KCC Planning Applications Committee 7th December 2016 Item D1
Proposed Expansion of Seal Primary School KCC/SE/0055/2016
Seal Parish Council Comments
Background
1Seal Parish Council PC objected to the proposed expansion of Seal Primary School in May 2016on the principal ground that:
“The proposals to manage the growth in traffic and the additional need for parking will not provide ‘safe and suitable access to the site…for all people’ and the cumulative impacts of development will be severe congestion”.
2The objection included a critique[1]ofthe assessment by KCC’s consultants [2]of parking and congestion on Zambra Way, Ash Platt Road and Highlands Park, and requested a planning condition that proposals for a new drop off and parking area should be submitted for planning approval before the opening of the new school buildings. In the light of these comments and numerous objections by local residents the application was deferred for further assessment.
3Since the resumption of school in September the Parish Council has received further complaints about parking and congestion. Following a meeting with the CabinetMember for Education and Health Reform and officers on 13th October, KCC commissioned an appraisal of site options for a school car park,[3] and a peer review of the Transport Assessment.[4]
4The applicants have written to KCC Planning Applications with views based on these reports,[5]and they are the basis of the supplementary report before the Planning Applications Committee as Item D1. Seal Parish Council wishes to make the following points on the new reports and has asked to speak at the Committee meeting.
Transport Assessment and peer review
5The Transport Assessments and peer review are summarised in paragraphs 9 to 13 of the report before the Committee.
6The applicant’s letter states that “The transport assessment has demonstrated that there is capacity to accommodate the proposal on the existing road network” and that the peer review finds “there should be no material impacts following the proposed expansion.” The Parish Council and local residents do not accept these conclusions with regard to parking and congestion in Zambra Way, Ash Platt Road and Highlands Park.
7The Transport Assessment recognises that the proposed school expansion will cause additional problems of parking and congestion but relies on the school Transport Plan to deliver changes in travel behaviour. It concludes:
“Based on current mode splits, unrestrained growth in car trips to and from the site as a result of the development could lead to a significant increase in local traffic levels and congestion.
However, the school will implement a robust travel plan to reduce and relocate parent drop-off / pick-up parking away from the immediate area around the school gates to a more managed use of safe available parking space on Zambra Way, Ash Platt Road and Highlands Park.
Encouraging a high turnover of short duration parking rather that extended dwell times, and other initiatives, it is considered any increase in parking demand could be accommodated.
The school and its Travel Plan will also encourage walking through schemes such as ‘Walking Buses’ and potentially ‘Park & Stride’, and promote car sharing. In doing so, the car based impact of the full two form of entry development will be minimised.”[6]
8Theseaspirationsfail to recognise that there are seldom spare parking places on these roads withthe school at its current size, and that school access and parking causes daily inconvenience to residents. Indeed the number of legitimate roadside spaces has reduced since the surveys were undertaken as residents install dropped kerbs to their properties.
9It is not conceivable that doubling the size of the school could result in ‘no material impact’ on these three roads.
10The peer review has not been made available to the Parish Council, but there is no indication that it has addressed the criticisms of the Transport Assessment by the Parish Council.
Site Options Appraisal
11The Response by Seal Parish Council to the Public Notice Consultation of March 2016 set out fully the current difficulties with parking and its concern with lack of progress investigating alternative sites. [7]
12The findings of the recent Options Appraisal are summarised in paragraphs 1 to 8 of the report before the Committee.
13The Parish Council is disappointed with the Appraisal which was commissioned too late to inform the matters thatrequire investigation. For example, on the ground conditions, contamination and costsof each site the consultants give only their view on the “likely” situation, but have made no site investigations. The report contains no advice from the Minerals and Waste Planning Authority (KCC) on the nature of the landfill on Options 1 and 4 and the practicality of surface car parking.The views of site owners are not available.
14The appraisal states that with regard to Options 1, 2, 4 and 5“In the case of Seal Primary School it has been proven that the proposal of expanding the school will have no material impact on the local highway and as such any proposal to develop greenbelt for car parking would be very difficult to justify”.
15There is no ‘proof’ that there will be no material impact on the three roads used for access and parking. If the needfor some additional parking is accepted the Very Special Circumstances that apply to the school expansion also apply to necessary parking. In any event parking is an open land use and need not be regarded as harmful to the openness of the Green Belt, particularly with landscaping and a surface such as ‘grasscrete’.
16It would appear that the location of Option 2 has been incorrectly identified. The report states that “The parcel of land which sits between Highlands Park and Seal Primary School is
divided into several titles.”However, the land with potential for a turning area and small parking baylies along the eastern side of Ash Platt Road and has a single title (K562019). It isoutside the former landfill owned by Biffa (Options1 and 4).
17On Option 3 the report states that “The entrance to the Biffa Site is currently a private shared access route which is used by local building contractors. The vehicles which use the road are often heavy commercial vehicles… Any proposal to make use of the existing road which enters the Biffa site wouldplace children in close proximity of large commercial vehicles”.
18The current heavy vehicle traffic is construction traffic for a 75 bed nursing home which has obtained a right of access over Biffa land and planning permission in the Green Belt. On completion the heavy traffic will cease. The report does not appreciate the reason for the current traffic, and does not acknowledge the potential for a similar access agreement for a school car park.
19It was hoped that the study would consider the combined impact of the new Free School and Grammar Annex under construction on the opposite side of the A25 from Ash Platt Road and the primary school. This was the purpose of including Option 5 which is land owned by KCC, but a wider assessment has not been made.
