should support
      development that makes efficient use of land.

4.31 Section 12 of the NPPF aims to ensure well-designed places are achieved. Paragraph 124
      emphasises that the creation of high-quality buildings and places is fundamental to what the
      planning and development process should achieve. Paragraph 127 requires planning policies
      and decisions to ensure that developments:

        a)     will function well and add to the overall quality of the area, not just for the short term but
               over the lifetime of the development;
        b)     are visually attractive as a result of good architecture, layout and appropriate and effective
               landscaping;
        c)     are sympathetic to local character and history, including the surrounding built environment
               and landscape setting, while not preventing or discouraging appropriate innovation or
               change (such as increased densities);
        d)     establish or maintain a strong sense of place, using the arrangement of streets, spaces,
               building types and materials to create attractive, welcoming and distinctive places to live,
               work and visit;
        e)     optimise the potential of the site to accommodate and sustain an appropriate amount and
               mix of development (including green and other public space) and support local facilities
               and transport networks; and
        f)     create places that are safe, inclusive and accessible and which promote health and well-
               being, with a high standard of amenity for existing and future users; and where crime and
               disorder, and the fear of crime, and the fear of crime, do not undermine the quality of life
               or community cohesion and resilience.

4.32 Section 13 is entitled Protecting Green Belt Land. This is particularly relevant to the consideration
      of this application.

4.33 Paragraph 134 of the NPPF sets out the five purposes of the Green Belt. These are:

        a)     to check the unrestricted sprawl of large built-up areas;
        b)     to prevent neighbouring towns merging into one another;
        c)     to assist in safeguarding the countryside from encroachment;
        d)     to preserve the setting and special character of historic towns; and
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       e)     to assist in urban regeneration, by encouraging the recycling of derelict and other urban
              land.

4.34 Paragraphs 143 and 144 relate to very special circumstances.

       Inappropriate development is, by definition, harmful to the Green Belt and should not be
       approved except in very special circumstances.

4.35 While Paragraph 144 states that:

       When considering any planning application, local planning authorities should ensure that
       substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not
       exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other
       harm resulting from the proposal, is clearly outweighed by other considerations

4.36 Paragraph 147 refers specifically to renewable energy developments in the Green Belt. The
      policy states that:

       When located in the Green Belt, elements of many renewable energy projects will comprise
       inappropriate development. In such cases developers will need to demonstrate very special
       circumstances if projects are to proceed. Such very special circumstances may include the wider
       environmental benefits associated with increased production of energy from renewable sources.

4.37 Paragraph 147 has particular relevance to the consideration of this application. It is
      acknowledged that in this instance it is necessary to explain why the provision of renewable
      energy alongside important transport infrastructure represents very special circumstances.

4.38 Section 14 concerns meeting the challenge of climate change, flooding and coastal change.
      Paragraph 148 states that the planning system should support renewable and low carbon energy
      and associated infrastructure.

4.39 Section 15 sets the approach to conserving and enhancing the natural environment. Para 170
      states that development should, wherever possible, help to improve local environmental
      conditions such as air and water quality.

4.40 Paragraphs 174-177 seek to address impacts on habitats and biodiversity. Paragraph 175 states
      that if significant harm to biodiversity resulting from a development cannot be avoided,
      adequately mitigated, or, as a last resort, compensated for, then planning permission should be
      refused. Additionally, development on land within or outside a Site of Special Scientific Interest,
      and which is likely to have an adverse effect on it, should not normally be permitted.

4.41 Paragraphs 178-183 of Section 15 concern pollution and ground conditions. Planning decisions
      should ensure that a site is suitable for its proposed use taking account of ground conditions and
      any risks arising from land instability and contamination.
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4.42 Paragraph 202 of the Framework is also relevant to the consideration of development proposals
      where the proceeds from the development would be used primarily for the purposes of securing
      the future conservation of designated heritage assets. In this respect, correspondence with the
      Knebworth Estates has confirmed that income from the lease will contribute to the preservation
      and maintenance of the historic Knebworth Park, its buildings, roadways and amenities, avenues
      and woodland, helping to maintain the heritage assets and safe public access.

      Other Material Considerations

4.43 Other material policy considerations at the local level include the Stevenage Borough Climate
      Change Strategy (September 2020) and the Council’s declared Climate Emergency (May 2019),
      both of which support initiatives to develop low carbon technologies to reduce the impact of
      transport on the environment. At the national level, policy support for electric vehicle charging
      infrastructure is unequivocal, as set out in the Government’s ‘Road to Zero Strategy’ (July 2018),
      the Automated and Electric Vehicles Act (2018) and the Government’s announcement to bring
      forward a ban on the sale of petrol/diesel cars to 2030. The recent appeal decision (enclosed at
      Appendix 1), for an electric vehicle charging station in the Cotswold District of Gloucestershire
      has found that all of these documents are material considerations in making planning decisions.

      Stevenage Green Belt Review (September 2015)

4.44 Stevenage Borough Council instructed Amec Foster Wheeler to review the areas of the Green
      Belt in the Borough. This is referred to in the following section, and in particular its findings in
      relation to the land parcel of which the site forms a part.

4.45 Given the findings of the recent Green Belt review, which concludes that the site makes only a
      limited contribution to the five purposes of the Green Belt set out in Paragraph 134 of the NPPF,
      it is considered that the proposed a GRIDSERVE Electric Forecourt® would only result in limited
      harm to the openness of the Green Belt or the purposes of including land within it. The findings
      of the Green Belt Review in the context of this particular site and the land parcel of which it forms
      a part are examined further below.

      Planning Policy Summary

4.46 Local and national planning policy is supportive of new electric vehicle charging infrastructure,
      in order to reduce carbon emissions and improve air quality. The Local Plan does not explicitly
      support investment in electric vehicle charging infrastructure throughout the Borough. However,
      these are explicitly required as part of strategic, large-scale developments to the north and west
      of Stevenage.
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4.47 The site-specific planning issues raised by this proposal are:

        i)     The location of the site within the Green Belt, where this form of development is
               considered to be inappropriate development. It is acknowledged that many aspects of the
               proposal are inappropriate development when considered in relation to the letter of Green
               Belt policy. However, the provision of an Electric Forecourt® is considered to represent
               very special circumstances which would outweigh the harm (by definition) to the openness
               of the Green Belt that would result from the proposal.

        ii)    The extent to which the proposal could be accommodated elsewhere in the Borough and
               why this site is the most appropriate for the provision of a GRIDSERVE Electric Forecourt
               ®. While new development would generally be directed to previously developed land, the
               specific locational requirements of an Electric Forecourt ® mean that it is only viable to
               provide this in a limited number of locations where there is convenient access to the
               strategic highway network and a point of connection to the grid infrastructure.

        iii)   The design and layout of the site in terms of its impact on the countryside and the
               landscape. As set out below, the site is well contained and the proposed development
               would not result in the prospect of significant visual impacts.

        iv)    The sustainability of the proposed development in terms of minimising energy use;

        v)     The highway implications of the proposal in terms of impact on the local highway network,
               pedestrians and cycles;

        vi)    The potential impact of the proposal on the ecology of the site and whether the
               development will result in a net gain in biodiversity;

        vii) The ability of the site to accommodate the proposal with a satisfactory drainage solution;
               and

        viii) The extent to which the benefits of the proposal in terms of reducing carbon emissions,
               job creation weigh in favour of the proposal.

4.48 These issues are considered further in Section 5 below.
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