WE NEED YOUR HELP! PLEASE WRITE AND OBJECT TO THE PLANNING APPLICATION!
Braywick Court School and their backers BPET have finally submitted their planning application. All the (complicated) files can be read on the RBWM website CLICK HERE.
Objections need to be submitted to the council by 31st May.
Please email your objections (include your postal address in the email) to planning.maidenhead@rbwm.gov.uk - include reference: 15/00801/FULL
You can also send your objection letter to RBWM Planning, Town Hall, St. Ives Rd, Maidenhead, SL6 1RF - include reference: 15/00801/FULL
Please write your letter in your own words & don't just copy and paste exact wording from this site.
Please note that some objections are invalid such as: "The development adversely affects my view / would have an adverse effect on property values / the construction would cause disturbance."
We have put together some detailed notes on specific points which you may find helpful when making your representation to the Council regarding the application (luckily some of us know about planning laws!).
Apologies for the length of the article, but there are just so many issues with the planning application that are completely contrary to planning policy, and factual errors in there too - that it's important to point them out and fight this!
Most importantly write about the issues that you care about most.
Valid planning objections include the
following:
1. The proposed development is contrary to
national or local planning policy etc.;
Below, various
objections are listed together with the policy reference from either the National
Planning Policy Framework (NPPF) or the saved policies from RBWM's Local Plan
(LP). The parking standards in the Local
Plan have been superseded by Parking Strategy, 2004.
2. The proposed development adversely affects
the openness of the Green Belt.
- NPPF
states in para. 79: 'The fundamental aim of Green Belt policy is to prevent urban
sprawl by keeping land permanently open; the essential characteristics of Green
Belts are their openness and their permanence.'
- LP Policy GB2 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,
- The
openness of the green belt would be adversely affected due to:
* the massing
and height of the proposed development and its position close to the boundary
wall;
* the need to
replace the Nature Centre with a new building within the formal gardens;
* the proposed
enclosure of the school site with 1.8 metre high weld mesh fencing
- The proposed
development is therefore contrary to national and local planning policy.
The proposed development is an
inappropriate development within the green belt;
- The
NPPF in para. 90 states that the construction of new buildings is inappropriate
in Green Belt. Exceptions to this include:
• Provision of appropriate facilities for
outdoor sport, outdoor recreation and for cemeteries, as long as it preserves
the openness of the Green Belt and does not conflict with the purposes of
including land within it;
• The extension or
alterations of a building provided that
it does not result in disproportionate additions over and above the size of the
original building;
• The replacement of
a building, provided that the new
building is in the same use and not materially larger than the one it replaces;
• Limited infilling
or the partial complete redevelopment of previously developed sites (brownfield
land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on
the openness of the Green Belt and the purpose of including land within it than
the existing development”.
- Similarly
LP Policy GB2 states: Permission
will not be granted for new development or the redevelopment, change of use, or
replacement of existing buildings within the green belt if it would:
A) have a greater impact
on the openness of the green belt or the purposes of including land in it than
an existing development on the site;
B) harm the character of
the countryside because of:
1) the scale, siting or
design of the development or the materials employed; or
2) a material
intensification in the level of activity on the site; or
3) a material increase
in the scale of development on the site; or
5) harm to residential
amenities in the locality; or
6) conflict with any other
policies of the plan.
- In the Planning Statement, the applicant makes the following
extraordinary comment:
'The NPPF confirms
that the re-use of buildings (paragraph 90), the infill of brownfield sites,
appropriate extension or alterations of a building and provision of appropriate
facilities for outdoor recreation (paragraph 89) are not inappropriate
development. For these elements, there is no need to demonstrate ‘very special
circumstances’ for planning permission to be granted.'
- These comments clearly disregard the caveats that any extension
should not be disproportionately bigger than the original building, the
replacement building should not be materially larger than the one it replaces,
and the limited infilling would not have a greater impact on the openness of
the green belt. The new school
development is almost 10 times bigger in terms of overall floorspace and the
footprint is 7 times larger, and the building is over 2 metres higher than either the Nature Centre or the school buildings
and is very close to the road. The bulk
and massing of the proposed development therefore has a significant adverse
impact on the openness of the green belt.
