Here is another letter of objection to the current planning application which may give some insight into our concerns, and the history of the application so far:
BACKGROUND: A HISTORY OF MISLEADING STATEMENTS & COMMENTS BY BELLEVUE PLACE EDUCATION TRUST (BPET) AND MISLEADING INFORMATION IN THESE PLANS
At the very first presentation by the School at Bray Village hall in 2012, before it opened, I asked representatives of Braywick Court School (BPET) if the site was big enough for a full sized primary school, and if they planned any development or building work on the site - after all, Winbury school, on that site, was a small, village school that only ever had up to 90 pupils. Braywick Court School is a full sized Primary School which intends to eventually have 210 pupils. I was told categorically “no that won’t be necessary”.
Deceptive & misleading. It would have been obvious to the Trust/School, with their experience, that the buildings on the site, and the site in general was no where near large enough for a full sized primary school, yet they were telling prospective parents & residents that no development was be required, or would happen.
In the school’s own promotional documentation at the time they changed their position, saying 'existing buildings will be refurbished'. We now see this to be far from the case. These plans are to completely demolish the existing building with a footprint of 319m2 and replace it with one of 784m2. The footprint of the proposed development is therefore almost 2.5 times bigger than that of the existing building. The total floorspace within the new building is 1211m2 which is almost 3.5 times bigger than the one it replaces (350m2). FAR from the simple ‘refurbishment’ originally announced, and completely ‘inappropriate development’ on this site.
The allocated playground space on the site is woefully inadequate for a school of this size, (one only needs to compare the site on google maps with similar primary schools in the area to see how obvious this is), so who is to say down the line, should permission for this development be granted, that the school will not seek to expand further, and take over more land on Braywick Park, or the Formal Gardens there for playground space (as I have heard was initially requested by the School)? On the basis of what would seem dishonest & misleading statements so far about the ACTUAL intentions of BPET on behalf of the School, one would be forgiven for being skeptical at what may happen post-build.
The school has already used the tactic of establishing momentum from a now already operating school (one that was given the go-ahead to open before these plans were even submitted, let alone approved) to put pressure on the council to approve the plans & also hidden their full intentions from the public in the past so you could be justifiably worried to expect a similar technique in the future.
The new plans say “the old Winbury School buildings are out of date, do not meet modern teaching standard requirements and are inefficient in design”. If that is true, why was this not mentioned & considered at the beginning?
Why did the Council buy the site in the first place when it is so glaringly obvious that it is too small for a full sized primary school, and would apparently require such radical redevelopment & squeezing of a much bigger building in there?
Why were alternative sites not considered?
Why, after the first application was withdrawn were alternative sites still not considered, despite over 200 signatures in a petition asking for this, and an alternative site suggested by members of Bray Parish Council at the meeting where BPC recommended the previous application be refused?
These plans are being framed as an 'expansion' to an already established school, which inherently puts pressure on the council to approve them. The school should not have been allowed to even start on this site without definite, approved plans, especially as it is so clear to anyone with common sense that it is much too small for a school this size, will have huge problems with access, traffic & parking, and negatively impact the park because of the size of the development & damage it will cause. Parents that signed up to send their children there are now faced with uncertainty for their future, and extra pressure will now be on the council to allow the development to go ahead from those families as a result. Given the deceptive and misleading nature of Bellevue Place Education Trust’s campaign so far I wouldn’t be surprised if that was a deliberately engineered tactic all along.
Bellevue Place Education Trust, are no strangers to objectionable and unpopular planning applications either, (again, google it & you will see). Which would also lead one to be skeptical about the changes in the plans that have transpired, from ‘no development required’ at the beginning, then to ‘some refurbishment’ to the now-proposed ‘demolish the whole (historical) site and build a huge, out of proportion, inappropriate, brand new modern building in its place, coupled with the tactics used so far: not telling parents about the uncertainty of the site & large development apparently required, (to get them signed up and use them to put pressure on the council later on), deceptive statements made to residents early on to hide the reality of the massive, destructive future development plans, and importantly errors, omissions, and misleading information these plans themselves.
This proposed building/development which:
- is contrary to national and local planning policy,
- includes insufficient landscaping and will result in significant loss of trees
- would damage the natural environment
- is inappropriate development within the Green Belt,
- adversely affects the openness of the Green Belt,
- would result in the loss of open space in Braywick Park which is important to the visual and environmental quality of the area
- would have an adverse impact on he Green Way recreational route
- is not in keeping with the scale or character of the local area,
- has inappropriate layout and density
- will have negative impact on the amenity of existing residential properties through noise, overlooking, overshadowing, loss of privacy etc.
- reduces the amount of car parking available
- would impact the setting of listed buildings
[See the other letters of objection submitted for more detailed background and evidence to support these various points in relation to the NPPF – I won’t repeat them here to keep this letter shorter!]
ARTISTS’ IMPRESSIONS & IMAGES IN THE PLANS ARE MISLEADING, STILL SHOW TREES IN PLACE THAT WILL ACTUALLY BE REMOVED, AND DON’T EVEN MENTION THE FACT THAT MANY TREES ARE TO BE REMOVED
Stylised 'artistic impressions' of selected views of the proposed development are included in the plans but no accurate renderings of what it would actually look like in real life are, and several important viewpoints are completely ignored. Some of the images show trees in place, ones that would screen views of the building, still there in the picture after development! Those are trees that would be removed permanently during construction. You have to check the tree survey to discover this as the plans do not mention the fact that a lot of trees will definitely be removed and many others may also be damaged so much that they have to be completely removed during the construction. (See other correspondence & the various letters of objection for exact details).
