HRA Email to RBWM Chief Executive rejecting the Thames Hospice Plans
| hra_reject_th.pdf |
Thames Hospice Planning Application Sadly Agreed at Borough Meeting
We are extremely sorry to report that despite objections, and a petition, the RBWM Councillors on the Development Management Panel on 18th July 2017 voted 11 for and 2 against, so the application was granted subject to some traffic and height matters being clarified and / or improved.
Apart from objecting to the plan itself, we object to the flawed process of this Development Management Panel, in that a development is approved subject to some essential matters being sorted out. It is this sort of slapdash behaviour that has resulted in the deaths in the disastrous Grenfell Tower fire on 14th June 2017, and this country's building component fire regulations being unfit for purpose.
For this panel, the proper course of action is to reject until all design matters have been fully documented so that we know exactly what is being presented for approval.
There was acceptance that traffic is a problem, the A308 being narrow. The RBWM Highways representative trotted out the usual sop to those in the ruling class on this RBWM Council, that the increased traffic as a result would be only 3% so "NO PROBLEMO". If it had been 4% we heard a Councillor say, then it would have been a NO. The Highways group always conveniently disregard the fact that each successive development they approve that adds 3%, all together add up to much more.
One Councillor said that a road carrying as much traffic as the A308 should be a dual carriageway.
We know that there will be more developments affecting traffic on this road - these being those scheduled in the Local Development Plan on areas HA11, HA18, Monkey Island Lane, Racecourse Hotel, LEGOLAND and CrossRail.
So we look forward to Highways rejecting all of these future development proposals as the traffic from any one of them together with the Hospice Traffic will exceed 4%!!!!!!!!!!!!!!!!
We also have had, just yesterday, news of developers and / or landowners proposing yet again that they will build on "Lodge Farm", the area between Holyport Road, Ascot Road, Aysgarth Park and old Holyport. This area is not shown in the Borough Local Development Plan to be allowed for building - but who knows - it seems that this RBWM Planning lot is capable of anything.
Local RBWM Councillors did in the past propose that area for development - we stopped it. Then in the early stages of developing the Bray Parish Neighbourhood Development Plan up it came again - we stopped it. Then it was proposed by RBWM in their Edge of Settlement Analysis of 2014 - we stopped it.
We were disappointed that our local RBWM Councillor David Coppinger voted in favour of the plan. This was despite his statement of concern, that he had only discovered last week how difficult it is to turn out from a property onto the A308.
It was not surprising that our Bray Parish Councillor, Derek Wilson who is also the RBWM Lead Member for Planning voted for the development. Not only that, he proposed it be accepted. It is of course part of his Borough Local Plan!!
Below we show the presentation given by Anu Chawla our Vice Chair who presented on behalf of Windsor Road Residents who will be sorely afflicted by this development on Green Belt Flood Plain. We also show a full version of her description of the problems arising from this development - due to time restrictions, the meeting could not have the benefit of the full presentation.
We also show below our analysis of the flood report that was created on behalf of the Hospice. We consider that it is impossible to develop in this area without causing emerging water or flood water problems. Further we believe we have demonstrated that RBWM have contravened the NPPF requirements restricting building in Flood Plain 2 and 3.
We thank Ken Elvin, the Leader of Bray Parish Council - who also spoke eloquently against the application.
Apart from objecting to the plan itself, we object to the flawed process of this Development Management Panel, in that a development is approved subject to some essential matters being sorted out. It is this sort of slapdash behaviour that has resulted in the deaths in the disastrous Grenfell Tower fire on 14th June 2017, and this country's building component fire regulations being unfit for purpose.
For this panel, the proper course of action is to reject until all design matters have been fully documented so that we know exactly what is being presented for approval.
There was acceptance that traffic is a problem, the A308 being narrow. The RBWM Highways representative trotted out the usual sop to those in the ruling class on this RBWM Council, that the increased traffic as a result would be only 3% so "NO PROBLEMO". If it had been 4% we heard a Councillor say, then it would have been a NO. The Highways group always conveniently disregard the fact that each successive development they approve that adds 3%, all together add up to much more.
One Councillor said that a road carrying as much traffic as the A308 should be a dual carriageway.
We know that there will be more developments affecting traffic on this road - these being those scheduled in the Local Development Plan on areas HA11, HA18, Monkey Island Lane, Racecourse Hotel, LEGOLAND and CrossRail.
So we look forward to Highways rejecting all of these future development proposals as the traffic from any one of them together with the Hospice Traffic will exceed 4%!!!!!!!!!!!!!!!!
We also have had, just yesterday, news of developers and / or landowners proposing yet again that they will build on "Lodge Farm", the area between Holyport Road, Ascot Road, Aysgarth Park and old Holyport. This area is not shown in the Borough Local Development Plan to be allowed for building - but who knows - it seems that this RBWM Planning lot is capable of anything.
Local RBWM Councillors did in the past propose that area for development - we stopped it. Then in the early stages of developing the Bray Parish Neighbourhood Development Plan up it came again - we stopped it. Then it was proposed by RBWM in their Edge of Settlement Analysis of 2014 - we stopped it.
