For your information (not least because Hampshire County Council doesn’t put submissions on its website), our response to the planning application for Westgate School.
While the architecture of the new school buildings is of a high standard â€“ irresponsibly inadequate attention has been given to the traffic, transportÂ and safety issues arising from 420 new primary pupils attending the expanded Westgate School; and the proposed relocation of the nursery school.Â Planning permission for the new school buildings should be withheld until there is a clear plan, with timetable and budget, for investing in transport infrastructure in the vicinity of the school in order to create a safer environment around the school with new measures to reduce congestion and increase safety in and around Cheriton Road and to make it easier for the majority of the 4-16 year old pupils to walk for some or all of their journey to school or â€“ for the older pupils â€“ to cycle.
The current planning application is not in accordance with paragraph 35 of the National Planning Policy Framework (NPPF) that â€˜plans should protect and exploit opportunities for the use of sustainable transport modes â€¦[and] should be â€¦designed where practical to give priority to pedestrian and cycle movementsâ€™.Â Â Â Nor is it in accordance with Policy T5 in the Winchester District Local Plan Review (2006) or CP21 in the Winchester District Local Plan Part 1 â€“ Joint Core Strategy. Â Â The creation of 420 new school places is a major development and the planning application currently itemizes little or no investment in off-site highway improvements including new and improved pedestrian and cycling facilities.Â Â In addition the application is not in accordance with the West Fulflood & Orams Arbour Neighbourhood Design Statement (NDS), published in 2008.
Specific issues raised by the Transport Statement and the School Travel Plan
- Para 3.22 of the Transport Statement (TS) fails to convey the highly unsatisfactory nature of parts of the pavements in Cheriton Road â€“ in places they are narrow and made bumpy by tree roots.Â Pavements in Western Road are also narrow, and, in places, not flat, though these pavements are heavily used not least by pupils of Westgate.
- Local residents are aware of other accidents in recent years (including two in Cheriton Road) in addition to those reported in Appendix E; and many â€˜near missesâ€™.Â There is much talk among local residents of â€˜an accident waiting to happenâ€™ in Cheriton Road.
- Paras 4.9 to 4.18 ( Car Parking): the new HCC Parking Standards are inappropriate and are being incorrectlyÂ applied; they are not compatible with the County Council being a self-styled Climate Change Centre of Excellence.Â Â Clearly Westgate is an ‘accessible location’ – so Westgate parking provision should be a maximum of 1.5 spaces per two classrooms – current provision is already far more generous than this and the new plans make matters worse.Â One way to achieve a more appropriate provision of parking spaces is to reduce the number of spaces or remove entirely the proposed Links Road car park.Â Â Links Road is already congested twice daily by WesternSchool parents delivering and collecting their children.
- The provision for manyÂ more staff parking spaces is also incompatible with one of the key provisions in the National Planning Policy Framework which states thatÂ â€˜plans shouldâ€¦be designed where practical to give priority to pedestrian and cycle movementsâ€™.Â The Westgate plans give priority to staff travelling by car since that is where most of the investment is being made. The top priority should be to make it safe for children to walk to school.
- The TS claims that traffic flows freely at the moment along Cheriton Road.Â This is disputed by local residents who report that Cheriton Road and Fordington Road are frequently congested â€“ and sometimes impassable â€“ at peak times.Â The TS relies on data extrapolated by using existing â€˜journey to schoolâ€™ data for primary schools within Winchester. Consequently it quotes (para 5.5) a travel by car average of 13.8% and applies this to the new school. This results in an extra 58 car journeys that the TS identified. Then (para 7.5) the TS makes, an assumption that much of this traffic will be parents on â€˜pass-byâ€™ trips to the Rail station or city centre which thus leads to only 30% of the estimated 58 journeysÂ (less than 20 vehicles) being additional traffic. No evidence is offered for this assumption â€“ described by the consultants as â€˜robustâ€™ but nonetheless highly questionable, and, in our view, unrealistic.
- The â€˜car averageâ€™ of 13.8% is technically flawed because it is taken from neighbourhood schools that by definition have a more localised catchment area. Ward Councillors are not able to guestimate the increase in the number of pupils coming to Westgate by car when the 4-16 school is fully functioning, but accept the argument put forward by Paul Cooper of Cheriton Road that â€˜parents will generally feel more relaxed about 12-16 year olds walking to school than they would about 4-11 year oldsâ€™.
- In addition the TS makes only a passing reference (para 8.7) to the additional traffic and drop off activity in Cheriton Road arising from the relocated nursery.Â It is to be assumed that the great majority of the 55 nursery age children will travel by car resulting in a very substantial increase in traffic movements impeding the free flow of traffic in Cheriton Road.Â Each â€˜dropping offâ€™ and collection of a nursery age child is likely to last for several minutes adding to the congestion. Â Â In addition â€“ as Ben Clifton of HCCâ€™s Economy, Transport and Environment Department points out (in his Note of 22 January 2013) Â – allowing two minutes to complete each â€˜drop offâ€™ for a primary school child â€˜appears very shortâ€¦.Parents of younger children are likely to take longer than two minutes to complete a drop offâ€¦.For robustness a scenario for longer stay drop off should be assessedâ€™.