Again, misleading & deceptive – the application hides the reality of what the plans will actually result in.
If you visit the site and look around the perimeter it is very clear how many established trees are at risk. Also please read Helen Leonard from the Tree Team’s cunsultee comments:
“The NPPF states: ‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss;’
The woodland immediately to the east and north of the site boundary, in Braywick Park nature area, shows up as ‘Priority Habitat Inventory – Deciduous Woodland (England) on Defra’s ‘Magic’ website. In addition, data from Thames Valley Environmental Records Centre shows the woodland to the east is probably ancient woodland… The direct impact on trees in the woodland, if found to be ancient woodland, would be unacceptable.”
The plans also don't include important views that would show the real visual impact of the building. No view from it looming over the Dell for example, (part of the local Nature Reserve), certainly not the likely view should the 4 Yew trees within the Dell be damaged and removed during construction, or at least ‘heavily pruned’. If you visit the site to get an idea of how close the new building will be to the nature area where the yew trees are it is difficult to see how they will not be damaged to the point of them having to be completely removed during the construction process. There is certainly no mention of any special approaches to the construction in order to avoid any damage either. Also no images showing the impact of the light pollution from the large windows on that side that will affect the same area. (See other letters of objection & consultee comments elaborating on the ecological problems from the resultant light pollution from the new building).
One view included (from the Braywick Cemetary side entrance looking towards the School site) included in the plans also appears to have been chosen to cover up the reality of how the building will dominate the Formal Gardens in Braywick Park at Hibbert Road. Anyone familiar with that part of the park knows there’s a huge bush and trees inbetween the cemetery entrance & the school, it’s 130m away from the school, this is all the image shows. Why no view from the other side of this? To misrepresent the reality of what this will look like should the build go ahead? Again, misleading and seemingly an attempt to cover up important realities of what this would look like in practice.
The plans make no reference to the tree survey and they should. It is important that the council and the public are aware of actually how many trees will be lost due to this development in the park area. Again it looks like BPET are deliberately trying to hide these facts from the public, and confuse & bamboozle Councillors & Planning Panel members trying to understand the key points in order to make a considered decision on approval or not.
IMPARTIALITY & TRANSPARENCY CONCERNS
While Cllr Dudley has so far been helpful & communicative in most correspondence on this issue, I wonder (and worry), how an unbiased, democratic decision can be made by this council, when its leader has been so openly in support of Braywick Court School since the beginning in local press & social media posts, has a working relationship with Place group (part of Bellevue Place Education Trust) from his involvement with them during the development of Holyport college and has openly supported the school further using his role as governor of Riverside to give them a temporary home there during building work should these plans go ahead.
I also understand another influential member of the Council, and Bray Parish Council, Cllr Burbage was the main driving force behind RBWM buying this site, so he would presumably also be strongly invested in the success of the School’s application to develop on this specific site. (I will write to them separately about this to clarify if they will be voting at the Bray Parish Council meeting, and the eventual Development Control Panel – Cllr Dudley made it clear that he would abstain last time because of the declared interest so I would hope the same to be true this time, as with the Parish Council vote). [Edit - Cllr Dudley left the room and didn't vote though he interfered by suggesting the council could build a new car park slightly closer to the school on the driving range site, Burbage was mysteriously running late and arrived immediately after the vote, so avoided answering the issue ^SBP].
Given the political climate and allegations of bullying etc at RBWM of late (though we are assured things are changing & a sensible decision on this application would be a good way to show that), how are we to be guaranteed a democratic, fair, and unbiased decision is reached if such powerful members of the cabinet & council are so openly supporting the school, in particular, the use of this particular site for it? How do we know other councilors on the Development Control Panel or council employees will not be put under undue pressure to vote in favour when it goes to panel, or to give favourable supporting reports on the plans?
Which leads me to the Highways comments... The previous Braywick Court School planning application on this site was recommended for refusal by Highways for many important reasons, all of which still remain in the new planning application seeing as the travel plan has not changed at all (bar the addition of uneccessary parking restrictions on Hibbert Road, but I’ll get to that later). Yet this time, Highways have NOT recommended for refusal. Why is this?
INCREASED TRAFFIC, ACCESS & SAFETY PROBLEMS
Para. 35 of the NPPF states that 'developments should be located and designed where practical to:
• accommodate the efficient delivery of goods and supplies;
• give priority to pedestrian and cycle movements, and have access to high quality public transport facilities;
• create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;
• consider the needs of people with disabilities by all modes of transport.'
RBWM LP Policy DG1 (Design Guidelines) states inter alia:
7) developments should provide adequate off street parking for vehicles and cycles in accordance with the Borough Council's adopted standards as set out in appendix 7. Such provision should be well landscaped and lend itself to a reasonable degree of surveillance;
8) development should provide adequate vehicle access, (including access for refuse collection and emergency vehicles), loading and unloading facilities and circulation space within the site as appropriate;
9) the traffic generated by the proposed development should not have an unacceptable effect on the local road network and the environment of the locality.
RBWM's Parking Strategy 2004 states in para. 9.10.2: Bus/coach loading and waiting areas either on the premises or on the highway will be required for most new schools and tertiary education facilities. Sufficient space should be reserved to allow buses to enter and leave the site safely.
