The official Highway Development Control comments have been submitted today and we're pleased to see that they recommend REFUSAL of the planning application.
Hopefully our RBWM Councillors will read the document, all the letters of objection they have received, and the petition signed by 200+ residents, other recommendations for refusal by Bray Parish Council & the Flood Authority, and take them into account when the application is put to the vote.
You can download the original document if you click here (or here) or read it below.
All of the planning documents, the Bray Parish Council's comments (also recommending refusal) and 100+ letters of objection can be downloaded from the RBWM website here.
Site Location
Hibbert Road is a local distributor that provides an alternative link between the A308 Braywick Road and the B3022 Bray Road. The road is also subjected to a 30mph speed limit.
Between its junction with the A308 Braywick Road and the entrance to the Braywick Car Park, Hibbert Road has footways along both sides of the road. However, there is only a single footway on the south side of Hibbert Road running between the car park entrance and The Causeway.
There are no pedestrian facilities along Hibbert Road from The Causeway towards the B3022 Bray Road. To the west of the school there are no pedestrian crossing facilities across the A308 Braywick Road for parents who wish to walk to the school.
The site comprises the school, formerly known as Winbury Primary School and Braywick Nature Reserve and car park.
The school is currently served by an existing access located to the south east of the site that offers wholly restricted views in both directions due to the absence of a footpath and the horizontal alignment of Hibbert Road. The proposed plan shows the retention of this access. However, given the limited views offered the Highway Authority recommend that this access is closed.
Access to the new school will be via Braywick Road car park and through double gates located north-west of the site boundary.
Access by Service Vehicles
The submission includes a swept path analysis of a small refuse vehicle manoeuvring to and from the site. As we understand RBWM Waste Management only collects recycling materials from the school and this undertaken by the small vehicle depicted in the plan.
Unfortunately, the submission again is silent on what provisions have been made to collect not only waste materials, but also the recycling materials when the number of pupils reaches 210. The plan excludes details of the waste/recycling storage facility, but infers that a waste vehicle will enter the car park and collect the waste from the main entrance. The distance between a refuse vehicle stationed in the car park and the main entrance exceeds the current guidelines detailed below:
BS 5906:2005 recommends that waste operatives should not be expected to move two- wheeled containers more than 15m between collection point and vehicle, and four-wheeled containers no more than 10m. Collection vehicles must be able to wait legally within 15 metres of all dustbin/sack collection points and within 10 metres of bulk bin collection points.
With reference to the Proposed Site Plan [6APES072/P/050.011 Rev 10] the distance between a vehicle parked in the car park and the main entrance gates exceeds 40m.
Parking Requirements
The previous school and the proposed site offers no off street parking facility. However, as part of the lease agreement 8 parking spaces in the Braywick car park will be given over to the school for staff and disabled users.
With reference to the Authority’s parking standard the new school attracts a parking demand of 1 space per 1 full-time equivalent staff, which includes visitors and parents.
Provisions should also be made either within the school premises or on the highway for a loading area for a school bus/coach and where necessary sufficient space allowed for buses to enter and leave the site safely.
Based upon the submission the servicing arrangement will take place within Braywick Car Park. Unfortunately, the application is silent with regard to whether a bus or coach will be used by the school and whether the appropriate provisions are in place for this.
From a historical context the Highway Authority has received complaints about inconsiderate parking along Hibbert Road, when the former Winbury School operated with 90 pupils. The consequence of some parents parking partly on the footway/carriageway and generally on the carriageway close to the school effectively reduced the free flow of traffic in the area, resulting in sections of Hibbert Road reverting to a one way operation.
Braywick Car Park was not only used by dog walkers and visitors to the nature reserve, but also by parents. The car park currently provides circa 44 spaces which will reduce to about 36 spaces as a consequence of the application.
Traffic Generation
The applicant has undertaken a ‘Mode of Transport to School’ survey for the current school year containing circa 27 pupils. These results when adjusted to reflect the mode of transport for a school with the 210 pupils suggest that 84% of parents will travel by car or taxi, 10% walking to school, and 5% travelling by cycle and scooter.