- The proposed new development is clearly inappropriate development
in the green belt. In terms of the very special circumstances set out by
the applicant, it is stated that there is an educational need for the school
and cites the Council's 10 Year School Expansion Programme. The applicant also stated that there was a
demand for places at Braywick Court School for 2015/2016. The applicant also set out a number of
alternative sites that had been considered but the preferred location was the
Hibbert Road site.
- However,
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 (though why 7 of the 11
sites looked at were in Slough is not explained…). The applicant did not consider the
possibility of a split site which has been advocated by local residents. The fact that DFE (or EFA) can basically take
control of any former educational site is considered the sole factor in the
selection of this site.
- Para.
87 of the NPPF states: 'As with
previous Green Belt policy, inappropriate development is, by definition,
harmful to the Green Belt and should not be approved except in very special
circumstances.' And para. 88
states: '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, is clearly outweighed by other
considerations.'
- It
is not considered that very special circumstances exist which outweigh the harm
to the Green Belt by reason of the inappropriateness of the development and
other harm.
- The proposed development is therefore
contrary to national and local planning policy.
3. The proposed development is likely to cause
traffic problems such as increased traffic generation, access or 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.
- The
Transport Assessment and the School Travel Plan (as well as the Planning
Statement) all totally ignore the fact that Park and Stride is not working with
just 30 pupils and will certainly not work with 210 pupils. The Kiss and Drop scheme works at the moment
but will become progressively more problematic as pupil numbers increase
gradually to 210. There is no
information regarding the impact of increased traffic generation on Hibbert
Road, the possibility of queuing out onto Hibbert Road, and concomitant road
safety matters. However, the intensification in the level of
activity on the site and the substantial increase in traffic generation on
Hibbert Road would have an unacceptable effect on the local road network and
the environment of the area, giving serious concerns for road safety.
- The
application site itself cannot accommodate the delivery of goods and services -
vehicles would be required to drive through the public car park to gain access
to the school. This 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.
- Refuse collection is carried out on the
public highway as there is no access into the site. The bin is left on the kerb
so I suspect the Grundon Waste Management vehicle empties there. Has anyone seen the bin emptied to confirm
this? Collection is on a Wednesday I think.
- There is no mention in the Transport
Assessment of where the occasional bus/coach parking will take place.
- The proposed
development is therefore contrary to national and local planning policy.
4. The proposed development is not in keeping
with the scale or character of the local area; The layout and density of the proposed
development is inappropriate;
- The NPPF in para. 58 states 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.”
- LP
Policy DG 1 (Design Guidelines) states inter alia: '
3)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….
11) harm should not be caused to the
character of the surrounding area through development which is cramped, or
which results in the loss of important features which contribute to that
character.'
- It
is proposed to demolish a building with a footprint of 71m2 and
replace it with one of 514m2.
The footprint of the proposed
development is therefore over 7 times bigger than that of the existing
building.
- The
total floorpsace within the new building is 762m2 which is 10 times bigger than the one it
replaces.
- The
height of the existing school building to be retained is approximately 8 metres
and the ridge line is located well over 25 metres from the boundary wall. The height of the school building to be
demolished is 5.7 metres and the ridge line is approximately 18 metres from the
boundary wall.
- The
ridge of the Nature Centre roof is 5.77 metres, and height to the eaves is just
over 3 metres.
- The
proposed new building is 9.77 metres to the ridge and a little over 6 metres to
the eaves. The ridge line is about 5.5
metres from the boundary wall, and the southern facade of the building is just
2 metres from the boundary wall at its closest point (which is near the Nature
Centre).
- Clearly
the proposed new building is not compatible with the scale of existing
buildings on the site (the school building or the Nature Centre) or in the vicinity
of the application site.
As the proposed new development is far
closer to the street, it will be overpowering in terms of mass and height.
- The
development is extremely cramped which again is out of character on Hibbert Road. (Note that the proposed north and south
elevations and Hibbert Road elevation are not accurate.)