As was stated with respect to the first application (15/00801) the School Travel Plan is not enforceable and therefore there is nothing to stop parents from using the Nature Centre car park. Not a big problem currently as there are only 2 classes, so 60 pupils, but at a full capacity of 210 it will become a huge issue. Parents are supposed to sign an agreement promising to only use the ‘park & stride’ car park, 500m away along a dark, waterlogged path, unpopular with parents/carers. This promise cannot be legally enforced & will be easily forgotten once the school has got planning permission & no longer has any reason to maintain the system, no sanctions can be taken against them to legally prevent parents doing what they like. But by then the damage will have already been done and it will be too late.
There is no difference as far as traffic/access/parking problems go between this application and the previous one to which the Highways Engineers objected. Why have the Highways Engineers changed their view?
The school site itself cannot accommodate the delivery of goods and services according to the plan submitted, vehicles would be required to drive into the Nature Centre car park and stop, either blocking the disabled car parking spaces or the entrance to the Nature Centre. Waste collection would also require collection vehicles entering the car park to gain access to the bins to be located along side the footpath (behind the Braywick Park sign); the vehicles would stop in the entrance to the Nature Centre. This arrangement would increase conflict between traffic and pedestrians in a well-used public car park and would cause noise and disturbance to users of the formal gardens of Braywick Park and the Nature Centre gardens.
The proposed development reduces the amount of car parking available:
LP Policy P4 states: The Borough Council will require all development proposals to provide car parking in accordance with the adopted standards as set out in appendix 7. (This has been superseded by Parking Strategy 2004 which states that the maximum required is 1 space per 1 full time equivalent for staff.)
LP POLICY P5 states: …… In all cases, on site operational car parking will be required.
The planning application site does include the Park and Stride car park (500m away) so theoretically 'on-site' operational car parking would be provided. However, there is no way to enforce the Travel Plan and thus potentially the Hibbert Road car park would be used by parents, to the detriment of the general public wishing to enjoy Braywick Park.
The proposed development is therefore contrary to national and local planning policy.
OBJECTION TO PROPOSED PARKING RESTRICTIONS ON HIBBERT ROAD
The Parking/Waiting restrictions on Hibbert Road in the proposal (ie single or double yellow lines on Hibbert Road) is something I strongly object to, and they seem to be the only new addition to anything related to traffic/parking in the plans. WHICH WERE NOT INCLUDED IN THE SCHOOL’S LAST PUBLIC EXHIBITION, I only spotted them hidden away in the last page of the travel assessment. (I mention this again as an illustration of lack of openness & things being hidden by the Trust behind the School & these plans).
I have always parked on Hibbert road, for the 15+ years I've lived here, as do many of my neighbours, some from Gas Lane, and also Ashley Cottage & the Old Coach House B&B on Braywick Road. We have no alternative off-street safe places to park our cars (you will be aware of the amount of car crime in the Bray area, so directly outside our houses is our only safe option). Even if some kind of ‘Residents only’ system were introduced it would just add inflexibility and inconvenience for those of us that live here, and our guests visiting. At the extreme end we would simply no longer be able to park safely near our houses, and the whole scheme wouldn’t solve the problem it is supposedly meant to anyway.
Since when did double yellow lines stop stressed out parents running late from quickly parking up inconsiderately on the pavement, on double yellow lines to run in and drop off their children? The reality if restrictions were put in place on Hibbert Road it would just be that residents could no longer park safely outside their homes & determined parents would still be able to get away with parking up briefly on Hibbert Road if they really wanted to.
There are (and can be) no legal restrictions preventing only Parents/Carers Parking, or dropping off/picking up in the Nature Reserve Car Park, which is even closer to the school, so if parents were going to ‘break the rules’ of their (unenforceable) Travel Plan then they would be more likely to drive right in the car park anyway & not on Hibbert Road, as it is much closer to the school entrance. Parking restrictions on Hibbert Road are not needed & should not be considered as part of this application.
The School's Transport Assessment in para 4.10 says this is 'an additional safeguard against parent/carer parking' that 'is a suggestion made by residents'. I dispute that statement. It has certainly never been brought up as a suggestion at any Hibbert Road/Gas Lane Neighbourhood watch meetings & scanning through the ‘consultation’ questionnaire responses I see nothing there from residents requesting it. (More misleading & misrepresentative information in the plans.)
If Braywick Court School's Travel Plan & 'Home School Agreement' is as 'robust' as claimed, then all parents/carers will use the 'Park & Stride' car park by Braywick Sports Ground. That is the key promise which the Travel Plan hinges on, and the School's only, (and unenforceable) answer to residents' concerns about all the extra traffic, access & parking problems a school of this size, on this site will create. Concerns which were shared by the Highway Development Control when they recommended the previous application be refused permission, which led to its withdrawal. Seeing as there is no change in the travel plan in this application I am puzzled as to why the Highway Development Control would now NOT recommend refusal. Unless they had been put under pressure to do so?
THE ALTERNATIVE
No need has been put forward for the school for 210 pupils to be specifically located on the Hibbert Road site. The school could be located anywhere in the Maidenhead area, given the admissions policy and the current intake of pupils.
As other letters of objection have pointed out, and the petition last year, another, larger and more suitable site exists within the Braywick Sports area, only 500m from the existing site, by the Target Shooting club, which apparently is available, but seems to have been dismissed from consideration by the applicant without any apparent reason so far. It is already owned by RBWM & was originally identified as a potential site for Oldfield previously.
-It would solve the parking and access issues, as it is right by the ‘park and stride’ car park.