We were disappointed that our local RBWM Councillor David Coppinger voted in favour of the plan. This was despite his statement of concern, that he had only discovered last week how difficult it is to turn out from a property onto the A308.
It was not surprising that our Bray Parish Councillor, Derek Wilson who is also the RBWM Lead Member for Planning voted for the development. Not only that, he proposed it be accepted. It is of course part of his Borough Local Plan!!
Below we show the presentation given by Anu Chawla our Vice Chair who presented on behalf of Windsor Road Residents who will be sorely afflicted by this development on Green Belt Flood Plain. We also show a full version of her description of the problems arising from this development - due to time restrictions, the meeting could not have the benefit of the full presentation.
We also show below our analysis of the flood report that was created on behalf of the Hospice. We consider that it is impossible to develop in this area without causing emerging water or flood water problems. Further we believe we have demonstrated that RBWM have contravened the NPPF requirements restricting building in Flood Plain 2 and 3.
We thank Ken Elvin, the Leader of Bray Parish Council - who also spoke eloquently against the application.
Presentation by Anu Chawla.
Chairman, Councillors, Ladies and Gentlemen
As the spokesperson for the residents of the area, I wish to state, we strongly object to the proposal. We submit that the proposal will have a detrimental impact on the residents health, wellbeing and properties; that it cannot pass the Exceptions tests and that Very special conditions are not met.
It is not possible to provide a detailed statement in 3 minutes so my full statement will be available on the Holyport Residents association website and to the press.
There is a growing nationwide concern that councils are not listening to residents’ concerns against bad planning. The area residents are concerned there is a predisposition to allow the proposal at any cost and without regard to the wellbeing of the existing residents.
This site has several significant issues against being developed, registered as double negatives on the council’s own Sustainability Appraisal.
We believe many of these issues have been underrated or understated in the case report to reduce their importance to allow Very special Consideration for the proposal.
- The land is Green belt and a hospice is not listed, as an appropriate exception in the NPPF, for construction is acknowledged
- However the importance to all residents and visitors, of the public amenity, the openness of the area and a landmark view from the road is completely undervalued. More than 200 people have signed a petition to ask for removal of this site from the development allocation.
- Traffic impact is underestimated. I refer the panel to the submitted photos of a typical peak period.
- The impact on the existing AQMA has not been addressed at all
- The impact of the height of the proposal (12 meters above raised ground) has been downplayed. 12 meters is twice the height of a house! The proposal is overbearing, will urbanise and completely dominate the neighbourhood.
- And critically this site has considerable issues with flooding. It is a flood plain!
Notwithstanding the value that the hospice movement provide to the community, the issue is whether this is the right site. We believe Very Special Conditions are not met. It is suggested that this is the only affordable site within their search but the search criteria submitted is neither extensive nor reasonable. We submit it is set specifically to target this site.
In today’s world driving 10 miles is not considered a long distance; imposing a 5 mile limit is placing unreasonable restrictions to reject any other sites.
The staff are located either in Windsor or Ascot, why is Windsor the epicenter of the search? Why not Ascot?
The constraint to combine all aspects of the charity headquarters maybe desirable but is not essential.
This site has only 6 useable acres due to flooding when the applicant is looking for a site of at least 8 acres.
It is ironic the applicant is looking for a semi rural area and then proposing to build industrial scale buildings which will dominate the area and remove its semi rural aspect.
In conclusion we urge the panel to dismiss the application and assist the hospice to find a more suitable alternative site, as there is severely detrimental impact on existing residents and properties, the Exception Tests cannot be passed and the very special conditions are also NOT met to allow the substantial harm to the Greenbelt.
ANU's full presentation
Chairman, Councillors, Ladies and Gentlemen
I am speaking on behalf of the residents of Windsor Road and surrounding areas, incorporating all their concerns, submitted as objections to the Planning Department. Over 55 households have objected so the actual number of people is around 110. None are in support of the suitability of this site for the Hospice. Additionally more than 200 people have signed a petition to ask for the site to be removed from the development allocation.
We the residents are concerned there is predisposition to allow the application at any cost, which is completely disregarding the welfare and wellbeing of the existing residents.
We believe this site is unsuitable for such a substantial development. The Flood Risk assessment report referenced by the case officer was only made available to the public last Friday. It has been carefully examined and due to lack of time provided, a report has been emailed directly to all the councillors by the chairman of the Holyport Residents Association. The analysis and questions raised conclude that the National Planning Policy Framework, NPPF and the PPG sequential and exception tests have NOT been met.
The local plan still has to undergo the test of soundness and legal compliance therefore has limited weight. In addition the council’s own Sustainability appraisal registers double negatives for water and flooding, Air and Noise Pollution, Use of Resources and landscape Quality.
The site is Green belt farming land, and therefore there is presumption against building here unless Very special conditions (VSC) can be proven. A hospice or care home is NOT listed in the NPPF as an appropriate exception for construction on Green Belt land.
The case officer has stated the scheme causes significant and substantial harm to the openness of the space by the locality of the site and its size and therefore the proposal is contrary to the Green belt policy.