- In
terms of design, the Nature Centre dates back to Victorian times whilst the school is early 1800's; the height,
massing, and design of the proposed building are not in keeping with the style/character of
these buildings.
- The development
is therefore contrary to national and local planning policy.
5. The proposed development will have negative
impact on the amenity of another property, through noise, overlooking,
overshadowing, loss of privacy, etc.
- The NPPF in para. 59 states: Local planning authorities should
consider using design codes where they could help deliver high quality
outcomes. However, design policies should avoid unnecessary prescription or
detail and should concentrate on guiding the overall scale, density, massing,
height, landscape, layout, materials and access of new development in relation
to neighbouring buildings and the local area more generally.
- LP Policy GB2 states: Permission
will not be granted for new development or the redevelopment, change of use, or
replacement of existing buildings within the green belt if it would:
B) harm the character of
the countryside because of: (inter alia)
5) harm to residential
amenities in the locality;
- There are clearly issues of noise, overlooking and loss of
privacy, particularly with respect to the Well House, Malvern House, Braywick
Lodge, The Coach House, and xx. Please write your objections from your point
of view.
- The proposed development is therefore
contrary to national and local planning policy.
6. The proposed development provides
insufficient parking/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.)
LP POLICY P5 states: …… In all cases,
on site operational car parking will be required.
- The planning application site contains
three distinct areas, one of which is
within the car park (the other two are the school site itself and the new area
for the Nature Centre). This site can
accommodate only 8 cars which is not adequate for 8 teachers and 16 part time
staff (full time equivalent is not provided on the planning application
form.) If the 'dedicated car parking'
by the Maidenhead Target Shooting Club is a key part of the school's Travel
Plan, then it should be included in the application site.
- The lease of 8 car parking spaces to the
school reduces the number of spaces available for the general public.
- From
the notes of the March Travel Working Party, the Head Teacher is trying to work
out whether staff could use the Emperor of India car park or whether they would
use the 'dedicated car park' by Maidenhead Target Shooting Club. This matter is not addressed in the Transport
Assessment or the School Travel Plan.
- It
is considered that given the lack of car parking on site, the failure of the Park
and Stride scheme after only 3 months, the need for delivery vehicles and waste
collection vehicles to travel through the car park, etc. there are firm grounds
on which to speculate that the Hibbert Road car park would eventually be taken
over by the school, were the development permitted. This would represent a significant loss for
members of the public who currently use and enjoy Braywick Park.
- The proposed development is therefore
contrary to local planning policy.
7 The proposed development would impact the
setting of listed buildings;
- The terrace of five cottages opposite the school
building are Grade 2 Listed Buildings.
- The
NPPF states in para 129: Local planning
authorities should identify and assess the particular significance of any
heritage asset that may be affected by a proposal (including by development
affecting the setting of a heritage asset) taking account of the available
evidence and any necessary expertise. They should take this assessment into
account when considering the impact of a proposal on a heritage asset, to avoid
or minimise conflict between the heritage asset’s conservation and any aspect
of the proposal.
- LP
Policy LB2 states: The Borough Council
will have special regard to the reservation of listed buildings and their
settings and will (inter alia):
5)
ensure that development proposals do not adversely affect the grounds and/or
setting of listed buildings.
- There is no site section showing the impact of the new
development on the listed cottages. The
closest representation is the modelled view from The Causeway immediately
adjacent to Rose Cottage. Mike Alcock had
requested a site section back in October/November but it was never provided and
does not form part of the planning application.
- The proposed development is therefore
contrary to national and local planning policy.
8. The proposed development includes
insufficient landscaping and will result in significant loss of trees;
The NPPF in para. 58
states that planning decisions 'should
aim to ensure that developments (inter alia):
· are visually attractive as a result of
good architecture and appropriate landscaping.'
- LP
Policy N6 states: The Borough Council
will, where appropriate, require applications for new development to:
1) submit a detailed tree survey as part of a
planning application wherever existing trees are a feature of the site. Plans
for new development should, wherever practicable, allow for the retention of
existing suitable trees;
3) include an appropriate tree planting and
landscaping scheme where the amenity value of trees outweighs the justification
for development, planning permission may be refused.