At the very first presentation by the School at Bray Village hall in 2012, before it opened, I asked representatives of Braywick Court School (BPET) if the site was big enough for a full sized primary school, and if they planned any development or building work on the site - after all, Winbury school, on that site, was a small, village school that only ever had up to 90 pupils. Braywick Court School is a full sized Primary School which intends to eventually have 210 pupils. I was told categorically “no that won’t be necessary”.
Deceptive & misleading. It would have been obvious to the Trust/School, with their experience, that the buildings on the site, and the site in general was no where near large enough for a full sized primary school, yet they were telling prospective parents & residents that no development was be required, or would happen.
In the school’s own promotional documentation at the time they changed their position, saying 'existing buildings will be refurbished'. We now see this to be far from the case. These plans are to completely demolish the existing building with a footprint of 319m2 and replace it with one of 784m2. The footprint of the proposed development is therefore almost 2.5 times bigger than that of the existing building. The total floorspace within the new building is 1211m2 which is almost 3.5 times bigger than the one it replaces (350m2). FAR from the simple ‘refurbishment’ originally announced, and completely ‘inappropriate development’ on this site.
The allocated playground space on the site is woefully inadequate for a school of this size, (one only needs to compare the site on google maps with similar primary schools in the area to see how obvious this is), so who is to say down the line, should permission for this development be granted, that the school will not seek to expand further, and take over more land on Braywick Park, or the Formal Gardens there for playground space (as I have heard was initially requested by the School)? On the basis of what would seem dishonest & misleading statements so far about the ACTUAL intentions of BPET on behalf of the School, one would be forgiven for being skeptical at what may happen post-build.
The school has already used the tactic of establishing momentum from a now already operating school (one that was given the go-ahead to open before these plans were even submitted, let alone approved) to put pressure on the council to approve the plans & also hidden their full intentions from the public in the past so you could be justifiably worried to expect a similar technique in the future.
The new plans say “the old Winbury School buildings are out of date, do not meet modern teaching standard requirements and are inefficient in design”. If that is true, why was this not mentioned & considered at the beginning?
Why did the Council buy the site in the first place when it is so glaringly obvious that it is too small for a full sized primary school, and would apparently require such radical redevelopment & squeezing of a much bigger building in there?
Why were alternative sites not considered?
Why, after the first application was withdrawn were alternative sites still not considered, despite over 200 signatures in a petition asking for this, and an alternative site suggested by members of Bray Parish Council at the meeting where BPC recommended the previous application be refused?
These plans are being framed as an 'expansion' to an already established school, which inherently puts pressure on the council to approve them. The school should not have been allowed to even start on this site without definite, approved plans, especially as it is so clear to anyone with common sense that it is much too small for a school this size, will have huge problems with access, traffic & parking, and negatively impact the park because of the size of the development & damage it will cause. Parents that signed up to send their children there are now faced with uncertainty for their future, and extra pressure will now be on the council to allow the development to go ahead from those families as a result. Given the deceptive and misleading nature of Bellevue Place Education Trust’s campaign so far I wouldn’t be surprised if that was a deliberately engineered tactic all along.
Bellevue Place Education Trust, are no strangers to objectionable and unpopular planning applications either, (again, google it & you will see). Which would also lead one to be skeptical about the changes in the plans that have transpired, from ‘no development required’ at the beginning, then to ‘some refurbishment’ to the now-proposed ‘demolish the whole (historical) site and build a huge, out of proportion, inappropriate, brand new modern building in its place, coupled with the tactics used so far: not telling parents about the uncertainty of the site & large development apparently required, (to get them signed up and use them to put pressure on the council later on), deceptive statements made to residents early on to hide the reality of the massive, destructive future development plans, and importantly errors, omissions, and misleading information these plans themselves.
This proposed building/development which:
- is contrary to national and local planning policy,
- includes insufficient landscaping and will result in significant loss of trees
- would damage the natural environment
- is inappropriate development within the Green Belt,
- adversely affects the openness of the Green Belt,
- would result in the loss of open space in Braywick Park which is important to the visual and environmental quality of the area
- would have an adverse impact on he Green Way recreational route
- is not in keeping with the scale or character of the local area,
- has inappropriate layout and density
- will have negative impact on the amenity of existing residential properties through noise, overlooking, overshadowing, loss of privacy etc.
- reduces the amount of car parking available
- would impact the setting of listed buildings
[See the other letters of objection submitted for more detailed background and evidence to support these various points in relation to the NPPF – I won’t repeat them here to keep this letter shorter!]
ARTISTS’ IMPRESSIONS & IMAGES IN THE PLANS ARE MISLEADING, STILL SHOW TREES IN PLACE THAT WILL ACTUALLY BE REMOVED, AND DON’T EVEN MENTION THE FACT THAT MANY TREES ARE TO BE REMOVED
Stylised 'artistic impressions' of selected views of the proposed development are included in the plans but no accurate renderings of what it would actually look like in real life are, and several important viewpoints are completely ignored. Some of the images show trees in place, ones that would screen views of the building, still there in the picture after development! Those are trees that would be removed permanently during construction. You have to check the tree survey to discover this as the plans do not mention the fact that a lot of trees will definitely be removed and many others may also be damaged so much that they have to be completely removed during the construction. (See other correspondence & the various letters of objection for exact details).
Again, misleading & deceptive – the application hides the reality of what the plans will actually result in.