Recreation Ground Car park
20Option 6 is Seal Recreation Ground car park, owned by Seal Parish Council. The findings of the Appraisal are summarised in paragraphs 6 and 8 of the report before the Committee.
21The Options Appraisal states that the “Kent County Council commissioned an independent transport consultancy to undertake a survey on the capacity of the recreation ground car park which proved that the current car park has capacity to be used as a drop-off facility for Seal Primary School.”
22While the car park as a whole may be large enough to serve as a drop-off facility for the school, its provision was required as a condition of planning consent for the pavilion to serve users of the pavilion and Recreation Ground. The car park is well used throughout the day and without doubt has few if any spare spaces at school start and end times because they correspond to those of the pre-school that uses the pavilion. The Parish Council is concerned that a park and stride or similar facility, which would have direct access to the A25, would make car park unusable at these peak times.
23The Parish Council is about to examine restrictions on parking to preserve access for local residents and users of the recreation ground and pavilion. A small number of additional spaces could be provided without encroaching on the playing fields, but they alone would not mitigate the parking problem created by the school expansion.
24The Options Appraisal also states “The use of Seal Recreation Ground Car Park would provide a feasible park and stride facility for use by Seal Primary School, however permission is required from the Parish Council …and this proposal has been met with objection by the Parish Council to date.”
25In its submission on the planning application of May 2016 the Parish Council states[8] “The Parish Council could not allow … community uses to be jeopardised by school traffic, but is willing to discuss how signage and layout of the car park together with some additional spaces might help pedestrian access to the school”.
26At the meeting with KCC representatives on 13th October 2016 it was stated that KCC had investigated options for the car park but this had not involved the Parish Council. To date the Parish Council has received no proposal from KCC or the school detailing how park and stride would operate, ortheir willingness to meet the costs of lighting, signsand marking etc.
27The Parish Councilwould be willing to examine the options that KCC and their consultants may have for use of the recreation ground car park, particularly in the light of their experience of‘Park and Stride’elsewhere and whether it could operate smoothlywhile preserving space and access for other current users.
Item D1 Conditionsand Informatives
Parking and Congestion
28The report to the Committee as Item D1 refers to the view that “By providing additional parking it would simply encourage more people to drive instead of encouraging them to look for alternative modes of transport”[9]. The Parish Council does not accept thatthe policy to encourage travel by other modes justifies no additional parking, regardless of the outcome. Increased congestion may encourage walking etc. but this is a former village school on the very edge of the urban area that it serves. The school expansion will draw children from a considerable distance, for many of whom public transport and walking will not be options.
29The report then concedes that there will be a material impact on local roads. It states “…the Highways and Transportation Officer does have some concerns over the additional local congestion and parking issues that this development would create” and “...the submitted information shows that the situation is likely to be worsened[10].”
30The Highways and Transportation Officerrefers to national policy that “development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are ‘severe’”. He is unable to conclude that severe conditions would result andthat additional parking/drop-off should be required as a condition of the school expansion.
31The Parish Council submits that it is not the intention to prevent or refuse development but rather to make reasonable provision to mitigate the recognised congestion. If KCC is unable to proceed with additional parking at present, the Parish Council proposes the following planning CONDITION:
“The County Council as Highways Authority will monitor traffic and parking in Zambra Way, Ash Platt Road and Highlands Park and nearby to determine whether further mitigation is needed to accommodate the impact of school expansion, including the investigation of additional parking.”
Parking Plan
32The Parish Council notes that the approval of an updated School Travel Plan is proposed as a planning condition, but the suggested content[11]which it is said cannot be conditioned, does not include the ‘parking plan’ outlined in the report to the July 2016 Planning Applications Committee.[12]The parking plan is a key part of the Transport Assessment on which its conclusions are based. However, it is recognised in the July report the plan needs to be updated and revised.
33The Parish Council therefore proposes that the following INFORMATIVE be added to the planning decision:
“The County Council should update and revise the parking plan proposed by the Transport Assessment in consultation with residents before a scheme is implemented”.
A25 speed limit
34The Parish Council also notes that the School Travel Plan includes “The School to lobby for the speed limit along the A25 to be reduced between the recreation ground and Seal Hollow Road from 40mph to 30mph”. Sevenoaks Town Council also asked for this speed reduction, and with increased pressure on the junction with Ash Platt Road due to school expansion, the adjacent improved access to the new care home, and the development of the Grammar Annex and Trinity Free School opposite, there is an urgent need to reduce traffic speed on this section of road, to Greatness Cemetery.
35The Parish Council therefore proposes that the following INFORMATIVE be added to the planning decision:
“The County Council should review the 40mph speed limit and the provision of school warning signs on the A25 between the recreation ground and Greatness Cemetery in the light of recent and current development.”
Seal Parish Council 2nd December 2016
1
[1] Seal Parish Council Response for KCC Planning Application Committee July 2016 Item D3 Section 5
[2] Paul Mew Associates March 2016 “Transport Assessment”. Revised May 2016
[3] Bailey Partnership “Options Appraisal” 22nd November 2016
[4] DHA Highways 2016
[5] Programme Manager, Capital Programme Delivery 23rd November 2016
[6] Paul Mew Associates March 2016 “Transport Assessment” paras. 8.4 to 8.7
[7]Seal Parish Council Response for KCC Planning Application Committee July 2016 Item D3 Annex1
[8]Seal Parish Council Responsefor KCC Planning Application Committee July 2016 Item D3 para. 5.23
[9] Item D1 para. 10
[10] Item D1 para. 11
[11] Item D1 para. 12
[12]Item D1 Appendix 1 para. 47