The submission includes a swept path analysis of a small refuse vehicle manoeuvring to and from the site. As we understand RBWM Waste Management only collects recycling materials from the school and this undertaken by the small vehicle depicted in the plan.
Unfortunately, the submission again is silent on what provisions have been made to collect not only waste materials, but also the recycling materials when the number of pupils reaches 210. The plan excludes details of the waste/recycling storage facility, but infers that a waste vehicle will enter the car park and collect the waste from the main entrance. The distance between a refuse vehicle stationed in the car park and the main entrance exceeds the current guidelines detailed below:
BS 5906:2005 recommends that waste operatives should not be expected to move two- wheeled containers more than 15m between collection point and vehicle, and four-wheeled containers no more than 10m. Collection vehicles must be able to wait legally within 15 metres of all dustbin/sack collection points and within 10 metres of bulk bin collection points.
With reference to the Proposed Site Plan [6APES072/P/050.011 Rev 10] the distance between a vehicle parked in the car park and the main entrance gates exceeds 40m.
Parking Requirements
The previous school and the proposed site offers no off street parking facility. However, as part of the lease agreement 8 parking spaces in the Braywick car park will be given over to the school for staff and disabled users.
With reference to the Authority’s parking standard the new school attracts a parking demand of 1 space per 1 full-time equivalent staff, which includes visitors and parents.
Provisions should also be made either within the school premises or on the highway for a loading area for a school bus/coach and where necessary sufficient space allowed for buses to enter and leave the site safely.
Based upon the submission the servicing arrangement will take place within Braywick Car Park. Unfortunately, the application is silent with regard to whether a bus or coach will be used by the school and whether the appropriate provisions are in place for this.
From a historical context the Highway Authority has received complaints about inconsiderate parking along Hibbert Road, when the former Winbury School operated with 90 pupils. The consequence of some parents parking partly on the footway/carriageway and generally on the carriageway close to the school effectively reduced the free flow of traffic in the area, resulting in sections of Hibbert Road reverting to a one way operation.
Braywick Car Park was not only used by dog walkers and visitors to the nature reserve, but also by parents. The car park currently provides circa 44 spaces which will reduce to about 36 spaces as a consequence of the application.
Traffic Generation
The applicant has undertaken a ‘Mode of Transport to School’ survey for the current school year containing circa 27 pupils. These results when adjusted to reflect the mode of transport for a school with the 210 pupils suggest that 84% of parents will travel by car or taxi, 10% walking to school, and 5% travelling by cycle and scooter.
The Highway Authority is of the view that given the limited opportunities for parents and pupil
to travel by foot or cycle, car borne trips are likely to be in the 90% range. The survey was
undertaken during September 2014 when the weather conditions are inviting and would
attract some parents who would consider adopting other modes of travel. Clearly a more
balanced result would have been to undertake a similar survey during the winter months.
Park and Stride
The applicant states that a majority of the pupils will be accessing the school via the purpose built footpath from the ‘Park & Stride’ drop-off point at Braywick Sports and Recreational Ground, and those parents that do drive into Braywick Nature Reserve Car Park will effectively be turned away and asked to use the Braywick Sports Ground. We question how this can be enforced since this is a public car park which the applicant has no control over its use. A further complication is that parents are permitted to park in the Nature Reserve Car Park out of normal school hours.
Presently, there are no restrictions preventing parents from parking in the Nature Reserve Car Park at any time during the day or on Hibbert Road, when dropping-off or picking -up their children.
The submission fails to acknowledge that there will be seasonal variations in the numbers choosing the Park & Stride option, and especially during inclement weather conditions.
Presently, the purpose built path is unlit and can hardly be considered an inviting prospect for parents and staff parked in the Sport Ground during the autumn and winter period. The Highway Authority understands that concerns have also been raised about the adequacy of the access road to the ‘Park & Stride’ and that this would be a further deterrent to parents and staff.
No measures are proposed in the Transport Assessment to address servicing arrangement, the increase traffic generation nor does it acknowledge that these trips will vary significantly during the seasons.
The School Travel Plan (STP) accompanying the submission states that,
‘Parking on Hibbert Road, Gas Lane or The Causeway is not permitted for school traffic at any time’. To reiterate there are no restrictions preventing parents from parking in these areas.