If you visit the site and look around the perimeter it is very clear how many established trees are at risk. Also please read Helen Leonard from the Tree Team’s cunsultee comments:
“The NPPF states: ‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss;’
The woodland immediately to the east and north of the site boundary, in Braywick Park nature area, shows up as ‘Priority Habitat Inventory – Deciduous Woodland (England) on Defra’s ‘Magic’ website. In addition, data from Thames Valley Environmental Records Centre shows the woodland to the east is probably ancient woodland… The direct impact on trees in the woodland, if found to be ancient woodland, would be unacceptable.”
The plans also don't include important views that would show the real visual impact of the building. No view from it looming over the Dell for example, (part of the local Nature Reserve), certainly not the likely view should the 4 Yew trees within the Dell be damaged and removed during construction, or at least ‘heavily pruned’. If you visit the site to get an idea of how close the new building will be to the nature area where the yew trees are it is difficult to see how they will not be damaged to the point of them having to be completely removed during the construction process. There is certainly no mention of any special approaches to the construction in order to avoid any damage either. Also no images showing the impact of the light pollution from the large windows on that side that will affect the same area. (See other letters of objection & consultee comments elaborating on the ecological problems from the resultant light pollution from the new building).
One view included (from the Braywick Cemetary side entrance looking towards the School site) included in the plans also appears to have been chosen to cover up the reality of how the building will dominate the Formal Gardens in Braywick Park at Hibbert Road. Anyone familiar with that part of the park knows there’s a huge bush and trees inbetween the cemetery entrance & the school, it’s 130m away from the school, this is all the image shows. Why no view from the other side of this? To misrepresent the reality of what this will look like should the build go ahead? Again, misleading and seemingly an attempt to cover up important realities of what this would look like in practice.
The plans make no reference to the tree survey and they should. It is important that the council and the public are aware of actually how many trees will be lost due to this development in the park area. Again it looks like BPET are deliberately trying to hide these facts from the public, and confuse & bamboozle Councillors & Planning Panel members trying to understand the key points in order to make a considered decision on approval or not.
IMPARTIALITY & TRANSPARENCY CONCERNS
While Cllr Dudley has so far been helpful & communicative in most correspondence on this issue, I wonder (and worry), how an unbiased, democratic decision can be made by this council, when its leader has been so openly in support of Braywick Court School since the beginning in local press & social media posts, has a working relationship with Place group (part of Bellevue Place Education Trust) from his involvement with them during the development of Holyport college and has openly supported the school further using his role as governor of Riverside to give them a temporary home there during building work should these plans go ahead.
I also understand another influential member of the Council, and Bray Parish Council, Cllr Burbage was the main driving force behind RBWM buying this site, so he would presumably also be strongly invested in the success of the School’s application to develop on this specific site. (I will write to them separately about this to clarify if they will be voting at the Bray Parish Council meeting, and the eventual Development Control Panel – Cllr Dudley made it clear that he would abstain last time because of the declared interest so I would hope the same to be true this time, as with the Parish Council vote). [Edit - Cllr Dudley left the room and didn't vote though he interfered by suggesting the council could build a new car park slightly closer to the school on the driving range site, Burbage was mysteriously running late and arrived immediately after the vote, so avoided answering the issue ^SBP].
Given the political climate and allegations of bullying etc at RBWM of late (though we are assured things are changing & a sensible decision on this application would be a good way to show that), how are we to be guaranteed a democratic, fair, and unbiased decision is reached if such powerful members of the cabinet & council are so openly supporting the school, in particular, the use of this particular site for it? How do we know other councilors on the Development Control Panel or council employees will not be put under undue pressure to vote in favour when it goes to panel, or to give favourable supporting reports on the plans?
Which leads me to the Highways comments... The previous Braywick Court School planning application on this site was recommended for refusal by Highways for many important reasons, all of which still remain in the new planning application seeing as the travel plan has not changed at all (bar the addition of uneccessary parking restrictions on Hibbert Road, but I’ll get to that later). Yet this time, Highways have NOT recommended for refusal. Why is this?
INCREASED TRAFFIC, ACCESS & SAFETY PROBLEMS
Para. 35 of the NPPF states that 'developments should be located and designed where practical to:
• accommodate the efficient delivery of goods and supplies;
• give priority to pedestrian and cycle movements, and have access to high quality public transport facilities;
• create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;
• consider the needs of people with disabilities by all modes of transport.'
RBWM LP Policy DG1 (Design Guidelines) states inter alia:
7) developments should provide adequate off street parking for vehicles and cycles in accordance with the Borough Council's adopted standards as set out in appendix 7. Such provision should be well landscaped and lend itself to a reasonable degree of surveillance;
8) development should provide adequate vehicle access, (including access for refuse collection and emergency vehicles), loading and unloading facilities and circulation space within the site as appropriate;
9) the traffic generated by the proposed development should not have an unacceptable effect on the local road network and the environment of the locality.
RBWM's Parking Strategy 2004 states in para. 9.10.2: Bus/coach loading and waiting areas either on the premises or on the highway will be required for most new schools and tertiary education facilities. Sufficient space should be reserved to allow buses to enter and leave the site safely.
As was stated with respect to the first application (15/00801) the School Travel Plan is not enforceable and therefore there is nothing to stop parents from using the Nature Centre car park. Not a big problem currently as there are only 2 classes, so 60 pupils, but at a full capacity of 210 it will become a huge issue. Parents are supposed to sign an agreement promising to only use the ‘park & stride’ car park, 500m away along a dark, waterlogged path, unpopular with parents/carers. This promise cannot be legally enforced & will be easily forgotten once the school has got planning permission & no longer has any reason to maintain the system, no sanctions can be taken against them to legally prevent parents doing what they like. But by then the damage will have already been done and it will be too late.