- The plans show a
plethora of proposed new trees on site; however, it is very doubtful that 37 'large
ornamental structure trees' would be planted on the school site, together with
12 fruit trees and three Scots pines of equivalent size to the existing yew
trees. A realistic landscaping scheme should be
submitted so that the impact on the adjacent formal gardens can be assessed.
- The
development involves the loss of the three yew trees plus two field maples and
the two apple trees in the 'orchard'.
The yew trees would be replaced with an equivalent number and size of
pinus sylvestris (Scots Pine). The
landscaping plans suggest that there will be 'proposed large ornamental structure
trees' - 21 along the northern and western boundary and a further 16 on the
southeastern boundary. The plans show
that the yew tree just outside the application site by the notice board would
need to be pruned. In addition, it is
likely that the two holly trees by the northern boundary would also need to be
pruned in order to get construction vehicles (tipper lorries, cement mixers,
etc.) into the site.
- The proposed development is contrary to national
and local planning policy.
9. The proposed development would damage the
natural environment
The
NPPF in para. 109 states: The planning
system should contribute to and enhance the natural and local environment by:
·
protecting and enhancing valued landscapes, geological conservation
interests and soils;
·
recognising the wider benefits of ecosystem services;
· minimising impacts
on biodiversity and providing net gains in biodiversity where possible
LP Policy N9 states: In
considering development proposals affecting local nature reserves and wildlife
heritage sites, the council will have particular regard to the need to protect
natural features and the availability of mitigation measures. Measures will be
required to safeguard and enhance wildlife heritage sites included within any
development proposals.
- The application site is virtually
adjacent to the Dell which forms part of the Local Nature Reserve, a statutory
designation; the Dell is also a Local Wildlife Site though this does not have
statutory designation. The impact of
noise and disturbance from 210 pupils may be addressed in the Ecology report
but that is not available on the Council's website. (At least I haven't found
it.)
- The
application does not address where the pupils will play. This past year, the pupils have been seen
playing in the Dell. Whilst the possibility of future impacts
is not a valid planning objection, it is considered that there are legitimate
concerns that an increasing number of children would use the Dell; this would have an adverse
impact on the LNR through noise and disturbance.
- There is no
information on where the pupils would play other than in the insufficient
spaces outside the classrooms. RBWM
stated in the Educational
Case and Site Options Assessment May 2013 that the Building
Bulletin 99 (2nd Edition) - Briefing Framework for Primary School Projects provides guidance on the number, type
and size of spaces required for new school buildings and outdoor space. For a primary school with an intake of 30
pupils (total 210 pupils), the likely site size is 9,592m2 . The site area of the proposed school is 2653m2
, which is only 28% of the
recommended size. Free schools however
do not need to meet the standards expected of local authority controlled
schools.
- It is considered that given the lack of
open space, there are legitimate concerns that there will be pressure on the
formal gardens for play space which would have an adverse impact on the
environmental quality of these gardens which are well used by members of the public -
and not just by dog walkers.
- The proposed development is contrary to national and local
planning policy.
10. The proposed development would result in the
loss of open space in Braywick Park which is important to the visual and environmental
quality of the area.
- LP Policy R1 states: The Council will not approve proposals which would result in the loss
of existing areas of important urban open land identified on the proposals map,
and other areas of open space which are important to the visual and
environmental quality of urban areas unless:
1) they are replaced by new provision which is at least
comparable in terms of facilities, amenity and location; or
2) they can best be retained and enhanced through the
redevelopment of a small part of the site.
The above exceptions will not apply to land which is
considered by the council to be of irreplaceable amenity value and, in any
other case, the council will expect to be satisfied that a retention of the
entire site for recreation or community use is not feasible.
