Ref. 13/02655/FUL R
Third Representation and Message to Members of the new Planning Committee
Introduction
The Two Mile Ash Environmental Group (TMAEG) extends a warm welcome to members of the new Planning Committee and wishes them well in their challenging task of judging planning applications. We note that at your first meeting you will be considering the above application which will have major implications for the area we cover, Two Mile Ash.
We have issued two previous representations regarding the proposed expansion and these can be found on Page 15 of the Council’s list of documents relating to this application:
- First representation published by TMAEG on 27/1/2014 and labelled ‘Annex 2’ on the Council’s list (posted 21/03/14):
- Second representation (Response to Transport Statement and Travel Plan) published by TMAEG on 14/3/2014 and labelled ‘Final Response’ on the Council’s list (posted 21/03/2014).
These earlier representations can also be found on the TMAEG website www.tmaeg.org under ‘Position Statements’.
In this Third Representation we wish to comment briefly on some recent documents issued in the last month. Our First and Second Representations still stand.
Transport Statement and Travel Plan – new version issued by applicant on 27 May 2014
We note that an earlier serious error has been corrected by the applicant; there is now an acknowledgment that the No.4 bus service does not currently serve the school during the peak school arrival and departure times.
There is nothing in the new document that addresses the major concern raised in our Second Representation that, following Government guidance, this application calls for a full Transport Assessment rather than the wholly inadequate Transport Statement that has been produced.
As detailed in our Second Representation, the three surveys carried out by TMAEG volunteers fully confirm – in terms of figures and detailed observations – that traffic generated by the School at its present scale of operations has a significant impact upon the environment of Two Mile Ash. There is a related issue over safety. Under the proposals significantly more children from outside TMA will be educated in TMA and inevitably even more vehicle journeys will be generated.
In our Second Representation, we list five reasons why the thorough analysis called for in Government Planning Practice Guidance should have been carried out, requiring a Transport Assessment. They include the factors of increased traffic volumes and ‘capacity that is already stretched’ and the need to consider cumulative impacts and traffic impacts relating not just to TMA School but to its two feeder schools, Ashbrook and Holmwood, as well.
We believe that members are ill served by the present Transport Statement to which they should attach little weight.
Sport England
We note the objection which was lodged by Sport England on 7 February 2014, in the light of its playing fields policy. We also note that the changes proposed by the school as an amendment to the earlier plans have not sufficed to cause Sport England to withdraw that objection (Sport England representation 2 June 2014). Sport England is a statutory consultee regarding planning applications that affect playing field provision and thus the position they have adopted cannot be disregarded.
In responding to this application, TMAEG has placed its emphasis on the traffic implications of this development. In sum, too much reliance is being placed on a site that was never designed to accommodate the level of traffic that is being generated now, let alone the increased levels that can be expected in the future were this expansion to go ahead.
To us, Sport England’s objection is evidence that the core school site has itself reached capacity in terms of its area. It provides a powerful second reason why this proposal should be rejected.
Alternatives
We return finally to a point that we made in our First Representation, the question of whether TMA is an appropriate place to take such a large part of the predicted borough wide shortfall in places for 4+ year olds. While objectors have concentrated upon the traffic and environmental effects of the proposal, many of us also adhere to the principle that – across Milton Keynes as a whole – there should be a realistic choice to send our youngest children to a school within their own local community and within walking distance of home. On that basis, this proposal goes in the wrong direction.
Chris Gossop MRTPI
Chair TMAEG
18 June 2014