There is no difference as far as traffic/access/parking problems go between this application and the previous one to which the Highways Engineers objected. Why have the Highways Engineers changed their view?
The school site itself cannot accommodate the delivery of goods and services according to the plan submitted, vehicles would be required to drive into the Nature Centre car park and stop, either blocking the disabled car parking spaces or the entrance to the Nature Centre. Waste collection would also require collection vehicles entering the car park to gain access to the bins to be located along side the footpath (behind the Braywick Park sign); the vehicles would stop in the entrance to the Nature Centre. This arrangement would increase conflict between traffic and pedestrians in a well-used public car park and would cause noise and disturbance to users of the formal gardens of Braywick Park and the Nature Centre gardens.
The proposed development reduces the amount of car parking available:
LP Policy P4 states: The Borough Council will require all development proposals to provide car parking in accordance with the adopted standards as set out in appendix 7. (This has been superseded by Parking Strategy 2004 which states that the maximum required is 1 space per 1 full time equivalent for staff.)
LP POLICY P5 states: …… In all cases, on site operational car parking will be required.
The planning application site does include the Park and Stride car park (500m away) so theoretically 'on-site' operational car parking would be provided. However, there is no way to enforce the Travel Plan and thus potentially the Hibbert Road car park would be used by parents, to the detriment of the general public wishing to enjoy Braywick Park.
The proposed development is therefore contrary to national and local planning policy.
OBJECTION TO PROPOSED PARKING RESTRICTIONS ON HIBBERT ROAD
The Parking/Waiting restrictions on Hibbert Road in the proposal (ie single or double yellow lines on Hibbert Road) is something I strongly object to, and they seem to be the only new addition to anything related to traffic/parking in the plans. WHICH WERE NOT INCLUDED IN THE SCHOOL’S LAST PUBLIC EXHIBITION, I only spotted them hidden away in the last page of the travel assessment. (I mention this again as an illustration of lack of openness & things being hidden by the Trust behind the School & these plans).
I have always parked on Hibbert road, for the 15+ years I've lived here, as do many of my neighbours, some from Gas Lane, and also Ashley Cottage & the Old Coach House B&B on Braywick Road. We have no alternative off-street safe places to park our cars (you will be aware of the amount of car crime in the Bray area, so directly outside our houses is our only safe option). Even if some kind of ‘Residents only’ system were introduced it would just add inflexibility and inconvenience for those of us that live here, and our guests visiting. At the extreme end we would simply no longer be able to park safely near our houses, and the whole scheme wouldn’t solve the problem it is supposedly meant to anyway.
Since when did double yellow lines stop stressed out parents running late from quickly parking up inconsiderately on the pavement, on double yellow lines to run in and drop off their children? The reality if restrictions were put in place on Hibbert Road it would just be that residents could no longer park safely outside their homes & determined parents would still be able to get away with parking up briefly on Hibbert Road if they really wanted to.
There are (and can be) no legal restrictions preventing only Parents/Carers Parking, or dropping off/picking up in the Nature Reserve Car Park, which is even closer to the school, so if parents were going to ‘break the rules’ of their (unenforceable) Travel Plan then they would be more likely to drive right in the car park anyway & not on Hibbert Road, as it is much closer to the school entrance. Parking restrictions on Hibbert Road are not needed & should not be considered as part of this application.
The School's Transport Assessment in para 4.10 says this is 'an additional safeguard against parent/carer parking' that 'is a suggestion made by residents'. I dispute that statement. It has certainly never been brought up as a suggestion at any Hibbert Road/Gas Lane Neighbourhood watch meetings & scanning through the ‘consultation’ questionnaire responses I see nothing there from residents requesting it. (More misleading & misrepresentative information in the plans.)
If Braywick Court School's Travel Plan & 'Home School Agreement' is as 'robust' as claimed, then all parents/carers will use the 'Park & Stride' car park by Braywick Sports Ground. That is the key promise which the Travel Plan hinges on, and the School's only, (and unenforceable) answer to residents' concerns about all the extra traffic, access & parking problems a school of this size, on this site will create. Concerns which were shared by the Highway Development Control when they recommended the previous application be refused permission, which led to its withdrawal. Seeing as there is no change in the travel plan in this application I am puzzled as to why the Highway Development Control would now NOT recommend refusal. Unless they had been put under pressure to do so?
THE ALTERNATIVE
No need has been put forward for the school for 210 pupils to be specifically located on the Hibbert Road site. The school could be located anywhere in the Maidenhead area, given the admissions policy and the current intake of pupils.
As other letters of objection have pointed out, and the petition last year, another, larger and more suitable site exists within the Braywick Sports area, only 500m from the existing site, by the Target Shooting club, which apparently is available, but seems to have been dismissed from consideration by the applicant without any apparent reason so far. It is already owned by RBWM & was originally identified as a potential site for Oldfield previously.
-It would solve the parking and access issues, as it is right by the ‘park and stride’ car park.
-Access from Hibbert Road and use of the car park at the Nature Centre would no longer be an issue, and traffic levels on the very narrow country road, Hibbert Road would be safer as access would be from the A308.
-The site is much larger so would accommodate a more suitable building with better facilities and more playground space.
-The site is closer to areas of new development (eg Stafferton Way) from where future pupils would be expected to come from.