- The development
involves the loss of open space around the Nature Centre which is to be taken
over by the school and the loss of open space where the replacement Nature
Centre is proposed to be located. The
formal gardens are well used by the public (not just dog walkers). The visual and environmental quality of the
formal gardens would be adversely affected by the massing and height of the new
school development together with the 1.8 metres high weld mesh fence along the
northern boundary, as well as by the proposed log cabin structure for the
replacement Nature Centre. The existing buildings on the site (with the
exception of the single story school hall) date back to the 19th century.
- It is considered that given the lack of
play space within the application for the school, there are legitimate concerns
that there will be pressure on the formal gardens for play space which would
have an adverse impact on the environmental quality of these gardens which are well used by
members of the public - and not just by dog walkers.
- The proposed development is contrary to local planning policy.
11.
The proposed development would have an adverse impact on the Green Way
recreational route
- LP Policy
R14 states: The Borough Council will
safeguard and enhance the public rights of way network and recreational cycle
routes. In particular the Borough Council will:
2) support the establishment of the Green Way recreational
route between Cookham and Bray as shown on the Proposals Map, through:
(i) signposting and promoting the use of the green way for
walkers and, where appropriate, cyclists;
(ii) making the route accessible to the elderly, disabled
and people with prams or pushchairs by removing steps and stiles;
(iii) resisting proposals which would prejudice the route or
detract from users' enjoyment of it;
(iv) encouraging improved access and landscape enhancement
to areas adjoining the route.
3) support the development of circular walks especially
where these enhance the recreational value of the Green Way and/or the Thames Path.
- The following aspects of the proposed development would detract
from users's enjoyment of the Green Way:
* increased
pedestrian/vehicular conflict due to an increase in vehicular movements (cars
and delivery lorries) within the Hibbert Road car park through which the Green
Way passes;
* increased
pedestrian/vehicular conflict due to an increase in vehicular movements
(delivery vehicles and possibly waste collection vehicles) along the Green Way itself
where it runs along the northern boundary of the school site to the entrance to
the school;
* increased traffic generation on Hibbert Road alongside which the
Green Way follows from the Hibbert Road car park to The Causeway;
* noise and disturbance from a 210 pupil school immediately adjacent
to the Green Way (as compared to a school with 90 to 100 pupils);
- Whereas the Council seeks landscape enhancement to areas adjoining
the Green Way, the proposed development involves the removal of the 3 yew trees
and the two field maples which are in the garden area to the north of the
Nature Centre and the addition of 1.8 metre weld mesh fencing along the northern boundary. The proposed new landscaping is rather questionable;
it is difficult to see how 21 large ornamental structural trees can be
accommodated along the northern boundary together with 12 fruit trees in the
vicinity of the former Nature Centre.
Therefore it is difficult to assess the impact of the development in
terms of landscaping unless a realistic landscaping scheme is submitted so that
the impact on the adjacent formal gardens can be assessed.
- The proposed development is contrary to local planning policy.
12. The proposed development involves the loss of
the Nature Centre for use by the general public
- LP
Policy CF1 states: The Borough Council will not permit the loss of existing community
facilities and buildings unless it is satisfied that:
1.
There is no longer a need for them; or
2. An acceptable alternative provision is to be made elsewhere.
- The proposed development involves the
loss of the Nature Centre, an attractive building with character dating back to
the 19th century, together with its open space for use by the public, including
schools, other user groups, and the general public. It is not considered that the proposed log
cabin development is an acceptable alternative provision.
- The proposed development is contrary to local planning policy.
* Note regarding the invalid objection that the
construction of the building would cause disturbance:
In this
case, the Transport Statement does not address construction impacts other than
to say that Hibbert Road may need to be closed in order to crane in certain
building materials. Clearly the
construction compound will not fit on the application site and therefore it
seems inevitable that the Hibbert Road car park will be taken over completely
during the construction process which will be a matter of many months. There will be lorries taking away excavated
material, cement lorries, and many lorry loads of building materials which will
all have to go into the Hibbert Road car park.
There will be no room to store the materials within the application site
for the school or the replacement Nature Centre. Therefore, as there will be construction
impacts - disturbance etc - outside of the application site, I think this
matter should be raised as an objection, particularly for residents living
opposite the car park.