- While there is some discussion of one of the existing zebra crossings on Stockbridge Road (paras 7.17 to 7.21) there is no mention of the need or demand for a new zebra crossing on Stockbridge Road linking Hatherley Road with Fordington Road.Â Â The statement (para 8.3) â€˜there are no barriers to walking within the local areaâ€™ is extraordinarily complacent, and contradicts the views of many parents.Â Ward councillors support the analysis of Greening Fulflood in Appendix 12 of the School Travel Plan about the need and importance of improving walking and cycling routes to Westgate.Â Â Â This is neglected in the plan proposals. Â With a larger catchment area for Westgate primary, safe routes for pedestrians and cyclists are needed from all parts of the St Bedeâ€™s catchment area, including Hyde and Abbotts Barton.
- Nor can local councillors accept the TS conclusion (para 8.9) that â€˜vehicular traffic associated with the Primary Element is unlikely to have a noticeable impact on the operation of the mini-roundabout of Cheriton Road / Stockbridge Road / Bereweeke Roadâ€™.Â Â Given what is said above a considerable increase in trafficÂ at that roundabout is anticipated â€“ unless some of the current and additional traffic is directed to a drop-off point on Chilbolton Avenue (see below).
- The survey data published in the School Travel Plan include disturbing numbers for pupils at Westgate travelling to school by car.Â Whereas at Western Primary school the percentage of pupils travelling to school by car has declined from 35% in 2006 to 13% in 2012 (an impressive change), at Westgate the figures have gone in the wrong direction (from 17% in 2007 to 26% in 2012) at a time when there has been a great deal of lip service paid to the importance of school travel plans and sustainable transport modes.Â Â There is more than one possible explanation for the fact that only one pupil is recorded as cycling to Westgate school in 2012 (compared with 23 five years earlier).Â Â On the one hand parents of Westgate pupils clearly think that it is unsafe for their offspring to cycle to school; but at the same time there has been a complete failure by HCC over the last twenty years to develop and encourage safe routes to schools, particularly for cyclists.Â Â Â Many secondary schools throughout England have been able to promote safe cycling to school.Â In Winchester there is still everything to do â€“ and a few hills should be seen as part of the challenge.
- Great play has been made of the proposal to stagger school hours to reduce peak flows in Cheriton Road. Indeed the TS uses this as further support of its â€˜robustâ€™ traffic assumption. But staggering school hours may well have an unintended consequence; it is probable that there will be additional waiting times and congestion caused where siblings attend the different schools and travel by car. So staggering school hours may do little to alleviate traffic impacts.
- For many years Green Lane has provided an important access route for parents and children walking to WesternSchool from the north and east.Â It is important that that access route is maintained. Indeed the future of Green Lane provides an example of how important it is to consider the â€˜travel to schoolâ€™ needs of Western and Westgate pupils wholistically and simultaneously.
Other considerations â€“ the character of the area, construction traffic
- There is no reference in the planning application to the West Fulflood & Orams Arbour Neighbourhood Design Statement (NDS), published in 2008 after years of work by local residents and adopted as a Supplementary Planning Document by Winchester City Council. The NDS acknowledges (p25) that â€˜there is significant traffic congestion on Cheriton Road at the beginning and end of the school day and â€“ as part of its Planning Guidance says that â€˜additional traffic strain should not be placed on the bend of Cheriton Road, at the junction with Cheriton Close, the mini roundabout at the junction with Stockbridge Road and on Cheriton Road near the Westgate school where traffic congestion causes problems at the beginning and end of the school dayâ€™.
- The NDS draws attention to the residential quality of the area â€“ â€˜an area of large houses and gardens, which retains the character of its rural and early suburban originsâ€™.Â Â The sudden increase of nearly 40% in the school population and the gradual increase in out of school and business activity on the Westgate siteÂ is an obvious threat to the character of the area and the current proposalsÂ can be seen as â€˜overdevelopmentâ€™ in a predominantly residential area.
- Councillors support the comment in an initial report from the highway consultant (15 March 2012) â€˜that it is unlikely that Links Road would be acceptable for construction trafficâ€™.
How best to address the transport and traffic consequences of the Westgate expansion
- The â€˜travel to schoolâ€™ objectives and realities of Western and Westgate school should be thought about wholistically â€“ the two schools are near neighbours with adjoining playing fields.Â Â The steadily rising numbers of pupils at Westgate (when added to those at Western primary) should act as a catalyst for major improvements to the safety considerations involved in more than 2,000 children and adults journeying to and from adjoining schools;Â and the opportunity to promote safe walking and cycling.Â In addition residents of the areas surrounding Western and Westgate schools â€“ who are having a major new development thrust upon them – expect and deserve clear measures to reduce congestion and improve the safety of the streets in their area.Â Â The promise of all these streets becoming 20mph is a small step in the right direction.