Another alternative site, also very close, would be part of the land that the council has arranged to lease from the Golf Driving Range at Braywick.
These sites should be given full consideration. The ‘Winbury Site’ would be better suited to a smaller educational use such as a nursery school.
I trust that the above objections and considerations be taken into account and the application recommended for refusal.
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[Edit - this post below is in relation to the 1st planning application, not the current 2016 although many of the same problems remain. Including it here for reference.]
At the outset, we would like to make clear that we have no objection to the use of the former Winbury School buildings for a school of 90 to 100 pupils, which was the number at Winbury School over the years.
-The site is much larger so would accommodate a more suitable building with better facilities and more playground space.
-The site is closer to areas of new development (eg Stafferton Way) from where future pupils would be expected to come from.
Another alternative site, also very close, would be part of the land that the council has arranged to lease from the Golf Driving Range at Braywick.
These sites should be given full consideration. The ‘Winbury Site’ would be better suited to a smaller educational use such as a nursery school.
I trust that the above objections and considerations be taken into account and the application recommended for refusal.
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[Edit - this post below is in relation to the 1st planning application, not the current 2016 although many of the same problems remain. Including it here for reference.]
At the outset, we would like to make clear that we have no objection to the use of the former Winbury School buildings for a school of 90 to 100 pupils, which was the number at Winbury School over the years.
Our objection is to the opening of a 210 place school which will be
crammed onto a very small site with no facility for parking, deliveries or
waste collection, and necessitating the relocation of the Nature Centre.
The proposed new development enabling the
school to accommodate far more pupils than previously would result in significant
increased traffic generation which would have an unacceptable effect on the
local road network and highway safety as well as the environment of the locality,
especially the formal gardens of Braywick Park.
Localism
It is
considered regrettable that the decision was taken back in the March Cabinet
meeting to lease the Nature Centre and the area of Public Open Space to BPET
before there was any community consultation.
It was thought that localism was meant to involve the devolution of
powers into the hands of individuals, communities and councils. In this instance, individual and communities
have been ignored completely - it is the Department of Education and local councillors
dictating the future of the Nature Centre and the formal gardens forming part
of Braywick Park.
We would
like to set out our main areas of concern and suggest an alternative location
for Braywick Court School.
The key
issues relate to planning, leisure, in particular the impact on the formal
gardens of Braywick Park, and property.
Planning
Green Belt:
The whole of the proposed school site is within the approved Green Belt.
Whilst the re-use of the existing school buildings would be no problem,
the proposal to more than double the size of the previous school and the
consequent requirement to erect a large new building would be inappropriate and
thus contrary to Green Belt planning policy as set out in the NPPF. It is also contrary to Policy GB1 which sets
out acceptable uses in the Green Belt.
It will therefore be necessary at the planning application stage for the
Trust to prove that there are ‘very
special circumstances’ to justify the amount of new building involved. There
are no such special circumstances evident in the consultation material so far
available as to why the new school needs to be more than double the size of
what previously existed.
In addition, the handover of the existing Nature Centre building to the Free
School requires the construction of a new Nature Centre on a site which is also
in the Green Belt. This obviously further compounds the problem of the
reduction in the ‘openness’ of the Green Belt that will occur if this proposal
proceeds as currently planned. The
proposed location of the replacement Nature Centre will severely reduce the
openness of that area of the Green Belt.
It is
useful to note the officer's report with respect to an application for single
storey front and rear extensions totalling 34m2 and new entrance canopy
(02/39593) which was granted permission on 20 February 2003.
The officer
concluded that very special circumstances had been demonstrated and that the
proposed extensions 'would not have a greater impact upon the openness of the
Green Belt than the existing buildings on the site. The extensions would be within the main built
envelope of the school buildings in a recessed location.'
The
proposed new development for Braywick Court School would have an adverse impact
on the Green Belt given the scale, siting and design of the building which
would not be in a recessed location but rather virtually adjacent to
Hibbert Road. This approximately 1.5
storey high building, rising to two storeys, would completely fill the gap
between the Nature Centre and the existing buildings. The
footprint of the proposed new building is not known but it appears to be slightly
larger than the floorpsace of the existing Winbury school buildings together
with the Nature Centre - ie more than doubling of the footprint.
The proposed development is therefore contrary to Policy GB2 which
states that new development will not be permitted if it has a greater impact on
the openness of the Green Belt than existing development on the site, harms the
character of the countryside because of the scale, siting or design of the
development, or results in material increase in the scale of development on the
site.
Public Open Space:
Further to the Green Belt consideration, all
the proposed new buildings are on land that is designated as Public Open
Space. There are very strict planning
rules that apply when new built development is being contemplated in these
circumstances. The NPPF states in para
74 that:
“Existing open space, sports and recreational buildings and land,
including playing fields, should not be built on unless:
● an assessment has been undertaken which has
clearly shown the open space, buildings or land to be surplus to requirements;
or
● the loss resulting from the proposed development
would be replaced by equivalent or better provision in terms of quantity and quality
in a suitable location; or
● the development is for alternative sports and
recreational provision, the needs for which clearly outweigh the loss”.
There is no evidence available so far that any of these requirements
have been met and it would seem that the proposed new school development would
be contrary to the NPPF as well as Policy R1 of the Local Plan which seeks to
protect open space. The site for the
proposed replacement Nature Centre is also on Public Open Space.