Having read some of the literature accompanying the application and the case Officer’s report I wish to address Visual Impact, Flooding, Parking , Traffic, Pollution and Very Special Considerations,
Visual Impact
This substantial development, equivalent to a small hospital will urbanise the area and dramatically change its semi rural character.
The land, including the site, is the only open space remaining between the Braywick roundabout and Fifield Road. It is an area of recreation for many local residents and the general public. Bray Lake is a landmark! The view to the public, from the road, of Bray Lake is critical to the openness and the semi rural character of the area and cherished by the residents and visitors. Significant weight should be attributed to this loss.
Moreover in order to mitigate the flooding issues, the proposal is to raise the land where buildings are to be constructed. It is not specified ultimately where the ground level will be relative to the surrounding properties. This means that the three 2 storey buildings which are stated to be 12 meters high (twice the height of a house), on Ground level further raised, will be seen for miles. They will be out of place in their surroundings, completely dominating the neighbourhood and creating light pollution. It is ironic the Hospice is looking for a semi rural location and in the process turning the existing semi rural location to an urban one.
What is proposed amounts to overdevelopment.
Flooding
It is clear that the prospect of flooding is a substantial issue for the applicant.
The site allocated to the hospice is the worst possible on this land parcel, almost entirely in flooding zones 2 and 3, with high probability (75% chance) of ground water flooding within its vicinity and the facts are that part of the site regularly floods in the winter. The water table is very high. The proposed development will exacerbate the problem. This is an unsuitable site for development
The Environment Agency originally objected to the application on the basis that that the development would increase the risk of flooding elsewhere. Their latest cautious response of 10th July approving the development but imposing conditions which require minimum finished floor levels and compulsory flood plain storage serves to highlight the real risks of flooding attached to this site.
Given that the policy is to direct developments to areas at lowest probability of flooding, notwithstanding the benefit of the hospice to the community, it is submitted that this site cannot meet the Exceptional test because it will increase the risk of flooding to neighbouring properties.
I refer you to the analysis and conclusions presented by the HRA email to all councillors and urge the panel to take account of the residents’ knowledge of conditions on this site in wet weather and accept it is unsuitable
Traffic, Parking and Congestion
The Hospice will be relocating both sites therefore all its existing staff, patients and visitors will need to travel. It is already established that virtually everyone will drive.
Provision of 201 car parking spaces for 150 full time equivalent staff ie around 200 real people plus 500 volunteers, outpatients , weekly training sessions for up to 50 people, is inadequate parking provision.
Much of the traffic generated will be at peak periods when traffic is nose to tail. Exiting from our drives is difficult, we are dependent on motorists letting us out at peak times and one can’t turn right. I refer the panel to the pictures distributed and taken during one peak time at 6:20 pm.
The Highways report states that this narrow road already carries 18000 vehicles daily of transit traffic. This is looking at the increased traffic in isolation, without considering the further increase in traffic anticipated when crossrail is operational or due to houses already permitted to be built further down the road.
Highways estimate 574 additional daily vehicle trips based on FTE numbers to and from a single access point on this busy road and say as this is a 3% increase this is sustainable.
In absolute terms this is an additional 200 to 250 trips all starting/terminating at the same point on the road at each peak time. Traffic from all these people, service vehicles and ambulances, using a single access, all using the narrow A308 which is currently unable to meet existing demands make this an untenable proposal.
Air Pollution and AQMA (Air Quality Management area)
Increase in traffic means increase in Air pollution. Windsor Road already suffers from Air pollution due to the M4. ANY increase in traffic means increase in that pollution and if the open space which disperses these fumes is taken away that impact is multiplied.
We already have an AQMA in near proximity and a number of residents with asthma and lung related diseases. This issue has not even been addressed when planning policy states that Planning decisions should take account of the impact on air quality, supporting proposals which will result in the improvement of Air Quality Management Areas (AQMAs).
We submit that at present levels ANY increase is harmful.
Very Special Considerations
Notwithstanding the value that the hospice movement provide to the community, the issue is whether this is the right site. Whilst it is suggested that this is the only affordable site within their search, the search criteria submitted is neither extensive nor reasonable.
In today’s world driving 10 miles travel is hardly considered a long distance; 5 miles is placing unreasonable restrictions to reject any other sites.
When the staff are located either in Windsor or Ascot, why is Windsor the epicenter of the search? Why not Ascot? Or even a midpoint between Windsor and Ascot?
The applicant is looking for a site of at least 8 acres. This site has only 6 useable acres due to flooding.
The constraint to combine all aspects of the charity headquarters maybe desirable but is not essential. Two smaller sites within close vicinity would fulfil the purpose.
The applicant is looking for a semi rural area and the application will remove the semi rural aspect of the existing area by industrial scale overbearing buildings which will dominate the entire area.
We submit that the entire search criteria and application is based specifically to target this site and to reject any alternatives. Therefore Very Special Conditions are NOT met.
I would urge the council to recommend that this application be dismissed and the District Council assist the hospice to locate a brownfield site nearer the urban area with better transport links for the staff and visitors using the facilities.