- Given that â€“ within a few years – more than 2,000 adults and children will be converging on the Westgate/Western campus each morning and dispersing each afternoon it must be sensible to try to minimise the congestion at the school gates of both schools and to encourage both staff and children to approach the schools from different directions.Â This leads us to the view that a safe drop off point on Chilbolton Avenue for both Western and Westgate would be a highly desirable innovation.
- The feasibility of the Chilbolton Avenue drop off point needs thorough discussion with the staff and governors of Westgate and Western schools followed by a full investigation and evaluation, followed by a period of public consultation.Â If such a new drop off point is feasible, apart from those delivering children to the nursery school, the majority of parents driving children to school â€“ and the daily school buses â€“ could all be directed to a new drop off point.Â It is possible that a safe drop off point can be created by establishing a â€˜secureâ€™ lane in the southbound carriageway close to the junction with Links Road.Â Â The other option is to create a new safe pull in and drop off area using a strip of the WestgateSchool playing field.Â Â The loss of a small section of the playing field would be highly regrettable, but could be a worthwhile sacrifice to enable a safer dropping off point â€“ for both buses and cars â€“ and will enable those pupils at both Western and Westgate for whom there is no realistic alternative to travelling by car or school bus to walk the last part of their journey to school.Â Â Such an innovation should also considerably reduce congestion â€“ and the threat of accidents â€“ in Cheriton Road; and bring relief to the residents of Links Road who every day witness up to two dozen cars each morning and evening delivering and collecting children who attend Western primary.
- The School Travel Plan is full of good intentions. There is repeated use of the word â€˜investigateâ€™ in the Travel Plan and very little firm commitment to action in 2013 and 2014.Â Â The measures addressed to school staff are not regarded as high priority – when it is staff who should be â€˜role modelsâ€™ in promoting walking, cycling and greater use of public transport.Â Â The targets in the Travel Plan lack urgency and the commitment to the investment which may give them some prospect of â€˜making a differenceâ€™.Â Â We believe that clear costedÂ proposals to implement measures to promote and enable significantly more â€˜safeâ€™ walking and cycling to Westgate by both staff and pupils â€“ including the creation of new safe routes for walking and cycling to school – should be agreed before planning permission is given.
- In addition to the measures listed in the above paragraphs there is a clear need to increase safety, and improve conditions for pedestrians and cyclists on Cheriton Road.Â This is in line with the Note from Ben Clifton, Highway Development Planning officer of HCC who (in his note of 22 January 2013 published on HCC website) has sought clarification â€˜about traffic and parking control along Cheriton Road, particularly in the context of the proposal to construct a build out to the north of the siteâ€™.Â Â Â Â A top priority should be given to improving (and, if and where appropriate) widening the pavements.Â This calls for a process of design, consultation, revised designs and implementation with an agreed budget.Â Â Parents, residents, and local councillors are justified in expecting that there will be a commitment to the substantial investment needed for these safety improvements before planning permission is granted.
Conclusion and conditions
Planning permission should not be granted until substantially funded plans are published to promote sustainable travel and improve safety.Â These should include as conditions for any planning permission:
- A full investigation and consultation on the feasibility of creating a new drop off and pick up point either on Chilbolton Avenue, or on a strip of Westgate schoolâ€™s playing fields; budgetary provision needs to be made to create such a drop off point and â€“ if and when it opens – school buses and parents dropping off and/or collecting primary or secondary age children should be directed to this point.
- Costed and budgeted measures for immediate improvements toÂ road safety and conditions for pedestrians and cyclists in Cheriton Road and nearby roads along with further clarification about traffic and parking control along Cheriton Road.
- Acknowledgement given to the fact that Westgate School is an accessible area with nearby bus and train routes.Â Accordingly on-site parking for staff should be reduced to 0.75 spaces per classroom with all staff encouraged to use sustainable transport wherever possible and parking spaces allocated according to greatest need.Â Our preferred option is to reduce or remove the unpopular Links Road car park.
- On top of the immediate commitments made above, firmÂ commitments to be made â€“ with appropriate timetables, targets and budgets – to the initiation and creation of a comprehensive programme of â€˜safe routesâ€™ for both pedestrians and cyclists to Westgate and Western schools from all parts of their Winchester Town catchment areas.Â Â Â Such an investment programme to be introduced over five years.
- Budgeted commitment to introducing other actions itemized in the School Travel plan with a published joint commitment from HCC and the Headteacher and Governors of Westgate School to implement all measures in the School Travel Plan itemized to be introduced by 2016 â€“ with a comprehensive review of the School Travel Plan during that year.
- Pedestrian rights of way maintained through Green Lane.
- No construction traffic in Links Road. Â
County Councillor Phryn Dickens
City Councillors Robert Hutchison, Ray Pearce. Martin Tod
30 January 2013