All in all, there will be a considerable reduction in the amount of open
space available to the public in Braywick Park as a result of the development
of the new Nature Centre, the transfer to the school of the open space within
the existing Nature Centre grounds, and the new school development on the
adjoining Public Open Space.
The arrangements for staff car parking at the former Winbury School is
not known for certain but it is believed that staff parked between the Nature
Centre and the school. The proposal for
the Braywick Court School includes provision of 8 car parking spaces in the
Nature Centre car park (subject to a licence from RBWM). This proposal would result in a further
uptake of Public Open Space by the proposed school and a loss of car parking
for users of Braywick Park.
Design:
The proposed new building represents over-development of the site –
there will be little space within the curtilage of the school which is not covered
in buildings. The design of the new
building is totally out of keeping with the local history of the site:
the Nature Centre which was once part of the stables for Braywick Lodge and the
school both date back approximately 200 years. The National Planning Policy
Framework (NPPF) states in para. 58 that developments should “respond to local character and history, and
reflect the identity of local surroundings and materials, while not preventing
or discouraging appropriate innovation.”
Similarly, the proposed design of the new
development is contrary to Policy DG1 which states that the design of new
buildings should be compatible with the established street façade having regard
to the scale, height and building lines of adjacent properties; it also states
that materials which are sympathetic to the traditional building materials of the
area should be used, and harm should not be caused to the character of the
surrounding area through development which is cramped.
Whilst a modern look is by no means out of the question, the proposed
design is not sympathetic in any manner the Nature Centre and the former
Winbury School buildings.
Highway Safety:
The
increase from 90 or so pupils to 210 pupils and the concomitant increase in
staff numbers represent an intensification in the level of activity on the site
and a substantial increase in traffic generation. It is considered that the proposed new
development enabling the school to accommodate far more pupils than previously
would result in increased traffic generation which would have an unacceptable
effect on the local road network and the environment of the locality, contrary
to Policy DG1.
Having experienced the former Winbury School in operation
over many years, we have no objection to a resumption of use of a similarly
sized establishment. However, Winbury School accommodated only 90 or so
pupils, whereas the new school is planned to expand to 210 pupils over the next
few years. When Winbury was operational, there was a small staff
car parking area (for about 8 cars) which will be lost if the new school is
permitted to develop that area as currently proposed. Assuming that these
8 spaces are to be ‘replaced’ by the school having exclusive use, via a
licence, of a section of the public car park, the effect of course will be to
reduce the number of spaces available for public use.
The school is proposing a drop off/pick up facility in the
overflow car park in Braywick Park (by the Maidenhead Target Shooting Club)
with pupils then walking the 500+ metres to the school. There has been no mention of widening the
access road to the overflow car park which is single track in places; one can
only imagine the traffic chaos with parents trying to enter/leave the overflow
car park on a single track with a couple of passing spaces. There are legitimate concerns that
realistically, many parents will not use this facility and will instead drop
off/pick up their child in the Nature Centre car park on Hibbert Road.
This point was acknowledged by representatives of the school at the
consultation event on 8 July 2014, who agreed that in reality, and despite the
best intentions of the proposed School Travel Plan, the school would have no
control over the number of parents who choose to drop off and pick up as close
as possible to the school. Assuming that parents do indeed behave as we expect,
then car parking for the public in this popular park will be severely
restricted, if not impossible at certain hours of the day.
Insufficient car parking spaces will inevitably lead to cars
queuing on Hibbert Road to enter the car park itself, adversely affecting road
safety. We know from personal observation that when the much smaller
Winbury School was in operation, the public car park was invariably full
at school drop off and pick up times and there were always cars parked along both
sides of Hibbert Road itself, mornings and afternoons. It is difficult to see how anything less than
severe congestion in Hibbert Road will result.
A much larger school will also require more deliveries than
Winbury School did or, alternatively, larger vehicles. Waste collection from Winbury School was via
Grundon Waste Management Company whose vehicles stopped outside the gates and
the bin was wheeled out to the refuse vehicle.
This is right by the double bend where there is no visibility forward on
the bend, and close to the new road narrowing installed earlier this year to
afford some protection for pedestrians as vehicles were constantly mounting the
pavement. In addition, delivery vehicles
such as Sainsburys, also stopped outside the school gates to make deliveries. If all such collections/deliveries are
subsequently made via the public car park, it will lead to potential increased
in pedestrian/vehicle conflict in this well used public car park.
The proposed major expansion of the school would be contrary
to paragraph 42 of the NPPF which states that safe and suitable access to the
site can be achieved for all people. It
would also be contrary to Policy DG1 which states that development should
provide adequate vehicle access (including access for refuse collection and
emergency vehicles) loading and unloading facilities and circulation space
within the site as appropriate. Clearly
none of the above can be accommodated within the school site due to the
over-development, and thus vehicle access will need to be via the public car
park.
Travel Plan:
Drop off by
the Maidenhead Target Shooting Club site is unrealistic given the distance from
that site to the school - over 500 metres.
The access road to the overflow car park is single track in places which
will cause gridlock were parents to use this proposed drop off facility.
Drop off
within the existing Nature Centre car park will cause traffic chaos with cars
queuing on Hibbert Road in order to gain access to the car park. This traffic congestion will be exacerbated
by the recent (and welcomed) road narrowing scheme implemented in April to
afford protection for pedestrians from cars consistently mounting the
pavement.
We foresee
cars parking on both sides of Hibbert Road, as happened on a regular basis when
Winbury School was operational with just 90 pupils - not 210 pupils.
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