The STP states that 8 staff and parents using the Early Birds and Evening Owls club will be issued a parking permit. As explained earlier this is a public car park.
The plan also mentions introducing incentive schemes to encourage walking and cycling by staff and parents.
At this point we should mention that the purpose of a School Travel Plan is to encourage parents, visitors and staff to adopt other modes of transport, thereby reducing the dependency on car borne trips. However, there are occasions whereby despite the introduction of the improved measures/incentives, the site location, the traffic conditions and the highway infrastructure is so poor there has not been a commensurate reduction in traffic levels.
Whilst we accept that there may be a number of shared trips and siblings already in attendance at the school, the increase nevertheless is significant and would further increase vehicular activity into the area, short term and ad hoc parking as well as inconsiderate parking on Hibbert Road and parking in Braywick Nature Reserve Car Park.
Park and Stride
The applicant states that a majority of the pupils will be accessing the school via the purpose built footpath from the ‘Park & Stride’ drop-off point at Braywick Sports and Recreational Ground, and those parents that do drive into Braywick Nature Reserve Car Park will effectively be turned away and asked to use the Braywick Sports Ground. We question how this can be enforced since this is a public car park which the applicant has no control over its use. A further complication is that parents are permitted to park in the Nature Reserve Car Park out of normal school hours.
Presently, there are no restrictions preventing parents from parking in the Nature Reserve Car Park at any time during the day or on Hibbert Road, when dropping-off or picking -up their children.
The submission fails to acknowledge that there will be seasonal variations in the numbers choosing the Park & Stride option, and especially during inclement weather conditions.
Presently, the purpose built path is unlit and can hardly be considered an inviting prospect for parents and staff parked in the Sport Ground during the autumn and winter period. The Highway Authority understands that concerns have also been raised about the adequacy of the access road to the ‘Park & Stride’ and that this would be a further deterrent to parents and staff.
No measures are proposed in the Transport Assessment to address servicing arrangement, the increase traffic generation nor does it acknowledge that these trips will vary significantly during the seasons.
The School Travel Plan (STP) accompanying the submission states that,
‘Parking on Hibbert Road, Gas Lane or The Causeway is not permitted for school traffic at any time’. To reiterate there are no restrictions preventing parents from parking in these areas.
The STP states that 8 staff and parents using the Early Birds and Evening Owls club will be issued a parking permit. As explained earlier this is a public car park.
The plan also mentions introducing incentive schemes to encourage walking and cycling by staff and parents.
At this point we should mention that the purpose of a School Travel Plan is to encourage parents, visitors and staff to adopt other modes of transport, thereby reducing the dependency on car borne trips. However, there are occasions whereby despite the introduction of the improved measures/incentives, the site location, the traffic conditions and the highway infrastructure is so poor there has not been a commensurate reduction in traffic levels.
Whilst we accept that there may be a number of shared trips and siblings already in attendance at the school, the increase nevertheless is significant and would further increase vehicular activity into the area, short term and ad hoc parking as well as inconsiderate parking on Hibbert Road and parking in Braywick Nature Reserve Car Park.
Much is mentioned about incentivising the parents and staff and introducing an Action Plan
with agreed targets and objectives set out in the STP. However, may I remind the applicant
that the STP should not be viewed as the panacea for addressing the potential increase in
traffic generation and parking associated with this scheme.
The National Planning Policy Framework states,
‘Development should only be prevented or refused on transport grounds where the
residual cumulative impacts of development are severe’.
This proposal would lead to a significant increase in vehicular activity into the area. For this and the reasons mentioned above it is our conclusion that the site does not lend itself to further expansion beyond that already permitted. Therefore, we recommend that permission is refused.
HDC Officer: M D Andrews
Date: 30 July 2015
The National Planning Policy Framework states,
‘Development should only be prevented or refused on transport grounds where the
residual cumulative impacts of development are severe’.
This proposal would lead to a significant increase in vehicular activity into the area. For this and the reasons mentioned above it is our conclusion that the site does not lend itself to further expansion beyond that already permitted. Therefore, we recommend that permission is refused.
HDC Officer: M D Andrews
Date: 30 July 2015
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